KTR00183

BRUCE EBERSOLE (VOL II) February 5, 2009
Page 318
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: KATRINA CANAL BREACHES CIVIL ACTION

CONSOLIDATED LITIGATION NO. 05-4182 K2
JUDGE DUVAL
PERTAINS TO: MRGO AND ROBINSON
(No. 06-2268)
(V O L U M E II)
Deposition of BRUCE A. EBERSOLE, P.E.,
given at the offices of the United States
Department of Justice, 400 Poydras Street, 9th
Floor, New Orleans, Louisiana 70130, on
February 5th, 2009.
REPORTED BY:
JOSEPH A. FAIRBANKS, JR., CCR, RPR
CERTIFIED COURT REPORTER #75005
JOHNS PENDLETON COURT REPORTERS 800 562-1285

Page 319 Page 321
1 REPRESENTING THE PLAINTIFFS: 1 EXAMINATION INDEX
2 LAW OFFICE OF JOSEPH M. BRUNO 2
3 (BY: JOSEPH M. BRUNO, ESQUIRE) 3 EXAMINATION BY: PAGE
4 855 Baronne Street 4
5 New Orleans, Louisiana 70113 5 MR. BRUNO ...............................323
6 504-525-1335 6 EXHIBIT INDEX
7 - AND - 7
8 ELWOOD C. STEVENS, JR., APLC 8 EXHIBIT NO. PAGE
9 (BY: ELWOOD C. STEVENS, JR., ESQUIRE) 9 Exhibit 5 ...............................323
10 1205 Victor II Boulevard 10 Exhibit 6 ...............................341
11 Morgan City, Louisiana 70380 11 Exhibit 7 ...............................356
12 985-384-8611 12 Exhibit 8 ...............................362
13 - AND - 13 Exhibit 9 ...............................368
14 SHER, GARNER, CAHILL, RICHTER, KLEIN & 14 Exhibit 10 ...............................408
15 HILBERT, L.L.C. 15 Exhibit 11 ...............................450
16 (BY: MATTHEW CLARK, ESQUIRE) 16 Exhibit 12 ...............................532
17 909 Poydras Street, 28th Floor 17 Exhibit 13 ...............................648
18 New Orleans, Louisiana 70112 18
19 504-299-2100 19
20 20
21 21
22 22
23 23
24 24
25 25
Page 320 Page 322
1 REPRESENTING THE UNITED STATES OF AMERICA: 1 STIPULATION
2 UNITED STATES DEPARTMENT OF JUSTICE, 2 IT IS STIPULATED AND AGREED by and
3 TORTS BRANCH, CIVIL DIVISION 3 among counsel for the parties hereto that the
4 (BY: RUPERT MITSCH, ESQUIRE) 4 deposition of the aforementioned witness may be
5 (BY: PAUL LEVINE, ESQUIRE) 5 taken for all purposes permitted within the
6 P.O. Box 888 6 Federal Rules of Civil Procedure, in accordance
7 Benjamin Franklin Station 7 with law, pursuant to notice;
8 Washington, D.C. 20044 8 That all formalities, save reading
9 202-616-4289 9 and signing of the original transcript by the
10 10 deponent, are hereby specifically waived;
11 ALSO PRESENT: 11 That all objections, save those as to
12 DAVID DYER, ESQ. 12 the form of the question and the responsiveness
13 TIANA CHRISTOPHER, ESQ. 13 of the answer, are reserved until such time as
14 IVOR VAN HEERDEN 14 this deposition, or any part thereof, is used
15 SANDY OLINDE 15 or sought to be used in evidence.
16 AARON JACKSON 16
17 17
18 PARTICIPATING VIA I-DEP: 18 * * *
19 ROBIN SMITH, ESQ. 19
20 JANE SMITH, ESQ. 20
21 KARA MILLER, ESQ. 21
22 CHRISTOPHER ALFIERI, ESQ. 22 JOSEPH A. FAIRBANKS, JR., CCR, RPR,
23 RICHARD PAVLICK, ESQ. 23 Certified Court Reporter in and for the State
24 VIDEOGRAPHER: 24 of Louisiana, officiated in administering the
25 TODD MEAUX (DEPO-VUE) 25 oath to the witness.
2 (Pages 319 to 322)

Page 323 Page 325
1 BRUCE A. EBERSOLE, P.E., 1 section --
2 USACE, ERDC, CEERD-HF, 3909 Halls Ferry Road, 2 A. On my Page 237?
3 Vicksburg, Mississippi 39180-6199, a witness 3 Q. No, 304. Bates page.
4 named in the above stipulation, having been 4 A. And what I'm asking you is, is this
5 first duly sworn, was examined and testified on 5 from the document edited by K.W. Pilarczyk?
6 his oath as follows: 6 Q. It is the document edited by K.J.
7 EXAMINATION BY MR. BRUNO: 7 Pilarczyk?
8 Q. Good morning, Bruce. Hope you had a 8 A. This was a chapter from a larger
9 good night. All right. Listen, I've put in 9 document. And that's my question, is this from
10 front of you a document that I've marked as 10 the document --
11 Exhibit Number 5. Can you identify this 11 Q. Yeah, you can see Chapter 14 right at
12 exhibit for us, please? 12 the top.
13 (Exhibit 5 was marked for 13 A. Well, I don't have a Chapter 14 in
14 identification and is attached hereto.) 14 mine, I have edited by Pilarczyk, 1998. So --
15 A. Let's see. Let's see if it's the same 15 Q. Well, we took your cite and pulled
16 one I referenced. 16 this document. So why don't you take a look
17 EXAMINATION BY MR. BRUNO: 17 at -- it seems to have the same figures, it
18 Q. Yes. Please do. 18 seems to have the same charts, it seems to have
19 A. Can you tell me what date, the date of 19 the same graphs. I mean, I don't know, we can
20 this document -- publication is? 20 stop the deposition and you can go verify it.
21 Q. '88? 21 But if you don't want to accept it as the same,
22 A. No, the document I referenced -- I had 22 that's your prerogative, but we have to have
23 1998. 23 some concept of reason here.
24 Q. '98, I'm sorry. '98. 24 A. And I'm not 100 percent certain it's
25 A. From a document edited Pilarczyk? 25 from the same document, but I see the same
Page 324 Page 326
1 Q. Well, on your -- in your report -- 1 figure. It looks to me like the one I used,
2 A. I just want to make sure it's the same 2 and I believe it looks like the same model that
3 document. 3 I used in my calculations.
4 Q. Yeah. Well, I mean -- 4 Q. Right. Okay. All right. So you're
5 A. I mean, you've asked me if it's the 5 telling me you're unable to confirm -- even
6 same document. I'm trying to ascertain whether 6 though the title is the same, the authors are
7 I think it is or it isn't. 7 the same and this article is in a book edited
8 Q. Well, I understand that, but since you 8 by somebody else, you can't confirm that this
9 read the original one and I'm giving you what 9 is the same paper referenced in your report;
10 you've cited -- 10 right?
11 A. Well, I'm trying to. 11 MR. MITSCH:
12 Q. -- I'm doing a double-check. Okay? 12 He's just being careful. That's
13 A. I'm trying to confirm that the 13 all.
14 document I have is the one that I referenced in 14 A. Yeah. I just want to make sure. But
15 my document. 15 if you want to proceed with the discussion over
16 Q. How about this? What I have is 16 the figure or the model, I'm okay with that.
17 exactly what you cited at Page 304. It says, 17 These look like the same equation that I used
18 Seijffert, J.W., Grass Covers and Reinforcement 18 in my report. Their Figure 4 looks to be the
19 Measures. 19 same figure that I've included in my report.
20 A. 304. 20 EXAMINATION BY MR. BRUNO:
21 Q. Oh, that's the Bates page, man. I'm 21 Q. Okay. Well, let's just --
22 sorry. 22 A. I'm looking at the ranges of
23 A. Mine ends at 302. 23 coefficient for good, average, poor grass
24 Q. The Bates page of your report. I got 24 cover, and they appear to be the ones I've used
25 it from your report. I went to your reference 25 in my document.
3 (Pages 323 to 326)

Page 327 Page 329
1 Q. All right. So at least whether this 1 exposed to wave action.
2 is or is not the same, the formula and the 2 Q. Right.
3 values are the same, right? 3 A. And they've established depths of
4 A. Formula is the same and the values for 4 erosion. It's not depth of erosion relative to
5 the coefficients appear to be the same. 5 the highest elevation on the grass, it's
6 Q. All right. Okay. Now, if this is the 6 erosion relative to the earthen surface.
7 same document, if you look at Page 289,which is 7 Q. Fine. Let's look at --
8 Page 1 of the article -- 8 A. So the model is vertical erosion
9 A. Okay. 9 below -- relative to the earthen surface.
10 Q. -- would you agree with me that the 10 Q. Can we turn to Page 294? Under the
11 intent of the authors was to assess the 11 section design, that's the design of the model,
12 erodibility of grass cover on levees? That was 12 right?
13 the true purpose of this paper. 13 A. Well, I see a section called design.
14 A. Well, I think they're looking at the 14 Q. All right. So you don't know what
15 resistance to erosion of a grass covered levee. 15 that means.
16 This chapter will mainly deal with the erosion 16 A. No.
17 resistance in relation to that agricultural 17 Q. Fair enough.
18 hydrological functions. 18 A. I'd have to read through here.
19 Q. And it goes on to describe types of 19 Q. That's okay. It says, research
20 grass cover, it talks about types of 20 activities under 3.1. You see that?
21 substitutions for grass cover, et cetera. So 21 A. Yes.
22 it's really aimed at the ability of the grass 22 Q. It says, the resistance of grass
23 cover to sustain erosion, isn't that true? 23 covers against wave attack has been examined
24 A. Well, you can't separate grass cover 24 intensively during the past fifteen years, full
25 from the sediments that are holding the root 25 scale tests, laboratory tests, field surveys
Page 328 Page 330
1 structure. I mean, they both operate together 1 and literature studies were carried out.
2 in determining the erosion resistance and the 2 Attention was focused on all aspects related to
3 erodibility. 3 the strength of grass covers such as quality of
4 Q. Bruce -- 4 the vegetation, root length, percentage of
5 A. You can't separate from one from 5 coverage, and soil quality percentages of
6 another. 6 fines. Then it says, three full scale tests
7 Q. -- I'm with you. That's your 7 were carried out: One with relatively small
8 explanation. I'm not asking you about what you 8 waves with 12 different sods dug out of river
9 said, I'm asking you about what the authors 9 dikes, and two tests with high waves on sods
10 said. What the authors said is that they are 10 from a sea dike. All tests were carried out in
11 discussing the erodibility of grass cover, and 11 the test facilities of Delft Hydraulics.
12 they're talking about the potential 12 Now, does that give us any insight as
13 substitutions with other materials, woven 13 to what it is that the authors were studying,
14 fabrics, meshes, mats, concrete armor layers, 14 do you think?
15 blah, blah, blah. 15 A. Yes.
16 They are talking about the erodibility 16 Q. All right. And it seemed to indicate
17 of grass cover; isn't that true? 17 that they're studying the sod, the grass.
18 A. Of a grass covered clay levee. 18 Isn't that true?
19 They're talking about the erosion of a grass 19 A. Sod is grass and soil.
20 covered clay levee. 20 Q. Okay.
21 Q. All right. Now, you have chosen to 21 A. You can't distinguish. It's not like
22 use this formula to discuss the erodibility of 22 Dr. Bea who wants to treat the grass as a astro
23 the clay levee itself, isn't that true? 23 turf mat that all of a sudden disappears from
24 A. Well, their model is based on data 24 the surface of the levee. The root structure
25 taken on a clay levee with grass cover that's 25 is in the soil.
4 (Pages 327 to 330)

Page 331 Page 333
1 Q. Right. 1 A. Um -- I remember there was a table we
2 A. In the surface. You cannot separate 2 were discussing yesterday where I did that in
3 erosion -- if you have no erosion of the soil 3 my report.
4 around the grass, the grass doesn't go 4 Q. Page 85?
5 anywhere. 5 A. Yes.
6 Q. Right. Well, you take it to the next 6 Q. All right. So can we do it in meters
7 level, don't you? You take this to be a study 7 so it's a little easier to adapt to what we
8 of the ability of waves to erode the soil below 8 have in front of us, the 296? And then we can
9 the grass. 9 change to feet later?
10 A. The combination of the two. I did it 10 A. Do it in meters.
11 as a method for me to look at, if wave impacts 11 Q. Yeah. Because we have good being .5
12 are occurring on the front face of a levee that 12 to 10 to the -6 -- is that a minus 1.5 to 10 to
13 has sod, sod equal grass plus the underlying 13 the -6?
14 soil, I wanted a rough check on what kind of 14 A. I think that means the range of .5 to
15 magnitude of erosion are we talking about with 15 1.5.
16 the kind of wave loadings that these levels 16 Q. Oh, there's a range there. I see. So
17 were subjected to, is it zero, is it a half a 17 good is .5.
18 foot, is it one foot, is it five feet, is it 18 A. There's uncertainty in the value.
19 ten feet? That was the purpose of me applying 19 They say -- it's a range of values based upon
20 this model. And they have data that quantifies 20 data, I believe.
21 that process. 21 Q. Okay. All right. So which one did
22 Q. All right. Can we go through the 22 you use, .5 or 1.5?
23 formula? 23 A. Um -- I think I used the median, a 1,
24 A. Sure. 24 I thought.
25 Q. Page 296. That's the formula; right? 25 Q. All right. Let's do 1.
Page 332 Page 334
1 C sub-E times M -1 S -1 close paren, right? 1 A. That's my recollection is I used 1. 1
2 That's the formula? 2 times 10 to the -6.
3 A. Could I repeat that again? 3 Q. 1 times 10 to the -6 is what number?
4 Q. I'm reading it. Am I reading it 4 I mean, is that dot five zeroes or six zeros?
5 right? 296. Grass cover quality. 5 Help me, it's been a long time since I was in
6 A. Well, the formula is above it. E 6 second grade.
7 equals C sub-E times the square of the 7 A. Where's my pad?
8 significant wave height. That's the formula. 8 Q. Here's an extra pad. (Tendering.)
9 Q. All right. 9 A. I would say it's a decimal and five
10 A. And then below they list various 10 zeroes and a 1.
11 ranges of values for C sub-E as a function of 11 Q. Okay. All right. And we multiply
12 good, average and poor grass cover. 12 that times the significant wave height, which
13 Q. All right. 13 is what? It's at three o'clock.
14 A. But E is erosion. It's erosion. It's 14 A. Three feet. I have to convert that to
15 removal of sediment, soil from the surface of 15 meters.
16 the levee. 16 Q. Yeah. Just help me. Where do we get
17 Q. Okay. All right. So -- 17 the three-foot wave at three clock in the
18 A. Nothing to do with dimensions of the 18 morning?
19 grass or anything else. It's E, it's erosion. 19 A. From Table 85. I'm sorry. Table 5 on
20 It's a vertical distance. 20 Page 85.
21 Q. I understand. That's the big E. 21 Q. Yeah, I know that you wrote it there,
22 A. Yeah. 22 but where did the three --
23 Q. So can we just do the math? E 23 A. Those values came from STWAVE output
24 equals -- now, you did this three times, so you 24 of a significant height.
25 did it for good, average and poor, right? 25 Q. So the three is the significant wave
5 (Pages 331 to 334)

Page 335 Page 337
1 at three o'clock in the morning. 1 Q. Okay. Now --
2 A. Significant wave height at 3:00 a.m. 2 A. So --
3 is three feet. 3 Q. So we have -- we have -- you've got
4 Q. All right. And so we have to square 4 here from three o'clock to eleven o'clock, so
5 that -- 5 we have eight hours.
6 A. You want to just -- let's just round 6 A. Yeah. But you don't want to do that.
7 it off to about a meter. Let's just -- 7 That's not what I did here. Because the wave
8 Q. Right. 8 height is varying. So what I did was just do
9 A. Okay? 9 it in half-hour increments and then add the
10 Q. So that will be 1. 10 cumulative erosion.
11 A. That way we won't have to pull out -- 11 Q. All right.
12 I don't have a calculator, unless you got one. 12 A. I mean, if the purpose here is
13 Q. I -- 13 checking --
14 MR. BRUNO: 14 Q. Yeah. Absolutely.
15 Do we have a calculator. 15 A. Let's just --
16 (Off the record.) 16 Q. So now we've got to multiply this too
17 A. What are we doing? 17 get to thirty minutes.
18 EXAMINATION BY MR. BRUNO: 18 A. Thirty minutes.
19 Q. We were going to take our significant 19 Q. So we have to multiply times 60 -- we
20 wave height of three feet and make it meters. 20 have to multiply our .00000083 times 60 to get
21 A. Okay, so three feet is we'll just say 21 a minute and then times 30 to get half an hour.
22 0.9 feet -- I'm sorry. I think I said that 22 Right?
23 wrong. Three feet equals 0.9 meters. 23 A. I believe that's the case. So I've
24 Q. Right. And we have to square that, so 24 got 1800 seconds in a 30-minute period. Do you
25 that's 8.1? 25 agree?
Page 336 Page 338
1 A. Yes. That would be 0.83 meters 1 Q. Yes. Equals a rate of erosion per
2 squared. 2 half hour. And what's our number?
3 Q. Wait. Where did you get -- .9 squared 3 A. It's not a rate, it's a distance, now.
4 is -- 9 times 9 is 81, isn't it? 4 We've multiplied it by the elapsed time. So
5 A. .9 times .9 is .83 meters squared. 5 it's .00144 meters.
6 Q. Some point .9 times .9 is -- 6 Q. Okay. So now we got to go back to
7 A. .83 meters squared. I misspoke 7 feet. So .11 meters equals how many feet?
8 earlier. E is not an erosion distance, it's an 8 A. 3.28.
9 erosion rate. So you're going to have to 9 Q. 3.28 feet, right? That can't be
10 multiply that by a time to get an erosion 10 right.
11 distance. 11 A. Yeah.
12 Q. We'll get there. I'm writing this all 12 Q. Did you say --
13 down for us. So .9 is .83? 13 A. 3.28 feet per meter. We get a very,
14 A. .9 squared -- .9 meters squared is .83 14 very, very small number.
15 meters squared. 15 Q. All right. I wrote it down wrong.
16 Q. So then we're going to multiply that 16 Three feet is big. Are you saying .0?
17 times .000001 and what do we get? 17 A. No, I'm saying we had to multiply the
18 A. .00000083. 18 rate, which was we said it was .00000083 meters
19 Q. All right. So that is a rate of 19 per second.
20 erosion per second -- 20 Q. Times --
21 A. That would be meters per second. I 21 A. Times the --
22 mean, .00000083 meters per second would be the 22 Q. 1800. We got .00144 meters.
23 erosion rate. That would be the erosion rate, 23 A. Right.
24 vertical erosion rate of the levee surface 24 Q. That's how much was eroded.
25 under the loading of three feet. 25 A. One one thousandth of a meter.
6 (Pages 335 to 338)

Page 339 Page 341
1 Q. And I said, all we have to do now is 1 my satisfaction.
2 change that into feet. 2 Q. We'll let you do that on a break,
3 A. Right. And there's 3.2 feet per 3 because I'm take to accomplish this dep -- but
4 meter, so I multiplied .00144 times 3.28. 4 I'm going to mark this and attach it to your
5 Q. And you get? 5 deposition as Exhibit Number 6.
6 A. I got .0047 feet. 6 (Exhibit 6 was marked for
7 Q. Okay. In one half hour. 7 identification and is attached hereto.)
8 A. In one half hour. So that would be, 8 A. Okay.
9 converting it the inches, that's one twentieth 9 EXAMINATION BY MR. BRUNO:
10 of an inch. 10 Q. All right. Now, let's look --
11 Q. Well, I know it's small, but you 11 MR. MITSCH:
12 reported .002. 12 This is Mr. Bruno 's writing.
13 A. Yeah. I have to think about how -- I 13 MR. BRUNO:
14 may have, um -- I think what I might have done 14 It's Mr. Bruno's writing, and
15 was assumed that the significant height of 3 15 you'll see it's consistent with the
16 represented a time from 2:45 a.m. to 3:15 a.m. 16 record. And if you want to check
17 I'd have to go back and check my calculation, 17 whether what I've written down is
18 but I think what we can see is, you know, the 18 consistent with the record we can do
19 cumulative grass cover in these first two 19 that on your time.
20 columns, whether it's .002 or .004 our 20 EXAMINATION BY MR. BRUNO:
21 calculation is .0047, these are tiny, minuscule 21 Q. Let's go to Page 297 of the article.
22 values. So if you want to go through the 22 You see that table there, Figure 6?
23 calculations again and see if we can reproduce 23 A. Figure 6?
24 these numbers, we can do that, but these are 24 Q. Yeah. Page 297.
25 minute values, that's the whole point here, 25 A. In the journal?
Page 340 Page 342
1 that's the message. These are minute. 1 Q. Yes.
2 Q. Bruce, I'm with you. But again, as I 2 A. Okay. When you said table you sort of
3 said, it's not for me to decide, it's for the 3 threw me.
4 third guy to decide. All I wanted to do was 4 Q. Figure. I'm sorry. Maximum
5 see how you got where you got. And the number 5 permissible duration of wave attack. Can you
6 you get is .0047 feet, and you reported 6 help me understand this table?
7 .002 feet. Isn't that true? 7 A. Probably not without going back and
8 A. I'd have to go back and check my 8 reading this paper. It's probably been a half
9 calculations on this. 9 a year to a year since I read this paper. It's
10 Q. All right. Well -- 10 not one that I used.
11 A. I think the real point here is that 11 Q. Okay. Does the line represent the
12 it's minute. 12 maximum permissible duration of wave attack?
13 Q. Listen, I'll give you that option, but 13 A. I said I can't help you.
14 see if this is an accurate -- 14 Q. You can't help me there.
15 A. I don't want to get us on the bark of 15 A. I would have to go back and reread
16 the tree and lose sight of the forest here, you 16 this paper and understand what this figure is
17 know. 17 about and what -- how it was derived and what
18 Q. I understand. I'm going to mark this 18 they're trying to do with the figure. As I
19 piece of paper as Exhibit Number 6. 19 said, it's not one that I've used in my report.
20 A. I guess I would like some more time if 20 Q. Okay. All right. In your calculation
21 we're going to really start checking 21 did you have a determination of the thickness
22 calculations to go do it in a situation where I 22 of the soil?
23 don't have to sit here and do it here. But if 23 A. I don't understand your use of the
24 we want to, we'll take time and we'll check 24 word thickness of the soil.
25 them, and I'll do them and we'll check them to 25 Q. Oh, I'm sorry. The thickness of the
7 (Pages 339 to 342)

Page 343 Page 345
1 roots in the grass. Was that necessary -- a 1 actually the beach processes and things that we
2 necessary variable? 2 put in along the beach, um -- seawalls,
3 A. Well, their model doesn't have that in 3 groins --
4 it. It only has a coefficient and a wave 4 Q. Wave breaks and things like that?
5 height. 5 A. -- breakwaters, things that you're
6 Q. All right. Okay. All right. Thank 6 either protecting against storm wave and water
7 you. 7 level attack or perhaps trying to do a shore
8 Where might we get the lat and long 8 protection, restoration through.
9 for each of the 21 locations -- point locations 9 Q. Littoral? Am I saying that right?
10 on the drawing that Mr. Resio used for his 10 A. Yes. That would be movement of
11 STWAVE or COULWAVE analyses? 11 sediments along the coastline, sand movement.
12 A. Dr. Westerink might be the best source 12 Q. Physical oceanography?
13 to get that information. 13 A. Yes. That was more of a deep-water
14 Q. Westerink's got it? 14 oceanography class, learning about large scale
15 A. I don't know if has -- 15 ocean circulation features, on an ocean basin
16 Q. How about this: Do you have it? 16 scale versus a near shore coastal scale.
17 A. I don't. 17 Q. And then of course you've already told
18 Q. You don't have it. 18 us about your -- this is your Master's thesis
19 A. No. 19 here; right?
20 Q. Okay. Okay, I think we stopped at 20 A. Yes.
21 modeling simulation techniques. What is 21 Q. "Numerical Modeling of Surf Zone
22 geophysical fluid dynamics? 22 Circulation and Rip Current Generation."
23 A. Can you tell me what page you're on? 23 A. Yes.
24 Q. 238, your CV. 24 Q. All right. Now, you are currently
25 A. This was an instruction about a lot of 25 Chief of the Flood and Storm Protection
Page 344 Page 346
1 long wave phenomena, some tides, trying to 1 Division, Coastal and Hydraulics Laboratory --
2 understand tides -- 2 A. Yes.
3 Q. All right. 3 Q. -- at Vicksburg.
4 A. -- salinity, things like that about 4 What does the chief of that division
5 water. 5 do?
6 Q. Hydromechanics; what is that? 6 A. Well, I'm really at the end of the day
7 A. I'm trying to recall what that course 7 responsible for the technical quality of all
8 was about. That, I believe, was talking about 8 the work that's done in my division. I have
9 fluid -- fundamental fluids, computational 9 input in developing research programs and
10 fluids. 10 plans, um -- responsible for helping to develop
11 Q. Hydraulic engineering? 11 research and work program and projects,
12 A. That's more classic river type 12 developing projects, scoping out projects. I
13 hydraulics. I would call it classical 13 typically get involved in the larger of the
14 hydraulics -- 14 projects that might involve a number of our
15 Q. Okay. 15 branches, bringing in interdisciplinary
16 A. -- looking at, um -- flow in rivers, 16 expertise in on a particular problem.
17 energy in rivers, sediment transport in rivers, 17 Q. Your role is primarily a management
18 things like that. 18 role, though, is it not?
19 Q. Ocean engineering? 19 A. Well -- by design I would say --
20 A. Ocean engineering is more what I call 20 Q. You've got 115 guys you've got to
21 the deeper water engineering, focused -- 21 watch.
22 looking at wave forces on structures, um -- 22 A. Over the last four years it's been
23 Q. Shoreline responses in coastal 23 very much related to IPET work and all of the
24 engineering structures. 24 studies that have been done since the IPET, to
25 A. Yeah. That was more looking at 25 look at designing higher level protections.
8 (Pages 343 to 346)

Page 347 Page 349
1 I've been actively involved in technical things 1 supervisor. I'm now a division chief which is
2 since Katrina. 2 a second line supervisor.
3 Q. Okay. Before Katrina, though, it was 3 Q. All right. So the first is lower than
4 primarily management. 4 the second?
5 A. Well, I'm a supervisor. I would have 5 A. The branch chief is lower than the
6 done the same things that I was just 6 division chief.
7 describing, I would just say since Katrina some 7 Q. Okay. But you called it second. You
8 of those other things have maybe taken a back 8 are now a second --
9 seat to all the much more technical things that 9 A. Second upward.
10 I've been doing since Katrina. 10 Q. Second upward. So you're second to
11 Q. Okay. 11 the top guy.
12 A. I've been contributing to develop -- 12 A. I report to the director, right.
13 updating the Corps guidance documents in light 13 Currently, yes.
14 of lessons learned from the IPET, so I've been 14 Q. Who's the director?
15 involved in several guidance document updates, 15 A. It was Tom Richardson. We have an
16 which is probably not normally what a division 16 accounting director right now.
17 chief would do. 17 Q. All right. So '88 to 2004 you were
18 Q. If you don't mind, I will want to ask 18 chief of the coastal processes branch --
19 you extensively about post-Katrina, but just 19 A. Right.
20 for ease of the questioning, what I'd like to 20 Q. -- coastal and hydraulics laboratory.
21 do is work my way back from pre-Katrina to the 21 A. Yes.
22 beginning. Because I do want to get very 22 Q. What are coastal -- what does the
23 specific about what you've done since Katrina. 23 coastal processes branch do?
24 So if you don't mind -- 24 A. Well, for that period of time our
25 A. Well, as division chief, I became in 25 branch was actively involved in designing
Page 348 Page 350
1 2004, I wasn't on the job long before Katrina 1 hurricane protection projects around the coast.
2 hit, so I'm not sure I ever really settled into 2 And as I said yesterday, most of that has
3 the division chief job yet. 3 involved beach nourishment, beach widening and
4 Q. Okay. When was it, in 2004 or 2005? 4 also dune construction to provide storm damage
5 A. 2005. I became the division chief in 5 reduction benefits to the people that live
6 2004. 6 behind there.
7 Q. Okay. Toward the end, I guess? 7 Q. Right.
8 A. Yeah. I can't recall. I recall being 8 A. And we've been actively involved in
9 in the job some months. 9 developing guidance for the Corps on how we do
10 Q. Okay. All right. So really, if we 10 that design.
11 were to talk about pre-Katrina, we'd be talking 11 Q. Okay. So during that period of time
12 about the 88(2004), which is about sixteen 12 from 1988 to 2004, would that have included
13 years in one location. 13 levee design?
14 A. Yes. 14 A. Well, as I said yesterday, there
15 Q. So that's where you really spent the 15 aren't many coastal levees in the U.S., and to
16 bulk of your career with the Corps, right? 16 my knowledge we haven't built one since I've
17 A. That was as a first line supervisor. 17 been with the Corps. I feel I might have known
18 I'm currently what we call a second line 18 if we were going to do a major coastal levee
19 supervisor. 19 somewhere else, but the experience has been in
20 Q. Slow down with me now. Chief? 20 designing projects, storm protection projects.
21 A. From 1988 to 2004 I was a chief of 21 Primarily of sand, but I've not personally been
22 coastal processes branch. 22 involved in design of a levee along the coast,
23 Q. All right. Now you're calling that a 23 an earthen levee, not sand, that was designed
24 second line? 24 to rebuff hurricane loadings.
25 A. The branch chief is a first line 25 Q. You use the word coastal levee. Is
9 (Pages 347 to 350)

Page 351 Page 353
1 the Reach 2 levee a coastal levee? 1 requires the evaluation of excavations that
2 A. I think so. Sure. 2 occur within a certain distance of a levee to
3 Q. Is the levee along Lake Pontchartrain 3 determine whether or not they're going to
4 a coastal levee? 4 impact the levee?
5 A. Yeah. I think -- I use coastal where 5 A. No.
6 there's a substantial wave component that would 6 Q. Do you, as a former chief of coastal
7 be required in the design versus an interior 7 processes branch, recognize that if you dig a
8 levee where you just have a static hydrostatic 8 hole within two or three hundred feet of a
9 loading condition. You know, the dynamic 9 levee on a water body that might induce
10 loading conditions that waves produce are quite 10 underseepage?
11 a bit more challenging to design against than 11 MR. MITSCH:
12 pure static, still water level loading with no 12 Objection to form. Vague.
13 waves present. So I think what makes it 13 A. Would you restate, pleas?
14 different is just the presence of a lot of wave 14 EXAMINATION BY MR. BRUNO:
15 energy. 15 Q. Yeah. You dig a hole on the banks of
16 Q. Are the levees along the river coastal 16 the Mississippi River. Isn't it true that that
17 levees? A lot of water there. 17 could induce underseepage?
18 A. Yeah. I think in those situations 18 A. Seepage is, to me, sort of -- we're
19 typically the wave loadings are much, much 19 getting into the geotechnical, subsurface
20 less. You know, in Reach 2, I mean, subjected 20 foundation, and I don't consider that my
21 the hurricane loadings, right? The wetlands 21 strength, that sort of deep seepage issue.
22 get inundated very fast, early in the storm, 22 Q. All right. So seepage issues would
23 and quite quickly it becomes what I consider a 23 not by your issue.
24 coastal design situation. 24 A. I think there are other people that
25 Q. Okay. That's fine. So the levees 25 know more about seepage than do I.
Page 352 Page 354
1 along Reach 2 are coastal levees. 1 Q. Fair enough. Who might that be?
2 A. I consider them to be. 2 A. Dr. Mosher, I think, on our team,
3 Q. Fine. Okay. And then from -- and you 3 would know I more about seepage and soil
4 managed -- let's see. You managed twenty 4 foundation kind of issues.
5 engineers, scientists and support. 5 Q. Okay. All right. And then from '79
6 A. Roughly a staff of twenty. 6 to '88 you were a research hydraulic engineer
7 Q. All right. And were you all asked 7 at the coastal processes branch up there in
8 from '88 to 2004 to study the erosion of the 8 Vicksburg.
9 banks of the MRGO? And generally. I'm making 9 A. Yes.
10 that as general as I can. Or any component 10 Q. And you were the principal
11 thereof? 11 investigator responsible for research into
12 MR. MITSCH: 12 tidal circulation and storm surge, nearshore
13 What year? 13 wave propagation, transformation and surf zone
14 MR. BRUNO: 14 wave breaking, shoreline and beach erosion
15 From '88 to 2000 -- when he was 15 processes, design and maintenance of coastal
16 the chief of the coastal processes 16 storm damage reduction projects, including
17 branch. 17 beach nourishment, numerical modeling and
18 A. I don't recall ever doing a large 18 coastal processes.
19 piece of work on that subject, but I do seem to 19 Okay. And that's consistent with what
20 recall some conversations back and forth that 20 you've told us, that you've been working
21 we might have had with the district about the 21 primarily with regard to how the surge and
22 MRGO. But I don't recall any large piece of 22 waves affects beach structures, sand
23 study or analysis that we did. 23 structures. Is that right?
24 EXAMINATION BY MR. BRUNO: 24 A. Correct.
25 Q. Are you aware of a policy which 25 Q. So you're well versed in the coastal
10 (Pages 351 to 354)

Page 355 Page 357
1 protection manual? 1 they describe how they went about the business
2 A. Reasonably. 2 of coming up with a still water level. Right?
3 Q. Okay. Okay. Now, in the beginning of 3 A. Okay.
4 your report, one of the first things you say 4 Q. Okay. And you can see they looked at
5 is, you say, at Page 5, in the third paragraph, 5 some historic storms, one in 1915, one in 1947
6 in the second sentence, these peak water levels 6 and one in 1956. They had some observed high
7 exceeded by nearly five feet those for which 7 water marks and they had some computed high
8 this levee reach was designed. 8 water marks, and they compared them and they
9 You see that? 9 got some checks and balances for some surge
10 A. Yes. 10 numbers. Right?
11 Q. Okay. All right. What I'd like to do 11 MR. MITSCH:
12 now is talk about the levee design. I'm 12 I'm sorry, Joe, I'm just not
13 certain that you went back and evaluated the 13 following where you are. You're in
14 design documents which formed the basis of the 14 the second clipped section?
15 design of the Reach 2 levee to get some sense 15 MR. BRUNO:
16 of what in fact was the intent of the 16 Yep. Hurricane Surge Heights,
17 designers. Right? 17 Table A11. Okay? Go to Page A18. It
18 A. No, that's not correct. 18 says Verification of Surge Heights.
19 Q. You didn't do that. 19 MR. MITSCH:
20 A. No. I have not delved into the 20 Oh, A18.
21 original design documents. In IPET our role 21 MR. BRUNO:
22 was to characterize the storm surge of waves on 22 You with me? Just walking
23 a regional scale. So I did go back enough to 23 through this.
24 look at what the design water levels were, 24 MR. MITSCH:
25 design wave conditions. 25 Okay.
Page 356 Page 358
1 Q. Okay. Well, let's explore that. I'm 1 EXAMINATION BY MR. BRUNO:
2 going to mark this as Exhibit Number 7. This I 2 Q. In fact, the Corps looked at some
3 will represent to you is Appendix A to the 3 hurricanes that happened in the past, looked at
4 Interim Survey Report of the Lake Pontchartrain 4 some high water marks and did some computations
5 and Vicinity -- it doesn't say anything else -- 5 in order to calculate surge. Simple enough.
6 21 November 1962, and it's entitled The 6 Right?
7 Hurricane Survey Interim Lake Pontchartrain, 7 A. Is there a question?
8 Louisiana and vicinity Report, and Exhibit A is 8 Q. Isn't that true?
9 the section that deals with hydrology and 9 A. Could you rephrase the question?
10 hydraulics. 10 Q. Isn't it true that what the Corps did
11 (Exhibit 7 was marked for 11 was go back and evaluate hurricanes that
12 identification and is attached hereto.) 12 occurred in the past, in particular what's
13 A. Okay. 13 reported here is a hurricane dated September,
14 EXAMINATION BY MR. BRUNO: 14 1915, September '47 and September '56. And
15 Q. All right? Okay? And to make it easy 15 they compared the observed high water marks to
16 for us I put some clips so we wouldn't have to 16 the computed high water marks.
17 go paging through it. First section talks 17 A. I'm not familiar with the design
18 about the climatology, which we can skip. 18 process. As I said, you know, in IPET my
19 A. Okay. 19 interest was what were the storm surge and
20 Q. Second section talks about hurricane 20 waves produced during Katrina as they related
21 surge heights. If you want to take that clip 21 to the design wave and water level conditions
22 off or just lose that first section, I just 22 that were incorporated into the design? I
23 wanted to keep it together for completeness. 23 received information about that from the
24 A. Okay. 24 district and did the comparison, but I'm not
25 Q. Hurricane surge heights. And here 25 familiar with their design process and
11 (Pages 355 to 358)

Page 359 Page 361
1 approach. 1 report.
2 Q. Well, you said that -- I'm quoting 2 Q. Well, I'll get there in a minute. I
3 you -- I was interested in what were the storm 3 just want to see -- is I guess what you're
4 and surge wave produced during Katrina as they 4 saying to me is it doesn't matter to you what
5 related to the design wave and water level 5 the actual design documents say, you relied on
6 conditions -- the design and water level 6 the IPET report for your information as to the
7 conditions that were incorporated into the 7 design wave.
8 design. Okay? And so that's what I'm trying 8 A. No, the IPET report contains
9 to find out. What were the design wave and 9 information that I was provided from the
10 water level conditions that were incorporated 10 district about what the design water levels and
11 into the design? I figured the best place to 11 wave conditions were.
12 go is to -- 12 Q. Okay. All right. Well, let me
13 A. Well, they're in the IPET. 13 just -- let's just do this, then. We'll put
14 Q. I'm with you. But isn't this better 14 those documents in evidence and then we'll
15 than IPET? This is the actual document. 15 allow the record to be complete and then we'll
16 A. Let's look in the IPET because that's 16 go to the IPET.
17 the information -- 17 All right. The other document we have
18 Q. That you used. 18 is the actual general design memorandum for --
19 A. -- that I've gotten from the district 19 I'll mark this as Exhibit 8.
20 at the time of the IPET, and they confirmed 20 For the record, this is a section from
21 that with me. So let's use the IPET, not this 21 the Lake Pontchartrain and Vicinity Design
22 document, because that's -- 22 Memorandum Number 1 entitled Hydrology and
23 Q. Well, wait, wait. You're telling me 23 Hydraulic Analysis for the Chalmette location.
24 that IPET is better than the actual design 24 And let's just put it of record and ask you
25 document? 25 just a couple of basic questions.
Page 360 Page 362
1 A. As far as I know, these -- what's in 1 Now, let's go to the IPET. And we can
2 the IPET are the design water levels and wave 2 compare. All right. So what was your
3 conditions along this levee. 3 understanding of the still water height
4 Q. Suppose they're wrong? 4 utilized by the designers, based on IPET?
5 A. Um -- 5 (Exhibit 8 was marked for
6 Q. Tough luck? 6 identification and is attached hereto.)
7 A. Well, I don't think they're wrong. 7 A. Well, let's turn to IPET Page 4-132.
8 Q. That's what we're exploring. 8 EXAMINATION BY MR. BRUNO:
9 A. I'm not familiar with the process or 9 Q. I have just the executive summary.
10 the document that you're referring to. 10 A. Figure 90. So Volume 4, Page 132,
11 Q. All right. Well, just bear with me 11 Figure 90.
12 then. Let's go to maximum run-up. You agree 12 Q. Okay. All right. So what was the
13 with me that the design of the levee at Reach 2 13 design still water height?
14 called upon the Corps to calculate still water 14 A. Well, let's talk about Reach 2.
15 height and called upon the Corps to calculate 15 Q. Okay. Reach 2.
16 the water run-up height, those two numbers were 16 A. And do you have this figure in front
17 combined and they formed the basis of the 17 of you?
18 height of the levee design. Isn't that true? 18 Q. I don't. I have the executive
19 A. I don't know. I'm not familiar with 19 summary. That's okay. I trust you.
20 the document. 20 A. Okay. There were three values, and it
21 Q. All right. Well -- 21 did vary along Reach 2, and I recall that we
22 A. I am familiar with the information 22 had to convert the water levels from the
23 that's listed in the IPET report. So if you 23 original design to NAVD88(2004.65), and I
24 want to go look in IPET report I would be glad 24 recall that there was some correction of
25 to talk about the numbers that are in the IPET 25 several tenths of a foot to make the datum
12 (Pages 359 to 362)

Page 363 Page 365
1 conversion. And after we converted the design 1 Q. Right. Okay. So first of all, do you
2 water level ranged from 12.9 to 13.4 feet. 2 know who it was that did the calculation to go
3 Q. Okay. If we look at the original 3 from mean sea level to NAVD88?
4 now -- go back to exhibit number -- what was 4 A. That we used in IPET?
5 the exhibit number I gave you? 5 Q. Uh-huh.
6 Let's look at Exhibit Number 8 and see 6 A. It would have been the datum task.
7 how that compares. Page 24, Table 13. 7 There was a whole separate task in he IPET that
8 A. Okay. 8 was responsible for looking at the datums.
9 Q. Chalmette. 9 Q. Who?
10 A. Okay. 10 A. I think I remember Jim Garster was one
11 Q. Okay? And then there are two areas, 11 of the coleads.
12 west of Paris Road -- 12 Q. Okay. All right. And then we have an
13 A. Okay. 13 average depth of 16.3 feet?
14 Q. -- east of Paris Road, Paris Road to 14 A. What do you mean an average depth?
15 Bayou -- I'm sorry. There's three locations; 15 Q. Well, there's a column that says
16 west of Paris Road, east of Paris Road, Paris 16 average depth.
17 Road to Bayou Lawler and then Bayou Lawler to 17 A. I don't know what that is.
18 Violet. You see that? 18 Q. Because you don't know what that is.
19 A. Yes. 19 A. No.
20 Q. And then there's a WTL? You see that? 20 Q. Okay. And then we have significant
21 A. Yes. 21 wave height. That's HS, isn't it?
22 Q. WTL is the still water height or surge 22 A. That's how it's listed here, yes.
23 elevation? 23 Q. And 7 feet?
24 A. I don't know. I'm not familiar with 24 A. Yes.
25 the document. If you say that's what it is, 25 Q. And then we have wave period of 6.4?
Page 364 Page 366
1 then -- I don't know. I can't confirm or 1 A. Yes.
2 refute that because I'm not familiar with the 2 Q. All right. So -- and we have a run-up
3 document. 3 elevation of 4.7.
4 Q. Okay. All right. Well, let's just 4 A. I see that under the table.
5 assume that that is correct. What's reported 5 Q. And then we have the proposed
6 here, first of all, is that there are two 6 elevation of the protective structure of 17.5.
7 sections of the reach, one is east of Paris 7 A. Yes. I see that.
8 Road to Bayou Lawler. Do you know where Bayou 8 Q. Do you know how the proposed elevation
9 Lawler is? 9 was computed?
10 A. I'm not sure. 10 A. No.
11 Q. Okay. And then you don't know where 11 Q. Do you know how wave run-up elevation
12 Bayou Lawler or Violet is, but in any case, 12 was computed?
13 what they show here is 13 feet to 12.5 feet. 13 A. No.
14 A. Okay. 14 Q. Do you know how the period was
15 Q. So that would seem pretty consistent 15 computed?
16 with what you got? 16 A. No.
17 A. It looks like maybe, I don't know, 17 Q. Do you know how the wave amplitude or
18 four tenths of a foot difference. 18 height was computed? Significant wave?
19 Q. But again, you said you changed it -- 19 A. No.
20 A. We tried to account for some datum -- 20 Q. And you don't know what the average
21 differences between the datum that they might 21 depth means.
22 have used or were using and the 22 A. No.
23 NAVD88(2004.65). They're referencing here to 23 Q. Do you know what wind speeds were used
24 mean sea level, it looks like, in the table 24 to calculate this number?
25 under WTL. If that's the water levels. 25 A. No.
13 (Pages 363 to 366)

Page 367 Page 369
1 Q. Would that be relevant at all with 1 Q. I'll let you use yours. Go to Page --
2 regard to your attempts to compare those 2 I'm sorry, Volume 1, Page 35, and that will
3 numbers with the Hurricane Katrina numbers? 3 give you the exact same page as me.
4 A. I'm looking at the table in the IPET 4 A. I'm on Volume 4, Page 112.
5 report under the waves, and I see a 7 and a 5 Q. I'm on the executive summary.
6 6.4. 6 A. I don't have the executive summary.
7 Q. Right. 7 Q. Okay. Well, then, you just have to
8 A. So my assumption was that I was being 8 trust me.
9 given accurate information on what was used in 9 A. This figure I believe is also in my
10 the design along Reach 2. 10 volume. So I'm referring here to my volume.
11 Q. Okay. All right. Okay. Did you -- 11 Q. That's fine. Well, just trust me that
12 but you didn't at all evaluate the wind speeds 12 I haven't hoodwinked you and I've copied the
13 utilized by the Corps back in '61, '62, '63 to 13 right pages.
14 come up with these numbers. 14 A. It appears to be the same one.
15 A. No. During IPET my interest was how 15 Q. Let's go the page I-36. Well, it
16 did they compare; how did the water levels and 16 starts on 35, and it's Exhibit Number 9. It
17 wave conditions produced by Katrina compare to 17 says, winds --
18 the wave conditions and the water levels that 18 A. Wait -- I'm confused with what page
19 were used in the design of the project. That 19 you are on.
20 was simply my interest in the IPET to do that 20 Q. Volume I, Page 35.
21 comparison. 21 A. Okay.
22 Q. Weren't you interested in comparing 22 Q. The paragraph which begins with the
23 the storms? In other words, the storm -- the 23 word winds.
24 synthetic storm utilized to calculate these 24 A. Okay. I didn't author this Volume I,
25 numbers in the sixties, wouldn't that be 25 so --
Page 368 Page 370
1 relevant to compare to the storm that produced 1 Q. Well, let's just see --
2 the wave and surge numbers experienced by 2 A. Let's keep that in mind.
3 Katrina? 3 Q. I understand. You authored the whole
4 A. That was not of interest to me. I was 4 Volume 4?
5 simply interested in comparing the water levels 5 A. I authored some of Volume 4.
6 used in the design, the wave conditions used in 6 Q. Which sections of Volume 4 did you
7 the design, compared with what Katrina produced 7 write?
8 along that levee section. 8 A. I don't think I could be that
9 Q. Okay. All right. So in any case, you 9 specific. You know, there were contributions
10 did that, and the IPET came up with a view 10 generated from many of the team leaders in the
11 about surge and waves that had occurred in 11 IPET.
12 Katrina, right? 12 Q. Okay.
13 A. Yes. 13 A. And it was probably -- I wrote some
14 Q. And that's Exhibit Number 9. And this 14 and did editing of other contributions of and
15 is a section of the executive summary. 15 blending of contributions and organizing of the
16 Have I reproduced the pages 16 material. But I couldn't go back and tell you
17 accurately? 17 I wrote that paragraph, I didn't write that
18 (Exhibit 9 was marked for 18 paragraph.
19 identification and is attached hereto.) 19 Q. Sure. Right. Well, I mean, I'm just
20 A. I'm just looking at my volume to see 20 a taxpayer here, can I rely on the executive
21 if it's the same figure. 21 summary of the IPET report as accurately
22 EXAMINATION BY MR. BRUNO: 22 summarizing what's contained in the --
23 Q. Why don't you just go to I-35 of yours 23 A. Let's see what it says and if I have
24 and just put mine down? 24 any problem I'll -- with what is written I'll
25 A. Pardon? 25 let you know.
14 (Pages 367 to 370)

Page 371 Page 373
1 Q. Yeah. But before we go there, you 1 from my document, what I wrote. Someone's
2 steam to be suggesting that it may be 2 interpretation of what I wrote is what you are
3 inaccurate. 3 reading me.
4 A. I'm not suggesting that at all. 4 Q. I am reading the IPET --
5 MR. MITSCH: 5 A. I know what you're reading.
6 He's not suggesting that at all. 6 Q. -- executive summary.
7 EXAMINATION BY MR. BRUNO: 7 A. I know what you're reading.
8 Q. Okay. All right. So I can rely on 8 Q. The someone is IPET, is it not? The
9 it. 9 report -- it's not the report of Bruce
10 A. No, I'm not saying that either. You 10 Ebersole, is it? It is a report from something
11 read along and if I have any problem with what 11 called IPET, isn't that true?
12 you're reading I'll let you know. 12 A. IPET was a group.
13 Q. All right. Well, I'm just reading the 13 Q. It was a group.
14 printed word. 14 A. A group.
15 A. That's fine. 15 Q. A group signed its name to this
16 Q. It says, winds from Katrina generated 16 document --
17 a record wave environment. 17 A. Yes.
18 A. Okay. 18 Q. -- it's been presented to the public
19 Q. Is that true? 19 of the United States of America as being the
20 A. Well, let me tell you what I wrote 20 best work of this group to examine what
21 about it. On that subject this is what I 21 occurred with regard to those areas of study by
22 wrote: Due east of the Mississippi River 22 the IPET group. Isn't that true?
23 delta -- 23 A. Could you restate that, please?
24 Q. Give us a page, Bruce. 24 Q. It's been presented to the public of
25 A. I'm sorry. In the IPET, Volume 4, 25 the United States of America to be the best
Page 372 Page 374
1 Page 1 in the Executive Summary. Due east of 1 work of this group to examine what occurred
2 the Mississippi River delta, a deep water 2 with regard to areas of study by the IPET
3 National Oceanographic and Atmospheric 3 group, isn't that true?
4 Administration buoy recorded the highest 4 A. I would agree.
5 significant wave height, 55 feet, ever measured 5 Q. All right. So are you taking issue
6 in the Gulf of Mexico. 6 with this sentence wind from Katrina generated
7 Q. Okay. Sorry. Missed your point. My 7 a record wave environment, or --
8 question was whether or not you agree with 8 A. I like my sentence better. It's more
9 statement winds from Katrina generated a record 9 specific and more accurate to what the fact
10 wave environment. You're talking about 10 was.
11 something that I'm not talking about. 11 Q. All right. The next sentence is,
12 A. I think we are. 12 again, the lack of measurements caused the IPET
13 Q. Well, do you agree or a disagree winds 13 to model the wind generated waves to determine
14 from Katrina generated a record wave 14 the conditions created by the storm.
15 environment? 15 Is that true?
16 A. The winds from Katrina generated the 16 A. Where are you now?
17 highest significant wave height ever measured 17 Q. I'm in the second sentence.
18 in the Gulf of Mexico. 18 A. First paragraph under the figure?
19 Q. Okay. So I guess -- help me. Are you 19 Q. Nope. The paragraph which begins with
20 agreeing or disagreeing? 20 the word winds, which is where I started.
21 A. Um -- 21 A. I agree with that.
22 Q. That shouldn't be too difficult to 22 Q. IPET used a nested approach that used
23 tell me. 23 the WHAM model to generate wind wave fields for
24 A. I don't know that I disagree. I'd 24 the entire gulf and STWAVE to model nearshore
25 rather go with my wording. This is the wording 25 waves in and around New Orleans.
15 (Pages 371 to 374)

Page 375 Page 377
1 Is that true? 1 of America, was it not?
2 A. Yes. 2 A. Yes, it was publicly available.
3 Q. Okay. The resulting wave heights and 3 Q. And the purpose of that publication
4 wave periods are shown in Figures 10 through 4 was to let the citizens of the United States of
5 13. And those are reproduced in the exhibit, 5 America know what conclusions were reached by
6 and they're all there. 6 IPET with regard to the experience of the
7 You see those, right? 7 levees in Hurricane Katrina. Isn't that true?
8 A. Let me check my own figures. 8 A. Yeah. The take home message from, you
9 Could you restate the question, 9 know, our comparison of water levels and wave
10 please? 10 conditions was really just to illustrate how
11 Q. The resulting wave height and wave 11 the system was completely overwhelmed by the
12 periods are shown in Figures 10 through 13. 12 water levels and wave conditions.
13 And those exhibits are reproduced in my 13 Q. Well, have you --
14 exhibit. 14 A. That hasn't changed from -- that would
15 A. I agree. 15 be my testimony in this case, and that would
16 Q. The most significant finding was that 16 have been my testimony after the IPET.
17 the waves along the GIWW, St. Bernard, MRGO and 17 Q. Well, is it your testimony that the
18 Plaquemines levees were ocean generated waves 18 waves generated in Hurricane Katrina along the
19 with wave period in the 15 to 16 second range, 19 MRGO reach were the same waves for which those
20 much more capable of overtopping structures 20 levees were designed? Isn't that going to be
21 than the design assumed wind waves with periods 21 your testimony in this case?
22 of 5 to 6 seconds. 22 A. Could you restate, please?
23 Is that an accurate statement? 23 Q. Well, is it going to be your testimony
24 A. That was a finding in the IPET, and in 24 that the waves generated in Hurricane Katrina
25 the more detailed modeling that we've done 25 along the MRGO reach were the same waves for
Page 376 Page 378
1 since we would probably modify that statement. 1 which those levees were designed?
2 Q. So it's wrong. 2 A. I would say with the best information
3 A. No, it was right at the time the IPET 3 that we have today the significant wave height
4 work was done. 4 and the mean wave period that we've calculated
5 Q. Well, it may have been right at the 5 are very similar to the design conditions.
6 time of IPET, but is it a true statement based 6 Q. Okay. All right. So Katrina didn't
7 upon your analysis and the opinion that you 7 make a really big bad wave, it's the same wave
8 propose to offer to the judge in this case? 8 for which the levee was designed. Identical,
9 A. Um -- I would offer a different 9 according to you.
10 assessment to the judge in this case -- 10 A. Well, the most important thing is the
11 Q. Uh-huh. 11 water level.
12 A. -- based on the work that's been done 12 Q. I'm asking about waves first. Answer
13 subsequent to the IPET. 13 my question about waves and you can talk about
14 Q. All right. So this is wrong. 14 water level all day long. Talking about waves.
15 A. It was right at the time. 15 A. Okay.
16 Q. Is it right now? 16 Q. The waves are the same, according to
17 A. No, I would modify it at the current 17 you.
18 time. 18 A. I didn't say the same, I said they
19 Q. Bruce, what was the purpose of the 19 were similar. The significant wave height and
20 IPET report, if you know, have any idea? 20 the mean wave period --
21 A. Well, the purpose of the IPET was to 21 Q. Are the same?
22 try to understand what happened during Katrina 22 A. -- produced during Katrina, as best we
23 and why did the system respond as it responded. 23 can determine, are very similar to the
24 Q. Right. And that information was 24 significant wave height and the period that
25 published to the citizens of the United States 25 were considered in the design of the levee.
16 (Pages 375 to 378)

Page 379 Page 381
1 Q. How are waves created? How does a 1 all I want is a few answers. And we'll talk
2 wave become a wave? 2 about the loading and stuff later. Let's just
3 A. Wind. 3 see if I can learn about this subject. Okay?
4 Q. Wind. 4 You make a statement about waves being
5 A. Wind. 5 the same, and I think I have a right to explore
6 Q. And what factors influence the height 6 that.
7 and period of a wave? 7 A. I said they were similar.
8 A. Wind speed. 8 Q. Well --
9 Q. Wind speed. 9 A. You've presented them as the same.
10 A. Wind fetch. 10 Q. Well, in --
11 Q. Okay. 11 A. The significant wave height.
12 A. Water depth. 12 Q. Let's go to your report and see what
13 Q. Okay. 13 you wrote --
14 A. Frictional resistance -- 14 A. Okay.
15 Q. Okay. 15 Q. -- what you wrote about the waves.
16 A. -- on the bed. 16 A. You talking about IPET or the current
17 Q. All right. 17 report?
18 A. Um -- topographic irregularities, 18 Q. Talking about you. Page 5. These
19 presence or absence of a structure. 19 conditions were quite similar to those factored
20 Q. Okay. Wind, wind speed -- 20 in --
21 A. Wind direction. 21 A. Can I find where we are?
22 Q. -- wind direction. Right? Okay. Is 22 Q. Page 5.
23 that it? 23 A. Of what document?
24 A. Um -- I don't know if that's an 24 Q. Your report.
25 all-inclusive list. 25 A. My expert report.
Page 380 Page 382
1 Q. All right. Fair enough. 1 Q. Bruce Ebersole, December 17, 2008,
2 A. I think I got the major ones. 2 Page 3, third paragraph, middle of the
3 Q. I'm with you. So let's see if -- what 3 paragraph, sentence says, these conditions were
4 I can learn from this exercise. 4 quite similar to those factored into the
5 The Katrina wave is six or seven feet 5 levees' design, wave heights of 6.6 to 7 feet
6 according to your report. The design wave is 6 and periods of 6.2 to 6.4 seconds.
7 six to seven feet according to your report. 7 Boom. That's what I'm focused on now.
8 The Katrina wave has a period of five to six 8 A. Okay.
9 seconds according to your report. The design 9 Q. Did you stand by that sentence?
10 wave has a period of six to seven seconds 10 A. Yes.
11 according to the report. So it's the same 11 Q. All right. Now, the wind fetch for
12 wave. Same peak wave. I'm sorry. Right? 12 the design wave is the same wind fetch for
13 A. Similar. 13 Katrina, isn't that true?
14 Q. Similar. Close enough. 14 A. I don't know that.
15 So did you compare the wind in Katrina 15 Q. Why not?
16 to the wind in the design hurricane? 16 A. I don't know how they -- I don't know
17 A. No. 17 the design process.
18 Q. All right. Well, the wind fetch is 18 Q. All right.
19 the same, right? I mean, we didn't change the 19 A. So I have no idea what was used for
20 location so the fetch is the same. 20 fetch. I mean, the fetch for hurricanes is the
21 A. I mean, I don't think the wind damages 21 whole Gulf of Mexico. So maybe I should ask
22 the levee. So I mean, I'm more interested in 22 you, did they consider the whole Gulf of
23 the loading on the levee. 23 Mexico?
24 Q. I appreciate all that, Bruce. But as 24 Q. No, they actually -- they considered
25 I said, I'm asking a couple questions here, and 25 the same thing that you did in your evaluation,
17 (Pages 379 to 382)

Page 383 Page 385
1 if you're asking me. They were the same. 1 That information came from STWAVE output.
2 A. I don't know that. 2 Q. Okay. All right. So where are the
3 Q. Since you're taking my word for it 3 waves? Are they at the toe, on the crest --
4 take my word for it, they're the same. 4 A. These would be incident away from the
5 A. No, I don't want to take your word for 5 levee. We've used the COULWAVE model to make
6 it. 6 estimates of conditions at the levee.
7 Q. Okay, fine. Let's assume they're the 7 Q. All right. Similar to what the Dutch
8 same. 8 did in using their, um -- their SWAN model,
9 A. I don't want to assume they're the 9 right?
10 same. 10 A. No, I don't know how far they brought
11 Q. You don't want to assume they're the 11 their waves in with the SWAN model. I think --
12 same. I'm asking you to assume they're the 12 Q. Right up to before the toe.
13 same. 13 A. Yeah. I think ours would be a little
14 A. I don't want to assume they're the 14 more seaward of that. I don't --
15 same. 15 Q. Well, close. I'm not saying to the
16 Q. Okay, Bruce. How about this? 16 millimeter. I'm just saying generally, it
17 A. I don't think they had the same kind 17 wasn't on the levee.
18 of technologies we have today to estimate 18 A. Seaward of the levee toe.
19 waves -- 19 Q. Fair enough. Seaward of the levee
20 Q. Very cool. 20 toe. So that's what we're talking about.
21 A. -- so I can't imagine they have used 21 Now, usually -- I mean, you know, the
22 the same fetch. 22 Corps of Engineers has been doing wave
23 Q. All right. Let me ask you this: 23 calculations for about fifty, sixty years,
24 You've already told me that water depth plays a 24 right? And they've used the shore protection
25 role in a wave height and period; right? You 25 manual to do that, haven't they?
Page 384 Page 386
1 listed it as one of the variables. 1 A. We've been using numerical models for,
2 A. Water depth certainly influences wave 2 gosh --
3 height. 3 Q. Fifty, sixty years.
4 Q. Okay. What does it do? How does it 4 A. No, I bet, um -- probably since I've
5 work? If the water is deeper is the wave 5 been here, twenty, twenty-five years, we've
6 taller or shorter? 6 been using computer models of wave prediction.
7 A. Are you talking -- I mean, the water 7 Q. Well, yeah, but the computer models
8 depth comes into influencing the generation of 8 use the formulas that find their genesis in
9 waves and it -- 9 the --
10 Q. I'm talking about -- no, no, no. 10 A. They're much more sophisticated
11 Let's be fair here. We're talking about your 11 than --
12 sentence. We're talking about the six to seven 12 Q. Well, I understand that--
13 foot significant wave height and we're talking 13 A. -- the old design methods. We've come
14 about the wave period of five to six seconds. 14 a long way in wave prediction in the last sixty
15 That's what we're talking about. 15 years, trust me.
16 A. Okay. 16 Q. Fine. Is it your testimony that wave
17 Q. And maybe we need to learn from you, 17 fetch no longer has a role in the calculation
18 where were those waves located relative to the 18 of wave amplitude and period?
19 levee? So we can get -- that's a good point. 19 A. That's not my testimony.
20 I'm glad you brought that up. Let's focus on 20 Q. Okay. Fine. All right. And the guys
21 that. Where are these -- 21 back in 1961, they were using wind, wind
22 A. The wave conditions created by Katrina 22 direction, wind speed, wind fetch, water depth,
23 along this levee reach were characterized by 23 resistance, topographic irregularities -- they
24 significant wave heights of six to seven feet 24 were using all those things back in 1961, 1966.
25 and mean wave period of five to six seconds. 25 A. I don't exactly know what they were
18 (Pages 383 to 386)

Page 387 Page 389
1 using in 19 -- 1 situation. Is there a fetch? Is there wind?
2 Q. Well, here's the fundamental question, 2 Is there --
3 Bruce: The deeper the water the higher the 3 Q. Yes, of course.
4 potential -- I'm sorry. An increase in water 4 A. That's fetch?
5 depth will increase the potential for a taller 5 Q. I tried to show it to you. You
6 amplitude of wave. Isn't that true? 6 wouldn't look at it. You said you couldn't
7 A. Could you restate that? 7 understand it. I gave you the materials that
8 Q. If you have deep water close to the 8 they used. They're in evidence. I have the
9 shore -- 9 '62 document and I have the '66 document. It's
10 A. Okay. 10 all there.
11 Q. -- all right? You can get a deeper 11 MR. MITSCH:
12 wave. 12 Objection. It is not all there.
13 A. A deeper wave. 13 MR. BRUNO:
14 Q. I'm sorry. A wave of a larger 14 Yes, it's all there.
15 amplitude. 15 MR. MITSCH:
16 A. Okay, I guess I'd like to know more 16 You're being argumentative.
17 about the situation that we're talking about 17 MR. BRUNO:
18 specifically before I answer that question. 18 No, I'm not.
19 Q. All right. Well, let's -- 19 EXAMINATION BY MR. BRUNO:
20 A. It's kind of a general statement. I 20 Q. I gave to you the design document
21 would rather talk about what's the specific 21 produced to me by the Corps of Engineers which
22 situation, what's the wind speed we're talking 22 describes exactly how the Corps calculated wave
23 about, what's the topography, the bathymetry? 23 amplitude in seconds. If you'd like to read it
24 Tell me those things and then I'll be better 24 at the break, you can. It's all there in front
25 able to answer your question. 25 of you.
Page 388 Page 390
1 Q. Well, as I told you they're the same. 1 So here's the question: If, as you
2 A. What's the same? 2 say, Katrina produced those ridiculously high
3 Q. Well, we're talking about Reach 2. 3 storm surges, wouldn't you expect, if the guys
4 Right? 4 back in '61, '62, '63, '64 used the same wind,
5 A. I think we are. 5 the same wind speed, the same wind direction,
6 Q. Okay. And I'm comparing Reach 2 6 the same resistance, the same topography, that
7 calculations utilized to establish significant 7 you would get a different amplitude of wave?
8 wave height and period back when the levee was 8 MR. MITSCH:
9 designed to the calculations utilized to 9 Objection, vague. A lot of
10 determine the significant wave and period 10 different things that are involved in
11 experienced in Katrina at the same location. 11 that; storm track, size -- it's not --
12 Okay? Do you understand where we are 12 you're not being specific enough for
13 now? 13 him to be able to comment.
14 A. Yeah. I'm not familiar with how it 14 MR. BRUNO:
15 was done way back when, so I don't know how I'm 15 Apparently he's not able to
16 going to compare something from way back when 16 answer the question himself, he needs
17 to something today. I don't know how it was 17 help by counsel.
18 done. 18 A. No, I agree.
19 Q. I'm not asking you to do that. 19 EXAMINATION BY MR. BRUNO:
20 A. Okay. 20 Q. I know you agree. He just gave you
21 Q. I'm asking you to do this: That if we 21 the answer.
22 have much deeper water in Katrina, wouldn't you 22 A. It's a complicated situation.
23 expect a different wave, assuming that the guys 23 Q. Sure, it is.
24 in '61, '62 and '63 did it correctly? 24 A. I need to know more. As I just said
25 A. You got to tell me more about the 25 earlier, tell me more about the specifics
19 (Pages 387 to 390)

Page 391 Page 393
1 about -- 1 EXAMINATION BY MR. MITSCH:
2 Q. I just did. 2 Q. I want to know if you have the
3 A. -- what's the topography, what's the 3 expertise to calculate wave height and period.
4 wind speed -- 4 Can you do it?
5 Q. I'm telling you, assume it's the same 5 A. Well, on this project I've relied on
6 topography. It's the same. It's the same 6 work of Dr. Resio and Dr. Smith to do the
7 location. It's the same area. It's the same 7 calculations of waves using the technology that
8 geography. It's the same vegetation. It's the 8 we're using today. The model technology.
9 same everything. 9 Q. Okay. That's all wonderful, but
10 A. I don't know what was used as input to 10 here's the question: Can you calculate wave
11 the original method. 11 height and period? Are you -- do you have
12 Q. It's right there in front of you. 12 sufficient expertise, the ability, the
13 A. Well, I'd have to do some serious 13 training, to calculate significant wave height
14 study before I would want to discuss with 14 and period? I'm just curious. And if you
15 you -- 15 don't and if it's Resio I should be talking to,
16 Q. Well, how about this Bruce: Let's go 16 that's fair. I'm not trying to trick you.
17 to today. 17 A. When you say calculate, do you mean
18 A. -- similarities between-- Okay. 18 apply a model, or --
19 Q. Let's say you had same geography, same 19 Q. Whatever method -- you're the expert.
20 topography, same wind direction, same wind 20 A. Okay.
21 speed, same everything. Okay? You run the 21 Q. Whatever method you might utilize,
22 Model A and your water depth is X. Run Model B 22 perhaps it's a mathematical calculation,
23 and you increase the water depth by 10 feet. 23 perhaps it's a computer program, I don't know.
24 Would you expect the amplitude of the 24 You're the expert.
25 wave that came out of that computer model to be 25 A. Okay.
Page 392 Page 394
1 exactly the same? If you manipulated the water 1 Q. The question is, if I would like to
2 depth. 2 know significant wave height and period, would
3 A. What's the technique you're using to 3 I call Bruce Ebersole on the phone and say,
4 estimate the wave? 4 Bruce, I'd like to know the wave height and the
5 Q. Your technique, the Bruce Ebersole 5 period, can you give it to me? Or would you
6 technique. 6 say to me, Joe, I'm sorry, you better call
7 A. Our current modeling. 7 Dr. Resio, that's his field, I'm doing
8 Q. I'm sorry? Yeah. The Bruce 8 something else? That's why I'm asking the
9 Ebersole -- 9 question.
10 A. You're losing me in your discussion. 10 A. Okay. Yeah, that would be my
11 Maybe we can find a different way to discuss 11 recommendation.
12 the issue. 12 Q. To call Dr. Resio.
13 Q. Well, probably we can, Bruce. 13 A. Dr. Resio.
14 A. If you want to discuss -- 14 Q. Okay. All right. So really, you
15 (Off the record.) 15 don't have the expertise to comment on whether
16 EXAMINATION BY MR. BRUNO: 16 or not the wave height and period is the same
17 Q. All right. Bruce, are you telling us 17 or dissimilar from that wave height and period
18 that you're not able to calculate wave height 18 used by the designers of the levees, that's
19 and period; is that what you're saying to us? 19 really Dr. Resio 's expertise, right?
20 A. No. 20 A. Could he restate that, again, please?
21 MR. MITSCH: 21 Q. You don't have the expertise to say,
22 In what environment? 22 in your report, anything about whether the
23 MR. BRUNO: 23 waves utilized as the basis for the design of
24 Doesn't matter what the 24 the levee are similar or not similar to the
25 environment is. 25 waves generated in Hurricane Katrina, that is
20 (Pages 391 to 394)

Page 395 Page 397
1 something that is within the expertise of 1 A. Um -- let's take the MRGO channel.
2 Dr. Resio. 2 Okay? We have an instant wave on one side,
3 A. No, I disagree. You know, I 3 wave propagating across the channel, wave
4 understand what a similar or small differences 4 going -- you know, propagating past the channel
5 between significant wave height and period for 5 on the other side. Under no wind situation
6 those two sets of results. What we're 6 that wave height is going to get smaller as it
7 calculating and what was used in the design. I 7 moves across that deep channel, from wave
8 understand enough about wave processes to 8 shoaling. Wave shoaling theory. It gets
9 interpret the two values and interpret the 9 smaller.
10 difference between the two values and know 10 Q. It doesn't take a lot of logic there.
11 whether they're similar or not. 11 If there's no wind then gravity takes over.
12 Q. Well, Bruce, I can look at that door 12 That's not rocket science. Got you. Not the
13 and that door and I can tell you that they're 13 question, though.
14 both gray. That doesn't make me an expert on 14 A. Okay.
15 doors or even colors or painting or the like. 15 Q. How about this: Does the shore --
16 The question is whether or not you have the 16 MR. MITSCH:
17 sufficient expertise to make this statement or 17 Wait. He was trying to respond.
18 whether or not Dr. Resio has the sufficient 18 A. Yeah. I'm trying to break this
19 expertise to make the statement that the 19 impasse we're on.
20 conditions were quite similar to those factored 20 EXAMINATION BY MR. BRUNO:
21 into the levee design, wave height of 6.6 to 7 21 Q. Okay. All right.
22 feet and periods of 6.2 to 6.4 seconds. That 22 A. So in the surf zone, for example,
23 statement. 23 where active wave breaking is occurring in
24 MR. MITSCH: 24 shallow water, you know, we know that that is
25 Asked and answered. 25 strongly influenced by the water depth. And as
Page 396 Page 398
1 A. I do have the expertise to make that 1 I said yesterday, I believe, the significant
2 statement. 2 wave height will generally be .4 to .6 times
3 EXAMINATION BY MR. BRUNO: 3 the local water depths. So I understand that
4 Q. And that's simply because you're able 4 wave energy in the surf zone gets saturated and
5 to compare a number, and that number being a 5 you can only get a significant wave height
6 wave height of 6.6 to 7, which you got from 6 that's generally in the .4 to .6 times the
7 somebody in the Corps, and you compared that to 7 water depth range.
8 a number generated by Dr. Resio. 8 EXAMINATION BY MR. BRUNO:
9 A. No. 9 Q. Okay. All right. So let's move away
10 Q. Isn't that true? 10 from the surf zone now and we can get an answer
11 A. I understand wave transformation 11 to my question.
12 processes. 12 A. Offshore?
13 Q. You do. 13 Q. No, not offshore. We were -- no, sir.
14 A. I have a good understanding. It's not 14 We weren't offshore. We were where Dr. Resio
15 as in-depth as Dr. Resio or Dr. Smith, but I 15 and the Dutch measured the waves, which I
16 have a good understanding. 16 thought we agreed was at some point seaward of
17 Q. So you're able to tell me, then, if 17 the toe. That's where we were.
18 you alter the depth, in identical circumstances 18 A. Okay.
19 by five feet, you can tell me what that will do 19 Q. You keep shifting all over the place
20 to the wave in terms of making it larger or 20 so suit yourself.
21 smaller. 21 A. I'm trying to understand --
22 A. Let me give you some examples, then. 22 Q. Well, I gave you the parameters.
23 I'm trying to figure out how we break this sort 23 A. -- where you have.
24 of logjam where we are here. 24 Q. I've been where I have been for about
25 Q. All right. 25 an hour.
21 (Pages 395 to 398)

Page 399 Page 401
1 A. Okay. 1 Q. Yes, sir. I told you everything was
2 Q. I'm seaward of the toe. 2 the same. How many times do I have to say it?
3 A. Okay. 3 A. What's the incident wave on the outer
4 Q. Which is where you said these numbers 4 extent of the area that we're looking at?
5 are relevant. Okay? 5 Q. What was the incident wave that you
6 A. Okay. 6 studied when you made this sentence? You said
7 Q. I haven't moved from there. That's 7 this sentence here: These conditions were
8 where I am. 8 quite similar. So what incident wave did you
9 A. Okay. 9 use, Bruce?
10 Q. So the question is, on the table, if 10 A. Okay.
11 you increase the depths of the water there, 11 Q. No, what incident wave did you use,
12 what does it do to the wave amplitude, if 12 since that's now a relevant parameter, in
13 anything? 13 writing this sentence in your report? What is
14 A. Over a very short distance -- 14 it?
15 Q. Not over a short distance, over the 15 A. Let me, um -- let me talk about -- as
16 entire distance. 16 I said earlier, the wave conditions created by
17 A. Over the entire what distance? 17 Katrina along this levee were characterized by
18 MR. MITSCH: 18 significant wave heights of six to seven feet
19 What distance? 19 and mean wave periods of five to six seconds.
20 EXAMINATION BY MR. BRUNO: 20 Q. Got you.
21 Q. As I told you, you're the one who said 21 A. That would be some distance seaward,
22 that Katrina produced this extraordinary surge. 22 um -- in the region from the channel -- that
23 Right? 23 would be defined at a point between the channel
24 A. Right. 24 and the levee toe, towards the outer end of
25 Q. Okay. And you said it's five feet 25 that.
Page 400 Page 402
1 deeper than the designed surge, didn't you? 1 Q. Fine. That's two hundred and fifty
2 A. Yes. 2 feet.
3 Q. Okay. So that's what we're talking 3 A.Okay.
4 about. 4 Q.Right?
5 A. Up to five feet. 5 A.So let's talk about --
6 Q. Up to five feet. Real good. That's 6 MR. MITSCH:
7 where we are. 7 You don't need to raise your
8 A. Okay. 8 voice.
9 Q. You with me so far? 9 MR. BRUNO:
10 A. Yes. 10 I'm not raising my voice.
11 Q. It's the five feet that you say is the 11 MR. MITSCH:
12 difference between the design surge and the 12 Yes, you are.
13 Katrina surge. That's the five feet. Now, we 13 MR. BRUNO:
14 got location, we got our conditions, we got our 14 I am frustrated, I'll admit that,
15 geography. Now, what's the answer? 15 because every time I ask a question
16 MR. MITSCH: 16 Bruce wants to go somewhere else where
17 What's the question? 17 he wants to go and avoid answering my
18 A. What's the question? 18 question, which is problematic but,
19 MR. BRUNO: 19 hey, what the heck?
20 Here we go again. 20 A. I'm trying to answer your question.
21 EXAMINATION BY MR. BRUNO: 21 EXAMINATION BY MR. BRUNO:
22 Q. The question is, one more time, if you 22 Q. I'm hanging in there with you.
23 increase the water depth by five feet what will 23 A. I'm trying to answer your question.
24 it do to the wave? 24 Q. Okay.
25 A. The wind is the same? 25 A. So that's where I've defined that
22 (Pages 399 to 402)

Page 403 Page 405
1 significant wave height and wave period. 1 we've already been through this twice but let's
2 Q. I know. We've already -- we 2 do it one more time. The reason why we have to
3 established that an hour ago, Bruce, but go 3 consider everything offshore is because you
4 ahead. 4 told me the surge is five feet higher.
5 MR. MITSCH: 5 A. Right. Well, offshore it's
6 It would also help if you stopped 6 probably -- you know, I don't know, we could
7 interrupting him. 7 look at what the map is seaward of that
8 MR. BRUNO: 8 location.
9 Yeah, it without also help if we 9 Q. Well, whatever. I'm asking you to
10 didn't have to retread the same ground 10 change the water depth to whatever water depth
11 over and over again. We established 11 you used in your computer simulation. Increase
12 an hour ago where we were talking 12 it by five feet. What does it do if anything
13 about. And now we are, an hour later, 13 to the wave height?
14 right back where we started which is 14 A. Depends what the winds are doing.
15 between the toe and the channel. 15 Q. I told you the winds are the same,
16 EXAMINATION BY MR. BRUNO: 16 Bruce.
17 Q. But go ahead. I'm with you. 17 A. I don't believe the winds are the
18 A. Okay. So that's where we are using 18 same. I don't know how the winds --
19 and defining wave conditions from the STWAVE 19 Q. Assume they're the same, Bruce. Just
20 model. 20 assume it. Okay? We're changing -- it's a
21 Q. Yes. 21 computer model. If you change the inputs one
22 A. So from that point on, those waves are 22 would assume you get different outputs. Maybe
23 going to continue to break because the water 23 you don't. That's why I'm asking you. You're
24 depth is getting shallower as we approach the 24 supposed to be the expert. You can't seem to
25 levee, there's going to be a continued wave 25 tell me. I'm trying to get a simple answer to
Page 404 Page 406
1 energy dissipation, wave height will go down, 1 a simple question. You've got this STWAVE
2 there's probably some slight frictional 2 model and it's got these variables, and I'm
3 resistance that's going to contribute to 3 asking you the tweak one variable. You told me
4 additional small energy dissipation due to 4 wave depth is important. I wrote it down. I'm
5 vegetation, and eventually those waves are 5 sorry, water depth was important. I wrote it
6 going to impact the levee. That's what's going 6 down, it's on my piece of paper. And I'm
7 to happen over that relatively short distance. 7 asking you to alter that one parameter by five
8 Q. That's not what I'm asking you, Bruce. 8 feet, and you can't tell me the answer.
9 I mean, I don't know why you won't answer my 9 A. So if we have the same wind fields --
10 question. Why is it so difficult? 10 Q. Yes.
11 A. I don't understand your question. 11 A. -- out in the sort of sound area --
12 Q. Well, let's try it one more time. The 12 Q. Yes.
13 significant wave height and period is a number 13 A. -- and let's say we have ten feet of
14 that is generated by the STWAVE model; is it 14 water over those wetlands versus fifteen feet
15 not? 15 of water over those wetlands. You will get a
16 A. Yes. 16 larger wave with the same winds.
17 Q. Okay. How about this: Change the 17 Q. Thank you.
18 water depth parameter by five feet. What does 18 A. Changing the water level, we're going
19 it do to the significant wave height? 19 to get --
20 A. At that location? 20 Q. A larger wave.
21 Q. At that location. 21 A. -- a larger incident wave.
22 A. So we would -- to do that, we would 22 Q. All right. Now --
23 have to consider everything that's offshore of 23 A. Because the depth limited breaking
24 that location. 24 will not be a strong over deeper water.
25 Q. We sure did, Bruce, because -- and 25 Q. Of course. All right. Now, when we
23 (Pages 403 to 406)

Page 407 Page 409
1 say larger wave, so we can stay consistent with 1 And first of all, simple question:
2 the terminology that you and I have been using, 2 Have you ever seen them before?
3 we haven't used the term larger wave, we've 3 A. From the 1966 manual?
4 been using wave height and period. 4 Q. Yes.
5 A. A greater significant wave height. 5 A. Those curves?
6 Q. Meaning higher height, larger height, 6 Q. Yes.
7 bigger number height, right? 7 A. Um -- no.
8 A. Bigger number height. Yeah. 8 Q. All right. Have those curves -- are
9 Q. Would it change the period? 9 these curves still in use today?
10 A. Um -- possibly slightly. 10 A. I would imagine maybe there might be
11 Q. Which way? 11 some similar curves like this in the CEM for
12 A. Not nearly as much as it would change 12 restricted fetch situations. Our current
13 the wave height. 13 technology today is to use modeling --
14 Q. I understand. But I'm just getting a 14 Q. Right.
15 broad sense. Would it make it shorter or 15 A. -- where we actually in the case of a
16 longer? 16 hurricane, instead of assuming a straight line
17 A. Um -- slightly longer, with a deeper 17 fetch and constant wind speed we actually look
18 depth. 18 at how the cyclonic wind fields of the
19 Q. All right. Let me show you sections 19 hurricanes evolve and how that rapidly changing
20 from the Shore Protection Planning and Design 20 wind field is influencing the generation and
21 Manual from 1966. I'm going to mark it as 21 propagation of waves.
22 Ebersole Number 10. Here's the manual if you 22 Q. Understood. It's far more --
23 want to check me again. I didn't want to -- 23 A. Design practice is far more
24 frankly I'm trying to save paper and not kill 24 sophisticated today.
25 so many trees. It's Page 57 through Page 62. 25 Q. Far more sophisticated today than back
Page 408 Page 410
1 (Exhibit 10 was marked for 1 then. But the fundamental, that is, whether
2 identification and is attached hereto.) 2 when you increase the depth you increase the
3 A. Okay. 3 wave height, that is demonstrated by these
4 EXAMINATION BY MR. BRUNO: 4 charts, is it not? And I invite you to look at
5 Q. First of all, does the Corps today 5 the charts and pick any chart for any given
6 have I guess an iteration, for lack of a better 6 wind speed and compare it to a chart with a
7 word, of the Shore Protection Planning and 7 five-foot difference to determine whether or
8 Design Manual? 8 not in fact the wave height is higher when the
9 A. Our current version is called the 9 depth goes up by five feet and see if you will
10 Coastal Engineering Manual. 10 agree with me that that's true. Take your
11 Q. All right. And that is the current 11 time.
12 version of this very same document, right? 12 If you look at the 100 miles an hour,
13 A. That's the current coastal engineering 13 it's just the easiest one to look at.
14 design manual. It supersedes the shore 14 A. So fetch is the same? We're going to
15 protection manual. 15 just take one case here to look at?
16 Q. Sure. All right. Now, in this 16 Q. Well, actually the --
17 particular version in 1966, there are things 17 A. Can we zero in on one of these charts
18 called forecasting curves for shallow water 18 and discuss it?
19 waves. And I've reproduced them. 19 Q. If you like.
20 A. These are from the '66 manual? 20 A. That would help me.
21 Q. Yes, sir. 21 Q. But again, to be fair to the record,
22 A. Okay. 22 the charts allow for a variety of fetches.
23 Q. I keep neglecting to write the exhibit 23 Anything from one to --
24 number. Okay. So again, please again trust 24 A. Yeah, but --
25 me, I gave you good copies of these pages. 25 Q. -- to ten thousand feet, and then from
24 (Pages 407 to 410)

Page 411 Page 413
1 fifteen thousand feet to a hundred thousand 1 me I wasn't asking you this question
2 feet. Right? 2 referencing this -- these charts, I was asking
3 A. Now, let's take the ten foot depth. 3 you the question referencing your fancy
4 That would probably be the closest of these to 4 computer models which have built into them all
5 the amount of inundation we had over the 5 of those variables. Right?
6 wetlands, say. Ten feet water depth. 6 A. Yes.
7 Q. I'm sorry. Ten feet in Katrina or ten 7 Q. Okay.
8 feet back in the 1966? 8 A. And I'm certain that our -- I won't
9 A. Ten feet in Katrina. Ten, fifteen, 9 say certainly. This will be something to ask
10 that range. 10 Dr. Resio. But I believe that our wind or wave
11 Q. Okay. 11 growth relationships that we're using in
12 A. Over the wetland. 12 technology today are different than what they
13 Q. Fair enough. 13 were in the sixties. But you could get
14 A. That would have been the inundation 14 confirmation from Dr. Resio on that.
15 depth out in Lake Borne of the surrounding 15 Q. That's fine.
16 wetlands around Lake Borgne. It probably would 16 A. But to my understanding the wind
17 have been ten to fifteen. So. 17 growth, the source terms, the treatment of the
18 Q. Wait, now. Forgive me for stopping 18 wind source terms in these models, I believe,
19 you but -- so you're just taking -- your fetch 19 are different than they were six years ago.
20 only goes to Lake Borne 's edge, you're 20 Q. Sure. And all I'm saying is that you
21 eliminating from our discussion Lake Borne 21 have a diagonal line, and the diagonal line, if
22 which also has a depth of about fifteen feet. 22 you go from twenty feet to, say, fifteen
23 So that would be twenty-five. 23 feet -- let's pick fifteen to twenty feet.
24 A. The depth isn't constant. 24 A. Well, I said -- you talking about
25 Q. It's an average. 25 depth?
Page 412 Page 414
1 A. Yeah. I think you're trying to make a 1 Q. Yes. Constant depth.
2 point about what happens to the wave as we 2 A. Well, these curves were generated
3 increase the wind speed. I think that's where 3 assuming that the depth remains constant over
4 you're going. 4 the fetch. If we don't have that situation --
5 Q. Precisely. But in fairness, I want to 5 Q. Bruce, that's fine. Okay? Forget it.
6 make sure that we're on the same page. 6 A. -- then the curves --
7 A. I mean, these -- 7 Q. We've left the real world add now
8 Q. You don't use ten feet for Lake Borgne 8 we're in chart land.
9 because Lake Borne is fifteen feet and if you 9 A. Okay.
10 have surge on top of that that's twenty five 10 Q. Okay? All I'm saying is, now we're in
11 feet. 11 chart land because we've established already in
12 A. Yeah. Well, I mean these curves 12 the real world, utilizing your very
13 assume a constant depth over the fetch. 13 sophisticated fancy computer models if you
14 Q. And they use averages, don't they? 14 increase the depth you're going to increase the
15 A. Yeah, they assume a constant depth 15 wave amplitude and you may lengthen the period
16 completely across the fetch. And this is what 16 a little bit. We've established that already.
17 I was trying to get back to. You tell me the 17 I'm just asking you now --
18 specifics of the situation. So I have to 18 A. Fetch comes in there. It's not just
19 understand -- if I'm going to answer you I need 19 depth. Remember I said earlier it's fetch
20 to understand what is the depth over the fetch? 20 also.
21 And now I'm saying, is it okay that we assume 21 Q. And I said assume the same fetch, in
22 that the depth is constant over the fetch? 22 fairness to us both. Both scenarios, same
23 Q. It is. 23 fetch.
24 A. Then I'll answer your question. 24 A. Okay.
25 Q. Except that, wait, now, in fairness to 25 Q. So we're not changing that. But let's
25 (Pages 411 to 414)

Page 415 Page 417
1 go to the chart. 1 the record Dr. Resio provided these
2 A. Okay. 2 numbers, you used these numbers when
3 Q. And I'm just simply pointing out that 3 you wrote the sentence. Cut me some
4 this chart demonstrates the same result, that 4 slack here, okay? We don't have to
5 is, if you increase the depth you're going to 5 re cover the same ground every single
6 increase the height of the wave. That's all 6 time I ask a question.
7 I'm asking. It's as simple as that. 7 EXAMINATION BY MR. BRUNO:
8 A. Okay. 8 Q. We are talking about wave amplitude
9 Q. Is that a true statement or a false 9 and period that you received from Dr. Resio,
10 statement? 10 right?
11 A. I believe that's true. 11 A. Yeah. I think you were inferring that
12 Q. All right. That's all I need. 12 this was a sentence from Dr. Resio 's report.
13 Thanks. 13 Q. No, I said it was a sentence from your
14 Now, which statement is the more 14 report but the substance of the sentence came
15 accurate statement about the Katrina waves? 15 from Dr. Resio 's efforts and report.
16 And if you want me to reread it again we will, 16 And that's a true statement, right?
17 but I think you know what I'm talking about. 17 A. Yeah. This wave information came from
18 The IPET report says these long period waves, 18 Dr. Resio and Dr. Smith.
19 twelve to fifteen seconds, and now in your 19 Q. Fine. Question again is: Is your
20 report, not you but Dr. Resio says, 6.6 to 7 is 20 statement the correct statement or is the IPET
21 the wave period. 21 statement the correct statement describing
22 Which is the correct statement, 22 Katrina wave height and period? Which one is
23 IPET 's statement or Dr. Resio 's statement? 23 right?
24 A. What's Dr. Resio 's statement? Could 24 A. Well, with the technology that we're
25 you read that to me? 25 applying today, we're running a full plane
Page 416 Page 418
1 Q. You wrote it. I thought you told me 1 spectral wave model compared to the half-plane
2 you copied it and put it in you report at 2 version that we ran in the IPET.
3 Page 5. 3 Q. All right. So which one is right?
4 A. No. I didn't say I copied it. 4 A. I believe what we're getting out of
5 Q. You told me you got wave heights and 5 the full plane is a more accurate estimate of
6 periods -- 6 significant wave height and the mean period.
7 A. From STWAVE output. 7 Q. Okay.
8 Q. And who did that? 8 A. We found from our work that when we
9 A. Dr. Resio, Dr. Smith. 9 went to the full plane we got more energy in
10 Q. Okay. Hello. Am I missing something 10 the directional spectrum at higher frequencies,
11 here? You got it from Dr. Resio. 11 lower periods, than we did in the IPET. We
12 MR. MITSCH: 12 still have, you know, this fifteen to sixteen
13 Come on. You're stepping over 13 second energy in our spectrum, but there's much
14 the bounds. 14 more energy at the high frequency end than what
15 MR. BRUNO: 15 we predicted originally in IPET.
16 No, I'm not stepping over the 16 Q. All right. So there's about a
17 bounds, Rupert. Give me a break. We 17 difference of a factor of 2 on wave period.
18 have the re-cover the same ground a 18 A. In IPET, we were reporting peak
19 million times. 19 period, and in our current work it's mean
20 MR. MITSCH: 20 period. There are some differences between
21 Your questions aren't specific 21 those two measures of wave period.
22 enough. 22 Q. Okay. All right. So I need to
23 MR. BRUNO: 23 understand if you were going to tell somebody
24 My questions were very specific. 24 on the street about what number was correct, I
25 I said, it's been he established by 25 mean, would you tell them go read the IPET
26 (Pages 415 to 418)

Page 419 Page 421
1 report or would you tell them -- 1 At page Volume I-3 --
2 A. Well, when we talk about -- the 2 A. Is that part of this?
3 statement here is about overtopping. So when 3 Q. No, it's not. As I said, I apologize
4 we talk about overtopping, the wave height is 4 I don't have copies, but I'll just show it to
5 much more important in determining the outcome. 5 you. Volume 1, Page 2, there's a heading
6 So I don't think our estimates of wave height 6 called the performance.
7 from the IPET differ so much from the estimates 7 A. Okay.
8 of wave height that we're getting currently. I 8 Q. And it says, with the exception of
9 recall they're on the order of a foot, foot and 9 four foundation design failures all of the
10 a half. But in terms of overtopping, 10 major breaches were caused by overtopping and
11 overtopping is much more a function of wave 11 subsequent erosion.
12 height than it is of wave period. Wave period 12 You agree with that.
13 is a lesser factor in run-up than is the wave 13 A. Could you repeat that? I'm trying
14 height. 14 to --
15 Q. What's the difference between mean and 15 Q. Under performance. (Indicating.)
16 peak period? 16 MR. LEVINE:
17 A. Peak period, um -- would be if you 17 Which version of the IPET exactly
18 have a two-dimensional energy spectrum, I don't 18 are we looking at now?
19 know if -- an energy spectrum just says how 19 MR. BRUNO:
20 much of the wave energy is at different 20 I don't know. Which one do we
21 frequencies. And period is the -- you know, 21 have?
22 inversely related to frequency. 22 MR. LEVINE:
23 Q. All right. 23 On the cover there.
24 A. So peak period would be the bin in the 24 THE WITNESS:
25 energy spectrum where the energy is a maximum, 25 March 2000. It says interim
Page 420 Page 422
1 and then the frequency that would correspond to 1 final.
2 that bin would be related to the peak period. 2 MR. BRUNO:
3 The mean period is more of a weighted 3 Okay.
4 average based on the complete spectrum. 4 THE WITNESS:
5 Generally the mean periods will be less than 5 I don't know if that's the final
6 peck periods. 6 final.
7 Q. What did the designers report, mean or 7 MR. BRUNO:
8 peak? 8 Who knows? There's eighteen
9 A. I don't know that they specified that. 9 different ones, but I don't think this
10 Q. All right. All right. 10 has changed, and if there's a change
11 A. If I remember from your table, it's 11 you'll tell me.
12 just a period. 12 A. Well, let me comment as it pertains to
13 Q. Just a period. So we don't know if 13 the polder that we're talking about. Okay? I
14 it's peak or mean. But somehow or another you 14 believe that the north breach was the result of
15 guys were able to compare those two even though 15 a geotechnical failure as the IPET found. I
16 you didn't know if it was mean or peak. 16 believe the south breach was caused by
17 A. Yeah. My judgment would be it would 17 overtopping.
18 be more similar to a mean because at that point 18 EXAMINATION BY MR. BRUNO:
19 in time they really weren't looking so much at 19 Q. Forgive me. Let's -- we're now
20 the directional wave spectrum so much. So I 20 jumping from Reach 2 to a different area. I
21 would think their measure would be probably 21 mean, you and I know what we're talking about,
22 more like a mean period than a peak period. 22 but for the record, north breach is IHNC --
23 Q. Right. Okay. You don't have the 23 A. North breach on the east side of the
24 executive summary and I apologize for not 24 IHNC.
25 having a copy, but I'll just hand you my book. 25 Q. Thank you.
27 (Pages 419 to 422)

Page 423 Page 425
1 A. It's my opinion based primarily on the 1 A. Again, we used Westerink's output in a
2 IPET report that that was caused as a result of 2 scaling method to develop -- well, in the
3 a geotechnical foundation failure. 3 Industrial Canal actually we used the observed.
4 Q. The design -- 4 That was the best data.
5 A. I don't have any -- the information 5 Q. Sure.
6 I've looked at in terms of water levels 6 A. And so from my analysis it appeared to
7 suggested to me that I have no reason not to 7 me that the water level was about nine feet in
8 believe the conclusion of the IPET. 8 that -- I think Steve Fitzgerald said I was
9 Q. All right. So you're taking that at 9 about 3:50. You could confirm the exact time
10 face value because you're not a soils engineer 10 with him.
11 or a geotechnical engineer, nor have you even 11 Q. I guess maybe I'm not articulating as
12 evaluated these parameters -- 12 well as I should. I'm trying to understand,
13 A. What I've looked at is the water level 13 you guys were engaged in a forensic analysis of
14 when that would have failed, and the water 14 the failure of the north breach, right? You
15 level was not at the top of the wall. So my 15 were trying to determine what happened.
16 conclusion -- but not -- you know, is that -- 16 A. Talking about IPET?
17 their conclusion that it failed as a result of 17 Q. Yeah.
18 geotechnical failure sounds reasonable to me, I 18 A. Yeah. I was not involved in the
19 accept that. It makes sense and is consistent 19 performance task of IPET.
20 with my observation of what the water level was 20 Q. All right. So you were not involved
21 when that structure failed. 21 in the forensic analysis at all with regard to
22 Q. All right, sir. Sounds to me, though, 22 the north breach?
23 that your contribution to the analysis was 23 A. In IPET, my role was to lead the team
24 simply whether or not the water went over the 24 that was developing the regional wave and water
25 top. 25 level information.
Page 424 Page 426
1 A. That was an important thing to me in 1 Q. All right.
2 the assessment of -- 2 A. I was not part of the team looking at
3 Q. I'm not denigrating it, I'm just 3 the performance of the walls.
4 saying -- 4 Q. You contributed, certainly, because
5 A. I just primarily looked at water 5 you gave those guys a water level for them to
6 level. The fact that when that north breach 6 do with what they wanted to do, right?
7 occurred sometime in the 3:30 to four o'clock 7 A. We passed on the surge information and
8 time frame the water level was only on the 8 we passed on the surge and wave information to
9 order of nine feet or so. 9 Dr. Resio who led the detailed hydrodynamics
10 Q. Okay. So your contribution was to 10 task who then also passed information on to the
11 assess the water level and then that's where 11 levee performance team who were making that
12 your contribution ended, and others decided 12 assessment.
13 what the mechanism of failure was. Is that an 13 Q. Who was in charge -- let me make
14 accurate statement? 14 sure -- you know what I mean by forensic
15 A. I accepted the IPET explanation of 15 evaluation, right?
16 that failure. 16 A. Yeah, I think so.
17 Q. Well, I know you accept it, but that's 17 Q. Okay. Who in IPET was in charge of
18 not my question. With regard to the mechanism 18 the forensic evaluation of assessing the
19 of failure, your contribution to the effort was 19 mechanism of failure of each of the branches?
20 that you provided the water height. And maybe 20 A. Reid Mosher was one of the team
21 I'm wrong. Did you not? Did somebody else? 21 co-leaders whose job it was to look at the
22 A. I looked at water level -- made an 22 performance of the levee wall system.
23 estimate of what the water level was as a 23 Q. All right. So you really -- you
24 function of time. 24 weren't part of that effort.
25 Q. Okay. You and Westerink? 25 A. No.
28 (Pages 423 to 426)

Page 427 Page 429
1 Q. You were a contributor, as I said, in 1 overtopping caused the destruction of the Reach
2 fairness to you -- 2 2 levee. And I've done that.
3 A. Yes. 3 Q. Right. Well, maybe I'm wrong but
4 Q. -- your contribution was, hey, guys, 4 isn't there a distinction between going into a
5 here's the water level that I believe the 5 problem trying to prove the answer as opposed
6 levees encountered during the variety of times, 6 to going into a problem and trying to find the
7 whatever. 7 answer?
8 A. As a function of time during Katrina. 8 A. No.
9 Yes. 9 Q. Wouldn't you agree with me that
10 Q. All right. So other than just 10 there's a difference there? I'm not saying you
11 offering an opinion as to whether those guys 11 did that, but there's a difference.
12 are right, you're not offering an opinion in 12 A. Say that again.
13 the case about the mechanism of failure of the 13 Q. I mean, there is a big difference
14 north breach, are you? 14 between going into a problem and trying to
15 A. No, like I said, I accept the 15 prove an answer as opposed to going into a
16 conclusion of the IPET. I accept our 16 problem and trying to find the answer. Those
17 conclusion for both of the Industrial Canal 17 are two different ways of approaching --
18 breaches, and I accept their conclusion about 18 MR. MITSCH:
19 the levees along Reach 2. 19 Objection. Vague.
20 Q. So is your expert opinion going to be, 20 EXAMINATION BY MR. BRUNO:
21 to the Judge Duval, that you accept the 21 Q. -- problem solving, isn't that true?
22 conclusion of IPET? Is that what you're going 22 A. Well, in my work I've tried to be open
23 to tell him? 23 to other alternatives. I have explored the
24 A. No. I would -- my testimony would be 24 possibility that -- the hypothesis that waves
25 that my conclusion is that the levees along 25 were a contributing factor to the destruction
Page 428 Page 430
1 Reach 2 failed as a result of overtopping. 1 of the levees, and I -- my conclusion, my
2 Q. Okay. But you -- now that we're 2 finding -- and I've done analysis to try to
3 switching locations, you didn't have anything 3 consider that possibility as well, and my
4 to do with the forensic evaluation of the 4 finding was that I don't believe wave erosion
5 failure of those levees, did you? 5 on the front side was a dominant process in the
6 A. No. In the IPET. 6 degradation of those levees. So I didn't go
7 Q. In IPET. 7 into that assuming one or the other, I looked
8 A. No, I did not. 8 at both as a possibility.
9 Q. You did not. 9 Q. Well, let's see. When you went into
10 A. Right. 10 the problem you had already decided as a member
11 Q. Nor did you, in this exercise, have a 11 of the IPET team that overtopping was the
12 role in evaluating, from a forensic analysis, 12 cause. It's documented. It's printed. It's
13 or utilizing a forensic analysis, the cause of 13 published. It's got color front and back
14 the failure of the Reach 2 levees. 14 pages. Right?
15 A. Well, I believe I have coastal 15 A. Yeah. The IPET developed an opinion,
16 engineering expertise to offer, if you want to 16 and I concurred with their --
17 call that a forensic analysis. 17 Q. So you --
18 Q. I don't want to call it that, no. 18 A. I concur with their --
19 A. You know, I believe it's part of 19 Q. Wait. Bruce, you concurred with an
20 understanding what happened and why. I have 20 opinion about overtopping before you began this
21 understanding about storm surge, waves, 21 so-called exercise to understand the cause of
22 overtopping, and I can take the information 22 the failure at Reach 2. Isn't that true?
23 that we use in current coastal engineering 23 MR. MITSCH:
24 design practice and apply it to make an 24 Objection.
25 assessment of whether or not I think 25 EXAMINATION BY MR. BRUNO:
29 (Pages 427 to 430)

Page 431 Page 433
1 Q. Isn't that true? 1 breaching.
2 A. No, I went through and did my own 2 Q. All right. Okay. So let me ask you
3 independent analysis based on my expertise. 3 this: And you may not know the answer. If in
4 Q. So basically, you threw away all of 4 fact the levees failed in part from front side
5 the information, knowledge that was gleaned by 5 wave attack, would the statement the levees
6 IPET and you started all over again as a true 6 performed as designed still be true?
7 scientist, you had a blank board, and you said 7 A. I don't know. I mean, as I just
8 to yourself, let me see if I can understand all 8 stated in my response to the last question, I
9 of the potential causes of the failure at Reach 9 don't -- I can't comment on as designed because
10 2. That's what you did; right? 10 I don't understand the whole process of their
11 A. That's not true. 11 design.
12 Q. I know it's not true. 12 Q. Fair enough. Bruce, as an engineer,
13 How about this: That IPET report says 13 isn't it kind of counterintuitive for an
14 that the levees at Reach 2 performed as 14 engineer to say that a structure that failed,
15 designed, does it not? That's at the second 15 whose intent was the protect people, performed
16 page. You can read it if you like. 16 as designed? Isn't that a little weird?
17 A. Where? Can you point me to that? 17 A. Say --
18 Q. Yeah. You've got it. No, I'm sorry. 18 MR. MITSCH:
19 Yeah. Next page. I have it highlighted. You 19 Objection. Vague.
20 got it in yellow. 20 EXAMINATION BY MR. BRUNO:
21 MR. MITSCH: 21 Q. Isn't it counterintuitive as an
22 Just for the record, again 22 engineer to say that a structure whose purpose
23 indicate what document you're looking 23 for being was to protect people performed as it
24 at. 24 was designed to perform when it failed?
25 MR. BRUNO: 25 A. I don't know. I'm focussed on the
Page 432 Page 434
1 That is the IPET -- 1 until overtopping occurred. I mean, you got to
2 THE WITNESS: 2 read the whole sentence. You're sort of
3 IPET Final Report, Volume 1 3 picking parts of the sentence. I think you
4 Executive Summary and Overview dated 4 have to read the whole sentence.
5 26 March 2007 called Interim Final, 5 Q. I am absolutely picking parts. I'm
6 Subject to Revision. 6 not asking about the whole sentence. I'm
7 EXAMINATION BY MR. BRUNO: 7 asking about part of a sentence because in
8 Q. And so it's Volume 1, and it's Page -- 8 engineering isn't there a principle that you
9 help me. 9 design things for what is known and what is
10 A. Page 1-3. 10 foreseeable? I mean, you design in
11 Q. 1-3, and I have it highlighted -- read 11 consideration of conditions that may exceed the
12 the sentence for me, please, for the record? 12 known conditions as a safety factor?
13 A. Ironically, the structures that 13 MR. MITSCH:
14 ultimately breached performed as designed, 14 Objection. Vague.
15 providing protection until overtopping occurred 15 EXAMINATION BY MR. BRUNO:
16 and then becoming vulnerable to catastrophic 16 Q. Is that something that you have ever
17 breaching. 17 heard of during your course study?
18 Q. Right. Now, do you agree with that 18 A. Could you ask me a more specific
19 assessment? 19 question?
20 A. I can't really comment on the first 20 Q. Yeah. Have you -- are you familiar
21 part of that, as designed, because I'm not so 21 with the engineering principle that a design
22 familiar with how they were designed. I would 22 should be made to be as safe as possible based
23 definitely agree with the part of that, that 23 upon considerations of the state of the art and
24 provided protection until overtopping occurred 24 economics? Have you ever heard that before?
25 and then became vulnerable to catastrophic 25 Or anything like that?
30 (Pages 431 to 434)

Page 435 Page 437
1 A. No. 1 a fact that St. Bernard would not have flooded?
2 Q. Never. 2 MR. MITSCH:
3 A. No. 3 Objection. Calls for
4 Q. So we have here a levee the purpose of 4 speculation.
5 which is to keep water out of people's houses, 5 MR. BRUNO:
6 right? Can we agree on that? 6 No, it doesn't call for
7 A. Yes. 7 speculation.
8 Q. And we know it failed so that's not 8 MR. MITSCH:
9 the issue. But we have this statement that 9 Vague.
10 this thing that was intended to keep water out 10 A. Could you repeat --
11 of people's houses performed exactly the way it 11 EXAMINATION BY MR. BRUNO:
12 was designed to perform. I mean, that's what's 12 Q. Yes, if the Reach 2 levee hadn't
13 implied by the statement, isn't that true? 13 fallen down, the water levels would not have
14 A. I can't talk about the design. I can 14 been sufficient to top the 40 Arpent levee
15 say that it performed its function until the 15 sufficient to flood St. Bernard. Isn't that
16 point it was overtopped. 16 true?
17 Q. Uh-huh. Well -- 17 A. I don't know.
18 A. It performed that function of keeping 18 MR. MITSCH:
19 water out of people's houses until the point it 19 Objection. Speculation.
20 was overtopped, and I would say it was 20 A. You'd have to get with -- Steve
21 massively overtopped. 21 Fitzgerald would know far more about those
22 Q. Exactly. So what you're saying to me, 22 kinds of hypothetical situations based on his
23 it was designed to fail if it was overtopped. 23 own work. I couldn't address that. I mean, I
24 Right? 24 agree that the performance of Reach 2 was a key
25 A. No. 25 factor in the flooding that's taken place.
Page 436 Page 438
1 Q. That's what the sentence says. 1 EXAMINATION BY MR. BRUNO:
2 MR. MITSCH: 2 Q. Okay. All right. What I'm driving at
3 Objection. 3 is that isn't it a fact that the Corps in
4 A. I'm not saying that. 4 making the statement that the levee performed
5 EXAMINATION BY MR. BRUNO: 5 as designed gets to blame, if you will,
6 Q. Well, Bruce, you said -- the sentence 6 somebody else in that they get to say we built
7 says, not you, you didn't write the sentence, 7 the levee to a certain height and that's all we
8 I'm sorry. The sentence says, it performed as 8 were told to do, and it's not our fault that
9 designed until it was overtopped. So that 9 the water was higher than the levee height
10 means that the designers knew that if it was 10 because we discharged our obligation?
11 overtopped it would fall down. 11 A. I wouldn't make that statement.
12 A. I don't know what the designers -- I 12 Q. You wouldn't make that statement?
13 want to use my words. 13 A. I can't make that kind of a statement.
14 Q. All right. Well, how do you interpret 14 Q. Would you agree with me that if that's
15 the sentence performed as designed? 15 true there's a motivation that exists -- a bias
16 A. Um -- I don't know. I was no involved 16 against believing that the levees failed from
17 in the design, I've not read the design 17 front side attack?
18 documents, and I don't know the design process. 18 MR. MITSCH:
19 Q. Fair enough. 19 Objection.
20 A. I've not been involved in that aspect 20 A. Can you ask a different question?
21 of it. But what I will say is that levee 21 EXAMINATION BY MR. BRUNO:
22 functioned to keep water out until it was 22 Q. Nope. That's my question.
23 overtopped. 23 Would you agree with me that if it's
24 Q. How about this: If the levee hadn't 24 true, that is, that the Corps says the levees
25 fallen down even with the overtopping, isn't it 25 performed as designed because they were told to
31 (Pages 435 to 438)

Page 439 Page 441
1 build to a certain height, they weren't told to 1 facts about what happened and why.
2 build it taller, they didn't believe it 2 EXAMINATION BY MR. BRUNO:
3 appropriate to consider backside erosion 3 Q. Right?
4 because all they were concerned about was 4 A. And so it does matter to me whether it
5 building to a certain height -- if that's true, 5 failed because of overtopping or some other
6 I'm not saying it's true, if that's true, would 6 cause.
7 you agree that would create a bias against 7 Q. Well, what would be the significance
8 finding that the levees failed from front side 8 to you, if any, if the science showed that the
9 attack? 9 levee failed from front side attack? What
10 MR. MITSCH: 10 difference would it make?
11 Objection. Calls for 11 MR. MITSCH:
12 speculation. You're asking him to 12 Objection. Vague.
13 come up with what -- to comment on 13 A. Would you restate, please? Or ask a
14 what you think is a perceived bias on 14 different question?
15 someone else 's part -- 15 EXAMINATION BY MR. BRUNO:
16 MR. BRUNO: 16 Q. What would be the significance to you
17 Actually, no, you're absolutely 17 if the science showed that the levees failed
18 wrong about that, because in science 18 from front side attack?
19 bias is an important issue to contend 19 A. Well, my science shows that it didn't
20 with particularly when one is 20 fail from front side attack.
21 investigating potential causes of 21 Q. That's not my question, Bruce. Would
22 failure. 22 you please answer my question? I know it's
23 EXAMINATION BY MR. BRUNO: 23 hard. I just want you to answer my question.
24 Q. But go ahead, Bruce. 24 All right? I didn't ask you about your
25 MR. MITSCH: 25 science. We've got your science in a 300-page
Page 440 Page 442
1 But it's someone else's bias that 1 document. Answer my question.
2 you're asking him to comment on. 2 Here it is again: What would be the
3 MR. BRUNO: 3 significance to you if the science showed that
4 No, it's scientific bias. 4 the levees failed from front side attack?
5 A. I don't feel that I can address 5 MR. MITSCH:
6 questions that talk about the design because 6 Same objection.
7 I'm not familiar with the design of the process 7 A. Well, that's a complicated process,
8 of design. 8 you know, what happened as a function of time.
9 EXAMINATION BY MR. BRUNO: 9 So I think all the outcomes that occurred
10 Q. Okay. Well, let me ask you this: 10 within that polder are very much dependent on
11 What difference does it make whether the levee 11 what happened and when it happened.
12 failed from front side attack or overtopping? 12 EXAMINATION BY MR. BRUNO:
13 Who cares? 13 Q. Right.
14 MR. MITSCH: 14 A. And, um -- I don't believe
15 Objection. Vague. 15 wave-induced was a major factor.
16 EXAMINATION BY MR. BRUNO: 16 Q. That's fine.
17 Q. You're a scientist sitting in this 17 A. I don't understand why I'm asking
18 room. I'm just curious, does it really matter 18 these hypotheticals --
19 whether the levee failed from front side attack 19 Q. It's not a hypothetical. I'm asking a
20 or overtopping or backside attack? 20 very simple question, you know. I'm trying to
21 A. Yeah, I think we -- 21 figure out whether it matters to you, and for
22 MR. MITSCH: 22 example, do you believe that if the judge
23 Same objection. Go ahead. 23 decides that the levees failed from front side
24 A. I think we -- as a scientist I viewed 24 attack that that will have some material
25 this as -- my role in IPET is to try to get the 25 outcome with regard to this case?
32 (Pages 439 to 442)

Page 443 Page 445
1 MR. MITSCH: 1 problem because you keep objecting.
2 Objection. You're asking him to 2 MR. MITSCH:
3 comment now about a legal decision and 3 No. I object --
4 a legal impact. 4 MR. BRUNO:
5 MR. BRUNO: 5 How about this: What's the
6 No, I'm not. 6 answer?
7 EXAMINATION BY MR. BRUNO: 7 MR. MITSCH:
8 Q. I'm asking you if you believe -- 8 I object. I've not instructed
9 A. What matter to me -- 9 him to answer.
10 Q. Okay, we'll go one more time. Do you 10 MR. BRUNO:
11 believe -- it's a question that asks about your 11 Rupert, what's the answer? If
12 beliefs: Do you believe that if the Judge 12 it's been answered, what's the answer?
13 finds that in fact the levees failed from a 13 You answer for him.
14 front side attack that that has any 14 MR. MITSCH:
15 significance with regard to who wins or losses 15 That would be inappropriate. I
16 this case? That's what I want to know. It's 16 wouldn't do something like that.
17 about belief. 17 MR. BRUNO:
18 MR. MITSCH: 18 I thought you said he answered.
19 No. Stop. Objection. Again, 19 MR. MITSCH:
20 you're asking him to comment on -- 20 He did.
21 MR. BRUNO: 21 MR. BRUNO:
22 A belief. 22 What's the answer?
23 MR. MITSCH: 23 MR. MITSCH:
24 -- a legal issue. 24 Read the record. I'm not going
25 MR. BRUNO: 25 to give the answer to you.
Page 444 Page 446
1 No, I'm not. It's a belief. 1 MR. BRUNO:
2 MR. MITSCH: 2 Well, I know, because there's no
3 He's here as an expert to talk -- 3 answer.
4 MR. BRUNO: 4 EXAMINATION BY MR. BRUNO:
5 It's a belief. It's a scientific 5 Q. Give me a break, Bruce. What's the
6 bias. It's a belief. 6 answer?
7 MR. MITSCH: 7 A. What's your question?
8 It's not. You keep on saying it 8 Q. For the fourth time, do you believe
9 is. I'll keep on saying it's not. 9 that if the judge find that the levees failed
10 MR. BRUNO: 10 from front side attack that that will have
11 Great. So how about we agree to 11 anything to do or play any role in who wins or
12 disagree and we let him answer the 12 loses this case?
13 question. Your objection has been 13 A. Well, it's my professional opinion
14 noted four times already. You keep 14 that the front side -- or erosion by front side
15 saying it over again. It's noted. 15 wave action on this levee had a small role. It
16 EXAMINATION BY MR. BRUNO: 16 was not the dominant process. So if we get --
17 Q. I'd like an answer. Do you believe 17 if somebody thinks that's the case, I believe
18 that if the judge finds that the levees failed 18 they're wrong. And so --
19 from front side attack that that will have any 19 Q. Fair enough.
20 role with regard to who wins or loses? 20 A. -- what are the implications being
21 MR. MITSCH: 21 wrong? I don't know what those are.
22 Same objection. Asked and 22 MR. MITSCH:
23 answered. An additional time. 23 So now --
25 We never got an answer is the 25 Q. Well, now we finally have a remote
33 (Pages 443 to 446)

Page 447 Page 449
1 answer because you don't know whether or not 1 A. I don't recall seeing any analysis of
2 that would have anything to do with the outcome 2 that.
3 of the case, right? 3 Q. Isn't it a fact that the only reason
4 A. I don't know. 4 why you and your team, post IPET, studied front
5 Q. All right. You don't know. That's 5 side attack is because the plaintiff experts
6 fine. That's all I was asking. It's no big 6 have studied front side attack?
7 deal? 7 A. No, I think the issue here is the role
8 A. I gave it to you. 8 of the MRGO. And I think to consider that we
9 Q. By the hardest. Okay? You got to 9 have to look at those two mechanisms. And
10 admit that. Give me that much. It wasn't 10 that's what I've done. I've looked at
11 easy. 11 overtopping as a potential cause for levee
12 Now, in IPET you all were doing this 12 damage, and I've looked at front side wave
13 study, you didn't study front side attack of 13 attack as a potential cause. And I've analyzed
14 the levee, did you? 14 those with the current state of the practice
15 A. I was not involved in the performance 15 and techniques as best I can determine, and
16 task of the IPET. 16 I've come to the conclusion that overtopping
17 Q. All right. I guess that means that 17 was the dominant mechanism that led to the
18 you don't know? 18 destruction of the levees along Reach 2.
19 A. I'll defer to the task area leaders 19 Q. Really. So you believe that it was
20 for that task. Dr. Mosher and -- I forget who 20 appropriate to study waves simply because the
21 it was. 21 problem presented was what was the role of the
22 Q. Bruce, given the fact that you were, 22 MRGO, right?
23 by your own statements, engaged to study that 23 A. No, waves contribute to overtopping,
24 in connection with this case, wouldn't it have 24 and they potentially contribute to front side
25 been prudent to ask the IPET fellows if they 25 wave erosion.
Page 448 Page 450
1 had studied that? 1 Q. Well, um -- you wrote an article on
2 A. I looked at their volume in 2 that subject before you started your work for
3 preparation for the work that I've done here. 3 the Department of Justice in connection with
4 Q. Okay. Fine. And when you looked at 4 this case, didn't you? And the article was
5 he volume, could you find anywhere in the 5 about the influence of the MRGO on surge.
6 volume where the IPET performance team 6 A. Yes. What's the article?
7 evaluated whether or not the levees on Reach 2 7 Q. It says, note on --
8 sustained damage from front side wave attack? 8 A. Is this an exhibit that I can look at?
9 A. I don't recall seeing much analysis of 9 Q. It will be in a second. I'm just
10 that issue. 10 asking -- you don't remember it?
11 Q. Okay. The fact is that the IPET 11 (Exhibit 11 was marked for
12 performance team did not evaluate front side 12 identification and is attached hereto.)
13 wave attack; isn't that true? 13 A. Let me look -- I want to see the
14 A. I said -- I answered it just in the 14 document.
15 last question. I don't recall that I saw a lot 15 EXAMINATION BY MR. BRUNO:
16 of analysis of that particular subject. 16 Q. Okay. I'll be more than happy. I'm
17 Q. Did you see any analysis of the 17 just sort of confounded by the fact that you
18 subject? 18 don't remember writing this, but that's okay.
19 A. I don't recall. 19 A. I've written a lot of documents in the
20 Q. Did the IPET team study vegetation? 20 last four years.
21 A. And with regard to what? 21 Q. How many have you written on the
22 Q. Wave attack. 22 influence of the Mississippi River Gulf Outlet
23 A. You're talking about like performance, 23 on hurricane storm surge?
24 the turf, erosion of the levee face? 24 A. We wrote that -- we have an appendix
25 Q. Yes. 25 on that subject in the IPET report. So I've
34 (Pages 447 to 450)

Page 451 Page 453
1 been looking at that particular subject since 1 failure of levees, and you said you could find
2 the IPET report. 2 very little? Didn't you just tell me that?
3 Q. Okay. Yeah. But I thought you told 3 A. Could you repeat the question?
4 me that the reason why you're studying waves 4 Q. No.
5 was because were interested in the influence of 5 MR. BRUNO:
6 the MRGO. That's what you told me a few 6 You read it back to him.
7 moments ago, right? 7 (Whereupon the previous question was
8 A. Well, I think to the look at the 8 read back.)
9 influence of the MRGO you have to look at the 9 A. I didn't go to any guys, I went to the
10 influence on waves and water levels. And I 10 report that that team produced and didn't find
11 will say I found that the influence on water 11 significant analysis of that subject.
12 levels is really the primary factor that's -- 12 EXAMINATION BY MR. BRUNO:
13 Q. Well -- 13 Q. Okay. Well, so there wasn't a
14 A. -- that's driving my conclusions 14 significant analysis of waves by IPET, right?
15 regarding the influence of the MRGO. Water 15 A. Wrong.
16 level's number one, freeboard, the difference 16 Q. Oh, there was a significant analysis
17 between water level and the crest of the levee, 17 of waves?
18 that's the number one most important factor. 18 A. Absolutely. We had -- our task was
19 Q. Can up answer my question, please? 19 the responsibility of characterizing the waves
20 A. But waves are also a factor. 20 on a regional scale, and Dr. Resio had a task
21 Q. Can you answer my question? I didn't 21 that looked at characterizing waves right at
22 ask you that. 22 the levee.
23 A. Okay. Maybe you could read or restate 23 Q. All right.
24 the question. 24 A. And I would characterize that as a
25 Q. Good. I didn't ask you any of that. 25 substantial investigation of waves.
Page 452 Page 454
1 A. Okay. 1 Q. As it relates to the failure of the
2 Q. What I asked you was whether or not 2 levees?
3 you started studying waves because the 3 A. All that information was passed on to
4 plaintiffs' experts studied waves? And you 4 the levee response team. So two out of the
5 said no, no, no, no, I started studying waves 5 IPET tasks were focused on waves and water
6 because I was interested in the influence of 6 levels, and that information was passed on to
7 the MRGO on hurricane-induced storm surge. 7 the levee response team. So I would disagree
8 That's what you told me. Did you say that? 8 that it was not a focus. It definitely was a
9 Maybe I got it wrong. Did you say that? 9 focus of the IPET.
10 A. Could you ask -- repeat what you asked 10 Q. All right. Did you study front side
11 me to say? Your questions are fairly long and 11 wave attack?
12 convoluted. 12 A. I did not --
13 Q. No, they're not convoluted. Not at 13 Q. Okay.
14 all. I disagree with that. I asked you 14 A. -- during IPET.
15 whether or not, simply, you and the expert team 15 Q. And the only reason why you studied
16 studied waves solely because the plaintiffs' 16 front side wave attack was because the
17 expert team studied waves? True or false? 17 plaintiffs' experts did, isn't that true?
18 A. False. We've been studying waves 18 A. I think I answered that question
19 since the IPET. It was recognized as an 19 already.
20 important contributor to the levee response 20 Q. Okay. Not. So then this report
21 since we've been doing IPET. That's why we had 21 should describe the study of front side wave
22 our task and Dr. Resio 's task. 22 attack, right? Exhibit 11.
23 Q. Didn't I just ask you whether or not 23 A. Well, the title of it is Note on
24 you went to the performance guys and asked them 24 Influence of the Mississippi River Gulf Outlet
25 if they had evaluated the role of waves in the 25 on Hurricane Induced Storm Surge. So the focus
35 (Pages 451 to 454)

Page 455 Page 457
1 of this is on storm surge. I don't see waves 1 A. -- document? I don't know where you
2 in the title. 2 got this.
3 Q. Right. So you didn't study waves. 3 Q. It's a published -- I don't know where
4 A. We looked at storm surge, the effect 4 I got it either. It's a note -- I mean, I'm
5 of it on storm surge. 5 sure I got it from, you know, the website.
6 Q. Well, did you publish any papers about 6 A. Well, in the IPET we have -- one of
7 the effect of waves with regard to the 7 our appendices in Volume 4 deals specifically
8 Mississippi River Gulf Outlet? Did you do 8 on this subject, and this note may be one of
9 that? 9 those appendices in that report.
10 A. I did not. 10 Q. Would your reference list in your
11 Q. Okay. All right. Fine. 11 report help us answer that question?
12 Now, in this article you detail all of 12 A. I think we can look back at the IPET
13 the study that has been done by the Corps 13 report.
14 regarding the influence of the MRGO on 14 Q. Okay. Fair enough. Through whatever
15 hurricane-induced storm surge, right? 15 method, I'd like to know that answer, actually.
16 A. The documents that we're aware of. 16 A. Okay. Let me look in the table of
17 Q. Well, was it your intent to identify 17 contents. I think it was a separate appendix.
18 all of the study? 18 Appendix 6, Volume 4, is entitled Note on the
19 A. Yes, at the time. 19 Influence of the Mississippi River Gulf Outlet
20 Q. Okay. And this is all you could find. 20 on Hurricane-Induced Storm Surge in New Orleans
21 A. I would say that's the ones that we 21 and vicinity. So I believe that note, if it's
22 were aware of that existed. 22 the same, is in IPET Volume 4, Appendix 6.
23 Q. All right. Well, okay. Can I 23 Q. Okay. All right. Having that said --
24 translate that into these were all you could 24 A. You know, I don't know the origin of
25 find? 25 that document, but I know we have an appendix
Page 456 Page 458
1 A. Yes. 1 with the same title in Volume 4.
2 Q. All right. 2 Q. All right. So that being said, it's
3 (Lunch break.) 3 clear, since you weren't involved, as you've
4 EXAMINATION BY MR. BRUNO: 4 already told us, in the evaluation of the
5 Q. All right. Let's see if we can kind 5 performance of the levees, this note wasn't
6 of remember where we were. Here's my subject: 6 intended to address front side wave attack.
7 The evaluation of front side wave attack as a 7 A. It was intended to address the
8 mechanism of failure for the Reach 2 levees. I 8 influence on the storm surge of the MRGO.
9 give that to you as a subject so that we don't 9 Q. All right. Now, next question is, I
10 have to make the questions so long, since you 10 know you answered it already, but just to kind
11 don't like my long questions. 11 of put it in context, you intended, you and the
12 All right. Did the IPET study front 12 group, to identify all study that the Corps had
13 side wave attack as a mode of failure? 13 undertaken since the construction of the MRGO
14 A. From my reading of the volume that 14 that regarded the potential influence of the
15 dealt with the responses of the levee and wall 15 MRGO on storm-induced surge. And you
16 system, I believe it was Volume 5, I don't 16 identified the result of that effort in this
17 recall that subject being addressed in the 17 paper.
18 document. 18 A. Yeah. Within the IPET we were asked
19 Q. Okay. Fair enough. Now, in your note 19 to take a look at this issue of the role of the
20 which is Ebersole 11, does this note address 20 MRGO on the storm surge during Katrina, and
21 front side wave attack? 21 this note, if that's the note that's in Volume
22 A. Yeah. I think -- is this the note 22 4, is the results of the IPET group taking a
23 that came from IPET Volume 4? We had an 23 look at that particular issue.
24 appendix. Is this the same -- 24 Q. All right. Now here's a different
25 Q. I don't know. 25 question: Did the IPET team evaluate the
36 (Pages 455 to 458)

Page 459 Page 461
1 influence of the Mississippi River Gulf Outlet 1 resulted in significant floodwater entering
2 on hurricane waves? And I'm going to say in 2 that polder.
3 the vicinity of the hurricane protection 3 That's the second component; right?
4 structures as I know that that's a big area. 4 A. Right.
5 A. No. 5 Q. Okay. Now, there are two broad
6 Q. Okay. Do you know if the Corps, since 6 subjects which need to be evaluated in order to
7 the MRGO was constructed, ever undertook an 7 assess the answer to Question 2, one of which
8 evaluation regarding the influence of the 8 is the effect of the MRGO on surge and the
9 Mississippi River Gulf Outlet on hurricane 9 other of which is the effect of the MRGO on
10 waves? 10 waves, isn't that true?
11 A. I don't know. 11 A. I would add and the effect of the MRGO
12 Q. Okay. And you were not asked by the 12 on overtopping.
13 IPET group to undertake a search of whether 13 Q. Would you regard that as a completely
14 there were such previous investigations, isn't 14 separate and distinct evaluation, or really
15 that true? 15 would that not be an evaluation that one would
16 A. Regarding the influence of the MRGO on 16 make after one completed 1 and 2?
17 waves? 17 A. Well, you need to look at waves and
18 Q. Yes. 18 water levels to assess overtopping.
19 A. No. We were not asked to take a look 19 Q. Right. That's where I was going. So
20 at that. 20 really, you look at the effect on water levels,
21 Q. Okay. Now, in your report, if we 21 you look at the effect on waves, and then after
22 could go there -- 22 you do that then you see if there is an effect
23 A. Okay. The IPET report. 23 on overtopping, right?
24 Q. No, no. Your -- I'm sorry. Your 24 A. Yes.
25 expert report. 25 Q. With me so far?
Page 460 Page 462
1 A. Okay. 1 A. Yes.
2 Q. December 7th, 2008. 2 Q. Okay. All right. Now, it is true, is
3 A. Okay. 3 it not, that up until you were asked to do this
4 Q. Which I trust we don't need to mark. 4 work no one on your side had evaluated the
5 At Page 7, it says, this expert report examines 5 potential impact of the MRGO on waves?
6 the following issues: And you have a 1. 6 A. That's correct.
7 A. Which paragraph? 7 Q. All right. But there had been some
8 Q. The first one. 8 work on surge.
9 A. Okay. 9 A. The effect of the MRGO on surge, yes,
10 Q. Scope of the report. This expert 10 that's correct.
11 report exams the following issues: 1. The 11 Q. Okay. And now let's talk about that
12 effect of the Mississippi River Gulf Outlet 12 work on surge. So the first one that you guys
13 navigation channel and historic changes to the 13 report -- and this is going back to your note
14 surrounding wetlands that have occurred since 14 again at Exhibit 11 -- the first is
15 its construction on the water levels, wave 15 Bretschneider --
16 conditions and overtopping overflow produced 16 THE WITNESS:
17 around the periphery of the St. Bernard polder. 17 Do we have the appendices from
18 And then it stops. Right? And then you go to 18 the IPET report?
19 and, and there's a 2. 19 MR. MITSCH:
20 A. Yes. 20 Um -- we may. I don't know, but
21 Q. So the second component is, the effect 21 we can check.
22 of the MRGO on levee and floodwall breaches 22 THE WITNESS:
23 along the eastern facing levee of the 23 Can we find if we have Appendix
24 St. Bernard polder and along the east side of 24 6?
25 the Inner Harbor Navigation Canal which 25 EXAMINATION BY MR. BRUNO:
37 (Pages 459 to 462)

Page 463 Page 465
1 Q. Is there some possibility that 1 Q. I'm sure they are. I don't really
2 Exhibit 11 is not that document? 2 care.
3 A. I don't know. When I asked you what 3 A. I don't know if this was a draft, an
4 the source was you couldn't really tell me, so 4 initial draft, um -- at what point in time --
5 I'd prefer to go back to the IPET report and 5 Q. Bruce, the question is did you write
6 look at the exact appendix on which this 6 it or not? All I care about is if you wrote
7 subject was covered in the IPET report. 7 it. We got it off the website, and apparently
8 Q. Did you write more than one note on 8 the website has got stuff on there with your
9 the influence of the Mississippi River Gulf 9 name on it that you don't want on there, you
10 Outlet on hurricane-induced storm surge in New 10 need to take it up with your boss.
11 Orleans and vicinity? 11 MR. MITSCH:
12 A. I don't recall. 12 Why don't we just use the
13 Q. You might have? 13 appendix from IPET?
14 A. Um -- possible. I don't think so, but 14 MR. BRUNO:
15 just to make sure, to satisfy myself I would 15 He says they're different. I
16 prefer to work from the IPET report. 16 have questions about this document.
17 Q. Okay. All right. Well, then, I guess 17 A. Well, if it's an earlier draft then it
18 perhaps we'll just break until we see if 18 would have been superseded by what's in
19 there's a -- 19 Appendix 6 of the IPET report.
20 MR. MITSCH: 20 EXAMINATION BY MR. BRUNO:
21 Sure. 21 Q. Bruce, who would be in the best
22 (Off the record.) 22 position to know whether it's an earlier draft,
23 MR. MITSCH: 23 me or you?
24 All right. We got it. 24 A. Me. And I'm telling you --
25 EXAMINATION BY MR. BRUNO: 25 Q. That's my point.
Page 464 Page 466
1 Q. Okay. Have you been able to satisfy 1 A. -- it's probably an earlier draft.
2 yourself that Exhibit 11 is in fact your work? 2 Q. Is it an earlier draft or not?
3 A. Um -- no, I just brought our Appendix 3 A. I suspect it has to be.
4 6 with me. 4 Q. You suspect.
5 Q. Okay. Well, is Exhibit 11 your work 5 A. This is the final.
6 or not? 6 Q. Okay. Well, let me look at the final
7 A. I don't know. I'd have to look 7 so I can see if my questions are unchanged.
8 through it. Could we not just make Exhibit 11 8 Bruce, I think if you look at these
9 Appendix 6 of the IPET report? 9 things you will find that they are identical
10 Q. Only if they're the same. I mean, I 10 save the addition of the sentence which is
11 want to ask you about Exhibit 11. 11 "this note white paper is not intended" until
12 A. Would you like me to look and confirm 12 the end of the paragraph. I've checked three
13 that they're the same? 13 pages of paragraphs and they're identical. Why
14 Q. Yeah. Sure. I mean, I've got a piece 14 don't you do the same.
15 of paper that says you wrote it. If you didn't 15 A. No, I'll stand behind the final
16 write it, just tell me. 16 document that I wrote that's in the IPET
17 A. I mean, I can tell you it's not. I 17 report.
18 mean, obviously, this first paragraph is 18 MR. MITSCH:
19 different -- is of a different length than the 19 Why don't you just ask those
20 one in your Exhibit 11. 20 questions you want to ask.
21 Q. Okay. Does that mean you didn't write 21 MR. BRUNO:
22 it? 22 Thank you. I'd like to. I find
23 A. I don't know. 23 it astonishing that the witness
24 Q. You don't know. 24 doesn't know what he wrote. But
25 A. They're different documents. 25 that's okay.
38 (Pages 463 to 466)

Page 467 Page 469
1 EXAMINATION BY MR. BRUNO: 1 them?
2 Q. All right. At -- there's a paragraph 2 A. Yes.
3 which begins, and the page numbers are probably 3 Q. Okay. And the second one involved
4 not exactly the same, where it says much 4 closing the MRGO reach at the Bayou La Loutre
5 concern -- 5 ridge? And that was done by?
6 A. Can give me -- help me with how many 6 A. Where do you see that?
7 pages in we are? 7 Q. The next paragraph, the second study
8 Q. It's the second page for mine. So 8 was also commissioned. Is that how your
9 it's going to be two or three. 9 paragraph begins?
10 A. And the paragraph? 10 A. Yes.
11 Q. Much concern. 11 Q. Does it end with was used to perform
12 A. On the second page? 12 the computations?
13 Q. It may be different. Much concern. 13 A. Yes.
14 A. Okay. 14 Q. Okay. It says this -- do we know who
15 Q. You see the paragraph much concern? 15 did this study?
16 A. Yes. 16 A. Um -- to the best of my recollection,
17 Q. Does it end with low amplitude tide 17 Joannes Westerink and Harley Winer. And I
18 has been established? Do you see that? 18 don't know if others were involved or not. I
19 A. Yes. 19 believe those two were involved in that study.
20 Q. Okay. It says, the past work of 20 I was not involved in that study.
21 McAnally and Berger, Carillo and Tate, for 21 Q. It says, results from this study
22 example, has shown that this section of the 22 showed that for low amplitude storm surges,
23 MRGO channel along with the critical section 23 peak surge having a magnitude of four feet or
24 GIWW at MRGO Reach 1 plays an important role in 24 less, the presence of MRGO Reach 2 increased
25 the propagation of the astronomical tide wave 25 the storm surge by up to the following amounts,
Page 468 Page 470
1 and in the flux of more saline water from Lake 1 and then it tells you the amounts. And then it
2 Borne, Breton Sound into Lake Pontchartrain via 2 says, for nearly all situations that were
3 the IHNC. 3 examined, results for all ten storms at the
4 Can you explain that sentence for me, 4 four locations shown in Figure 1, the presence
5 please; what does it mean? 5 of the MRGO Reach 2 either did not cause a
6 A. Well, the MRGO Reach 2, which runs 6 significant change or the increase was less
7 from the confluence of the GIWW with the MRGO, 7 than .3 feet? And then it says, for higher
8 or that reach that connects all the way down 8 amplitude storm surges, peak surges on the
9 through Breton Sound, is a deep channel and it 9 order of 7 to 12 feet, which included Hurricane
10 allows saline water to propagate with the tide 10 Betsy, changes in use by MRGO were .3 feet or
11 through that channel into the region. 11 less for all situations.
12 Q. Okay. All right. The next paragraph 12 What does that mean, for higher
13 you have starts three previous studies -- 13 amplitude storm surges?
14 A. Yes. 14 A. Well, if you have something that's
15 Q. -- ends with essentially the same 15 propagating in the channel, primarily, then the
16 surge elevations with or without the MRGO? 16 presence of a channel is going to have a
17 A. Yes. 17 significant impact. So when I said there was
18 Q. Okay. Seem to suggest that you guys 18 significant change -- or we said a significant
19 identified that there were three previous 19 change or an increase was less than .3, maybe
20 studies performed to examine the influence of 20 it would have been .3 without the channel and
21 the MRGO Reach 2 on flooding in the New Orleans 21 .6 with the channel. That would be a
22 and vicinity. So apparently there is three 22 100 percent change. But that might be
23 previous studies, right? 23 significant. But obviously nobody is really
24 A. Yes. 24 concerned with storm surges of .3 or .6 feet.
25 Q. Bretschneider and Collins is one of 25 Q. No, I understand that. Okay.
39 (Pages 467 to 470)

Page 471 Page 473
1 A. So then what happens is, as -- you 1 version that we applied in the IPET. And that
2 know, when the long wave, whether it's tide or 2 version is different from the SO8 model, and
3 surge, is no longer confined to the channel, 3 it's a different from the SL15 model that we
4 then other factors come into play regarding the 4 applied in support of this case.
5 influence of the MRGO. 5 Q. Okay. I think you mentioned that in
6 And, you know, for the surges that are 6 here somewhere, I'm just trying to figure out
7 causing -- for the hurricanes that are causing 7 where it is.
8 large storm surge in the region, that's 8 A. TFO1x2, I think
9 generally because of water that's entering in 9 Q. Here it is. The paragraph that
10 from Lake Borgne. So the higher the storm 10 begins, we have simulated --
11 surge the more and more water is going to come 11 A. Tell me what page.
12 through Lake Borgne and not up the MRGO 12 Q. Well, mine is Page 5. It's the
13 channel. So it says, for higher amplitude 13 second-to-last page of the report. It's close
14 storm surges the changes are quite small 14 to the end.
15 because the MRGO becomes less and less of a 15 A. TF01.
16 factor the higher and higher the storm surge 16 Q. Yeah. That's it. TF01.
17 gets the more and more the storm surge is 17 A. So I think that would have been even a
18 coming in front from the east through Lake 18 slightly earlier version of the final ADCIRC
19 Borgne and over the wetlands. 19 model we used in the IPET which I think was
20 Q. Okay. I got you. All right. And 20 TF01X2, if I recall.
21 then the third study, it says a follow-up study 21 Q. And the difference between the S08 and
22 was commissioned by the State of Louisiana 22 the TF01 was the added details and resolution
23 Department of Natural Resources. And that was 23 for the coastal flood plains of the north shore
24 the one done by URS, I think? 24 of Lake Pontchartrain, Mississippi and Alabama,
25 A. Yes. 25 right?
Page 472 Page 474
1 Q. Now, okay. Now, attached to this -- 1 A. Yeah. You know, at some point during
2 well, my copy, does yours have this graph at 2 the IPET we added a good bit of resolution
3 the back, Figure 4A and 4B? 3 along the wetlands to try to capture that zone
4 A. Yes. 4 of wave breaking so we could do a better
5 Q. Okay. All right. These graphs come 5 description of the wave radiation stresses.
6 from which of the three studies? 6 So.
7 A. I believe these came from the work 7 Q. Well, but you're confusing me. Is
8 that we did and within the IPET to examine the 8 that TF01? If you'd just answer my question it
9 issue. 9 will help me, because all I'm asking you is
10 Q. Okay. 10 this: Is whether or not the difference
11 A. I mean, I think you cited three other 11 between, or the primary difference, there may
12 previous studies. 12 be other differences, but the primary
13 Q. All right. 13 difference between SO8 and TF01, according to
14 A. So ours would have been -- it's a 14 your paper, is that the TF01 has added details
15 fourth. 15 and resolution for coastal flood plains of the
16 Q. Okay. All right. So this is the work 16 north shore of Lake Pontchartrain, Mississippi
17 that you did within IPET. 17 and Alabama.
18 A. Yes. 18 A. Yeah. I see what it says. I don't
19 Q. Okay. And this work was done 19 recall if there was additional resolution along
20 utilizing an ADCIRC model? 20 Louisiana in the wave breaker zone for this --
21 A. It was done using an ADCIRC model that 21 I mean, I know that was for the IPET mesh. And
22 was an improved version of the original SO8 22 this work was done in February, which would
23 model was that developed for the IPET called 23 have been documented in February, so this would
24 the TF01 -- let me see if I can find it. 24 have been a pretty early version of what we
25 Anyway, it's a designation we gave as the 25 were developing for the IPET.
40 (Pages 471 to 474)

Page 475 Page 477
1 Q. Okay. But so the answer is yes or no? 1 then as better information came in we revisited
2 A. I don't know. 2 a third time. And the reason we did that is
3 Q. Well, SO8 didn't have Alabama, 3 because, you know, our task was regional waves
4 Mississippi and -- 4 and storm surge predictions. So Don Resio 's
5 A. No, that's what I'm saying. 5 task relied upon our information, and then Reid
6 Q. I'm trying to establish -- 6 Mosher 's task would rely upon Don Resio 's
7 A. I'm reading the text. 7 information, and so we had to get out
8 Q. Right. 8 information very, very quickly as part of our
9 A. And so, I believe it when it says we 9 first spiral. And so to do the first spiral we
10 added details and resolution for the areas that 10 decided we were going to do a Planetary
11 are listed here. What I'm telling you is I 11 Boundary Layer application just in the interest
12 don't know if we perhaps omitted a description 12 of expediting some information out to the other
13 of adding resolution along the Louisiana coast 13 teams. And it was our plan that in subsequent
14 to try to accommodate our treatment of wave 14 spirals we would take advantage of the much
15 breakers. 15 more accurate wind fields that were created by
16 Q. Let's approach it from this angle: 16 Ocean Weather, Inc., and the hurricane research
17 Did SO8 include details and resolution for the 17 division. So it was just really our effort to
18 coastal flood plains of the north shore of Lake 18 get at the best information we could very, very
19 Pontchartrain? 19 quickly into the process so other teams could
20 A. To my recollection, the SO8 model is 20 begin to do their analysis. And then in
21 very crude in its resolution of those areas. 21 Spirals 2 and 3, we came back and began to use
22 And I believe for that reason we would have 22 better wind fields and better information in
23 added resolution into those areas. 23 our modeling.
24 Q. Okay. Does SO8 include any details 24 (Off the record.)
25 for Mississippi or Alabama? 25 EXAMINATION BY MR. BRUNO:
Page 476 Page 478
1 A. I think it's a very, very crude 1 Q. So conclusions. And those are
2 representation of the Mississippi coast and the 2 reflected graphically as 4A and 4B.
3 area that would have been inundated by 3 A. Okay.
4 Hurricane Katrina along the Mississippi coast. 4 Q. And I want to make sure I understand
5 Q. All right. Now, what topography did 5 the graphic because it says, positive
6 you use? 6 differences indicate increased elevations with
7 A. I can't recall. You would probably 7 the MRGO in place, and negative differences
8 have to ask -- Joannes would have a better 8 indicate decreased waters with the MRGO in
9 appreciation. 9 place. So this chart would detail for us the
10 Q. So he did that. 10 increases in water levels throughout the region
11 A. He actually did the model application 11 shown by color diagram from the MRGO, right?
12 of ADCIRC in support of the IPET. 12 A. Yes.
13 Q. Do you know if there were included any 13 Q. Okay. And if I look at New Orleans
14 Manning's coefficients for vegetation, trees, 14 East, I see colors blue, light green, and maybe
15 swamps, et cetera? 15 a lime color in there. Right?
16 A. I don't recall. 16 A. Are you talking about the area to the
17 Q. Okay. And the wind comes from the 17 left? Which figure are you looking at? 4A?
18 Planetary Boundary Layer, PBL model? 18 Q. 4B. 4A is too small. Couldn't see
19 A. Yes. For this -- that was not -- 19 it.
20 maybe I should explain how we operated in the 20 A. Which area. There's a big area of
21 IPET. In Task 4 -- well, in the IPET in 21 white. Are you talking about to the left or to
22 general we took what we called a spiral 22 the right of these colors?
23 development process. We would generate 23 Q. Talking about New Orleans East.
24 information, and then as better information 24 A. Okay. But -- okay.
25 came in we would revisit our information, and 25 Q. And I said, I thought I said to you in
41 (Pages 475 to 478)

Page 479 Page 481
1 New Orleans East I see green and blue. 1 Q. Right.
2 A. You mean inside or are you talking 2 A. So what the sort of those, um -- well,
3 about in -- 3 let's -- let me give you an example. Let's
4 Q. Inside New Orleans East. 4 look along Reach 2. Okay?
5 A. Okay. I mean, we don't -- I would 5 Q. Uh-huh.
6 never advocate using ADCIRC for interior 6 A. You see the darker blue along Reach 2?
7 flooding estimates. It's not accurate for that 7 Q. Sure.
8 purpose. So we should not be looking at 8 A. That would say if we removed the MRGO
9 results other than things -- areas that are 9 we would actually increase the water level. So
10 outside the levee system, we should not be 10 the MRGO actually -- the presence of the MRGO
11 using ADCIRC results for interior inundation. 11 actually decreased --
12 It's not a suitable model for that -- 12 Q. The water levels.
13 Q. Okay. 13 A. -- the water level in this simulation.
14 A. -- purpose. 14 So, but out here in Lake Borne we see
15 Q. Well, did I do this graph or did you 15 what looks like some very small,
16 do this graph? Who but this on the record? 16 tenth-of-a-foot changes that we would say the
17 A. We did. 17 presence of the MRGO actually resulted in a
18 Q. You did. Okay. 18 slight increase out there.
19 A. Yes. 19 Q. Uh-huh. All right.
20 Q. And you have colors inside of New 20 A. So if you look carefully at the
21 Orleans East. And those colors indicate that 21 scale --
22 there is an increase in water levels inside New 22 Q. All right. So you want me to
23 Orleans East. That's what this graph shows. 23 eliminate everything within the levee system,
24 A. I understand. But as the expert or 24 so really the only thing that I should be
25 the person who's done the modeling, I'm telling 25 looking at is inside Lake Borne or along the
Page 480 Page 482
1 you disregard those results, they're 1 MRGO outside the levee system or in the river.
2 inaccurate, the models should not be used for 2 Everything else is irrelevant to you.
3 that purpose. 3 A. Could you restate that again?
4 Q. All right. Well, I don't know if you 4 Q. Well, am I wrong here? But I'm
5 know the purpose for which I'm using it, so 5 looking at Figure 4B, and if I look at
6 here's the simple question: 6 everything that's colored that's north of the
7 A. Okay. 7 English Turn or the Chalmette Extension levee,
8 Q. The simple question is this: Does the 8 and I exclude what's outside of the MRGO levee,
9 MRGO influence surge, yes or no? 9 all that stuff is inside levee protection
10 A. You have to tell me where. I see a 10 system and therefore I need to ignore it.
11 lot of white area where I would say the answer 11 A. Yeah. Yeah, just ignore results
12 is no, and I see some colored areas where I 12 inside the levee system.
13 would say the answer is yes. So tell me where 13 Q. So what is this showing?
14 you're talking about. 14 A. Well, along -- I think I just told you
15 Q. Yeah. Right. No, that's fine. 15 what it shows me. Along Reach 2, what it shows
16 Everywhere where I see color the answer is yes. 16 me is that actually the presence of the MRGO
17 A. Yes. 17 Reach 2, if you want to look at it, it's
18 Q. Okay. So the light colors, blue to 18 somewhat beneficial in that it would actually
19 green to yellow to red mean that it increases 19 lower the storm surges along Reach 2. Up in
20 surge, right? 20 this area along MRGO, GIWW Reach 1 and along
21 A. Well, there's some -- there's -- the 21 the GIWW, presence of the MRGO actually
22 blue -- the dark blues are negative. 22 increases the water level by several tenths of
23 Q. Uh-huh. 23 a foot.
24 A. And I see I don't know if that's blue 24 Q. Uh-huh.
25 green or greens, are positive. 25 A. And then everywhere you see white, the
42 (Pages 479 to 482)

Page 483 Page 485
1 change is very, very small. Less than plus or 1 during Katrina.
2 minus a tenth of a foot. 2 Q. Bruce, this is not intended to discuss
3 Q. All right. So the bottom line is that 3 breaching.
4 all three studies demonstrate that the MRGO has 4 A. The model doesn't treat breaching, so
5 an impact on surge levels, albeit small, but it 5 I'm telling you for that very reason alone --
6 does increase surge levels. 6 Q. Bruce, we didn't ask about breaching.
7 A. No. 7 Who's talking about breaching? It's not even
8 Q. Right? 8 on the table.
9 A. I just said the opposite. I mean, you 9 A. You just asked me why --
10 can look at the color scale. And the influence 10 Q. No, sir.
11 is an opposite sign along Reach 2 and along 11 A. -- I would not use ADCIRC --
12 Reach 1. 12 Q. I didn't ask you that at all.
13 Q. All right. Okay. Now, what the 13 A. -- for interior inundation.
14 ADCIRC does is ADCIRC gives us a water level, 14 Q. No, sir. That wasn't the question.
15 right? 15 What I asked you was whether or not the
16 A. Water surface elevation. 16 coloration inside the polders was relevant, and
17 Q. It's a water surface elevation. 17 you said it's not relevant because ADCIRC can't
18 A. Uh-huh. 18 do it, or some such nonsense, and I'm trying to
19 Q. Now, in the topography were the levees 19 understand why you're saying that. Okay?
20 included? 20 A. Well --
21 A. In the model itself? 21 Q. In this ADCIRC model, breaching wasn't
22 Q. Yes. 22 included, was it? That wasn't what you were
23 A. The levees are treated -- yes. 23 studying.
24 Q. They're there. And this was using 24 A. Breaching has not been included in any
25 NAVD88? 25 ADCIRC simulation --
Page 484 Page 486
1 A. I don't know. I don't know. That's a 1 Q. Fair enough. So then why are we
2 pre detail question that Joannes would be the 2 talking about breaching? Why did you bring it
3 better one to ask that question. 3 up?
4 Q. Do you know how dense the grid was 4 A. Well, because it was a very important
5 inside the polders? 5 influence on the water that actually entered
6 A. No, I don't recall. Joannes would be 6 the polder during Katrina.
7 the better one -- you're asking some pretty 7 Q. That's not what this chart is intended
8 detailed questions about the model itself. He 8 to show. This chart is intended to show -- if
9 would be the better one. 9 I read it, it's intended to show me where the
10 Q. Fair enough. But that means that you 10 positive differences in elevations are with the
11 really can't speak to whether or not the MRGO 11 MRGO in place. That's what it says. I mean,
12 has an influence on surge, I've got to speak to 12 can I not read the words and interpret those
13 Mr. Westerink. 13 words intelligently?
14 A. No, I can interpret the results coming 14 A. Okay.
15 out of here, I just can't give you the details 15 Q. Is there some footnote or asterisk
16 about the input that went into the model. 16 which says ignore the colors inside the polder?
17 Those were things that you were just asking me. 17 Do you see that on this piece of paper?
18 Q. If you don't know anything about the 18 A. No, but I'm just telling you from my
19 details of the model, how can you tell me to 19 knowledge to ignore them.
20 ignore the results inside the polder? 20 Q. Fine. So some schmo who would
21 A. Well, I know things that it doesn't 21 download this off of the Internet would just be
22 account for. 22 stuck with the grossly incorrect perception
23 Q. Like what? 23 that the colors inside the polder mean
24 A. Like breaching. Breaching we know was 24 something. Right? Is that true?
25 a major factor of water entering the polder 25 A. We probably should have masked them
43 (Pages 483 to 486)

Page 487 Page 489
1 out. 1 results in terms of the coloration, right?
2 Q. If you want to hide something you 2 A. Right.
3 would mask it, sure. 3 Q. And you are now telling me to ignore
4 A. No, no, no, no. That way we would not 4 what's on the piece of paper, without any
5 have Joe Schmo interpreting what's in that 5 footnote, without any reference and without any
6 area. 6 explanation on the piece of paper. Isn't that
7 Q. How about this? How about we tell Joe 7 true?
8 Schmo exactly why these things count or they 8 A. That's false. I just told you to
9 don't count. So let's ask the question. 9 ignore the results inside the levee system. By
10 Bruce, this ADCIRC model had good 10 all means use the results outside the levee
11 topography in it, didn't it? 11 system.
12 A. In which areas? 12 Q. Tell me exactly why it is we should
13 Q. The whole area. The area that you 13 ignore the results inside the polders.
14 were studying. How about St. Bernard? The 14 A. Okay.
15 central wetlands unit? Let's just talk about 15 Q. Explain it to me in as much detail as
16 that and nothing else. You can trust the 16 you can.
17 topography there, can't you? 17 A. Okay. This is a simulation of
18 A. That's inside the levee system. 18 Hurricane Katrina. And we know for a fact that
19 Q. So, can you trust the topography or 19 breaches occurred during Hurricane Katrina.
20 not? Just tell me yes or no. 20 The whole Reach 2 was devastated by Katrina
21 A. I don't know. 21 storm surge simulations -- excuse me, storm
22 Q. You don't know. Okay. Well -- 22 surge and waves.
23 A. It was not a focus. 23 Q. All right.
24 Q. How do you know? You didn't design 24 A. We know that breaches occurred in
25 this? 25 the -- along the Industrial Canal on the east
Page 488 Page 490
1 A. Well, it's not a focus of our 1 side. So if we know that breaches occurred and
2 application here. 2 we know ADCIRC doesn't treat breaches, it would
3 Q. You don't know that, Bruce, because 3 be irresponsible for us to recommended that
4 you didn't design it. You told me Professor 4 people use results on the inside of this polder
5 Westerink designed it. 5 as an indicator of what actually happened
6 A. Well, then, you should talk to Joannes 6 inside the polder during Hurricane Katrina.
7 and ask the questions about elevations -- 7 Q. That's not the purpose of this figure,
8 Q. That's fair enough. And all I want 8 Bruce. I don't know why you're talking about
9 you to admit to me is that you're not the guy 9 breaches. This figure -- this paper has
10 to talk to about whether or not MRGO influences 10 nothing to do with breaching. I read the paper
11 surge, it's really Professor Westerink. Isn't 11 title. It says, note on the influence of the
12 that true? 12 MRGO on storm-induced surge. So what this
13 A. That's false. 13 tells me is that the MRGO increased storm surge
14 MR. MITSCH: 14 to the point where it went over the levees and
15 No. Objection. 15 to some tiny little degree caused some
16 EXAMINATION BY MR. BRUNO: 16 additional flooding. That's all. We know that
17 Q. Okay. So you're telling me that you 17 the storm surge in Katrina, based upon your
18 are interpreting Professor Westerink's results, 18 testimony this morning, was high enough to
19 right? 19 overtop the levees. So we know even without
20 A. I'm very capable of interpreting 20 breaching you got water in those polders. So
21 ADCIRC results. 21 what we're showing here is that there's a
22 Q. And what we're looking at are ADCIRC 22 difference in the level of that water which
23 results, right? 23 this report says is related to MRGO. Isn't
24 A. True. 24 that true?
25 Q. And we are interpreting the ADCIRC 25 A. Rephrase your question, please.
44 (Pages 487 to 490)

Page 491 Page 493
1 Q. All right. This is a Katrina 1 A. Let's restrict our interpretation to
2 simulation. We know that Katrina overtopped 2 anything outside the levee system.
3 the levees and flooded portions of -- and would 3 Q. What's what I'm just trying to say.
4 have in fact flooded portions of New Orleans 4 A. Okay.
5 with or without the breaches. We know it would 5 Q. So it doesn't work inside the levees,
6 have flooded New Orleans East with or without 6 so I have to limit the use of ADCIRC to areas
7 the breaches, and we know it would have flooded 7 outside the levee. Yes or no?
8 certain portions of the central wetlands unit 8 A. As far as interpreting the effect on
9 with or without the breaches. So what this 9 storm surge, yes.
10 seems to say is that the difference, the 10 Q. And insofar as interpreting anything
11 percentage -- the difference in the water level 11 from ADCIRC. You told me it's not good inside
12 changes by this coloration chart, and again, 12 the levee, period.
13 it's not a lot, it's .2, .3, across those 13 A. No.
14 surfaces. So if this model included levee 14 Q. That's what you just told me.
15 heights, this shows the relative difference in 15 A. No. We get very accurate simulations
16 water height with the MRGO and a no MRGO 16 of results outside the levee system.
17 contribution, and it shows that there's a 17 Q. No, I said inside the levee system.
18 little bit of contribution on all the areas 18 A. And I'm telling you disregard the
19 that are colored. Without breaches being 19 levee -- inside.
20 shown. It still shows the same thing, doesn't 20 Q. And I'm trying to get you to help me
21 it? 21 understand. Does that mean that you can't use
22 A. You're referring inside or outside? 22 ADCIRC for any purpose inside the levee? I
23 Q. Inside, outside, wherever there's 23 don't know why you're not listen to me.
24 color. 24 A. I am listening. I'm listening very
25 A. We don't use -- we don't rely on 25 carefully to you.
Page 492 Page 494
1 ADCIRC results inside these polders. Now, I 1 Q. No you're not, because I said
2 don't -- I'm not sure why we're having this 2 inside --
3 barrier of not understanding that. 3 MR. MITSCH:
4 Q. I don't know what we rely for, because 4 He's told you twelve times.
5 I'm talking about this particular report. 5 EXAMINATION BY MR. BRUNO:
6 A. ADCIRC is not a reliable tool to 6 Q. -- and you keep jumping outside. One
7 estimate inundation on the inside of these 7 more time: That means that you can't use
8 levees during Katrina. 8 ADCIRC for any purpose inside the levee.
9 Q. Okay. Fine. All right. That's fine. 9 I-N-S-I-D-E.
10 A. That's why we rely on the HEC-RAS 10 A. I've already answered this question.
11 modeling. 11 Q. Is what?
12 Q. No problem. But for whatever reason 12 A. It's back in the record.
13 you guys chose not to say that in this report. 13 Q. Actually, what you said was outside.
14 Right? 14 I'm trying to ask the question about inside.
15 A. And I think I said earlier, in 15 A. Let me tell you one more time to give
16 retrospect it probably would be better for us 16 you an angles of where I think ADCIRC gives
17 just not to show results on the interior of 17 reliable information.
18 these polders because they could be misleading. 18 Q. That's not my question.
19 Q. So what you're saying to me generally, 19 A. Well, I know it's not your question,
20 though, is all of your ADCIRC modeling is no 20 but I giving you the answer of --
21 good once you get to the levee. 21 Q. Even though it's not my question
22 A. I'm not saying that, Joe. 22 you're going to give me an answer. Remarkable.
23 Q. Well, I'm trying to understand what 23 A. I'm going to tell you where ADCIRC
24 you said. It doesn't work when you go beyond 24 information is reliable. Do you care?
25 the levee. 25 Q. Yeah. I want to know where it's
45 (Pages 491 to 494)

Page 495 Page 497
1 reliable and not reliable. Okay? That's what 1 MR. BRUNO:
2 I'm trying to understand. You've told me it's 2 This is where I got it. Whose
3 reliable outside the levee. I get that. I'm 3 fault is that? I didn't put it on the
4 trying to understand if you could use any 4 Internet.
5 ADCIRC output, any one of them, inside the 5 EXAMINATION BY MR. BRUNO:
6 levee. Some of them or is it none of them? 6 Q. Let's see what you've got. You've
7 A. I would not use ADCIRC results inside 7 got, while the simulations clearly show that
8 the levee. 8 Reach 2 of the MRGO does not significantly
9 Q. Okay. None of them. 9 influence the development of storm surge in the
10 A. None of -- 10 region for large storm events -- that's exactly
11 Q. None of the ADCIRC outputs. Don't use 11 the same -- Reach 1, the combined GIWW/MRGO
12 those inside the levee. I'm just trying to 12 section and the IHNC together provide a
13 understand the rules of the game. Right? 13 hydraulic connection between Lake Borgne and
14 A. Yes. 14 Lake Pontchartrain. As a result of this
15 Q. Okay. That's it. That's no problem. 15 connection, the storm surge experienced within
16 I got it. 16 the IHNC in Reach 1 is a function of storm
17 Now, the last paragraph of this report 17 surge in both lakes. A water level gradient is
18 I didn't quite understand. It says, while the 18 established within the IHNC in Reach 1 that is
19 simulations clearly show that the Reach 2 of 19 dictated by the surge level in the two lakes.
20 the MRGO does not significantly influence the 20 This is true for both low and high storm surge
21 development of surge in the region for large 21 conditions. To prevent storm surge in Lake
22 storm events, the presence of the critical 22 Borgne from reaching the IHNC or GIWW/MRGO
23 Reach 1 combined GIWW/MRGO and IHNC connection 23 sections of waterway, flow through Reach 1, the
24 between Lake Borgne and Lake Pontchartrain, as 24 channel must be dramatically reduced or
25 well as the funnel defined by the hurricane 25 eliminated either by a permanent closure or
Page 496 Page 498
1 protection levees along the banks of the MRGO 1 some type of structure that temporary serves to
2 and the GIWW locally, collect and focus surge 2 eliminate this hydraulic connectivity. The
3 in the region, influencing all hydraulically 3 presence of an open channel is the key factor.
4 connected regions as well as New Orleans 4 Okay. All right. That's worse. I
5 proper. 5 like that. I'll take it.
6 A. Wow. You lost me. I thought I was 6 So what does that say? That tells me
7 with you but now I'm not with you. What's the 7 that the Reach 1 is causing increased surge
8 beginning of that paragraph? 8 inside the IHNC.
9 Q. While. What do you got? You have 9 A. No, what it's saying is the presence
10 while, too. I can see it from here. 10 of that Reach 1 allows surge that's generated
11 A. Let me see the text? 11 in Lake Borne to propagate to the Industrial
12 Q. Sure. (Tendering.) 12 Canal. That's basically what it says.
13 A. Your text is different from mine. It 13 Q. Okay. Which means that you got
14 could be a result of this being an earlier 14 increased surge inside the IHNC.
15 version. 15 A. Could be increased. May not be.
16 Q. How is yours different? 16 Q. Well, Professor Westerink says three
17 A. Well, I don't know. 17 and a half feet. So I should throw that out?
18 Q. Again, you can go on line right now 18 A. Well, the IHNC runs from Seabrook to
19 and get this. 19 the lock.
20 A. Would you like to read this? 20 Q. Right.
21 Q. Yeah. I would. Because you can go 21 A. So the changes that are introduced
22 online and get this off the Internet right now. 22 depend on where you are along that waterway.
23 MR. MITSCH: 23 Q. So you would disagree with Professor
24 Well, we have it. You gave it to 24 Westerink. He said 3.5 feet he attributes to
25 us. But it's different. 25 the MRGO, with his no MRGO, MRGO runs. Or did
46 (Pages 495 to 498)

Page 499 Page 501
1 you look at that? 1 you could just answer my questions. Now you're
2 A. Well, tell me where the change is 2 giving me an opinion on something I didn't even
3 three and a half feet? 3 ask you about. I didn't ask you about
4 Q. In the IHNC at Lower Nine. 4 outcomes. I'm asking whether or not -- listen,
5 A. I think -- okay. Down on the south? 5 you're the guy that wrote this sentence and you
6 Q. Sure. Which is the relevant place of 6 said the first thing you do is you see if
7 inquiry. 7 there's a connection between historic changes
8 A. Let me look at the report. At a table 8 in the MRGO and water levels and wave
9 in mine that talks about that. 9 conditions and overtopping.
10 MR. MITSCH: 10 A. Where are you?
11 You might also show him the 11 Q. I'm in your report, Page 7.
12 Westerink report that shows that, so 12 A. I thought we were on Appendix 6.
13 we can -- 13 Q. No, I'm trying to remind you of what
14 MR. BRUNO: 14 you wrote.
15 I'll show him the Westerink 15 A. Okay.
16 deposition which is where he testified 16 Q. What you wrote was, this report exams
17 to it. How about that? 17 the following: You said 1. And the first
18 EXAMINATION BY MR. BRUNO: 18 thing that you examined was the connection
19 Q. Have you found it? 19 between, if any, the MRGO and water level. By
20 A. I have a table, and I can give you my 20 itself, independent of Number 2. That's why
21 perspective on that particular issue, unless -- 21 you have a Number 1 and then you follow with A
22 if you want me to comment on something in 22 number 2. They're two separate and distinct
23 Joannes' report I'll comment on it. 23 analyses. Isn't that accurate?
24 Q. Well, no. I mean, are you going to 24 A. What were the two distinct analyses?
25 testify about the impact of surge inside the 25 Q. You wrote them. You tell me. One of
Page 500 Page 502
1 IHNC or is that Westerink? 1 them addresses impact on water level and waves,
2 A. Well, what I will say -- 2 and then the second analysis is whether or not
3 Q. Because, I mean -- 3 that impact on water level and waves influenced
4 A. What I will say is if the MRGO in 4 flooding. So before you get to 2, you got to
5 Reach 1 is at its, um -- preconstruction 5 do 1. Right?
6 dimensions, I believe there is a reduction 6 A. Okay.
7 through Reach 1 and a larger reduction than 7 Q. Okay. I'm trying to learn about 1,
8 would be the case for the present situation. 8 and you keep talking about 2. And I'd like to
9 However, changes that the MRGO have introduced 9 focus my inquiry on 1.
10 in Reach 1 and in the IHNC don't really change 10 A. Okay.
11 the outcome because the outcome of flooding in 11 Q. So I've asked you quite simply whether
12 the St. Bernard polder is driven by and large 12 the MRGO influenced surge levels on the IHNC.
13 by what's happening along Reach 2. So if there 13 And I think you agreed and then went off on
14 are changes that happen in Reach 1 -- 14 whether or not the outcomes would have been the
15 Q. That's Mr. Fitzgerald, isn't it? 15 same. And so I'm going to go back to my
16 That's not you. 16 question one more time and ask you to agree or
17 A. Pardon me? 17 not agree that MRGO influences surge elevations
18 Q. That's not your opinion. That's 18 inside the IHNC at the Lower Ninth Ward, yes or
19 Fitzgerald 's opinion. He does the modeling. 19 no. Simple.
20 You didn't do any modeling on that. 20 A. Yes.
21 A. Yeah, I mean I looked at some of the 21 Q. The degree to which it influences is
22 plaintiffs. I think they come to essentially 22 Professor Westerink, not you, right?
23 the same conclusion. 23 A. No.
24 Q. Not really. But in any case I didn't 24 Q. That's you?
25 ask that question. And I would appreciate if 25 A. It's me. It's essential for me to
47 (Pages 499 to 502)

Page 503 Page 505
1 make that assessment to do Number 2, the effect 1 to go off in Never Never Land when he
2 of MRGO on levee and wall breaches. My 2 want to, that's his problem.
3 conclusion in my report is that these changes 3 EXAMINATION BY MR. BRUNO:
4 would have had no influence on the occurrence 4 Q. I didn't ask you a question about
5 of either the north or south breach. 5 breaching. Didn't ask you about north or
6 Q. How much is the change? 6 south. Real simple question: Refocus you one
7 A. How much is the change? 7 more time. Try to stay focused this time. I
8 Q. How much is the change? How much does 8 want to know about the influence on storm surge
9 MRGO influence surge level in the IHNC? What's 9 in IHNC. That's it. Okay? You can talk about
10 the number? 10 breaches with your compadres tonight over
11 A. Um -- I'd have to look back in my 11 drinks. I want to know about influence of the
12 report here. For all those cases that we 12 MRGO on level. Okay?
13 examined, including those without the MRGO and 13 A. Okay.
14 with the various wetland conditions, my 14 Q. Now, what is the influence of the MRGO
15 analysis shows that the water levels in the 15 on water level in the IHNC? Can you tell me?
16 Industrial Canal would have been greater than 16 A. I believe it slightly reduces those
17 13.5 feet. And I'm on Page 154 at the top. 17 water levels.
18 Q. You're comparing H1 to H3, right? 18 Q. It reduces them. So if you take the
19 A. I'm discussing all the alternatives. 19 MRGO out, the water level goes down. Right?
20 Q. Well, isn't H3 no MRGO wetlands back 20 A. A bit. A small amount.
21 to '58? 21 Q. Did you look at Professor Westerink's
22 A. Would you like to just talk about one 22 report?
23 case? 23 A. No, I have not read this report.
24 Q. No. I want to talk about what I 24 Q. Would you be surprised if he has a
25 thought we were talking about, which is we were 25 different result? Would you like to see it?
Page 504 Page 506
1 comparing the no MRGO with the Katrina results. 1 A. Um -- no, I don't think I would be
2 H1 is Katrina, and H3 is no MRGO, wetlands back 2 surprised.
3 to their original condition. That's what I 3 Q. Well --
4 want to talk about. 4 A. I've seen the results. I haven't seen
5 A. Okay. H3, no MRGO, wetlands condition 5 his report.
6 pre-MRGO. 6 Q. He says three and a half feet. You
7 Q. Exactly. 7 want to see it?
8 A. Okay. My conclusion for H3, for the 8 A. Yeah. I know what he's predicting.
9 north breach -- 9 And I cover the reasons --
10 Q. I didn't ask you about the north 10 Q. So he's wrong?
11 breach. 11 A. Yeah, I don't think that's an accurate
12 A. What are you asking me about? 12 assessment.
13 Q. You forgot already? 13 Q. That's fine. So Professor Westerink
14 A. Well, that's what's really important 14 is wrong on Page 178 where he reports the
15 here. 15 difference between H1 and H3 maximum water
16 MR. MITSCH: 16 surface elevations in the vicinity of the IHNC,
17 Come on. 17 regions that H3 reports higher maximum water
18 MR. BRUNO: 18 surface elevations are represented by warm
19 No, I'm sorry. 19 colors, cool colors report higher H1
20 MR. MITSCH: 20 elevations.
21 It's pretty hard to follow you. 21 So let's at least establish the facts.
22 MR. BRUNO: 22 Professor Westerink, in his modeling, shows
23 Give me a break. It's very easy 23 that the difference in water level is -- well,
24 to follow me. Everybody in the world 24 between 3, 3.5 and 4 feet, and I believe he
25 can follow me. But the witness wants 25 testified for us the other day three and a half
48 (Pages 503 to 506)

Page 507 Page 509
1 feet. Will you agree with me that that's at 1 EXAMINATION BY MR. BRUNO:
2 least what's in his report? 2 Q. Okay. All right. Now, before the
3 A. I haven't read his report. 3 break we established that Professor Westerink
4 Q. Okay. So you don't know that this 4 had a table or a chart of his report. And
5 is -- once again, you don't trust your lying 5 let's see if we understand what he's doing.
6 eyes. It's right here. 6 He's got an H1 scenario --
7 A. I'd like to read the report. 7 A. Can I see a copy of the table?
8 MR. MITSCH: 8 Q. Before we even see the table, in your
9 It's about four feet away. 9 report you describe H1 and H3, don't you?
10 MR. BRUNO: 10 A. Yes.
11 How about I get it closer then? 11 Q. Do you know what H1 is?
12 A. Well, I'd like to read the report. 12 A. The base case.
13 MR. MITSCH: 13 Q. What is the base case?
14 You're pulling one page out of a 14 A. The Katrina as conditions were prior
15 multi-paged report. 15 to Katrina.
16 MR. BRUNO: 16 Q. All right. And the H3 case?
17 I'm pulling one page out of a 17 A. It's a hypothetical condition that
18 multi-paged report done by your 18 assumes the MRGO channel does not exist and
19 experts. 19 wetlands were in their pre-MRGO condition.
20 EXAMINATION BY MR. BRUNO: 20 Q. All right. So all of the other
21 Q. And I just want to make the record 21 parameters are the same, save for the
22 clear that, Bruce, you who is an expert in the 22 elimination of the MRGO and changing topography
23 case, you haven't read Professor Westerink 's 23 to meet some supposition as to what that might
24 reports. 24 have been in 1958, correct?
25 A. I've looked at his results and I've 25 A. Correct.
Page 508 Page 510
1 looked at -- I know -- I understand the 1 Q. Okay. All right. So you take that
2 limitation of ADCIRC results within the 2 data and you say that's really not an accurate
3 Industrial Canal. 3 depiction of what happened in lower IHNC, you
4 Q. Okay. Fine. That's okay. No 4 say, in fact if you remove the MRGO the water
5 problem. 5 levels at the Lower Ninth Ward are lower.
6 (Brief recess.) 6 Right? Than they would have been with the
7 EXAMINATION BY MR. BRUNO: 7 MRGO. That's what you told us a little bit
8 Q. All right. Let me digress for one 8 ago. Isn't that correct? Water levels now.
9 second. I neglected to ask this question. 9 A. Could you rephrase the question?
10 Fitzgerald used ADCIRC in connection with his 10 Q. I thought you told me that Westerink's
11 interior modeling, didn't he? 11 results were incorrect, you felt like the water
12 A. Yes. 12 levels with a no MRGO scenario were in fact
13 Q. So did he make an error, based upon 13 lower than they would be without the MRGO.
14 what you've told me today? 14 A. I believe the ADCIRC model that we're
15 A. No, we used the ADCIRC results where 15 using overstates the influence of Reach 1 in
16 we think they're most reliable and where we 16 water levels back in the Industrial Canal. I
17 have less confidence in them in the Industrial 17 tried to explain that in my report, and I can
18 Canal we actually use the measured hydrograph 18 try to explain that here if you'd like me to.
19 or a scaled version of the measured hydrograph. 19 Q. Okay. Well, here's the thing: ADCIRC
20 Q. Okay. So the ADCIRC was acceptably 20 was used for H1 and ADCIRC was used for H3.
21 used by Fitzgerald for his interior flood 21 Correct?
22 model. Just yes or no? 22 A. Used by me?
23 MR. MITSCH: 23 Q. In the same way. By him.
24 If he can answer it yes or no. 24 A. By who?
25 A. Yes. 25 Q. Westerink. By the man in the moon.
49 (Pages 507 to 510)

Page 511 Page 513
1 A. Yes. I got you. 1 that connection to open water. And three is
2 Q. Okay? Same model. 2 what's the wind trying to do to the water
3 A. Yes. 3 surface within the Industrial Canal.
4 Q. Same parameters. So even if it does 4 EXAMINATION BY MR. BRUNO:
5 overestimate, the difference that you get is 5 Q. Okay.
6 going to be what is significant in the 6 A. So if you look at the -- you know, the
7 exercise. You want to see the difference 7 results for ADCIRC for the base case --
8 between the two, and so the fact that it may 8 Q. H1?
9 overestimate means really not a lot if one is 9 A. -- we know that we -- over on the Lake
10 comparing one to the other to see if there's a 10 Borgne side we generally underestimate based on
11 difference. Isn't that true? 11 really good quality, excellent quality high
12 A. Well, I think the magnitude of any 12 water marks.
13 overestimation is important. 13 Q. Underestimate what?
14 Q. Okay. Well, if there is an 14 A. We underestimate the peak water level.
15 overestimation in H1, isn't there also an 15 ADCIRC underestimates what we believe to be a
16 overestimation in H3? 16 more accurate estimate of what the actual water
17 A. Well, I'm a fan of using the best 17 levels are.
18 information available. And for the base case, 18 Q. Okay.
19 the Industrial Canal, the best information we 19 A. So, and the reason I believe that
20 have is the observed hydrograph. It's really 20 happens is there's something out in Lake Borne,
21 the only place around the polder that we do 21 in the wetlands, something about the physics we
22 have a measured hydrograph. And in our 22 don't understand well enough, and so ADCIRC is
23 interior flooding analysis we only looked at 23 yielding an underestimate over on Lake Borne.
24 two cases, case H1, if I recall, and -- 24 Q. Okay.
25 Q. Once again, I'm not interested -- 25 A. The other thing we know, that in Lake
Page 512 Page 514
1 MR. MITSCH: 1 Pontchartrain ADCIRC also underestimates the
2 No, no, no. Let him finish. 2 peak water level on the south shore of the
3 EXAMINATION BY MR. BRUNO: 3 lake. The ADCIRC estimate was approximately
4 Q. I am not interested in interior 4 nine feet. We know from high water marks that
5 flooding, Bruce. So I'm going to cut you off 5 the measurements were twelve feet. That might
6 because I'm not interested in interior 6 be for a number of reasons. We're not quite
7 flooding. I didn't ask you about interior 7 sure. It could be our wind drag formulation,
8 flooding, I'm asking about water levels in the 8 maybe, or the physics of that aren't well
9 canal. Can we stay there? 9 described in Lake Pontchartrain. It could be
10 MR. MITSCH: 10 because we're not simulating the effect of wave
11 And that's what he's trying to 11 setup against the levees on the south shore of
12 explain. 12 Lake Pontchartrain. But for whatever reason
13 MR. BRUNO: 13 that we don't really know, that ADCIRC model is
14 No. One the contrary, he wants 14 underestimating the peak storm surge level at
15 to talk about interior flooding. I 15 the entrance to Lake Pontchartrain.
16 ain't going there. 16 Q. Okay.
17 A. All right. Well, let me talk some 17 A. We think we have a good estimate of
18 more about water levels in the canal. All 18 what the winds are in the system. So out of
19 right. The water levels in the canal, I think 19 the three variables that are important, we got
20 I said earlier there's three important 20 about a three-foot error at the peak in Lake
21 variables that dictate what the water levels 21 Pontchartrain and we've got about a, oh, one a
22 are in the Industrial Canal. One is the water 22 and a half to two foot underestimate on the
23 level over on Lake Borne. That's one 23 other side. So if I'm after the best
24 connection to open water. Two would be the 24 information possible, I have to understand the
25 water level in Lake Pontchartrain because of 25 limitations of the ADCIRC model in the
50 (Pages 511 to 514)

Page 515 Page 517
1 Industrial Canal. I have great confidence that 1 through it three or four times, we keep doing
2 we can scale our ADCIRC hydrograph up in the, 2 it over and over again. You told us that this
3 um -- on the Lake Borgne side and make good 3 expert report exams the following issues: (1)
4 estimates of water levels on Lake Borne. But 4 The effect of the MRGO and historic changes
5 the fact that the model is underpredicting in 5 that have occurred on water levels. That's it.
6 Lake Pontchartrain affects water levels up and 6 You told me that was a separate and distinct
7 through the Industrial Canal and into Reach 1. 7 analysis.
8 Q. Okay. I'm with you. 8 A. No, Number 1 is a step on the way to
9 A. Okay? 9 doing number 2.
10 Q. Won't that happen in Reach -- I'm 10 Q. Right. So I only want to talk about
11 sorry. Won't that also happen in H3? Same 11 Step 1.
12 thing will happen. 12 A. Well, I want to talk about them all
13 A. I think the same thing will happen. 13 because that's what's most important.
14 Q. Right. So that there's still a gap 14 Q. You can talk about them all after you
15 between the two and the gap is three and a half 15 talk about step 1, okay? Because you told me
16 feet. 16 that the first thing you do is Step 1, and when
17 A. Well here's -- the thing is. 17 you finished Step 1 then you move to Step 2.
18 Q. Am I right? Let's just answer my 18 So I want to stay on Step 1 for a little while
19 question and you can explain. If you if your 19 so I can understand what you did with regard to
20 argument is H1 is too high, then H3 is also too 20 Step 1.
21 high. And it's going to be high by the same 21 So Step 1 is, did MRGO influence the
22 amount because you haven't changed your winds 22 water level, yes or no?
23 and you haven't changed your ADCIRC, and even 23 A. I have not used ADCIRC results in Step
24 if you scale it you're going to scale both H1 24 1 in the Industrial Canal.
25 and H3 the same way, aren't you? 25 Q. Okay. Fine. How did you determine
Page 516 Page 518
1 A. Um -- in the Industrial Canal, to 1 whether or not the MRGO and historic changes to
2 support the analysis -- Steve 's analysis -- 2 the surrounding wetlands affected or don't
3 Q. Steve? 3 affect water levels in the IHNC? What did you
4 A. Fitzgerald. 4 do to evaluate that question?
5 Q. We're not talking about -- once again, 5 A. In my analysis, I'm interested in the
6 all we're interested in -- 6 IHNC at the two breach sites. Okay? Because
7 A. Well, we're not calculating water 7 I'm going to do Number 2.
8 levels just in the Industrial Canal for the 8 Q. All right, fine.
9 sack of calculating water levels, we're doing 9 A. That's the only places I really want
10 something with the water levels. And what 10 to look at water levels in the Industrial
11 we're doing with them -- what I do with them is 11 Canal.
12 to make an assessment of do I think the changes 12 Q. Not a problem. So now we got a
13 induced by Reach 1 would have altered the 13 location. We're interested in the location at
14 occurrence of breaches in the Industrial Canal. 14 the north breach and we're interested in the
15 Q. No, Bruce. I'm sorry. 15 location at the south breach. Okay. So now we
16 A. And Steve is using those data to make 16 got geography.
17 an estimate of interior flooding. 17 A. Okay.
18 Q. Bruce, you forgot. 18 Q. So what did you do to determine the
19 A. Nobody is calculating water levels for 19 influence of the MRGO on water levels at those
20 the sake of water levels. 20 two locations?
21 Q. Yes, we are, Bruce. 21 A. Okay. Well, I know at the north
22 A. I'm not. 22 breach the breach occurred when the water level
23 Q. Yes, you are. You told me you were. 23 was approximately nine feet. So the question
24 Let me remind you. Let's go back o Page 7 of 24 in my mind is, with any of those alternatives
25 your report one more time, because we've been 25 in place did any of them have any chance of
51 (Pages 515 to 518)

Page 519 Page 521
1 producing a water level that was less than nine 1 A. No, I think I just --
2 feet? If they all produced a water level that 2 Q. Wait. Listen to me. Let me ask my
3 exceeded nine feet, then my conclusion would be 3 question.
4 that any of those cases would not have changed 4 A. Okay.
5 the occurrence of the north breach that 5 Q. You did not evaluate whether or not
6 occurred first between 3:30 and 4:00 o'clock. 6 the MRGO and its historic changes affected
7 Q. So you don't do a Step 1. 7 water levels in the IHNC. Isn't that true?
8 A. Pardon me? 8 A. That's false. I did. And I just
9 Q. You didn't do a Step 1, did you? You 9 explained to you how I did it, by the sources
10 jumped right over Step 1 and right into Step 2. 10 of information that I considered in the process
11 A. No. That's not true. 11 of doing it.
12 Q. Sure it is. 12 Q. Well, did the MRGO increase water
13 A. What I've done is I looked -- 13 levels or did the MRGO make water levels the
14 MR. MITSCH: 14 same, or did MRGO make water levels lower at
15 Don't argue with the witness. 15 the location of the north breach?
16 Just ask a question. He'll answer. 16 A. MRGO decreased the water levels but
17 MR. BRUNO: 17 not enough to make any difference in the
18 I got it. 18 occurrence of the north breach.
19 MR. MITSCH: 19 Q. How did the MRGO decrease water levels
20 But don't argue. 20 at the north breach and what is the proof
21 MR. BRUNO: 21 thereof?
22 All right. 22 A. The ADCIRC model showed a decrease and
23 A. What I did was I looked at all the 23 the plaintiffs' modeling showed a decrease.
24 predictions. 24 Q. All right. The ADCIRC model is the
25 EXAMINATION BY MR. BRUNO: 25 model produced by Professor Westerink, isn't
Page 520 Page 522
1 Q. Predictions of what? 1 it?
2 A. Of water level. I looked at the 2 A. True.
3 plaintiffs' reports and their estimates of what 3 Q. And didn't we just look at it and it
4 the water levels were in the Industrial Canal 4 doesn't show a decree, it shows an increase of
5 at the north breach, and I looked at the ADCIRC 5 3.5 feet.
6 results but with an eye towards understanding 6 A. Well, I thought we decided and agreed
7 that they're limited. And so but in either way 7 that the presence of the MRGO, when we remove
8 I looked at it, with whatever set of results, 8 the MRGO, we reduced the water level.
9 my conclusion was that at the site of the north 9 Q. It went up three and a half feet.
10 breach in the Industrial Canal the water level 10 Maybe we're not asking the same -- maybe we're
11 would have been greater than nine feet; 11 not on the same page here.
12 therefore, none of those cases would have 12 A. I'm not sure we are.
13 altered the occurrence of the north breach. 13 Q. Because the question is whether there
14 Q. All right. So this first sentence is 14 was an impact. It says, right here, the
15 a lie, because you say here this expert report 15 difference between H1 and H3 elevations: H3
16 examines -- 16 reports a higher level of water.
17 A. Where are you? 17 A. Okay. I don't know. I'm a little
18 Q. Back on Page 7, Line 1. This expert 18 confused by the wording, but what I do know is
19 report examines the following issues: Number 19 in the pre -- in the base case we had a deeper
20 1. The effect of the MRGO navigation channel 20 MRGO. In Case H3 --
21 and historic changes to the surrounding 21 Q. Wait. Which one? You lost me.
22 wetlands that have occurred since its 22 A. The base case. In the base case.
23 construction on the water levels. 23 Q. You have what's out there now.
24 So that is not true, you did not 24 A. We have what's out there now. In Case
25 evaluate -- 25 3, in Reach 1 we would have a smaller channel.
52 (Pages 519 to 522)

Page 523 Page 525
1 Q. No, H3 has no channel. 1 the degree to which we move H1 we also have to
2 A. In Reach 1 it does have a channel. 2 move H3, so the gap between them stays the
3 Q. I'm sorry. You're right, A smaller 3 same.
4 channel. I apologize. 4 A. I don't think it's that -- it's not
5 A. So. 5 that simple.
6 Q. So -- unless I'm reading this wrong, 6 Q. Well, tell me why one if them doesn't
7 it says that the water level goes down when you 7 move. Why is it that only the H1 changes and
8 remove the MRGO. And it goes down by three and 8 the H3 stays the same?
9 a half feet. 9 A. Um -- if you look at the ADCIRC
10 A. Okay. I understand. Okay. I think 10 results, um --
11 we're on the same page. 11 Q. Here they are. Here are the ADCIRC
12 Q. Okay. So that would seem to 12 results at Page 178 of the Westerink report.
13 suggest -- 13 A. Let me look. I have a figure in my
14 A. I think the three foot is an 14 report that I think it might help our
15 overestimate. 15 discussion here. All right. I want to talk
16 Q. Three and a half foot. How can it be 16 about using two figures, Figure 35 and Figure
17 an overestimate? You've explained the ADCIRC, 17 3. Figure 3 is on Page 14. Figure 35 is on
18 but then if you change both of them the 18 Page 43.
19 difference between the two stays the same 19 Q. All right. I would suggest you do
20 because both of them are going up and down the 20 what I'm doing, just sort of fold the page back
21 scale. 21 so you can flip back and forth and easily look
22 MR. MITSCH: 22 at both of these hydrographs.
23 Why don't you just let him 23 A. Okay.
24 explain why he thinks that difference 24 Q. Okay.
25 is. 25 A. On the right-hand side we show -- this
Page 524 Page 526
1 A. The same shortcoming in ADCIRC for the 1 is for the base case -- this is the ADCIRC
2 base case is present in the ADCIRC model for 2 result at the breach sites.
3 all the cases. 3 Q. Wait. Right-hand side, that's 35.
4 EXAMINATION BY MR. BRUNO: 4 A. 35 is the ADCIRC prediction.
5 Q. I agree with you. So that means that 5 Q. And that's after you scaled it.
6 they both go up or down a scale. 6 A. Um -- no. Didn't scale it.
7 A. No, no, no, no. 7 Q. No, you told me you scaled it.
8 Q. But the distance between them stays 8 A. Let me take a back. Let me check.
9 the same. 9 Yeah. I think it is scaled up by 4 percent. I
10 A. No, the deficiency -- maybe this is 10 believe you're correct.
11 where we're -- the deficiency is because -- is 11 Q. All right.
12 primarily because we understate the peak water 12 A. All right. So the right-hand side is
13 level in Lake Pontchartrain. So we know that 13 the scaled ADCIRC result, and the Figure 3 is
14 at the south shore of Lake Pontchartrain from 14 the observations from the IHNC lock. And they
15 measurements the water level was twelve feet. 15 should be very similar. They're not too far
16 There are many high water marks, at least, I 16 away from one another physically so they should
17 don't know, five or six that tell us that. So 17 be very similar. So one obvious difference is
18 reliably we know that the peak water level got 18 the fact that the ADCIRC hydrograph in the
19 to twelve feet. 19 Industrial Canal has two peaks. The measured
20 Q. All right. So the H1 is wrong. 20 hydrograph has one peak. And the measured
21 Westerink 's H1 is wrong. 21 hydrograph peak is about at nine o'clock.
22 A. In the Industrial Canal I believe it 22 Probably between 8:00 and 9:00.
23 is. 23 Q. Okay.
24 Q. Right. His L3 is equally wrong. Same 24 A. And at nine o'clock -- approaching
25 lake, same winds, same overestimation, so that 25 nine o'clock the storm surge on the south shore
53 (Pages 523 to 526)

Page 527 Page 529
1 of Lake Pontchartrain was approaching and at 1 not, and you're saying we're going to eliminate
2 its maximum value. 2 the dip. So we've eliminated the dip.
3 Q. Nine o'clock at IHNC. 3 A. Okay.
4 A. Right. Of about twelve feet. And so 4 Q. So how does that make the water go
5 what I'm saying is I believe this little dip 5 down? That should make the water go up. It's
6 that's being calculated by the ADCIRC model is 6 more water.
7 wrong. I don't believe it's physically 7 A. In the Industrial Canal.
8 possible to dip down that low, and it's an 8 Q. Exactly.
9 artifact, I believe, and in part due to that 9 A. We should have a higher surge for the
10 underprediction in Lake Pontchartrain. 10 base case.
11 Q. Okay. This is -- you'll remember you 11 Q. Right. And we should have a higher
12 told me that this artifact is the bump. The 12 surge for H3, because we can eliminate the dip
13 water goes and hits the Gulf Coast and comes 13 on both of them.
14 back. 14 A. True. I agree with you.
15 A. Uh-huh. 15 Q. Okay. So again, I think that sort of
16 Q. That's what you told me. 16 bolsters my point that we're moving them both
17 A. Yeah. 17 up and down this scale that you were talking
18 Q. So now you're telling me that's not 18 about. So our difference is still three and a
19 accurate? 19 half feet and so we still are left with the
20 A. No, I think it is, over on -- I think 20 conclusion that --
21 we're doing it well over on the Lake Borne, 21 A. Well, I don't -- you see, maybe that's
22 we're not doing it well in the IHNC. 22 where we're wrong. If the water level on the
23 Q. Okay. So -- all right. The 23 Industrial Canal is twelve or higher, not eight
24 hydrograph, it's the same computations, it's 24 foot, I don't think the gradient of three and a
25 the same wind, it's just that in this location 25 half foot is going to be the same. If you had
Page 528 Page 530
1 you think that dip is inappropriate. 1 a more accurate boundary condition, which the
2 A. I don't think the dip is there, 2 plaintiffs' modeling has done, they've used a
3 because the dip should be driven by what's 3 12-foot at the Lake Pontchartrain entrance, so
4 happening on the south shore of Lake 4 I think they'll have a good boundary condition
5 Pontchartrain in combination with the wind 5 on the other end, I think they have a better
6 that's blowing out of the north and creating 6 boundary condition at the entrance to Lake
7 that water surface slope in Lake Pontchartrain 7 Pontchartrain. They've avoided this dip by
8 which the wind is also going to try to create 8 forcing with the measured data.
9 in the Industrial Canal. 9 Q. And all I'm saying to you is that the
10 Q. So if you eliminate the dip, it looks 10 plaintiffs -- let's not get into a discussion
11 kind of -- very much like what we have on 14. 11 about how big a gap there is. All I'm asking
12 A. Similar. 12 is whether you agree that the MRGO increases
13 Q. There's no dip there. 13 the surge level inside the IHNC by some amount.
14 A. Similar, yes. I would agree. 14 A. I agree.
15 Q. All right. So I'm still not with you 15 Q. Okay. And that's fine. We can fight
16 yet. So so far everything is matching up. 16 over the degrees another day.
17 A. Well, you know, I don't believe the 17 Now, let's talk about waves now.
18 water level dipped down like this. 18 A. Okay.
19 Q. On the hydrograph? 19 Q. Waves are a little bit more difficult
20 A. On the hydrograph. 20 because with waves we have already established
21 Q. Yeah. But we've got real numbers 21 you guys didn't study that before so this is
22 there so we don't have to worry about that. We 22 the first time we're going to study the MRGO 's
23 know that these observed water marks are real, 23 influence on waves. Right? This is the first
24 so what you're saying make sense to me, they 24 time.
25 should be the same, and you're saying they're 25 A. First time I've looked at it, yes.
54 (Pages 527 to 530)

Page 531 Page 533
1 Q. Well, first time your whole team 1 factors in the overtopping and levee erosion
2 looked at it, in fairness. 2 processes?
3 A. Yes. 3 A. Paragraph D-2?
4 Q. Okay. And the reason why you guys are 4 MR. MITSCH:
5 looking at it is because the plaintiffs looked 5 D-4. Page D-2.
6 at it. Right? 6 EXAMINATION BY MR. BRUNO:
7 A. No, I think I looked at it because 7 Q. Page D-2. I'll start from the top.
8 it's important in deciding how those levees 8 The IPET investigation of Hurricane Katrina and
9 along Reach 2 responded and whether they would 9 response of the hurricane protection system in
10 have responded differently with or without 10 southeast Louisiana to that extreme event
11 MRGO. That's why I looked at it. 11 showed that levee system and floodwall failure
12 Q. Well, again, Bruce, you're getting 12 was dominated by overtopping. Either one,
13 ahead of me again. Remember, I'm only on Step 13 overtopping of levees and subsequent erosion of
14 1, I'm not on Step 2. 14 the levee from the protected side toward the
15 A. Okay. 15 flooded side, or overtopping of walls, scour on
16 Q. All I'm saying -- just stick with me 16 the protected side of the wall and subsequent
17 on Step 1. We are now asking the question did 17 failure of the wall. To a lesser degree,
18 anybody evaluate MRGO's potential impact on 18 failure was caused by scour at transitions
19 waves, and the answer is, well, the nobody 19 between levees and hard structures, levees and
20 really looked at that until this report. And 20 response and wave and water condition
21 the fact is you don't look at it, IPET didn't 21 throughout system were far from uniform.
22 look at it, Resio didn't look at it. Right? 22 Okay? And that's consistent with
23 Until now. Until this expert exercise. 23 everything you've told us today, right?
24 A. Until this work. Until this body of 24 A. Uh-huh.
25 work, yes. 25 Q. All right. The IPET had reached the
Page 532 Page 534
1 Q. All right. And that fact is supported 1 conclusion that the predominant failure mode
2 by this document which I will mark as Exhibit 2 was overtopping. Right?
3 the next, 12. Shall we turn to Appendix D. 3 A. Pardon me? Would you restate the
4 I'll try to get it for you. Appendix D. 4 question?
5 (Tendering.) 5 Q. I said, the IPET determined that the
6 (Exhibit 12 was marked for 6 primary failure mode was overtopping.
7 identification and is attached hereto.) 7 A. For which area? Which part of the
8 MR. MITSCH: 8 system?
9 Is there a page number? 9 Q. As indicated in this sentence.
10 MR. BRUNO: 10 A. Could you restate the question,
11 Let me help you, too, Rupert. 11 please?
12 MR. MITSCH: 12 Q. Well, read it and tell me if you a
13 Is it after the templates? 13 agree with it.
14 MR. BRUNO: 14 A. The first sentence?
15 Yes. 15 Q. The first sentence. Do you agree with
16 MR. MITSCH: 16 it or not?
17 Okay. 17 A. I generally agree with it.
18 EXAMINATION BY MR. BRUNO: 18 Q. All right. Now, it says it was not
19 Q. D-2, Bruce. Top paragraph? 19 possible within the time frame of the IPET
20 A. Okay. 20 investigation to fully evaluate the relative
21 Q. D- 4 in particular. 21 roles of the following factors in the
22 A. Okay. 22 overtopping and levee erosion process,
23 Q. It says it was not possible within the 23 spatially varying waves and still water levels,
24 time frame of the IPET investigation to fully 24 overtopping duration, levee soil variability,
25 evaluate the relative roles of the following 25 vegetation cover, construction method and
55 (Pages 531 to 534)

Page 535 Page 537
1 protected side inundation. 1 Q. Well, that's Step 2 again. All we are
2 Is that a true statement? 2 is Step 1. All we want to know is influence of
3 A. Well, the intent of this statement was 3 MRGO on waves.
4 to distinguish and separate out the relative 4 A. I consider waves and hydrodynamic
5 roles of all these different factors. You 5 parameters that are influenced and dictated by
6 know, it's a very complicated process. That's 6 the waves.
7 what's meant by this sentence. And in the time 7 Q. Fine. But you have to first determine
8 frame -- 8 whether or not MRGO is having any impact on the
9 Q. You agree with it. 9 waves. That's number 1.
10 A. -- it was not possible to distinguish 10 A. True.
11 among all those factors. 11 Q. So what I'm trying to figure out is,
12 Q. Right. So it didn't say that. It 12 what are the components of the wave, or the
13 says to fully evaluate the relative roles. So 13 characteristics of the wave that might have
14 they want -- 14 been influenced by the MRGO?
15 A. I would agree with that sentence. 15 A. The whole two-dimensional energy
16 Q. Yeah. In order for you to determine 16 spectrum --
17 what the role was you have to evaluate, and 17 Q. Amplitude and the period?
18 then you can -- once you decide whether it's a 18 A. -- significant wave height, measure of
19 component, then you can determine its relative 19 period, direction?
20 contribution, right? 20 Q. Sorry. Significant wave height,
21 A. Is that a question? 21 period, direction?
22 Q. Isn't that true? 22 A. Direction --
23 A. Could you repeat the question? 23 Q. MRGO could influence direction, and it
24 Q. In order for you to determine whether 24 can influence -- I'm sorry.
25 or not something has a relative role, you have 25 A. Period, significant height, direction,
Page 536 Page 538
1 to determine first that it has a role. Right? 1 directional wave spectrum.
2 A. True. 2 Q. Wave spectrum. Okay. Anything else?
3 Q. Okay. All right. So what we have is, 3 A. Plus the other wave-related
4 at the time that you were asked to do this 4 parameters; velocities, overtopping rates.
5 work, nobody has evaluated whether or not MRGO 5 Q. Okay. Or discharge?
6 influenced the waves. And in your report you 6 A. What do you mean by discharge?
7 say that this report evaluates whether the MRGO 7 Q. The amount of water flowing over the
8 and historic changes have affected wave 8 levee.
9 conditions. Right? That's what you say? 9 A. Overtopping rate or discharge rate, if
10 A. Yes. 10 you want to call it that.
11 Q. All right. Now, so my first question 11 Q. Okay. Discharge rate, okay,
12 is, what wave conditions did you study? 12 overtopping.
13 A. I looked at the along the levee 13 A. We use the same term.
14 variation in wave conditions, coming from the 14 Q. Okay. All right. Now, so I guess
15 STWAVE model, how they would have varied along 15 then that much like the surge evaluation, you
16 the reach of levee for the various cases that I 16 set up a model to evaluate the waves generated
17 examined. Um -- I also looked at wave-induced 17 in the H1 scenario, and then you compared that
18 velocities on the crest and backside of the 18 to the waves generated in the H3 scenario to
19 levee. And those are related to waves that 19 see what the differences were. Right?
20 came from the COULWAVE modeling. 20 A. Yeah. I relied on Dr. Resio and
21 Q. Okay. 21 Dr. Smith to do the modeling, and they provided
22 A. And I've also looked at the 22 me with the wave information for each of the
23 contributions of waves to overtopping and how 23 cases that they simulated with the model.
24 they vary along the levee and as a function of 24 Q. All right. So once again you did not
25 levee crest elevation. 25 do the modeling.
56 (Pages 535 to 538)

Page 539 Page 541
1 A. No, I used their output in my 1 A. And we're sure they are for our base
2 analysis. 2 case?
3 Q. All right. Well, did you have some 3 Q. They're ADCIRC elevations.
4 understanding of what Resio did for his no MRGO 4 A. I mean I'm showing the base case. Are
5 model? 5 you sure you're showing me the base case?
6 A. I would probably defer to him on the 6 Q. Yes. It says, for Hurricane Katrina.
7 details of his modeling, he and Dr. Smith on 7 A. Okay. So we're looking at 7 UTC?
8 the details of their modeling those cases. 8 0700?
9 Q. Okay. All right. Well, let's see if 9 Q. Yeah.
10 we can learn what your contribution was then to 10 MR. MITSCH:
11 this effort. 11 This one is showing more. This
12 A. Okay. 12 is a much larger area.
13 Q. I think we covered that yesterday. 13 A. Yeah. It's a little different area
14 You did this -- you did -- first thing you did 14 that we're looking at. Is there a particular
15 was you pulled an ADCIRC, um -- hydrograph. 15 place you want me to look?
16 YOU got a hydrograph from Westerink, right? 16 EXAMINATION BY MR. BRUNO:
17 A. Yes. 17 Q. Yeah. Along Reach 2. The fact is
18 Q. Let's start with that. Okay. So you 18 that the Westerink contours show winds that are
19 got some ADCIRC elevations from Westerink and 19 different -- I'm sorry, not winds but
20 you reproduced those as Page 18 of your report. 20 elevations that are different than you show.
21 A. What I got from Joannes was time 21 And I just was wondering if --
22 series. That was really the primary -- water 22 A. Are they? I mean, the color scales
23 level time series. I had one of my staff pull 23 are different.
24 back some of these snapshots just to sort of 24 Q. Well, you can check it if you look
25 illustrate the kind of large scale -- the 25 at --
Page 540 Page 542
1 temporal evolution of the surge and wind fields 1 A. As I said yesterday, I always get a
2 during time. So I didn't get these directly 2 little leery trying to get too quantitative
3 from Westerink. I had one of my staff go to 3 with this type of graphic.
4 the files where they were and pull them back 4 Q. Well, these seem to be a lot off.
5 and generale some graphics. 5 A. You know, I don't know. I get fooled
6 Q. So you generated -- 6 all the time looking at color scales. And I
7 A. I had one of my staff -- one of my 7 mean, I think I said yesterday that I don't --
8 folks that work in my division did that for me. 8 I would rather work off of time series if I can
9 Q. Okay. All right. So -- well, because 9 work off of time series.
10 when I compared what you have in Figure 5, 10 MR. MITSCH:
11 which is a storm surge snapshot at 2:00 o'clock 11 If you look, 15 is in yellow
12 in the morning -- 12 here, and on this scale it seems to
13 A. Okay. 13 be -- you know, a much different
14 Q. -- and I compare it to Westerink at 14 number is in the yellow.
15 seven o'clock UTC which is two o'clock in the 15 A. Yes. 18 to 19.
16 morning -- 16 MR. BRUNO:
17 A. Okay. 17 Yeah. That's interesting because
18 Q. Maybe you can tell me, but to me 18 they both are supposed to be from
19 they're different. 19 Westerink. So I'd like to have that
20 A. Okay. 20 explanation.
21 Q. And once again, I don't want you to 21 A. I can give that to you. We use a
22 hold me to my word, but here is your report, 22 plotting software, and the plotting software
23 18, 18, this matches up, a little sharper color 23 allows us to do different things in our display
24 maybe. 155 comes from this report. Got it 24 of what might be the same data. And the
25 right here. Okay? 25 scales -- I mean, it's clearly whoever
57 (Pages 539 to 542)

Page 543 Page 545
1 generated these plots and whoever generated 1 time on your report? Pick a time. Is it 7:00?
2 these plots used a different color scale. 2 A. I'm looking at a picture here for 12
3 Q. Okay. 3 Z, 7:00 a.m. Central Daylight Time.
4 A. So it makes it hard for me to do a 4 Q. Okay. All right. And that's on what
5 direct comparison. 5 page?
6 Q. Let see if we can just try just for 6 A. Of my report, 21.
7 the hell of it. Okay? 7 Q. Okay. Now, what is the water level at
8 A. Okay. 8 the MRGO reach on your storm surge snapshot?
9 Q. Let me see what we've got here. Since 9 A. Well, let me give you some -- my
10 you don't want to do it. If we go -- let's see 10 graphics aren't very good. I got a ton of
11 how this works. 11 shades of green that are hard for me to
12 MR. MITSCH: 12 differentiate, and I don't have surges --
13 What page are we on again? 13 contours labeled. And so as I wrote my
14 MR. BRUNO: 14 description in this report I was referring back
15 155 and 18. 15 to my time series data to get actual values
16 MR. MITSCH: 16 that I used in my text.
17 It's 155 of Westerink. 17 Q. Okay.
18 EXAMINATION BY MR. BRUNO: 18 A. I cannot reliably pull a value off of
19 Q. All right. Let's look at these and 19 my Figure 8. And I didn't do that as I wrote
20 just see -- at Page 156 of Westerink, it says 20 my report because I couldn't tell from those
21 12:00 o'clock UTC, which is seven o'clock CDT, 21 graphics.
22 and that would correspond with your Figure 8 on 22 These graphics were meant to
23 Page 21, right? 23 illustrate regional patterns of storm surge and
24 A. Okay. 24 wind felids and how they evolved during the
25 Q. Yes or no? 25 storm. They were not intended for -- to begin
Page 544 Page 546
1 MR. MITSCH: 1 to try to pull values off of. And as I said
2 Well, he can't see. You haven't 2 yesterday, if we're going to try to pull values
3 shown him. 3 at specific times, we should -- I used the time
4 A. I can't see your picture. 4 series, and I can do that more reliably and
5 EXAMINATION BY MR. BRUNO: 5 precisely.
6 Q. I'm asking you to look at your own. 6 Q. That's fine. You can't do it, and
7 A. Well, the question -- 7 perhaps someone else can. How about this?
8 Q. Wait, wait. Hold the phone. You 8 Let's compare the contours. Shouldn't the
9 didn't get the question. 9 contours at least be the same width, the bands
10 MR. MITSCH: 10 should be the same?
11 I didn't get it either. 11 A. You would like to think so. I found
12 EXAMINATION BY MR. BRUNO: 12 in my experiences with our graphical software
13 Q. A 12:00 o'clock UTC -- 13 that sometimes it doesn't always match up
14 MR. BRUNO: 14 exactly right.
15 Pay attention. You'll get it 15 Q. Okay. All right.
16 this time. 16 MR. MITSCH:
17 EXAMINATION BY MR. BRUNO: 17 Which Westerink page are you
18 Q. -- is what time Central Standard Time? 18 looking at?
19 MR. MITSCH: 19 MR. BRUNO:
20 That wasn't the question. 20 158, Figure 118.
22 Yes, it was. 22 Q. All right. How do we know that you
23 EXAMINATION BY MR. BRUNO: 23 and Westerink used the same ADCIRC outputs?
24 Q. I'm asking if the times are right. So 24 MR. MITSCH:
25 should I compare twelve o'clock UTC to what 25 Are you sure?
58 (Pages 543 to 546)

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1 MR. LEVINE: 1 contours, it's going to look different because
2 That's 156. 2 you've got a different geography, even though
3 MR. BRUNO: 3 it's the same ADCIRC outputs.
4 What did I say? 4 A. Yeah. Like I said, contouring
5 MR. LEVINE: 5 software, in my experience, kind of does
6 158. 6 some -- ours does some flaky things sometimes.
7 A. I said 156. Figure 118. 7 Q. That's fine, Bruce. Here's the
8 (Off the record.) 8 question: Did you use the same ADCIRC data
9 EXAMINATION BY MR. BRUNO: 9 that you got from Westerink to generate the
10 Q. Well, just tell me if I'm wrong, but 10 color charts that appear in your report at
11 the contours seem to be different. Maybe I'm 11 Pages 21 and 22 and 23, et cetera? Is the
12 wrong. 118 compared to your Figure 8, 12 ADCIRC data the same?
13 particularly as you move out into the lake. 13 A. Well, the intent was to be the same,
14 Here we are, over here to there. 14 as I said. The time series data that I used in
15 A. I don't know. Look how many shades of 15 my analysis, Joannes or John Atkinson who works
16 green there are. I can't distinguish -- I 16 for Joannes provided the time series data.
17 mean, that's a much nicer color scale. 17 These graphics, I asked my employee to go pull
18 Q. All I'm saying is -- 18 from a server the files and generate the
19 A. It's regrettable that these aren't in 19 graphics. So the intent would have been for
20 the same color scheme. 20 them to be the same. I can't tell you that in
21 Q. I switched. You told me you couldn't 21 fact they are.
22 look at the colors, so I asked you now to look 22 Q. Okay. All right.
23 at contours. The contours -- 23 A. These graphics were just meant for
24 A. That's what I'm referring to. 24 illustrative purposes. The data that I use in
25 Q. The lines, they're black. The contour 25 my analysis are the time series data that I got
Page 548 Page 550
1 lines are black. 1 from Joannes from his modeling.
2 A. I can't tell you which is which on my 2 Q. Okay. All right. Now, so you didn't
3 graphic. 3 rely on pictograms, if you will, to assess the
4 Q. You can't see which contour lines -- 4 differences in the waves, you would have looked
5 A. They're not labeled. These are 5 at --
6 labeled. 6 A. I would have used the time series
7 Q. I'm just talking about the shapes. 7 data.
8 A. I cannot see them. 8 Q. All right. Did you note any
9 Q. The shapes are different. You can't 9 difference between significant wave height as
10 see the lines? Those black squiggly lines that 10 between a wave model utilizing, let's call it,
11 are contours? 11 H1 versus the wave model utilizing H3?
12 A. Well, I see one in here that looks a 12 A. Yeah. I have a graphic in the back
13 lot like this one. 13 here where I did comparisons of the --
14 Q. Is it the same? 14 Q. Where is that?
15 A. Not precisely. But as I said, 15 A. Along Reach 2, variations in
16 sometimes our graphics contouring software may 16 significant height.
17 not give you the exact same thing. I mean, I'm 17 Q. Is that Page 144?
18 looking for general patterns. 18 A. Yes. Figure 97, Page 144.
19 Q. Okay. 19 Q. Okay. All right. And so base case is
20 A. And keep in mind, this is a 20 the black line, right?
21 different -- the area that's covered in this 21 A. Yes.
22 graphic is different from the area covered in 22 Q. And Case 2 is the red line with the
23 my graphic. 23 squares?
24 Q. That's fine. So the way your software 24 A. Yes.
25 works is that it's going to produce different 25 Q. And let's see, H2 is no MRGO but with
59 (Pages 547 to 550)

Page 551 Page 553
1 a degraded marsh, et cetera. Or I should say 1 A. You pointed out a line --
2 Katrina-like topography/bathymetry, but no 2 Q. No, I pointed out one location, and I
3 MRGO. 3 want to ask you about that one location.
4 A. Yes. It was sort of the present day 4 A. You said look at such a long length.
5 wetlands with just -- 5 Q. No. Yeah, the long length between 10
6 Q. With Mr. MRGO? 6 and 16. Then you decided to jump somewhere
7 A. Let me make sure. H2 you're asking 7 else because it suits your purpose. And I get
8 about? 8 that. I understand you're advocating your
9 Q. Yeah. 9 position. But how about this? I'm asking you
10 A. It assumes the MRGO channel did not 10 specifically about between 10 and 16. That's
11 exist and wetlands were in their 2005 11 where I am. And I'm just looking at -- these
12 condition. 12 are your results that you are relying on, and
13 Q. Right. 13 I'm looking at something that tells me that the
14 A. Okay. 14 wave heights are higher. All of the topography
15 Q. What we see according to this chart is 15 ask the same. You remove MRGO and the waves
16 that from about Point 9 all the way to Point 16 16 are higher.
17 the maximum wave height with no MRGO is higher 17 Now, here's what's really confusing:
18 than the wave height during Katrina. 18 Then you go to the base case which is no MRGO
19 A. Okay. 19 with -- which can't -- by the way, can it make
20 Q. Right? 20 any sense at all that the waves are higher with
21 A. That's what it shows. 21 no MRGO?
22 Q. That's what it shows. That's a long 22 A. Yeah. You know, MRGO is -- has a very
23 length. 23 irregular shoreline.
24 A. Yeah. But that's not much of a change 24 Q. There's no shoreline. It's gone.
25 in wave heights. It's small. 25 A. Oh, okay. We're replacing this case
Page 552 Page 554
1 Q. It's a foot. 1 with topography.
2 A. You know, on average half a foot, not 2 Q. Right. So that means that the waves
3 quite half a foot. 3 are -- even -- essentially, and maybe I'm wrong
4 Q. How about we look at 12? 4 here, you told me today that if the water depth
5 A. How about we look at 11 and 12 and 13 5 is deeper the wave is higher. So one presumes
6 and 14 and 15 and 16? And let's look at 10. 6 that if the water depth is shallower the wave
7 Zero difference. Let's look at 11. Oh, three 7 is smaller. And what you're showing me here is
8 or four tenths? 8 that the waves are higher after you took out
9 Q. All right. 9 the MRGO. How can that physically be?
10 A. Let's look at 12. 10 A. Okay. Let me try to explain.
11 Q. That's fine. 11 Q. Okay.
12 A. Less than a foot. 12 A. You know, this is a highly irregular
13 Q. Sure. Bruce, but-- 13 area. This is not -- there's irregular
14 A. Let's look at 13. Two tenths. 14 topography in the wetlands, there's irregular
15 Q. Could anybody reasonably conclude -- 15 water depth in Lake Borne, um -- there are
16 (Off the record.) 16 irregular depths in the MRGO. And so when we
17 EXAMINATION BY MR. BRUNO: 17 eliminate those we make some -- we make
18 Q. You weren't answering the question, 18 different changes to the topography. All along
19 Bruce. 19 the MRGO when we pull it out, we're making
20 A. Yeah. You were looking at the 20 different changes.
21 differences. 21 Q. Makes no sense, Bruce.
22 Q. No. I wasn't, Bruce. I was looking 22 A. Well, sure it does.
23 at a difference in one point, and you jumped 23 Q. Tell me how it -- tell me how --
24 all over the map again because it suits your 24 listen, we agree, do we not, that for one
25 point. 25 quarter of the length, one full quarter of the
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Page 555 Page 557
1 length of this whole reach, the waves are 1 Case 3 --
2 higher when there's no MRGO than there was 2 A. Okay.
3 before. So that means you've filled in the 3 Q. -- which also has no MRGO, but it's
4 MRGO and effectively you've reduced the water 4 got the -- it's got the '58 topography.
5 depth at that location. 5 A. Okay.
6 A. But would you agree with me that by 6 Q. Right? And one would assume, wouldn't
7 filling in the MRGO we've altered the 7 we, that the MRGO topography would have been
8 topography in different ways along the MRGO? 8 higher, more lush, and would have provided more
9 We've made different changes. The base case 9 opportunities to reduce waves than would the H2
10 reflects one set of topography along the MRGO. 10 case? I'm just comparing H2 to H3.
11 And Case H2 reflects a different topography and 11 A. Yeah. You know, the difference
12 we've altered them not all in the same way, 12 between H2 and H3 is really some different
13 we've made different alterations all along MRGO 13 wetland characteristics.
14 to the topography. We've transformation is 14 Q. Right. We're raising up the wetland.
15 very much dependent on topography. So if we're 15 We're adding more friction. We're adding
16 changing the topography from one base case to 16 trees, we're adding bush and brush?
17 another, there's a good chance we're altering 17 A. So we're changing topography, we're
18 the wave refraction and the wave shoaling and 18 maybe changing frictional resistance. Changes
19 that whole transformation of the waves. So I 19 to topography influence wave refraction and
20 guess I'm not so surprised by the fact that 20 shoaling.
21 maybe we have some modulation relative to the 21 Q. Right.
22 base case, some higher, some lower. That 22 A. Changes to the vegetation are changing
23 doesn't surprise me whatever. 23 the wave dissipation rate.
24 Q. All I'm telling you is -- here's the 24 Q. So it should reduce the waves.
25 question: The question is not the Step 2 25 A. Not necessarily. This is a very
Page 556 Page 558
1 question, the question is your Step 1 question. 1 complicated wave propagation situation. When
2 What this establishes beyond question is that 2 you have waves propagating over irregular
3 the MRGO affects waves. Doesn't it? 3 topography, and I raise or lower the
4 A. It has some small effect, from these 4 topography, the waves are probably going to get
5 results. 5 higher in someplace and maybe lower in another
6 Q. You would regard almost two feet a 6 place. It's not -- we're not changing things
7 small effect? 7 uniformly across the entire Reach 2 levee.
8 A. Yeah. You know, as we get into the 8 We're changing things in irregular ways.
9 analysis, if you really look at the effect of a 9 Q. All right. So you didn't look at wave
10 two-foot wave on overtopping rates, it's quite 10 period, or did you, between those different
11 small. Water level's what's driving the 11 scenarios?
12 overtopping rates. 12 A. No. And wave height's really the
13 Q. How about wave energy? 13 predominant thing in overtopping, the periods
14 A. I assume, wave energy would be related 14 don't really change from case the case. It
15 to the square of the wave height. 15 really is quite small changes in period. It's
16 Q. Sure it would. Did you evacuate wave 16 more important to look at wave height changes.
17 energy? 17 But having said that, if you look later in my
18 A. No. I evacuate overtopping because 18 report you'll see that even a two-foot change
19 that's how I assessed the influence on 19 in wave height has -- you know, it has a change
20 overtopping and on levee degradation. 20 in the overtopping rate but the change is not
21 Q. You didn't evaluate relative wave 21 small enough -- or the change is small enough
22 energies, did you? 22 that it really wouldn't have changed the
23 A. No, I compared wave height. Which is 23 outcome in terms of levee degradation.
24 related to energy. 24 Q. It might change the outcome with
25 Q. All right. Fine. Now, we also have a 25 regard to wave energy with regard to its attack
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Page 559 Page 561
1 took on the front side, though, couldn't it? 1 Q. You didn't evaluate the energy. I
2 A. I don't believe front side erosion was 2 know it's related, but you didn't evaluate
3 a factor. 3 energy.
4 Q. Right. And that's because you looked 4 A. No.
5 at a bunch of photographs and determined that 5 Q. No. You didn't do that. And the only
6 there was no evidence of it, and you discarded 6 thing you really did is that you looked at
7 it that way. 7 photographs in order to assess whether or not
8 A. I did some calculations, also. Some 8 those photographs indicated to you evidence of
9 analysis. 9 front side wave attack isn't that true?
10 Q. You did the calculations which were 10 A. That's not correct.
11 for grass, and then you looked at some 11 MR. MITSCH:
12 photographs. 12 Asked and answered.
13 A. I did calculations for -- 13 A. That's not correct. That's one aspect
14 Q. For grass. 14 of what I did.
15 A. -- for a grass covered clay levee. 15 EXAMINATION BY MR. BRUNO:
16 Q. Okay. 16 Q. One aspect. Okay. All right. Now,
17 A. I looked at velocity regimes on the 17 how did you rule out front wave attack?
18 front versus back sides, I looked at 18 A. Well, based primarily on my
19 overtopping rates on the front and back sides. 19 understanding of what the velocity regime on
20 Q. Well, that has to do with the back 20 the front side is versus --
21 side. We're talking about the front side. 21 Q. What's the velocity regime on the
22 This is before it gets over the top. 22 front side where do we get that?
23 A. Yeah. Plus I used -- 23 A. I just know from my expertise.
24 Q. Why do we have to keep going to the 24 Q. You just know?
25 other scenarios. I mean, a good forensic 25 A. Yeah. I know what kind of velocities
Page 560 Page 562
1 engineer, a good forensic scientist is going to 1 we get under these kind of wave conditions. So
2 look at one cause and evaluate that cause -- 2 the peak orbital velocities that we're going to
3 A. I've looked at both. 3 get under the kind of waves that are impacting
4 Q. -- isn't he? 4 the front side of a Reach 2 levee, the maximum
5 Well, did you look at underseepage? 5 orbital velocities are probably four, five, six
6 A. No. 6 foot per second. And they happen for a very
7 Q. Didn't even look at that. 7 short time. The mean velocities on the front
8 A. No. That's out of my -- 8 side are probably near zero. Because they
9 MR. MITSCH: 9 oscillate back and forth.
10 On Reach 2? 10 Q. Where is that?
11 MR. BRUNO: 11 A. I did comment -- I referred back to
12 Yeah. 12 some of IPET work on front side velocities.
13 A. It's out of my technical area. 13 Q. Did you put that -- is that in your
14 EXAMINATION BY MR. BRUNO: 14 report? Did I miss it?
15 Q. So in order to do a good evaluation of 15 A. I describe it somewhere. Let me look.
16 front side attack you need to focus on front 16 So I'm around Page 50, 51 is where I'm talking
17 side attack, right? 17 about velocities.
18 A. I think I analyzed it in a way that 18 Q. 51. Levee response. This says --
19 led me to believe it's not that important a 19 A. All right. Bottom of Page 49. That's
20 factor in levee degradation. 20 where I'm really referring to the IPET.
21 Q. So what you did, you didn't do any 21 Q. Well, let's see. Because 52 says data
22 analysis of the energy of the waves at all, 22 sources and it talks about your visual. So --
23 right? 23 A. No. Let's.
24 A. Well, wave height is related to 24 Q. -- 52 is all about the visuals, for
25 energy. 25 the record, right? And then 49, it says
62 (Pages 559 to 562)

Page 563 Page 565
1 results from high resolution modeling of 1 No -- what he chose to do. He
2 velocities at the Reach 2 levee. 2 can state what Dr. Resio gave him.
3 A. Right. Here's where I'm addressing 3 MR. BRUNO:
4 the issue of velocities, front side versus 4 One would assume that you if he
5 backside. In IPET they found the peak 5 didn't give them to him he chose not
6 velocities were on the order of 3 to 5-foot per 6 to, unless it was by error.
7 second. You know, I think the waves are a 7 EXAMINATION BY MR. BRUNO:
8 little bit higher here. So the peak orbital 8 Q. But the fact of the matter is you
9 velocities are going to be, you know, 4, 5, 6, 9 don't have from Dr. Resio the results of his
10 maybe 7-foot per second. But I guess the key 10 COULWAVE outputs that relate to the front side
11 point is they last for such a short duration. 11 of the levee. Isn't that true?
12 They only last with the passage of the wave 12 A. I don't have them and I don't believe
13 crest. And if you look at -- if you really 13 he calculated them.
14 look at the velocity regime on the front side 14 Q. All right. So now we know why he
15 versus the backside, it's clear that the 15 didn't give them to you, because he didn't
16 backside velocities, whether you're talking 16 calculate them. Why didn't he calculate them,
17 about a mean or the kind of time varying 17 if you know?
18 velocities, velocities on backside dominate 18 A. I don't know.
19 over velocities on the front side. 19 Q. Did the IPET calculate them?
20 Q. So show me the front side velocities. 20 A. I believe they did.
21 Where are they? I don't see them. 21 Q. All right. Is there somewhere where
22 A. They're described in the text. I 22 we can look at those calculations?
23 don't have a figure. 23 MR. MITSCH:
24 Q. Because Resio didn't give it to us 24 He just told you. Bottom of 49.
25 either. So COULWAVE -- he ran COULWAVE in 25 MR. BRUNO:
Page 564 Page 566
1 order to determine what those front side 1 It's not in the paper, Rupert.
2 velocities were; correct? 2 You're not paying attention.
3 A. All right. He gave me crest and 3 EXAMINATION BY MR. BRUNO:
4 backside. 4 Q. I want to see the results. I want to
5 Q. Well, why didn't he give you front 5 see the whole chart. I want to see all the
6 side? 6 analyses. I'm entitled to that. Where are
7 A. Because we didn't expect them to 7 they and when can I see them? Okay?
8 change very much. We sort of know what they 8 A. It's in the IPET report.
9 are. 9 Q. All right. I'm with you on that,
10 Q. Well, I mean you're a scientist. You 10 Bruce, just tell me where to go look. Where
11 weren't curious to know what his results were 11 are they? And while we're at it, where in the
12 to see if they were at least corroborated by 12 writing here are you referring to the front
13 what you thought? 13 side, Page 49?
14 A. He didn't give me those information. 14 A. The bottom paragraph.
15 Q. All right. So for the record, for 15 Q. Which one?
16 good, bad or ugly, Mr. Resio chose not to give 16 A. On Page 49.
17 you the results of his COULWAVE analysis with 17 MR. MITSCH:
18 regard to front side of the levee. 18 There is one bottom paragraph.
19 MR. MITSCH: 19 A. Well, there's two paragraphs under C.
20 Wait a minute. Wait a minute. 20 MR. MITSCH:
21 He can't talk about what Dr. Resio -- 21 The bottom one.
22 MR. BRUNO: 22 A. The bottommost paragraph.
23 Gave him? Are you out of your 23 EXAMINATION BY MR. BRUNO:
24 mind? 24 Q. Okay. And it says -- all right. So
25 MR. MITSCH: 25 okay. I'm looking at the paragraph. It says,
63 (Pages 563 to 566)

Page 567 Page 569
1 um -- mean velocities on the front side were 1 know, remember the example I gave you with the
2 never zero? 2 front orbital velocity one way one time, one
3 A. True. 3 way the other time? The mean is the time
4 Q. Mean velocities on the front side 4 average.
5 were -- so that little phrase there, that's the 5 Q. Right.
6 only phrase that refers to the front side, or 6 A. So then the over curves are the mean
7 is there more? 7 maximum uprush and downrush. This would be for
8 A. I don't know. You're asking me to do 8 a point -- if I recall correctly, they picked a
9 two things at once. You're asking me to find 9 point about midway up the levee. And so the
10 stuff -- 10 uprush speed would be whenever you had a peak
11 Q. I sorry. I would like to see it but I 11 velocity directed onshore, with each wave --
12 need to understand the reference first. 12 right?
13 A. What would like me to do first? 13 Q. Uh-huh.
14 Q. Let's go the Page 49 first and get 14 A. There's a brief period of time as each
15 that out of the way so we can -- it says IPET 15 wave goes up, passes, you know, up the slope,
16 showed that prior to the mean water surface 16 where the velocity is directed shoreward. If
17 exceeding the levee crest height at a positive 17 we took -- and it has a maximum speed, but just
18 freeboard of one to two feet, mean velocities 18 for a very brief instant of time. What they
19 on the front side were near zero. And average 19 did was they looked at all the waves that were
20 peak velocities associated with passage of 20 passing up the crest, and they took each
21 individual waves both up rushing and down 21 maximum associated with each wave and did an
22 rushing were 3 to 5-foot per second. Is that 22 average of those, and that's what the mean
23 on the front side? 23 maximum uprush speed would be.
24 A. Yes. 24 Q. Right.
25 Q. Okay. Peak velocities only occurred 25 A. And then I told you, you know, there's
Page 568 Page 570
1 for short periods of time during the passage of 1 always a point during the wave when the
2 each wave. A fraction of each wave period 2 velocity is directed back offshore. And they
3 notably results showed that whenever 3 did the same thing, they took the maximum of
4 overtopping occurred due to wave action alone 4 that value for each wave and did an average,
5 the mean velocities on the crest and backside 5 and that would be the mean maximum downrush
6 were of a greater magnitude than those on the 6 speed.
7 front side. 7 Q. All right. They did that for a 12 to
8 Okay. So we'd like to know where we 8 15-second wave.
9 can find these mean velocities on the front 9 A. Yes.
10 side. That's what we'd like to see. 10 Q. Am I right?
11 A. Okay. Go to the IPET, Volume 4, 11 A. They did it for the waves at that
12 Page 237, Figure 169. 12 time.
13 Q. Okay. All right. May I? I don't 13 Q. Right. So --
14 have copy of that one. 14 A. Well, it was a spectrum of waves.
15 A. And I'll just explain what's here. 15 Q. I understand.
16 Q. Sure. Let may just look over your 16 A. The peak period was higher than what
17 shoulder. 17 we --
18 A. Okay. We have -- this would be a time 18 Q. Yeah. In fairness, they didn't do the
19 axis in UTC. We have several curves here at 19 six the seven waves that we're now realizing
20 four different locations, Location 1, 2, 3, 4. 20 was the Katrina case.
21 And there's a map over here. Let me see where 21 A. Yeah. There's some differences in
22 those are; 1, 2, 3, 4. 22 period. These heights were a little bit lower
23 Q. Uh-huh. 23 than what we think --
24 A. And this red plot, that would be the 24 Q. And the period is much low longer, so
25 mean velocity, the time averaged velocity. You 25 they're not quite as powerful.
64 (Pages 567 to 570)

Page 571 Page 573
1 A. That's so that's why I say, you know, 1 that this new wave, or this new belief about
2 IPET looked at the mean maximum uprush and 2 the wave, and --
3 downrush, they said 3 to 5. I'm saying for the 3 A. I'd have to -- I'm not sure you've
4 conditions that are out there I'm thinking 4, 4 charactered the effective period on velocity
5 5, 6 for the -- just the means. The mean 5 correctly. I'd have to go check that. I know
6 uprush and mean downrush. The time varying 6 it's proportional to height. I can't recall
7 regimen is still going to be about zero. It's 7 exactly the relationship between orbital
8 not -- 8 velocity and wave period.
9 Q. Well, but what role does the period 9 Q. All I'm suggesting is that IPET said
10 play? In other words, if you have this wave -- 10 12 to -- let's get it out again. I don't want
11 let's compare waves. We've got the same wave, 11 the misquote it. IPET said 12 to - I'm wrong.
12 one's got a 12 to 15 second period, the other 12 IPET said 15 to 16 seconds.
13 one has got a 4 to 5 second period. Which one 13 A. Peak period. Is that what they said?
14 is going to have more energy? 14 Q. Let's see if they say peak. No, it
15 A. I'd have to go back and look at the 15 doesn't say peak.
16 wave theory to make an estimate of that. 16 A. That's the parameter of period we were
17 Q. Well, is it fair to draw conclusions 17 using in the IPET. Peak period. We've used
18 from those results when we now know that the 18 mean period, which mean period is going to be
19 wave period is dramatically different? It's 19 less than the peak period.
20 literally half of what IPET thought the wave 20 Q. Okay. And then it says the designed
21 period was. 21 assumed wind waves with periods of 5 to 6. So,
22 A. Well, from my own experience, for 22 you know what I'm asking you, Bruce. I'm just
23 these heights and periods, I expect our orbital 23 trying to -- in fairness, you got two different
24 velocities will be in the 4, 5, 6 foot per 24 waves. Can we use the IPET results regarding
25 second, the maximum mean uprush and downrush. 25 average peak velocities, knowing that they did
Page 572 Page 574
1 Q. I respect that, but that's not what 1 those tests with a far different wave, to draw
2 I'm asking. I'm asking you about IPET. I'll 2 conclusions about the wave that your STWAVE
3 let you expound about your experience, but you 3 modeling suggests was the true picture of the
4 made the suggestion to me on this record that 4 wave environment at Reach 2?
5 IPET had done this and therefore there was no 5 A. I can.
6 need to do it again, et cetera, et cetera. So 6 Q. Okay. And are they the same?
7 I've got to explore the IPET business first. 7 A. I believe the velocities will be
8 A. I don't recall what I said along those 8 slightly higher for those other waves. But I
9 lines. 9 also know that what really matters at the end
10 Q. Well, okay. 10 of the day is the fact of -- let just assume,
11 A. I don't know what you're talking 11 and I said they would be in my opinion four,
12 about. 12 five, six, maybe seven foot per second, if
13 Q. You said IPET did this. In fact, in 13 that's the average, versus 3 to 5. Even if
14 your report you said, Page 49, IPET showed. 14 that's the case, even if those mean uprush and
15 A. Right. 15 downrush velocities are slightly higher, the
16 Q. Okay. So I'm trying to understand 16 mean will still be about zero, and those, you
17 whether or not we can truly rest -- we can 17 know, somewhat higher velocities are still
18 truly put the matter to bed based upon the IPET 18 going to only occur for very short periods of
19 evaluation when we know that IPET was using the 19 time at each wave period. That doesn't change
20 wrong wave, they were using a wave that was 12 20 the conclusion -- my conclusion that the
21 to 15 seconds in period which is not going to 21 velocity regime on the crest and the backside
22 have as much energy as a wave that's 5 to 7 22 far exceeds the velocity regime on the front
23 seconds in period. And so my question to you 23 side. And that's just one more analysis that
24 is, can you rely on the IPET results on these 24 I've done to convince myself that wave-induced
25 average peak velocities to draw a conclusion 25 erosion on the front side was not a dominant
65 (Pages 571 to 574)

Page 575 Page 577
1 erosion mode during Katrina, 1 Q. Okay. Now, we know based upon the
2 Q. Well, the plaintiffs' view is that the 2 rudimentary calculations that you made that
3 front side attack occurred before the backside 3 these waves were of a type to cause grass
4 attack, so how does that address the timing 4 erosion and even to get to the point where they
5 issue? I mean, I understand your point. Okay? 5 can get six inches into the clay, if you will.
6 Yeah. We've evaluated overtopping. 6 We know that much, right? They had that
7 Got that clear. But the plaintiffs' 7 potential.
8 experts suggest that the wave attack occurred 8 A. Yes.
9 earlier, that the attack to the front caused 9 Q. Okay. Now, so what did you do, if
10 failure, in some locations, not all, earlier 10 anything, other than evaluate the photographs,
11 than this overtopping regime that you describe. 11 because I know you did that, I'm not
12 So I'm trying to understand what you did to 12 discounting that, I know you did that, but did
13 evaluate whether or not that is a realistic 13 you do anything else to learn whether or not
14 mechanism of failure. 14 there was a potential wave environment before
15 A. Okay. 15 overtopping began that may have caused front
16 Q. And what I'm hearing you keep saying 16 side erosion, period?
17 over and over again is about overtopping, which 17 A. Yeah. I did. And I have a table in
18 doesn't have a lot of relevance because the 18 here that I'd like you to go to to discuss
19 experts that we've retained suggest it occurred 19 my -- based on my experience what I believe was
20 earlier, before that overtopping regime began. 20 happening in the way of incident wave
21 So that's why I keep getting confused about 21 conditions, water level conditions, overtopping
22 this analysis. 22 conditions. So let me find that table and we
23 Now, you know -- so Step 1, IPET. 23 can use that as a basis for discussion here.
24 IPET does an analysis of a wave that we now 24 Q. All right. Bruce, I want to go to
25 know is not the right wave. What model did 25 that chart, but I've been asked to do a little
Page 576 Page 578
1 IPET use, by the way, to evaluate the 1 cleanup, some holes that they'd like me to
2 velocities? 2 fill. The COULWAVE worked as the IPET did.
3 A. COULWAVE. Same model. 3 I've taken your copy of the thing. Is there
4 Q. The same model that Resio uses. 4 somewhere in here that tells us the wave height
5 A. Yes. He did the work during the IPET. 5 and period and all that? Is that -- do we
6 That was his task. 6 know -- can we -- is that published, or --
7 Q. He did the IPET. 7 A. I can look. Here are plots of the
8 A. Yeah. The results I just cited to you 8 time variation of significant wave height and
9 were from his task in the IPET. 9 period at each of those points. Maximum wave
10 Q. All right. Now, so Resio now knows 10 height are about -- approaching six feet. Five
11 he's got a different wave, and Resio decides 11 and a half, six feet.
12 that he doesn't want -- or doesn't need to, in 12 MR. MITSCH:
13 fairness to him, do the COULWAVE analysis using 13 For the record, note the page.
14 the new wave parameters, right? 14 THE WITNESS:
15 A. I don't know if that's what he felt or 15 Okay. This would be IPET Volume
16 not. You should ask Dr. Resio. 16 4, Page 233, Figure 166.
17 Q. Well, we'll ask him. All right. 17 EXAMINATION BY MR. BRUNO:
18 That's not -- in fairness to you, that's not 18 Q. All right.
19 your deal. 19 A. And this page would have the time
20 A. Right. 20 variation of the period.
21 Q. But he didn't do it, right? 21 Q. Okay. Great. And that page being the
22 A. I don't know that for a fact. 22 next page, whatever that is, which is Roman
23 Q. Okay. All right. 23 numeral IV, 234. And it's showing peak periods
24 A. I recall him saying they were not 24 of about 15 seconds. You want to --
25 calculating that. 25 A. Approximately.
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Page 579 Page 581
1 Q. Okay. All right. And then if I'm 1 Q. No, I didn't ask you that, Bruce. I
2 reading this thing right, Page 169 shows the 2 don't care how they compare. I really didn't
3 velocities along the front face of the levees, 3 compare -- what I said to you was this: I
4 so that's this page here. 4 didn't state it very clearly. I said the
5 A. That's the one we were looking at 5 plaintiff experts believe that the front side
6 originally. 6 attack occurred before overtopping.
7 Q. Right. And it goes from five seconds 7 A. Okay.
8 to -- five seconds to ten seconds at Location 8 Q. I don't think the plaintiffs' experts
9 3, to five seconds at Location 4. 9 disagree that, you know, overtopping can cause
10 A. Let me see. 10 erosion. I don't think there is any issue
11 Q. Yeah. 11 there. I think you've read that.
12 A. We have to be careful about what time 12 A. Okay.
13 we're talking about. I was referring to prior 13 Q. What they say is that there was front
14 to overtopping. So we need to -- my discussion 14 side attack and front side erosion that
15 in my report addresses prior the overtopping. 15 occurred before --
16 So we would have to definitely make sure that 16 A. Okay.
17 we're discussing the time of overtopping. Or 17 Q. - the overtopping erosion.
18 prior to the time of overtopping. 18 And so the question on the table is
19 Q. Okay. All right. So -- fair enough. 19 what did you do, if anything, to determine
20 Can you determine front side velocity with 20 whether or not front side erosion occurred, at
21 COULWAVE? 21 all I guess, and then secondly, if it occurred
22 A. Yeah. I think -- I mean you're going 22 did it occur before, you know, the overtopping
23 to get a chance to talk to Dr. Resio. He will 23 erosion? So that's where we are.
24 be very much an authority on wave-induced 24 A. Okay. Think this table sheds a lot of
25 velocities and details about COULWAVE. So I 25 inside into those processes.
Page 580 Page 582
1 would defer you to your chance to talk to him. 1 Q. All right.
2 Q. That's fine. 2 A. Let me explain what the table is
3 A. To really delve into the issue of 3 again. I took a typical levee crest elevation
4 velocities. 4 on the low end of what exists in that very
5 Q. All right. Okay. And finally, your 5 critical reach between Dupre and Bienvenue, and
6 estimation is that if you had -- if you'd do 6 I used a levee crest height of 15.4 feet, and
7 the same work with the 6 to 7 second waves with 7 again I assumed that there's a levee toe in
8 the peaks of 6 to 7 feet, you would get from 4, 8 front of this levee at an elevation of 9 feet.
9 5, 6, maybe 7 feet per second. 9 And then I took what I considered to be a
10 A. They'll be higher. Yeah. Just from 10 representative hydrograph, a time variation of
11 my experience, I believe those averages will be 11 water level and a time variation of wave
12 higher. 12 height, and I made some calculations of how
13 Q. Okay. All right. Now, I'm sorry, I 13 would the overtopping rate evolve during the
14 stopped you from going to your chart which is 14 storm and how would vertical erosion rate
15 where we now want to go. 15 evolve during the storm using that model, that
16 A. You want me to just -- 16 fairly simple model of Seijffert and Verheij
17 Q. Yeah, tell me where you are. 17 that related vertical erosion to wave height
18 A. We're on Page 111, Table 7. 18 and some function of grass cover. And for my
19 Q. Okay. This is our chart again. 19 sample calculations here, I just used an
20 A. It's a little different. But some of 20 average grass cover. I could have used a
21 the same information. But let me explain to 21 different grass cover, but I just picked the
22 you what's in the chart. You asked before 22 average value. And so on the first column of
23 about how do I make an assessment of what's 23 this table I have evolving time in Central
24 more important, wave erosion, overtopping? How 24 Daylight Time during the storm. In Column 2, I
25 do two compare? 25 have the scaled hydrograph as it evolves
67 (Pages 579 to 582)

Page 583 Page 585
1 through time, and these are water surface -- 1 still, the water level isn't high enough -- or
2 water levels in feet. The third column would 2 low enough that there's considerable wave
3 be the incident wave height from the STWAVE 3 breaking taking place on the slope in front of
4 model. That would be really at the same 4 the levee.
5 location that we provide input to our COULWAVE 5 Q. Uh-huh.
6 model. And then the fourth column is my 6 A. So that the wave height at the levee
7 estimate, based on my experience, of what I 7 toe is rising to 1.4 feet, but it's still
8 think the levee height at the toe of the levee 8 limited due to breaking at the toe. The mean
9 would be. That's really the wave height that's 9 overtopping rate is still zero, and we're
10 going to be interacting with the levee front 10 getting some additional erosion such that the
11 face. And if there are differences, it's 11 cumulative erosion has now accumulated to
12 because in my estimation there would have been 12 0.028 feet.
13 breaking that would have been occurring on the 13 Q. Wait. Now you say that's an
14 slope in front of the levee and reducing the 14 accumulation of 8 plus 6? If that were so,
15 wave height to a value of approximately .6 15 then the 11 number would be a big number.
16 times the wave height. So it could be .4, it 16 A. No, if you want to calculate the
17 could be .6, I've used .6. The fifth column is 17 erosion between two times you have to subtract
18 an estimate of the wave setup that's coming 18 those two numbers. I've already done the
19 from the COULWAVE model. And the next column 19 addition.
20 is an estimate of the mean overtopping rate 20 So from 3:00 a.m. to 4:00 a.m., I've
21 coming from the COULWAVE model, and both of 21 had an additional .02 feet of erosion. I
22 these are as we are evolving through the storm. 22 started off at .008, an hour later I'm at .028.
23 And the last column is a calculation of the 23 So, I'm accumulating erosion.
24 cumulative vertical erosion that's occurring on 24 Q. Okay.
25 the levee front face using that -- the method 25 A. Let's go to 5:00 a.m. 12.9 feet, the
Page 584 Page 586
1 that the Dutch guys developed based on large 1 water level. It's gone up about 1.6 feet in
2 scale laboratory study of grass covered clay 2 that hour. The incident wave height is
3 levees. 3 growing, as well; 4.3 feet. The wave height at
4 And so let's, um -- let's just go 4 the toe has increased to 2.3 feet. At
5 through, time increment by time increment. I 5 12.9 feet, you know, we have a levee crest of
6 think it's insightful to do that. So at 6 about 15.4, so we're about two and a half feet
7 3:00 a.m. the water level's at 10.1 feet. I 7 below the levee crest. Okay? And at this
8 know the incident waves seaward of the toe are 8 point overtopping has begun. And it's reached
9 3 feet, but because of the water is not yet so 9 a rate of .06 cubic foot per second per foot.
10 high the water over the berm in front of the 10 Now, let's talk about that, how that
11 levee is still pretty shallow, so by the time 11 relates to our levee design damage thresholds.
12 the wave reaches the toe of the levee where the 12 So for -- if you recall back to that chart, we
13 depth is about nine feet the significant wave 13 said, you know, according to the current
14 height will have been reduced from about 3 feet 14 guidance levee damage would begin in the range
15 to about 0.7 feet. And the overtopping rate is 15 of .01 to .1. So at these overtopping rates,
16 zero. There's no overtopping yet. The water 16 while the water level is still two and a half
17 levels just barely above the toe. But there 17 feet below the levee crest, overtopping has
18 would be, using their model, some calculated 18 begun and probably started to erode the
19 vertical erosion of -- these are in feet -- 19 backside. And the cumulative erosion at this
20 .008 feet. 20 time has increased to now .064 feet.
21 Um -- let's go every hour for now, 21 Q. That's also doing damage on the front
22 just to kind of move through this. Let's look 22 side using your own numbers.
23 at 4:00 a.m. One hour later, the water level 23 A. There's erosion. I mean, it's small.
24 has risen by 1.2 feet, so we're now at 24 .06 feet is, um -- between a half and one inch.
25 11.3 feet, the incident wave light is 3.3, but 25 Q. Okay.
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Page 587 Page 589
1 A. Okay? All right, let's look at -- now 1 Q. Right.
2 let's just go one half hour here. Let's step 2 A. I don't believe that levee was
3 up one increment. So in a half hour the water 3 subjected to the duration of loading that these
4 level has risen a whole foot. The wave height 4 others were.
5 has gone up to 4.6 feet. Still limited. You 5 Q. Okay.
6 know, there's going to be breaking taking place 6 A. And the vertical erosion, though, is
7 on that slope in front of the levee. So the 7 quite small. It's .12 feet. Yeah, .12 feet.
8 wave height at the toe is going to be not 4.6 8 Which is maybe an inch and a half. So at the
9 but it's going to be about 2.9 feet. The mean 9 point in time where we have massive overtopping
10 overtopping rate has increased to .24 cubic 10 of the levee, we've only had an inch and a half
11 foot per second per foot, which is exceeding 11 of vertical erosion according to their model.
12 even the upper end, now, of our levee design 12 Q. Sure. Now, that's -- of course, once
13 criteria for a high quality clay levee. The 13 again, if you use this grass cover thing, you
14 guidance says .1. 14 could have also used COULWAVE, you would have
15 Q. Sure. But -- 15 velocities.
16 A. So we're over. So I would expect 16 A. Yeah, I could have.
17 there to be erosion taking place on the 17 Q. You could have had those. But you
18 backside, as we discussed yesterday. 18 don't have them. And the second thing is is
19 Q. Uh-huh. 19 that you you've got a wave height based upon a
20 A. Cumulative erosion at this point on 20 levee toe of nine feet. Did you know that nine
21 the front side has increased to .088 feet, 21 foot was the design parameter for the levee
22 which is about one inch. 22 toe?
23 Let's look at 6:00 a.m. This is where 23 A. I don't recall. I thought it was nine
24 the water level is starting to rise rapidly. 24 or ten feet.
25 It's increased 1.6 feet in that half hour. 25 Q. No, it was nine. The good news is I
Page 588 Page 590
1 15.5 feet is now -- we have overflow over our 1 got it. It's right here. All right?
2 levee. The levee crest was 15.4. We have 2 A. Okay.
3 15.5, we have a small amount of overflow. And 3 Q. So that would mean that there had been
4 on top of that we have a lot of waves come over 4 no subsidence at the levee toe at all. It's
5 that levee. Think back to the video that I 5 pretty amazing, huh?
6 provided you from our laboratory where we had 6 A. I think the important thing is that
7 about a foot of water and a lot of wave 7 slope in front of the levee is going to limit
8 propagation over the levee. So there's massive 8 wave energy.
9 overtopping taking place at this point. The 9 Q. How about this: If the levee toe is
10 overtopping rate is 1.7 cfs per foot. If you 10 really six feet, that's going to change all
11 recall from our guidance, at about 2 cfs per 11 these calculations.
12 foot that overtopping rate is significant 12 A. Slightly. I don't think it would have
13 enough to start damaging even levees that are 13 an appreciable -- I don't think it would change
14 protected on the backside with paving. This is 14 the fact that the vertical erosion on the front
15 massive overtopping coming over here. Um -- my 15 face is on the order of inches.
16 gut feeling, you know that photo under Paris 16 Q. Well, it's going to change your wave
17 Road? That would probably not be so unlike 17 height at the levee toe, right? By a factor --
18 what's happening at this point in time. 18 A. It would increase it, uh-huh.
19 Q. All right. In that photo you don't 19 Q. By two feet.
20 have backside erosion uniform, you've got just 20 A. It would increase it.
21 one location. 21 Q. All right.
22 A. Yeah. You got to think about levee 22 A. Probably could increase the
23 properties, also. 23 overtopping, too.
24 Q. Right. 24 Q. All right. Well -- and actually,
25 A. And duration and other things. 25 adding to that discussion, if MRGO contributes
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Page 591 Page 593
1 to wave height, then MRGO could contribute to 1 MRGO contribute to surge? And if it does, by
2 overtopping. Right? 2 what amount? Right?
3 A. You're saying the change in wave 3 A. True.
4 height would contribute the change in 4 Q. Next question: Does the MRGO
5 overtopping? 5 contribute to surge -- I'm sorry. To wave
6 Q. No, no, no, no, no. 6 height, yes or no? And then --
7 A. You lost me. 7 A. Change.
8 Q. I said if the MRGO makes the waves 8 Q. -- to change, what's the amount?
9 larger -- 9 A. And how? And how much.?
10 A. Yes. 10 Q. How. And does it alter the wave
11 Q. -- then the, shall we say, MRGO 11 period, does it make the wave more energetic,
12 neutral, then MRGO is contributing to the 12 less energetic, those are the questions that he
13 overtopping regime as well. 13 has to answer, right?
14 A. True. Small. Small amounts. And I 14 A. Right.
15 have some graphics in my report that show 15 Q. And then the next question he has to
16 just -- even with the kind of changes we are 16 figure out is once we've decided what that
17 seeing attributed to the MRGO, which we do see 17 change is and how that change is characterized,
18 reductions in height, that the change in 18 whether or not that change was sufficient to
19 overtopping rate is quite small. 19 cause front side erosion, right? And then the
20 Q. Right. So even you guys find a 20 last thing would be whether or not that change
21 contribution to wave height by the MRGO, albeit 21 contributed significantly to the overtopping.
22 small, but you do find a contribution. 22 Right? Isn't that a fair way to do it?
23 A. Yes. 23 A. Yeah, in general. But I think you
24 Q. Okay. And so really, what we're 24 have to understand, you know, during the event
25 talking about is just how much -- the fight 25 there is some front side erosion and
Page 592 Page 594
1 between us is -- 1 overtopping -- they're happening at the same
2 A. Yeah. 2 time. You can't say, well one happened first
3 Q. -- how much does MRGO contribute to 3 and the other happened later. They're
4 the wave height. 4 happening at the same time.
5 A. And did it really matter to the 5 Q. Well, again, that's your position.
6 outcome along Reach 2. I think that's -- 6 I'm trying to be -- I'm trying the stay
7 Q. And once that is established -- but 7 objective here.
8 it's really a step process, and the first step, 8 A. Okay.
9 is, number one, what is the contribution of the 9 Q. Just objectively, for the guy who's
10 MRGO to wave and surge between the two sides? 10 resolving the dispute between us, I'm just
11 And only after you resolve that question can 11 asking you if you would agree that's a
12 you resolve the next series of questions, which 12 reasonable process for him to work through.
13 is, all right, now that we've established what 13 Because if they're happening at the same time
14 that difference is, then we have to analyze 14 your point is well taken, but that's for him
15 whether that difference was sufficient to 15 the decide, are they happening at the same time
16 either, A, cause front side attack, or B, to 16 or not. But before he answers that question,
17 have contributed significantly to overtopping? 17 he has to answer this question, that is,
18 A. Yeah. And I believe I've done that. 18 whether or not there is front side wave attack,
19 Q. No. No. I'm not talking about you. 19 and secondly, did that front side wave attack
20 I'm just saying the process. The process that 20 occur before overtopping and did it contribute
21 the judge needs to use. 21 to the failures of the levees.
22 A. I agree. 22 A. I mean, that's one way. I don't think
23 Q. As between us. So we have difference 23 I would approach him that way, but I would
24 of opinion here, but the way for him to resolve 24 rather approach it the way I believe things
25 it is for him to answer the question does the 25 actually happened. And they're happening at
70 (Pages 591 to 594)

Page 595 Page 597
1 the same time. 1 question next. Because that's what in the
2 Q. But you're being an advocate. I'm 2 chronology we say occurred next. You say it
3 trying to be objective. 3 didn't occur, we say it did occur. But it has
4 A. Well, so are you. 4 to be answered. Right?
5 Q. No, no. I'm not saying anybody is 5 A. Yes. I guess my knowing what I know
6 right. Actually, I'm not, Bruce. I'm saying 6 about how conditions evolved through this
7 you have to answer some questions yes or no. 7 storm, I don't believe we got very far into
8 No, I take offense at that because, no, I'm not 8 this event before overtopping was producing
9 being an advocate here. I'm saying you have to 9 levels of overtopping that were significantly
10 answer a series of questions. And I'm asking 10 degrading the levee. And once the levee
11 you, if you can possibly be neutral about this, 11 degradation starts, there's a feedback between
12 is this a reasonable way to answer the 12 overtopping also. As it's degrading
13 questions, they have to be in series. If the 13 overtopping is getting higher and higher and
14 proponent, either side, says something happened 14 higher, and the rate of levee degradation is
15 before something else, one has to test that 15 increasing. And so I don't --
16 hypothesis, did it happen before something 16 Q. That's all true, man, but, you know,
17 else, yes or no? If the answer is no, then you 17 the fact of the matter is you guys changed your
18 move along, we lose. But if it happened before 18 timing just to suit the arrival of water in
19 it, then the next question is, did that cause 19 St. Bernard. So there was a certain component
20 or contribute to flooding? So I'm trying to 20 of make this thing fit, on your side.
21 see if there's a possibility here for us to 21 A. You know, I view that differently. I
22 agree on a reasonable process to evaluate these 22 view that as an effort on our part to make sure
23 questions and whether these things can be done 23 that our model is trying to reproduce that
24 one piece at a time. 24 observation of water over the 40 arpent levee.
25 And I'll ask it again. Don't you 25 Q. It also is somewhat, a cynic would
Page 596 Page 598
1 agree the first step in this process is does 1 argue, some attempt to make certain that your
2 the MRGO contribute to surge? Yes or no? Is 2 model fits the facts, as they can't be changed.
3 that a reasonable first question? 3 A. Yeah. I mean, I view it the same as
4 A. Yes. 4 scaling, you know, an effort to get, you know,
5 Q. The next question, if it's does, by 5 closer to what the reality was.
6 how much? Right? Yes or no? 6 Q. Okay. All right. I'm going to pull a
7 A. I agree. 7 Richard Stone on you, so beware. He was served
8 Q. By how much. I mean, this is what you 8 up a bunch of questions by others, and I said
9 put in your report. 9 ask away. So I'm in the same boat. So let me
10 A. Okay. 10 blast away at this. As you'd say, I'm a
11 Q. Next question is, does MRGO contribute 11 messenger.
12 to waves? And that's a broad brush, I know. 12 Based upon the work documented in your
13 The answer would be yes or no. 13 December 2008 expert report, would you describe
14 The next question would we, how? Does 14 the analytical process or processes you used to
15 it make the waves, the amplitude higher, 15 evaluate the performance of the earthen
16 smaller, dollars it make the period longer, 16 hurricane flood protection structures adjacent
17 shorter, what is the effect? Does it change it 17 to the MRGO Reach 2 during Hurricane Katrina.
18 in any way? 18 A. Wow. I feel like we've covered that.
19 The next question would be, how do 19 Q. I think you can give me an
20 those changes, whatever they are, help us 20 encapsulated -- I think you're right. You
21 answer the question as to whether or not front 21 didn't really do that.
22 side attack occurred earlier than overtopping? 22 A. I analyzed graphical images, the
23 And if you can't answer, we lose. If you -- 23 pictures, the whole sets of pictures, um -- I
24 you know, I'm not saying who wins, I'm just 24 did this kind of a calculation that we just
25 saying it's just a process, you answer that 25 went through, looking at a model for front side
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Page 599 Page 601
1 erosion of grass-covered clay levees and looked 1 A. The Seijffert and Verheij model of
2 at how that -- what implications that would 2 front side levee erosion induced by wave
3 have in the way of wave-induced erosion, did a 3 action. I used their model which is based on
4 lot of overtopping calculations, and looked at 4 large scale laboratory investigation of sodded
5 the kind of damage one might expect for those 5 clay levees.
6 levels, um -- 6 Q. All right. And your water levels come
7 Q. All right. Fine. In the analysis 7 from ADCIRC, your incident wave heights come
8 documented in your report you applied results 8 from Resio, your wave height at the toe is
9 from the analytical studies that determined the 9 based upon your belief that the levee toe is
10 environmental conditions associated with 10 nine feet, and then you add to that the wave
11 Hurricane Katrina, the winds, waves, surge, 11 height that comes from ADCIRC, right?
12 currents. Why are you confident that these 12 A. Yeah. I mean, we could use COULWAVE
13 results represent what really happened along 13 if we wanted to do additional analysis to
14 the MRGO Reach 2 during Hurricane Katrina? 14 actually calculate the wave height at the toe.
15 A. Well, in the case of overtopping, you 15 We could get that from the model.
16 know, I'm really using overtopping rates and 16 Q. Right.
17 translating those into levee damage, and that 17 A. I don't believe those results would be
18 is based on actual field observations made 18 so different from what I have here that it
19 both, primarily in Europe, primarily in Japan, 19 would change my interpretation and conclusion
20 so there is an experience base upon which those 20 based on -- that led me to believe that the
21 engineering criteria are developed. And 21 erosion induced by overtopping is the dominant
22 since -- it is based on actual observations. 22 mode of levee destruction and the erosion by
23 In the case of wave-induced erosion on the 23 waves is not. I don't think the differences
24 front side, again, I'm using a model that's 24 that we could see in that wave calculation
25 based on data collected in large scale tank 25 would lead me anywhere differently.
Page 600 Page 602
1 experiments that is measuring the process that 1 Q. That's fine. Just want top establish
2 we are talking about. 2 that you didn't do it. And so we have what we
3 Q. Okay. Do you know what the sources of 3 have.
4 the data were? Or do we need to talk to 4 A. Okay.
5 Professor -- 5 Q. Now, did -- you introduce adjustments
6 A. Sources of which data? Could you be 6 to the results from the analytical models that
7 more specific? 7 were intended to match observations made in the
8 Q. Yeah. For the ADCIRC. 8 field following Hurricane Katrina, for example,
9 A. Dr. Westerink. 9 adjustment the surge elevation s? And I think
10 Q. Okay. And the erosion information 10 the answer -- you've already said yes.
11 that came from, well, IPET and also Resio. 11 A. Yes.
12 A. Erosion. Can you be more specific? 12 Q. So let's walk through that right now
13 Q. Well, let's see. It says, that is 13 and discuss those changes. I forget where you
14 based upon field observations made both 14 were in the report. Do you know where it is?
15 primarily in Europe and Japan, so there's 15 A. What are you looking for?
16 evidence -- or experience -- so that's not you, 16 Q. The ADCIRC adjustments.
17 that's somebody else. That's from a report. 17 A. The table?
18 A. Somebody else's experience being 18 Q. Well, I don't know if it's a table,
19 factored into both the design guidance that we 19 but --
20 use in the Corps and which the Dutch use in 20 A. You mean Table 1? Page 27.
21 their levee design practices. 21 Q. ADCIRC, Page 27. Okay. All right.
22 Q. And it says since it's based on actual 22 So, now, is there some textbook or some peer
23 objective -- I've got it. I think what is here 23 reviewed publication which would tell us how to
24 is that you are referring to that Dutch study 24 go about the business of making adjustments to
25 which had some tank studies and observations. 25 an ADCIRC model in the way that you made
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Page 603 Page 605
1 adjustments to the ADCIRC model? 1 A. Okay.
2 A. I think we talked about that 2 Q. So then I guess what you then did was
3 yesterday. 3 what, you then -- difference percent and you
4 Q. We did? 4 have a -16. So you subtracted 2.5 from 15.7?
5 A. You asked me that yesterday. 5 A. I would divide 2.5 -- where is that
6 Q. And I think you said there are none. 6 calculator? I divided 2.5 by 15.7.
7 A. Yeah, I mean, this is based -- 7 Q. And what did you get?
8 Q. On your experience. 8 A. 16 percent difference.
9 A. -- on my experience -- 9 Q. All right. And then you divided 2.9
10 Q. Bruce, that's fine. I apologize. 10 by 15.8 and you got?
11 A. -- on how to try make a more accurate 11 A. 18 percent.
12 estimate of what the water levels were. 12 Q. 18 percent difference. So if we
13 Q. All right. So you found some -- let's 13 multiply 16 percent times 13 we get a number,
14 see. Where's your little map with all your -- 14 and then we're going to add that to 13 to get
15 A. High water marks? 15 our number, right?
16 Q. Yeah, your marks. 16 A. Say that again.
17 A. Figure 2 on Page 12. 17 Q. Well --
18 Q. Okay. I'll put those two together. 18 A. I'm spending time on the calculation.
19 Okay. So at Chef Menteur, you measured 19 I should listen to your question.
20 15.7 feet? 20 Q. Let me see if I'm making any sense to
21 A. There were two marks there. IPET 21 myself. How about that? So we have -- so we
22 established two excellent marks there, one 22 take 13.2, which is our computed number, and we
23 15.7, one 15.8. 23 multiply that times our .17 which is our new
24 Q. Well, there are two different 24 number, and we get 2.6.
25 locations, apparently, because you have two 25 A. Okay.
Page 604 Page 606
1 computed levels. 1 Q. And then we add 2.6 to our 13.2, and
2 A. I'd have to go back in the IPET report 2 we get 15.8 which is close enough to where you
3 and look at the description of each mark to 3 want to go.
4 know. I mean, there were two distinguished 4 A. Okay.
5 marks. I can't recall if it was two separate 5 Q. Okay. And that's what you did, so
6 buildings or what. We could try to delve into 6 that's how you got to -- well, here you have a
7 that, if you want, back in the IPET report. 7 17 percent, 8 percent, 16 percent, et cetera.
8 Q. All right. I only make the point, 8 A. I tried to look at those particular
9 Bruce, because -- see the next column? 9 locations, or they were separated by some more
10 A. Um -- 10 significant distance than the distance between
11 Q. Computed? 11 those two high water marks.
12 A. Yes. 12 Q. All right. Now, what I don't
13 Q. You have two different numbers. 13 understand about what you did is, I can -- you
14 A. Yes. 14 know what Paul Kemp did, right?
15 Q. So it must be two different locations. 15 A. My understanding is he also did some
16 A. I presume they are. 16 scaling of his boundary conditions with high
17 Q. All right. So anyway, the next thing 17 water marks. I don't -- I don't understand
18 you did was you took the 15.7 and we subtracted 18 where his high water marks came from, because
19 13.2, and we got 2.5, right? 19 there are some discrepancies I don't understand
20 A. Yes. 20 in the results --
21 Q. Okay. The next thing we did was we 21 Q. Same as yours. 18.1, 18.7 here --
22 had -- 22 A. I don't think so.
23 A. Minus. Okay. 23 Q. 17 --
24 Q. -- 15.8, and, um -- subtracted 12.9 24 A. I don't think so. And I can go in one
25 and we get a -2.9. 25 of the plaintiffs' experts' reports and raise a
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Page 607 Page 609
1 question because -- it doesn't appear that he 1 and then he would have a spike up to a peak
2 did use my high water marks. Or the IPET high 2 value that was scaled, and then another spike
3 water marks. 3 back down to some other hydrograph. So I
4 Q. All right. 4 believe he must have scaled the entire
5 A. I say mine. It's the IPET. 5 hydrograph. But --
6 Q. Well, he difference between what he 6 Q. Right.
7 did and you did generally was he altered the 7 A. -- I don't know. That's a good
8 boundary and said the model is going to fill in 8 question.
9 the surface between those two, which I can 9 Q. All right. Well, the thing is that
10 understand. 10 his hydrographs matched the marks more
11 A. What he did was -- my understanding of 11 consistently than yours.
12 what he did was he took a hydrograph from the 12 A. They didn't. And let me show you an
13 SO8 model, which I think are terribly flawed on 13 example. Let me open up this TU Delft Svasek
14 that second peak, and he scaled them not unlike 14 Flow Modeling, Hurricane Katrina, August --
15 what I'm doing with using the high water mark 15 let's look at Scenario 1 results, which was
16 information, I presume so that the peaks 16 your Katrina case.
17 matched the high water marks at the location of 17 Q. Exactly.
18 the high water marks. That's what I gathered 18 A. So I'm looking up in that report,
19 from reading his report. 19 Page 14.
20 Q. Well, that's what you did, too. 20 Q. There's a bump, by the way.
21 A. Similar. 21 A. Let me look at Page 13. And I'm going
22 Q. You had the peaks -- the difference is 22 t look at Shell Beach because I thought he was
23 that you changed the entire hydrograph, and he 23 using Shell Beach high water marks to do the
24 just change the peak. 24 scaling. Okay? So if I look at -- if I look
25 A. I don't think he did that. Because I 25 at the Shell Beach hydrographs, there are two
Page 608 Page 610
1 think his model must be driven with the 1 listed here, one from the ADCIRC SO8
2 hydrograph, not just the single value. He must 2 calculations and one from the Finnel
3 be driving it with a hydrograph. 3 calculation. That's the model that they used.
4 Q. Right. 4 And the red curve is from ADCIRC, and the blue
5 A. And so I don't think he just scaled 5 curve is from Finnel. So Finnel shows a peak
6 the one value at the peak -- I hope not, that 6 of 16 feet, and ADCIRC shows a peak, I'm going
7 would not be very good. He must have scaled 7 to estimate, of, I don't know, a little less
8 the whole high hydrograph, just like I did. 8 than 17 feet. So these are the peaks, 16 and a
9 Q. Well, the hydrograph represents the 9 little less than 17. But at Shell Beach we
10 movement of water over time. 10 have two excellent marks of 18.7 and 18.1. So
11 A. It's the time variation of the water 11 I'm not sure what he did. I would think he if
12 surface elevation. My understanding is that's 12 he used Shell Beach high water marks to scale
13 what he used as his boundary condition. 13 the hydrographs, than I would be seeing peaks
14 Q. And the winds change over that time, 14 that are, you know, in the 18.1 to 18.7 feet
15 or they could change, a lot of things can 15 range. So I am not sure what he did.
16 change during that time frame. 16 Q. Well, you also don't know what he's
17 A. He must have modeled the change of all 17 referring to as Shell Beach either, do you?
18 the winds. 18 A. No.
19 Q. And so we don't have water marks for 19 Q. I don't know. I mean, what you call
20 each point along the hydrograph, all we have is 20 Shell Beach and what they call Shell Beach
21 water marks for the top. 21 could be different.
22 A. Yeah, but I think he also scaled -- I 22 A. And I think the answer is what high
23 feel certain, but I don't know for sure, but I 23 water marks did he use to do that scaling?
24 presume that he scaled the hydrograph. If not, 24 Because my impression was he took Shell Beach
25 he would have a time series that's not scaled, 25 and also a point up around New Orleans East,
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Page 611 Page 613
1 which I presume would maybe be the Chef Menteur 1 here. Let's did a logic check. We have this
2 marks. 2 polder that's been flooded. All right?
3 Q. Uh-huh. 3 Q. Right.
4 A. But I don't know that. 4 A. And we know from the observations that
5 Q. Okay. 5 the water level peak got to about eleven feet
6 A. Yeah. I guess I'm kind of curious 6 in that polder.
7 what high water marks did he use, because I 7 Q. Ultimately. Depends on what day it
8 thought Paul shared with us during IPET all of 8 is.
9 his high water marks. 9 A. You talking about the maximum?
10 Q. He did. And he did not -- I think 10 Q. Thursday at one o'clock, to be
11 where you're mistaken is that you're assuming 11 precise. It was several days later.
12 that Shell Beach, that the hydrograph is 12 A. No. I'm talking about that same day,
13 precisely done at the location where the high 13 that afternoon.
14 water mark is, and it's not. 14 Q. Okay.
15 A. Yeah. My personally, I'm kind of 15 A. My understanding from all the data
16 wondering, well, what mark is it? Is it one of 16 that we have assembled in the IPET is the peak
17 the IPET high water marks or is it some other 17 at, for example, Jackson Barracks, I believe it
18 mark that IPET does not have? 18 was, the observations recorded the peak water
19 Q. Well,I think it's the IPET water mark 19 level there about 2:00 the 3:00 p.m. that
20 and I think it's been established in his 20 afternoon time frame. That's the --
21 deposition. 21 Q. That's the peak for the whole flood?
22 A. I couldn't find that anywhere. I 22 Is that what you're saying?
23 looked at his report and I couldn't find 23 A. Yeah. The highest water that was
24 information that told me what high water marks 24 experienced at Jackson Barracks during Katrina
25 he used. 25 was experienced at about 2:00 to 3:00 p.m.,
Page 612 Page 614
1 Q. Well, the purpose of this is to 1 kind of early afternoon time frame. Okay? And
2 demonstrate that the -- that there's a 2 so I believe by, um -- by 7:30 our modeling
3 calibration between the Finnel and the ADCIRC. 3 suggests that we would have had both the north
4 Would you agree that there's a good 4 breach and the south breach and major
5 calibration there? 5 degradation of the levee along Reach 2. So
6 A. Well, there's agreement. I mean, the 6 there would have been a lot of water pouring
7 reality of it is you're not -- you're forcing a 7 into the polder starting at about 7:30.
8 boundary with a hydrograph. We're not 8 Q. Right.
9 propagating it very far. We should be getting 9 A. And eventually that flooding led to a
10 about the same hydrograph out. 10 maximum of about eleven feet early, early
11 Q. And there is a second bump here. 11 afternoon. So I think you would agree that if
12 A. Yeah. It's so, so grossly 12 the water level is above eleven feet we
13 understated. 13 definitely have to have water coming from
14 Q. I understand. 14 outside toward the inside.
15 A. If you want to compare that with our 15 Q. I thought you just told me it was the
16 hydrograph -- 16 peak. If that's the peak, then how do you have
17 Q. No, I know yours is much bigger. 17 more water?
18 A. We get a peak up to almost 14. 18 A. Okay. Let's use 10 as my example.
19 Q. Right. 19 Q. But you told me it was 11.
20 A. I mean, I can tell yours is not right, 20 A. Well, ten or eleven.
21 just from -- 21 Q. Well, Bruce --
22 Q. How could you do that? 22 A. All right.
23 A. Well, you want me to go into that? 23 Q. I mean, come on.
24 Q. Yeah. 24 A. Look. Do you want me to explain or
25 A. Okay. Let's start of do a logic check 25 not?
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Page 615 Page 617
1 Q. No, I'm trying to follow your logic 1 Q. Bruce, there's no breaching in those
2 and it seems like you're changing it to make it 2 hydrographs.
3 work. 3 A. I understand. But I'm saying
4 A. Let me make it more general, then. 4 before -- at higher elevations it's still going
5 Q. All right. 5 in.
6 A. Would you agree that as long as the 6 Q. Okay.
7 water level outside the perimeter is higher 7 A. I mean, these are your hydrographs.
8 than the water level inside we would have flow 8 Q. All right. Yeah. But that -- there's
9 into the polder? Just pure hydraulics. 9 no breaching in those hydrographs.
10 A. Absolutely, yes. 10 A. Okay. Let's just -- just hang with
11 Q. Okay. Uh-huh. 11 me.
12 A. And we wouldn't start to see water 12 Q. Like you said, these are all outside
13 leaving the polder until the water levels 13 the levees in order to assess -- we were trying
14 outside the polder dropped below the level 14 to evaluate water levels, so we did it, you
15 inside. 15 know, the right way, I think, which was to
16 Q. Right. But for the bump. 16 assume no breaching. But okay, go ahead.
17 A. Simple hydraulics. 17 All right. So anyway, you got a water
18 Q. Right. But for bump because it's 18 level there.
19 going to go up again. 19 A. All right. And so your hydrograph
20 A. Would you agree with me, then, that 20 suggests that we're passing through at about --
21 the crest, the cresting of the water level 21 that's about ten o'clock in the morning. So
22 inside the polder, should occur roughly at the 22 this hydrograph would suggest that water would
23 time when the outside hydrographs are dropping 23 begin in the Industrial Canal flowing back out
24 below eleven feet? 24 at roughly 10:00 in the morning. Just a few
25 Q. Um -- yeah. I'm picking your 25 hours after your peak surge.
Page 616 Page 618
1 arbitrary eleven, sure, I'm with you so far. 1 Q. It doesn't suggest that, Bruce,
2 Sure. That's your peak. 2 because that doesn't -- again, like I tried to
3 A. That's my peak. So if the water 3 tell you, those hydrographs don't factor in
4 level's gotten to eleven feet -- 4 breaching, and the breaching changes all of the
5 Q. And it's going to drop -- 5 levels, obviously, because once you have a
6 A. -- I wouldn't start to see water level 6 hole, Bruce, then the level in the IHNC goes
7 exiting the polder until the levels outside got 7 down and those hydrographs are meaningless.
8 below the eleven feet. 8 A. All right. Let's try the same
9 Q. Okay. 9 thinking out on Reach 2.
10 A. I feel like I'm the attorney here. 10 Q. Simple.
11 Q. I'm trying to -- I follow your logic. 11 A. Let's try the same --
12 I'm with you. 12 Q. Reach 2 is the same problem --
13 A. Are you with me? 13 A. -- same logic.
14 Q. Yeah. 14 Q. No, because the logic fails because,
15 A. Okay. Now, let's go back to the 15 Bruce, the levees fail, and when the levees
16 technical Delft Svadek report. And we're going 16 fail the water -- the hydrographs are all
17 to look at two hydrographs. We'll look first 17 different because then the effect of the water
18 at the IHNC lock. These are, you know, the 18 moving across or through the breaches changes
19 hydrographs. 19 the numbers. Again, these things were utilized
20 Q. Uh-huh. 20 simply to demonstrate water levels, which is
21 A. And so let's look -- I don't know if 21 what I kept asking you about, water level.
22 you have it. This is the hydrograph. It's 22 Water level is a different analysis than the
23 IHNC lock master. Let's look at the time that 23 flood which is SOBEK, the SWAN which is the
24 the water level drops, you know, is passing 24 wave. They're all different analyses. So it's
25 through eleven feet. Okay? 25 not really appropriate to jump from one to the
76 (Pages 615 to 618)

Page 619 Page 621
1 other without understanding what their purposes 1 Q. Wait. Wait. You just told me the
2 are. The fact of the matter is that your 2 eyewitnesses say the water got to its highest
3 second bump means that the water has to go to 3 point and then went down again. Now in fact --
4 Mississippi and back in an hour. And it's a 4 A. No, they didn't say that. They said
5 whole bunch of water, and it all comes back to 5 it crested. It reached its peak.
6 Louisiana. It doesn't go to Alabama, it 6 Q. Okay. So what the eyewitness should
7 doesn't go back in the gulf, it only comes in 7 have said to make your hydrograph hold water,
8 one direction, which is pretty hard to believe, 8 if you will, is they should have said, well,
9 too. Don't you agree? 9 the water went down, and then all of a sudden
10 A. Well, what I would maintain is that 10 it went back up again. And Bruce, it did it
11 our hydrograph shows a passing through eleven 11 within an hour or two hours.
12 feet at about 3:00 p.m., which is a lot closer 12 A. Let's look at some data. Okay?
13 to the observations than the 10:00 a.m. that 13 Q. And by the way, you may remember that
14 your hydrographs suggest. 14 the second bump, you said, doesn't work in the
15 Q. Wait. 15 IHNC so there's no second bump there.
16 A. Maybe you and I don't agree on the 16 A. No, I was --
17 hydraulic analysis -- 17 Q. It's not there, it's in the Reach 2.
18 Q. Help me. 3:00 p.m. represents what? 18 A. No, I mean, I think the IHNC
19 A. 3:00 p.m. that afternoon, the time on 19 hydrograph tells us what that point in time
20 our hydrograph at which the water level would 20 would be.
21 have been becoming less than eleven feet and 21 Q. How about this: Would you agree with
22 which water would begin to flow out of the 22 me that for your hydrograph to work, the
23 polder along Reach 2. 23 eyewitness observation has to be the water
24 Q. I'm with you. I'm just trying to -- 24 peaked, the water went down, and the water went
25 now, I hear your logic. Tell me what facts, 25 up again?
Page 620 Page 622
1 though. So you're telling me that you have 1 A. If that was observed. I don't know --
2 eyewitness testimony that says the water 2 I don't have an observation that relates that.
3 started going down at 3:00? 3 Q. In fact, there are no observations by
4 A. There's eyewitness accounts in the 4 anybody that said the water went back up. And
5 IPET report that say it -- I believe Jackson 5 by your bump, it's a pretty -- isn't it like a
6 Barracks, but in the Lower Ninth Ward area, the 6 four foot jump? Let's go back. How much is
7 water crested at about 2:45:00 p.m. 7 the bump?
8 Q. Okay. I hear you. 8 MR. LEVINE:
9 A. And what I would say is it wouldn't 9 Where does the water --
10 have crested and started dropping until the 10 hydrograph have to go back up at,
11 water levels -- 11 though, what location?
12 Q. Well, Bruce -- 12 MR. BRUNO:
13 A. -- outside dropped below the water 13 Your bump shows about a
14 levels inside. 14 four-foot, isn't it -- tell me if I'm
15 Q. I don't know how the makes sense 15 wrong. That bump is a big old bump.
16 because you've got a hydrograph the goes up and 16 It goes to a trough and it goes back
17 comes down and goes up again. So quite 17 up again.
18 candidly, for your logic to hold true, what has 18 MR. LEVINE:
19 to happen is the water level has got to go down 19 I'm just asking you to specify a
20 and then it's got to go back up again. 20 location for him.
21 A. And that's what it did. 21 MR. BRUNO:
22 Q. Is that what the eyewitnesses say? I 22 He didn't specify location, so
23 thought you just told me that the eyewitnesses 23 I'm not.
24 said -- 24 A. All right. I'm looking at our
25 A. No. They said -- 25 hydrographs on Page 142 of my report, Figure
77 (Pages 619 to 622)

Page 623 Page 625
1 95. 1 I'm correcting the computed, not
2 EXAMINATION BY MR. BRUNO: 2 the measured.
3 Q. All right. So, we had one with a 3 EXAMINATION BY MR. BRUNO:
4 bigger bump than that. But I'll take that one. 4 Q. So did I do that wrong, Bruce?
5 A. These are three locations along Reach 5 A. Say that again. You did it right the
6 2. 6 first time. I don't know why we're doing it
7 Q. So the water would have gone down for 7 again. You did it right the first time.
8 three hours, and then it would have come back 8 Q. Well, I'm being asked to do it again.
9 up an hour and a half later. So if I'm sitting 9 You know, it's like life.
10 in the water, I'd have pretty frightened if an 10 A. Well, you may do it incorrect this
11 hour and a half later I saw the water coming up 11 time.
12 again. 12 Q. Well, 18.7 -- that's why I've got you
13 A. Well, I'm just -- I don't know. 13 here guiding me. 18.7 minus --
14 Q. Am I describing accurately what this 14 A. Where are we?
15 hydrograph shows me, that the water comes up a 15 Q. Shell Beach east -- 15.2 equals 3.5,
16 whole foot an hour and a half after it goes to 16 correct?
17 this trough, wherever it is? So the water 17 A. The difference? Yes.
18 comes down, and all of a sudden an hour and a 18 Q. And then I divide 3.5 by what, you
19 half later the water goes up a whole foot. 19 tell me? 15.2, huh? Because I'm correcting
20 A. It goes back up and then it drops and 20 my --
21 it passes through eleven feet at about 3:00 21 A. 3.5 divided by 18.7.
22 p.m. in the afternoon. 22 Q. All right. So I get my .19 percent.
23 Q. Okay. 23 Now I take my .19 percent and I multiply that
24 A. So if the water level inside the 24 times my computed number, right? So I can get
25 polder is eleven, we wouldn't expect the 25 an add-on.
Page 624 Page 626
1 draining through Reach 2 to take place until, 1 A. Maybe I can save us all a lot of time
2 you know, early in the afternoon. 2 here. For Reach 2, the computed peak surges
3 Q. Bruce, you'll remember that in 3 were roughly 16 feet. They were scaled up by
4 St. Bernard that that has nothing to do with 4 approximately anywhere between 1.5 and 2 feet.
5 the drainage, because you may remember that 5 So if you want to ask me what the peak water
6 they had to blow a levee. Do you know that, 6 levels were that were computed and what they
7 that they had to blow a levee in Lower Nine -- 7 were scaled up to, I can provide you that
8 I'm sorry, in the St. Bernard 40 arpent to get 8 information.
9 the water out of there? 9 Q. It's 18. It's off by seven tenths of
10 A. I don't believe anybody was blowing up 10 a foot. What are we doing wrong?
11 anything at 3:00 p.m. on the afternoon -- 11 A. That's why I said, I don't know what
12 Q. That's my point. 12 you're doing, but I said I can save you some
13 A. -- of that storm. 13 time and I can tell you that the computed peaks
14 Q. The fact is the water wasn't going 14 along Reach 2 with ADCIRC were roughly 16 feet.
15 anywhere. 15 And they were scaled up to be approximately
16 A. I think it absolutely was. 16 values near 17.5 feet. Now, I can give you the
17 Q. Well, okay. We'll see. I'm told I 17 exact computed values and how they were scaled,
18 didn't do it right, so let's do it right. All 18 if you would like. I'm not sure what you're
19 right. Shell Beach. Okay. All right. Shell 19 doing in these calculations.
20 Beach east 18.7 -- I'm sorry. You with me? 20 Q. Well, I'm doing what you told me to
21 Page 27. 18.7 minus 15.2 equals 3.5. And then 21 do. I'm taking the measurement, I'm
22 we divide 3.5 by 15.2, right? 22 subtracting the computed number, and I get a
23 MR. MITSCH: 23 negative 3.5. And then I take my 3.5 and I
24 No. 18.7. 24 divide that by 18.7, and I get 19 percent.
25 MR. BRUNO: 25 A. All this table is is showing
78 (Pages 623 to 626)

Page 627 Page 629
1 differences between -- percent differences 1 A. So at Shell Beach I'm seeing a
2 between measured and computed. 2 difference of 16 percent, so my thinking there
3 Q. All right. And so once you did all 3 is, well, I've got -- I'm only lower by
4 this, what was the next thing that you had 4 8 percent up at Paris Road, I'm off at
5 done? 5 16 percent at Shell Beach, I'm probably off by
6 A. Well, I looked at these averaged 6 somewhere between those along Reach 2.
7 differences. So I look at them and they're all 7 The other thing that I did was --
8 negative numbers. 8 Q. Wait. So your conclusion was between
9 Q. They're all different, though. 9 Shell Beach and Paris Road I'm off but the
10 A. Well, okay. But they're all negative. 10 percent difference is higher at Shell Beach
11 They all tell me that we -- regionally, we are 11 than it is at Paris Road.
12 underestimating the storm surge peaks. 12 A. Correct.
13 Q. You're underestimating, which is a 13 Q. All right. And that might be
14 good thing. You're not overestimates it, 14 accounted for by some problems with your
15 you're underestimating it. 15 topography.
16 A. I don't know if it's good or not, but 16 A. Well --
17 it's different and it's an underestimate. And 17 Q. Isn't that true?
18 so the fact that they're all negative maybe in 18 A. I don't think so.
19 some ways tells me, well, we're going to be 19 Q. It's possible. I mean, to be fair.
20 doing things consistently. If one would have 20 A. Not likely. My interpretation I think
21 said we're plus and one would have said we're 21 there was fundamentally something we don't
22 minus, that might have posed a more challenging 22 understand about the physics. I found it
23 decision to make about to try to improve the 23 interesting that we do better the further away
24 accuracy. But the fact is they're all negative 24 from the core of the storm. There must be
25 numbers. That means we're regionally, at each 25 something in the physics that we're not doing
Page 628 Page 630
1 of these locations, underestimating. So now 1 very well.
2 the question is -- and I assume we would be 2 Q. All right. In any case, you got
3 underestimating along Reach 2. I don't have 3 almost double the difference --
4 any reason to believe that we're not 4 A. Yeah.
5 underestimating. 5 Q. -- from Paris Road to Shell Beach.
6 Now the question becomes, what do I 6 A. Let me put those differences in
7 use to raise the ADCIRC water levels to values 7 context. Let me --
8 that I think are much closer to what was 8 Q. And so a 16 percent difference, just
9 actually occurred in light of this systematic 9 so I'm kind of -- that's about -- that's going
10 underestimating? 10 to be about a foot?
11 Q. Well, it's not systematic, it's only 11 A. Well, two and a half to three and a
12 systematic insofar as they're all negative. 12 half.
13 A. Because they're all negative. Yeah, 13 Q. That's a big change.
14 that's what I mean. 14 A. Well --
15 Q. But there's no logic to it because you 15 Q. I mean, let's talk about overtopping
16 go from 17 to 4. That's a big range. 16 rates and all that. It's a huge change.
17 A. That was my -- I'm using systematic to 17 A. I don't agree with you that it's huge,
18 mean all negative. 18 and let's address that issue. Let's look in
19 Q. Okay. They're all negative. 19 the IPET report. I wish I had the figure from
20 A. So I look at Paris Road, that's to the 20 the SL15 model, but I don't. These are sort of
21 north of Reach 1, and I see only a difference 21 error measures for the storm surge model. This
22 of 8 percent. And then I look down at Shell 22 is how good, from the IPET results, did ADCIRC
23 Beach and I saw a difference of 16 percent. 23 and high water marks compare? And here's a
24 And so my -- 24 plot, Volume 4, Page 121, Figure 81 and Figure
25 Q. Go ahead. 25 82. And what we find during the IPET was, you
79 (Pages 627 to 630)

Page 631 Page 633
1 know, the average errors here are from .25 to 1 A. No, that's not what I said.
2 -.25 to -6 feet, so regionally we're a little 2 Q. Well, look, here's the deal: Whatever
3 underestimating. 3 IPET did they did. Fair enough?
4 Q. A little bit. 4 A. Okay.
5 A. A few tenths of a foot. 5 Q. And what IPET found was that when they
6 Q. That's nothing. 6 ran an ADCIRC the difference was only 1-1/2 --
7 A. But the average absolute error is 7 or 1.3 feet at Shell Beach. Am I reading that
8 about 1.3 feet. 8 number right, 1.3? That's the closest one I
9 Q. Did y'all scale IPET? 9 can find to Shell beach.
10 A. Um -- no. We did not scale. 10 A. I see two, a -2.3, -1.8.
11 Q. Why not? 11 Q. Let's take them both, because
12 A. I don't think it warranted it for that 12 remember, you mapped them?
13 situation. Don Resio did some -- you know, we 13 A. 1.23 is to the west.
14 made some estimates of what we thought the 14 Q. All right. Let's see. Remember we
15 actual peak was, and it was 17-1/2, in IPET. 15 mapped them. In your report you got map. So
16 So I probably misspoke. In his work, my 16 they have to be -- one would assume, would we
17 recollection is he did some scaling to make his 17 not, that IPET would have used those same good
18 calculations of overtopping. 18 solid high water marks that you used in your
19 Q. Wait. His IPET work was STWAVE? 19 report. So it's got to be the 18.1 or the
20 A. COULWAVE. 20 18.7, and that's a different of about .6, and
21 Q. COULWAVE. 21 so you're going from 1 point -- yeah. Those
22 A. When he did his COULWAVE work, my 22 two there, right? 2.3 to 1.6 is a difference
23 recollection is Don did scaling of the 23 of --
24 hydrograph to match a peak of 17-1/2 feet. 24 A. 1.8.
25 Q. All right. 25 Q. -- 1.8?
Page 632 Page 634
1 A. But you can ask him, you know, when 1 A. This is the difference.
2 you speak with him. 2 Q. All right. So IPET sees a difference
3 Q. What was your error at Shell Beach in 3 of between -2, -2.3 to -1.8, and you see
4 the IPET ADCIRC? That's yours, IPET. Because 4 difference of between -- or you have -- I'm
5 we had that same good mark, right? So one 5 sorry. You have the same -- you have the three
6 would assume that -- 6 points, too. And they've got three points. So
7 A. I don't think I can identify that 7 those three points must add up. So they see
8 readily. 8 -1.3, -2.3, -1.8, and you get -3.5, 2.7, 2.4.
9 Q. So that right there, Bruce, is that 9 So your difference is about almost three times
10 Shell Beach -1.3 to -2.3? 10 if not double the difference that I IPET got in
11 A. Yeah. Let's do this: This is better. 11 their ADCIRC one, right?
12 This is the SL15. This is from Westerink's 12 A. I wouldn't agree with your quantities
13 expert report. 13 that you just cited, but I will agree that at
14 Q. No, it's not better because I'm not 14 those three marks the differences for the SL15
15 asking about Westerink, I'm asking about IPET. 15 model are greater than the differences for
16 I mean -- 16 those same three locations from the IPET
17 A. Okay. This whole analysis involved 17 modeling.
18 use of the SL15 model. I'd rather put these 18 Q. All right.
19 differences in the context of what we found for 19 A. But I will say that regionally, if you
20 the SL15 model or else we're comparing apples 20 look at all the high water mark data, the SL15
21 to oranges here. 21 model gives a better prediction than the ADCIRC
22 Q. How about we compare what IPET did to 22 model we applied in the IPET. That would not
23 what you did. Let's do that first. Because 23 be true for that group of three points.
24 IPET didn't feel the need to scale, and you 24 Q. All right. Well, let's talk about
25 felt the need to scale -- 25 which point you regard as all, because again
80 (Pages 631 to 634)

Page 635 Page 637
1 you've already told me we need to discount it 1 A. Yeah. It's close to 16. It's right
2 when it comes to the IHNC. Are we talking 2 around 16 at the -- right about Bayou Dupre.
3 about all three points in Figure 80? And 3 Q. And then at Paris Road, that's where
4 there's lot of them. I can't even count them, 4 the contour stops.
5 but there's bunches and bunches. 5 A. Yeah. I think the computed is between
6 A. Yeah. I don't recall the number. 6 14 and 15. I mean, we can look back on the
7 Q. Well -- 7 previous table.
8 A. They're throughout the system. We 8 Q. Well, I guess what I'm --
9 used as many high water marks as we rated 9 A. 14.2 and 14.4 were the computed.
10 excellent and good, as I recall. 10 Q. Right. Yeah. But here's the deal:
11 Q. All right. But you did use only Shell 11 The contour, and I think that's what you used
12 Beach -- you used Shell Beach as one of the two 12 was the contour, stops before Paris Road.
13 to scale Reach 1. 13 A. Well, let me finish. I mean, you're
14 A. Well, you never let me finish my 14 kind of putting words in my mouth.
15 explanation. I only got part of the way 15 Q. All right.
16 through. 16 A. Let me talk about how I used the
17 Q. Sorry. I need to tell you finish that 17 contour. So again, I have good confidence that
18 explanation. So anyway, the point is is that 18 ADCIRC overall is giving us the pattern, you
19 we have a variety of differences all over the 19 know, areas, gradients, higher areas, lower
20 map, and now we're at Reach 2 and you were -- 20 areas, in general, albeit there are differences
21 before I interrupted you, and I apologize -- 21 between the high water marks.
22 you were going to tell us how you scaled Reach 22 Q. Uh-huh.
23 2. 23 A. So what I looked at is this, um -- so
24 A. Okay. Let me kind of pick up where I 24 in looking at the pattern, we go back to the
25 was. Paris Road bridge, that group of marks is 25 high water mark plot, Figure 2 on Page 12,
Page 636 Page 638
1 to the north of Reach 2. 1 looking at this particular high water mark of
2 Q. Right. 2 17.1 -- I can't remember where -- what the name
3 A. And the difference there is 8 percent. 3 of that location is, but it's just sort of to
4 At Shell Beach, and I guess it's Reggio, that 4 the immediate southeast of the polder. Do you
5 group of three marks is to the south of Reach 5 see the 17.1? And so -- and then I look at
6 2, and that average is -16. So my rationale is 6 that location on this map and I look at the
7 that along Reach 2 I'm probably going to have 7 location of where that point is, and looking at
8 to make an adjustment that's somewhere between 8 the surge contours along Reach 2, and I ended
9 8 and 16 percent. So that was one piece of 9 up, um -- let me refer to my report and make
10 information that I factored into my decision 10 sure I get this correct.
11 making. 11 Q. You didn't scale the 17.1, did you?
12 Q. Okay. 12 A. No. My thinking here is really --
13 A. Um -- let me illustrate the next part 13 from looking at the contours of the surge, my
14 of the decision making with a figure. Figure 14 conclusion was that the peak along Reach 2 had
15 15 on Page 26 of my expert report. 15 to be higher than the 17.1 value, just by
16 Q. Okay. 16 looking at the pattern of the surge.
17 A. And in this case I'm relying on the 17 Q. Well, wait, wait. Bruce, here's your
18 fact that I think ADCIRC is getting the general 18 problem. You used the 17.1 to get your
19 pattern of the surge correct. Even though 19 average. So you've already skewed your
20 we're understating the peak surge slightly, 20 results.
21 we -- I believe it's -- because we've used such 21 A. Let's see.
22 good winds I believe we're getting the pattern 22 Q. Look at your Shell Beach east, Shell
23 of the storm surge pretty well. 23 Beach west, and your Reggio. There's your
24 Q. So according to this, we're getting a 24 17.1.
25 green which means that that is about 15 feet? 25 A. True.
81 (Pages 635 to 638)

Page 639 Page 641
1 Q. All right. So you put that in your 1 fact that it went from 8 percent to 16 percent,
2 average. So you can't -- 2 almost double --
3 A. Sure I can. 3 A. I could have.
4 Q. So can put it in, take it out? 4 Q. And the logical thing -- if you were
5 A. Sure. 5 going to buy --
6 Q. Okay. Fine. Okay. You're the 6 A. I could have. I didn't want to get
7 expert. So you used that number to average and 7 too cute --
8 then now you took it out. 8 Q. All right.
9 A. I used the average to -- again, I'm 9 A. -- with that analysis.
10 using -- my reasoning was that the correction I 10 Q. So the point is that you increased the
11 would have to apply is between 8 percent and 11 surge heights by 1 point -- how many feet?
12 16 percent based on those three marks that does 12 A. I'd have to go back and multiply it.
13 include Reggio. So now I'm trying to figure 13 But the peak -- the computed peaks were, you
14 out what should my peak be along Reach 2? And 14 know, 15.7, 15.8, maybe as high as 16, and they
15 so when I look at the contour patterns, my 15 were scaled up such that the peaks ended up --
16 thinking is that the peak along Reach 2 16 you know, the maximums were 17.5, 17.6, 17.4,
17 should -- if I believe these patterns, which I 17 roughly that magnitude.
18 think they're pretty good, it should be greater 18 Q. All right.
19 than 17.1. And so I ended up adopting a value 19 A. And as same said, if you want me to
20 of 17.5. And that's a scaling of approximately 20 provide you those exact numbers I would be glad
21 12 percent. So I increased my high water 21 to do that.
22 marks, you know, from computed peaks in the 22 Q. All right. But the scaling factor
23 vicinity of, you know, approximately 16 to 23 was -- let see if I've got this right. You
24 computed -- to estimate peaks of approximately 24 scaled upward by a factor of 1.12, which is a
25 17.5 feet. 25 percent change of what?
Page 640 Page 642
1 Q. So your assumption was that the water 1 A. It was 12 percent consistent with this
2 level was the same height along the entire 2 table.
3 reach? 3 Q. 12 percent was the number you settled
4 A. No, I scaled them all with the same 4 on. And so 12 percent is -- well, that's 1.12.
5 value. So the model -- the model predicts a 5 So you increased the water level and you guys
6 variation of peak along Reach 2. 6 decreased the heights of the levee. So that
7 Q. Right. 7 would certainly have an impact on overtopping,
8 A. And so do the scaled peaks. 8 wouldn't it?
9 Q. I know. That's what I was very 9 A. What do you mean decreased the heights
10 confused about. How did you plug this into -- 10 of the levee? Clarify that, please.
11 well, you didn't plug it into the model, you 11 Q. Well, you took the LIDAR data and you
12 plugged it into the outputs. So did you just 12 decided to reduce the heights of the levee
13 go to each of those 21 points and change it? 13 based upon LIDAR by one half a foot, and then
14 Is that what you did? You didn't re-run the 14 you cut it in half where there was still a
15 model, you just -- 15 levee. So I mean to be cynical about it, you
16 A. No, I just -- I went to each -- I went 16 reduced the levee height and you increased the
17 to the computed values -- 17 surge heights in all of your work, didn't you?
18 Q. All right. 18 A. No.
19 A. -- for each of the 21 points and 19 Q. Okay.
20 multiplied them by the same factor to get to 20 A. We made the best estimate that we
21 the peak value. 21 could with the data that we had for what the
22 Q. All right. Well, shouldn't you 22 levee and wall heights were along Reach 2,
23 have -- 23 based on both pre and post-storm data.
24 A. The same scaling. 24 Q. Now, your Figure 15, is that another
25 Q. -- used a graduated change given the 25 one of those things that you had your folks
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Page 643 Page 645
1 generate or did you use the Westerink created 1 looks to me like he gets eleven.
2 figure which I think is at Page 166, Figure 2 A. Eleven?
3 137? 3 Q. Eleven.
4 A. No, I had my folks generate these. 4 A. For the base case?
5 Q. They did. 5 Q. Am I reading it wrong no?
6 A. Yes. 6 A. I don't know.
7 Q. And did you -- and so despite the fact 7 Q. Look, like you said, it could be bad
8 that you really don't like to look at these 8 colors, or it might be my lying eyes, but --
9 things, and these computer models have some 9 it's green along -- I see green.
10 possible error in them, you did rely upon this 10 A. It looks like around 16, a little bit
11 I guess you'd call it -- what would you call 11 more than 16, from this plot.
12 this? 12 Q. Okay, 16. That's fine.
13 A. It's a distribution of peak water 13 A. I don't know how you're getting
14 level. 14 eleven.
15 Q. You relied on that for this exercise? 15 Q. Like I say, I trust you, man.
16 A. Yeah. Again, just general shapes of 16 A. You and me. I don't like reading
17 contour patterns. I didn't -- you know, at the 17 stuff off those color maps.
18 end I ended up scaling this, looking at some 18 Q. But 16, and 16 is what you -- I think
19 specific high water marks. 19 Ivor was telling me 16 is what he reports in
20 Q. What did the IPET get as a number for 20 his report. So Westerink gets closer to the
21 the surge height at Reach 2, what number did 21 IPET surge height, didn't he?
22 they use? 22 A. Say that again.
23 A. I'm estimating here. 23 Q. Westerink 's surge number for Reach 2
24 Q. Using the color spatial 24 is closer to the IPET result than you are.
25 distribution -- 25 A. I'm using Westerink's results.
Page 644 Page 646
1 A. No, I was using this graph. These are 1 Q. Okay. And are you're scaling them up?
2 some time series from some points. My estimate 2 Never mind. I'm sorry. Okay.
3 would be 15-1/2 to 16-1/2 at roughly 7:30, 3 So is it a foot -- foot and a half or
4 7:45. 4 is it a foot?
5 Q. 15-1/2 to -- I'm sorry. 5 A. Is what a foot or a foot and half?
6 A. 16-1/2. 6 Q. The scaled number. So it's 12 percent
7 Q. And you're -- 7 so it's going to be --
8 A. 17, that range. 8 A. Roughly a foot and a half to two feet,
9 Q. And you're higher by about a foot, 9 as I remember.
10 right? 10 Q. So it could be as much as two feet.
11 A. The values I'm quoting here don't have 11 A. Okay.
12 wave setup in them, so we've added wave setup. 12 (Brief recess.)
13 Q. Wait. No. The values that we've been 13 EXAMINATION BY MR. BRUNO:
14 talk about don't include wave setup. All we 14 Q. All right. Bruce, you said that you
15 did was alter the hydrographs. 15 would give me -- I'd like for you to give me
16 A. Okay. I got you. 16 for each of the calculations for the 21 points,
17 Q. Let's be fair. 17 so that we can figure out --
18 A. I got you. 18 A. I said that I would do that at a later
19 Q. So your still water heights are about 19 date.
20 a foot higher than the IPET. 20 Q. Oh, yeah. Not now. I'm not asking
21 A. Yeah. These peaks for the SL15 were 21 for you to do it now, but I would is for you to
22 roughly 16, and then here -- yes. Looks like a 22 give it to Rupert and send it to me. Because I
23 little bit less than 17, maybe 16.8, maybe 23 have to tell you, I'm a little confused. When
24 eight tenths of a foot. 24 I multiply the 19 percent times the 15.2, I get
25 Q. And Westerink gets -- my goodness, it 25 a figure, a then I add that to 15.2 which is
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Page 647 Page 649
1 the scaled number, I don't get my 18.7, I get 1 higher than the oranges?
2 less than that. It seems to me that the right 2 Q. No. I'm talking about the round
3 way to do it would be to divide the difference 3 things. You see those?
4 by the measured number and then multiply that 4 A. I think we're talking about the same
5 result times the computed in order to figure 5 thing.
6 out -- I'm sorry -- to divide my 3.5 by the 6 Q. They're all here. These little --
7 15.2, and I get .23. And then when I add .23 7 they're round. They're small round circles.
8 to 15.2 -- it still doesn't come out. 8 A. Okay.
9 18.7 minus 15.2 is -3.5. Then if I 9 Q. Okay? And if that's the MRGO, it
10 take the 3.5 and divide it by 15.2 I get 10 should be represented or it should look like
11 .23 percent. And then if I multiply 23 percent 11 the Mississippi River does, shouldn't it?
12 times -- let's see. If I multiply the 15.2 12 A. Could you rephrase the question?
13 times my .19, I get 2.888. When I add that to 13 Q. In other words, there should be two
14 15.2, I get 18. So I'm seven tenths off. So 14 parallel lines. If that's the MRGO --
15 maybe I'm doing something wrong. 15 A. Is this the base case, Case H1?
16 A. Well, what I'll do is I will provide 16 Q. It's Page 33 of his report, so --
17 you with that, those 21 points, the computed 17 Oh, it's in your report. I'm sorry.
18 peaks -- 18 It's also in yours. Sorry.
19 Q. Great. 19 A. What was the figure?
20 A. -- and the peaks of the estimated 20 Q. We shall find it. 33.
21 hydrographs. 21 A. Page 33?
22 Q. All right. Now, let me show you -- 22 Q. Page 33, yeah. It's Figure 20, and
23 I'll mark this as Exhibit Number 13. I'm going 23 yes, it's Figure 20. You see the beads?
24 to represent these come from -- and I'm happy 24 A. Okay. I think I understand what
25 to attach the cover those, but this comes from 25 you're calling a bead. That's not a term I use
Page 648 Page 650
1 Resio 's report. 1 a lot. So.
2 Have you seen Resio 's report? 2 Q. Well, that's where the MRGO channel
3 (Exhibit 13 was marked for 3 is. And you see that represented --
4 identification and is attached hereto.) 4 A. Approximately somewhere in there I
5 A. No, I have not. 5 would agree. I don't know exactly how you can
6 EXAMINATION BY MR. BRUNO: 6 determine exactly where the channel is from
7 Q. Okay. This is a chart in his report 7 this particular image.
8 which indicates maximum significant wave 8 Q. Well, I'm doing it by logic.
9 height. Okay? 9 A. Yeah. It's following the levee, more
10 A. Okay. 10 or less, so.
11 Q. Would you look at where the MRGO 11 Q. And it's also based upon the
12 should be? You see a series of blobs? Beads? 12 resolution of this model, which I know is not
13 A. I see the high and low areas. 13 very good at this point, it's six hundred and
14 Q. No, the little round circles. 14 some odd feet by six hundred and some odd feet.
15 A. Some kind of -- yeah, some sort of a 15 So in many instances his grid picks up the
16 modulation in the wave height, goes up a little 16 MRGO, and in some instances it doesn't pick up
17 bit, down a little bit, up a little bit? Is 17 the MRGO because the MRGO may be on the edge of
18 that you're describing? 18 one of these six hundred and fifty foot
19 Q. No. I see beads. I see a round thing 19 squares.
20 and then a round thing and then a round thing 20 A. Okay.
21 and a round thing. 21 Q. Right? Does that make sense?
22 A. Okay. 22 A. Well, I know the MRGO in the base case
23 Q. I'm calling those beads. 23 is -- the bankline is highly irregular.
24 A. The darker colors are a little bit 24 Q. Sure.
25 higher than -- the darker reds are a little bit 25 A. Okay?
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1 Q. Irregular or not, if you have a low 1 Bayou Dupre coming up here? I'm looking at
2 resolution model, one that has grids as large 2 Figure 2 in my report. There's kind of an
3 as 650 feet, you have instances where the 3 image.
4 650 feet may capture the whole of the channel 4 Q. I have no idea. I don't know where
5 and then you have grids that may capture only a 5 Bayou Dupre is. But anyway?
6 small portion of the channel. Right? And that 6 A. Well, I think I do. That's where it
7 would account for why these things are -- I'm 7 is.
8 going to call them beads, or if you've got a 8 Q. All right. That's where it is.
9 better word for them I'll use it, but that 9 That's fine.
10 would explain why we're seeing beads on here, 10 A. So that's a little bit north of that
11 because of the resolution. Isn't that true? 11 little bend in the levee.
12 A. You probably have to ask Dr. Resio 12 Q. Okay.
13 exactly -- he's more familiar with the 13 A. Yeah, I think I got it right here.
14 modeling. He's the developer of the model. 14 Q. Now I see beads in that same section,
15 Q. Sure. 15 so I don't know what the point is, but --
16 A. You should ask Dr. Resio. 16 A. I don't see beads in there. I see
17 Q. Well, fine. How about this? Would 17 some areas of high waves, and I see areas of
18 you agree with me that those beads represent 18 low waves -- Lower waves. I don't see areas of
19 wave heights, and the beads reflect, based upon 19 beads.
20 the color chart, wave heights that are higher 20 Is this what you're talking about,
21 inside of those beads than outside the beads? 21 little beads, these little --
22 A. Yeah. That's what I was trying to 22 Q. I'm talking about where you drew, I
23 describe. It looks like some of those areas 23 see right there. In fact, look, here's one.
24 the wave height is a little bit higher than 24 A. This one? Is this a bead?
25 either side. 25 Q. 19? Yeah, I'll show you. First of
Page 652 Page 654
1 Q. Right. And so which really shouldn't 1 all we're going to Westerink. I'm sorry, this
2 be the case, in the case of a -- of the MRGO 2 is our boy, um -- Resio. I see a bead there,
3 channel, they should all pretty much be 3 and I see one there. I see -- where I see a
4 uniform, shouldn't they? 4 channel I see not a continuous channel but I
5 A. Well, I'm looking up in the area that 5 see the channel is cut off. And I'm wondering,
6 matters most, between Bienvenue and Dupre, you 6 given the fact that these happen to coincide
7 know, these areas that you're pointing out -- 7 with your wave chart where there's some waves
8 MR. MITSCH: 8 that are -- seem to be too high, that that
9 And just for the record, why 9 would account for the difference, that is, its
10 don't you just point out on the 10 resolution is what is making those wave heights
11 document where you think that is. 11 appear irregular, because, as you -- I think
12 A. All right. I mean, the area that 12 you agreed with me, the chart at least shows
13 really matters is between Bienvenue and Dupre, 13 that the H2 run has wave heights that are
14 and so I'm going to suggest that, I don't know, 14 higher than the Katrina run. And that might be
15 maybe in there. 15 explained by the fact that his resolution is so
16 EXAMINATION BY MR. BRUNO: 16 big he's not capturing the true waves that
17 Q. You think Dupre is halfway? 17 close in to the MRGO. Isn't that possible?
18 A. I don't know. 18 A. Well, I don't see a lot of beads, as
19 Q. All right. 19 you describe them, in this area that really
20 A. I feel like I'm probably close. 20 matters to this case.
21 Q. Well, there are some beads inside of 21 Q. All right.
22 what you've drawn. 22 A. And I do see areas of slightly higher
23 A. Hang on. I got a little map here. 23 waves and slightly lower waves. And I -- as we
24 Yes. I think I got it pretty good. I 24 described earlier, spectral wave transformation
25 think I have it real good. Right. Isn't this 25 over irregular topography oftentimes produces
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Page 655 Page 657
1 areas of slightly higher waves and slightly 1 they change all the time, for your purposes?
2 lower waves. 2 A. The waves I used were at whatever
3 Q. Page 32 of your report? 3 occurred at those 21 locations.
4 A. So there's nothing here that sort of 4 Q. All right.
5 alarms me, but, you know, I encourage you to 5 A. And when I look at these, I'm looking
6 talk to Dr. Resio about resolution and 6 for general patterns, increases, decreases --
7 influences of resolution. 7 Q. Okay.
8 Q. I didn't suggest you needed to be 8 A. -- lowering. I don't maybe put quite
9 alarmed. But if you look at Figure 19, do you 9 as much stock as you do in those small
10 see any beads in that location? 10 fluctuations of wave height from one location
11 A. Figure 19? 11 to the next. These small changes in wave
12 Q. Page 32. Your report. Do you see any 12 height are not going to dramatically influence
13 beads there? Or are they nonexistent? 13 the overtopping rates that are really driving
14 A. Um -- gosh, you got a blowup? You 14 the degradation along this critical reach.
15 guys were merciful and gave me a blowup of 15 Q. How did you validate the
16 other one. You got a blowup of this one? 16 characterization of surge that developed during
17 Q. No, I don't. I think the beads are 17 Hurricane Katrina which you document in your
18 clear in that one, but since they're not clear 18 report, that is, how did you validate your
19 to you I thought we'd look at your own report. 19 scaling?
20 A. Again, I'm looking at the area of 20 A. Validate my scaling.
21 interest. I don't see a whole lot of beads out 21 Q. Yeah.
22 there. 22 A. Well, the surge model has been
23 Q. You see some beads? 23 extensively validated with high water marks and
24 A. I see some areas as high wave and low 24 hydrographs. My scaling is simply an attempt
25 wave, and that is not uncommon in cases of wave 25 on my part to -- knowing that the model has
Page 656 Page 658
1 transformation over irregular topography. 1 some consistent underestimation in an area that
2 Q. And Figure 20, do you also not see 2 I'm interested in, the scaling is my attempt to
3 some beads? 3 get closer to what I believe actually was
4 A. Not up in the area. Again, I'll 4 present along that levee.
5 restate, I see some areas of higher waves and 5 Q. All right.
6 some areas of lower waves. 6 A. So it's not a validation issue, it's
7 Q. Figure 22, you also don't see any 7 my attempt to get as accurate as I can be and
8 beads in that same area. 8 make the assessment of --
9 A. Not in the little box I just drew on 9 Q. Okay.
10 Exhibit 13, I don't -- 10 A. -- waves and water levels and
11 Q. You don't see two circles? 11 degradation of that levee.
12 A. -- see what I would consider beading. 12 Q. How did you validate the
13 Q. I see two circles right at the orange 13 characterizations of waves that you
14 where it says -- right where the orange 14 developed -- I mean that developed during
15 contacts the yellow line. 15 Hurricane Katrina that you document in you
16 A. Yeah. 16 report? How were those validated?
17 Q. No beads there either. 17 A. Again, I think the wave models that
18 A. Not as you've described them. I 18 we're using have been validated for this
19 see -- I do see areas of higher wave and lower 19 particular region to the greatest extent
20 wave. 20 possible with admittedly limited wave data.
21 Q. All right. Well, which -- 21 And the COULWAVE model has undergone
22 A. I think you ought to just talk to 22 considerable validation. So me personally? I
23 Dr. Resio about this beading issue. 23 did no additional validation.
24 Q. What waves did you pick, the ones that 24 Q. You've documented best estimates of
25 were higher or the ones that were lower, since 25 the environmental conditions associated with
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Page 659 Page 661
1 Hurricane Katrina. What are the uncertainties 1 though, they're -- range from -1.6 to
2 or the error bands associated with the 2 +1.6 feet.
3 Hurricane Katrina environmental characteristics 3 Q. Okay.
4 that you've used in your analysis? 4 A. So I think most of that error would be
5 A. Wow. That was a mouthful. Could you 5 within that range. But there are some areas
6 maybe break that down into some shorter 6 that are more than that. That kind of error
7 questions, please? 7 just strikes me as being on the order of maybe
8 Q. All right. Well, what is the error 8 10 percent, 15 percent error on peak surge.
9 band associated with the Hurricane Katrina 9 Q. Okay.
10 environmental characteristics that you've used 10 A. I think that's excellent for storm
11 in your analysis? 11 surge modeling, just based on my experience in
12 A. By environmental -- what do you mean 12 other applications of models and comparisons
13 by environmental? I don't understand that term 13 with that.
14 in this context. 14 Q. All right. That's fine. It is what
15 Q. All right. The winds, the various 15 it is.
16 inputs into the model, what are the 16 A. So, um -- wind? I can't really
17 uncertainties of the error band associated with 17 comment on wind. I'd have to really -- you
18 each of those inputs? 18 should really talk to someone like a Vince
19 A. Um -- on the storm surge, I think you 19 Cardone from an Ocean Weather or a Mark Powell
20 want to go look at that figure -- 20 from the Hurricane Research Division. And they
21 THE WITNESS: 21 can provide you with information on the
22 You showed me, Rupert a figure 22 accuracy of the wind products that they
23 from the Westerink report. Let's see 23 produced for us which we've used in our wave
24 if we can find that. Maybe the one 24 and surge modeling.
25 that showed magnitude of differences 25 Q. Would you know how the COULWAVE model
Page 660 Page 662
1 between computed -- 1 has been validated for the purposes for which
2 MR. MITSCH: 2 it was used? Or is that a question better
3 Is that it? 3 asked of Resio?
4 THE WITNESS: 4 A. A question better asked of Dr. Resio.
5 -- and measured. 5 Q. Okay. Do you know if -- what SOA is?
6 EXAMINATION BY MR. BRUNO: 6 A. SOA?
7 Q. Where are you? 7 Q. Analytical model?
8 A. I'm on -- in the Westerink expert 8 A. SOA.
9 report -- 9 Q. SOA.
10 Q. All right. 10 A. The letters?
11 A. -- Pages 171 and 172. And I believe 11 Q. Well, have you ever heard of an SOA
12 what we're looking at here is predicted versus 12 analytical model. State-of-the-art analytical
13 measured peak storm surge values. And the 13 model as opposed to a state-of-the-practice
14 colors are indicating the magnitude of the 14 analytical model. Have you ever heard of those
15 difference between the predicted and observed. 15 two phrases?
16 And so -- 16 A. What was the first one?
17 Q. Okay. 17 Q. State-of-the-art analytical model
18 A. -- I think -- 18 versus a state-of-the-practice analytical
19 Q. So the error band would be those two 19 model. Are those phrases that you're aware of
20 lines? 20 or use?
21 A. Yes. 21 A. Yeah. I've used those phrases. I'm
22 Q. Those two light blue lines? 22 aware of them.
23 A. Yes. So -- well, you can see the 23 Q. Do you know whether COULWAVE is one of
24 discrepancies. You know, they range from 24 or the other? Or should I ask Dr. Resio?
25 -5 feet to +3 feet. I would say, in general, 25 A. I think Boussinesq type models are
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Page 663 Page 665
1 state-of-the-practice. I would consider all 1 told me, the soil or the sediments underneath
2 those models state-of-the-practice right now. 2 the grass of the actual levees on Reach 2.
3 Q. Okay. 3 A. No, there's such sparse data available
4 A. You're welcome to solicit his opinion 4 about the composition of the levees.
5 there, as well. 5 Q. All right. In Section 1 of Section IV
6 Q. In your report at Section 4 -- IV, you 6 of your report at Page 57, you summarize in
7 cite the large number of factors that influence 7 detail your analysis of the performance of the
8 levee erodibility. 8 levees along the GIWW, that's east of the
9 A. Can you direct me to a page, please? 9 Michoud Canal.
10 Q. Page 53. You with me? 10 A. Yes.
11 A. I'm on Page 53. 11 Q. Why did you not assess this
12 Q. All right. Well, are you -- have you 12 performance for the New Orleans East back levee
13 found where you cite the large number of 13 that was comprised of dredged spoil?
14 factors, since you need to follow me? 14 A. I really focused on the levees that --
15 A. No. Could you help me? Which 15 the sections of levees that were degraded.
16 paragraph? 16 Q. Okay. It says, in this section of
17 Q. I don't know. I'm just giving you a 17 your report you draw a large number of
18 reference. These include the maximum 18 inferences based upon photographic evidence,
19 storm-induced water level which is the single 19 soil boring results and reported grass cover
20 most important hydrodynamic parameter, the 20 condition. Have you performed any quantitative
21 incident wave conditions and the duration of 21 analysis of the performance of these earthen
22 high water levels and wave conditions, these 22 flood protection structures?
23 conditions also include the erodibility of the 23 A. Yeah. I would certainly consider the
24 sediment or soil comprising the levee and by 24 analysis I did using the Dutch model to look at
25 grass cover and how it resists the onset of 25 wave-induced erosion to be a quantitative
Page 664 Page 666
1 erosion -- that's at Page 55. 1 analysis.
2 Would you tell me how these conditions 2 Q. That's the only one. Right?
3 were evaluated based upon the COULWAVE 3 A. Well, I consider what I did with
4 velocities? If you know. Or should we ask 4 overtopping rates and use of those rates to
5 Dr. Resio? 5 look at damage of levees due to overtopping, I
6 A. You know, I used the COULWAVE 6 consider that to be a quantitative analysis.
7 velocities to -- in my report to describe some 7 Q. Okay. In this same section you
8 of the magnitude of velocities on the crest and 8 address erodibility. The results for ILIT
9 the backside and show just how extremely large 9 flume tests. Have you used results from those
10 they are once overtopping begins and conditions 10 tests, the ILIT flume tests?
11 progress towards massive overtopping. 11 A. No. I concluded those results were
12 Q. Uh-huh. 12 essentially useless.
13 A. And I used the overtopping results 13 Q. Have you consulted with Dr. Jean-Louis
14 from the COULWAVE model and wave setup values. 14 Briaud?
15 Q. All right. What did you use to 15 A. No.
16 evaluate the erodibility of the sediment of 16 Q. Dr. Briaud provided any information
17 soil comprising the levee and grass cover? We 17 which you have incorporated with or without
18 know what you used for grass cover, you used 18 reference in your expert report?
19 the Dutch stuff. What did you use for 19 A. No, for that material I relied upon
20 erodibility of the sediment or the soil which 20 the ILIT report that I cite in my report as a
21 was comprising the levee? 21 reference.
22 A. Well, to look at the issue of front 22 Q. Do you know Dr. Jean-Louis Briaud?
23 side erosion due the wave action I used that 23 A. No.
24 Dutch model. For grass-covered clay levees. 24 Q. No?
25 Q. You didn't evaluate, I think you've 25 A. No. We have a number -- we use
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Page 667 Page 669
1 similar types of flumes in our research, and we 1 device, just like the, um -- the flume that was
2 have a number of in-house experts in that 2 used, the EFA flume that was used in the ILIT
3 particular area. I rely on them during 3 report, we have a lot of concern that that
4 preparation of this material. 4 device is not an accurate representation of the
5 Q. The IPET studies involve in situ 5 hydrodynamic loadings that occurred on those
6 measurements of erodibility of the levee 6 levees during the storm. So we would question
7 sediments. How did you use this information in 7 results that are obtained using that type of an
8 development of your quantitative analysis of 8 erosion device.
9 the performance characteristics of the earthen 9 Q. Have you performed any integrated
10 protection, flood protection structures? 10 quantitative analysis of the performance of the
11 A. That was multiple questions. Could 11 earthen flood protection structures during
12 you break that down for me, please? 12 Hurricane Katrina?
13 Q. No, it's one question. It says -- 13 A. Could you repeat that, please?
14 A. It sounded like two to me. 14 Q. Have you performed any integrated
15 Q. Well, it's one. One is a statement. 15 quantitative analysis of the performance of the
16 The IPET studies -- 16 earthen flood protection structures during
17 A. Can we forget about the statement and 17 Hurricane Katrina?
18 just ask the question? 18 A. Yes. I would consider which table
19 Q. Well, I have to say how did you use 19 that we discussed earlier where we're stepping
20 this information, so if I leave out the 20 through time and looking at the magnitude of
21 statement you'll want to know what this 21 overtopping rate and linking that back to the
22 information is. 22 thresholds for levee damage as well as looking
23 MR. MITSCH: 23 at the potential for front side wave erosion to
24 All right. Let's start over 24 be a quantitative analysis.
25 again. 25 Q. Have you -- in the recently published
Page 668 Page 670
1 EXAMINATION BY MR. BRUNO: 1 30 September 2008 document titled Certification
2 Q. Do you think you can follow -- 2 of Levee Systems for the National Flood
3 A. No. You know, it's a long -- you're 3 Insurance Program, which is the document that I
4 reading a lot of text fast. It's hard to -- 4 showed you a moment ago --
5 Q. I'm reading three sentences. I hardly 5 A. Yes.
6 think that's a lot of text. 6 Q. -- it says -- the Corps states,
7 A. Well, you're reading very fast, and 7 whether or not wave overtopping degrades a
8 it's hard for me to sort of get my arms around 8 levee depends upon the overtopping magnitude
9 it. 9 and subsequent velocities at the crest and on
10 Q. Well, I'm being told I don't have any 10 the protected side, soil properties, vegetation
11 time left, so I have no choice. 11 cover, duration of overtopping, presence and
12 A. Okay. 12 nature of pertubations on the protected slope,
13 Q. The IPET studies involve in situ 13 and the levees quality of construction and
14 measurements of erodibility of the levee 14 maintenance.
15 sediments. That's a statement. 15 Have you taken all of these factors
16 How did use this information in 16 into account in the analysis documented in your
17 development of your quantitative analysis of 17 report?
18 the performance characteristics of the earthen 18 A. Could you repeat that? That was a
19 flood protection structures? 19 mouthful for me to digest.
20 A. I didn't use them. 20 Q. All right. The Corps states that
21 Q. All right. Why not? 21 whether or not wave overtopping degrades a
22 A. Um -- I know the particular erosion 22 levee depends upon the overtopping magnitude
23 device that they use, and in my opinion and 23 and subsequent velocities at the crest and on
24 talking to experts in our group, we have 24 the protected side, soil properties, vegetation
25 concern about whether that particular erosion 25 cover, duration of overtopping, presence and
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Page 671 Page 673
1 nature of pertubations on the protected slope 1 at a time after some --
2 and the levee 's quality of construction and 2 A. No, as I said, I focused on
3 maintenance. 3 overtopping and front side erosion due to
4 Have you taken all of these factors 4 waves.
5 into account in the analysis documented in your 5 Q. Okay. All right. So I'm trying to
6 expert report? 6 understand. I understand that in retrospect or
7 A. I've taken them into account to the 7 looking in hindsight other failure modes may
8 greatest extent I can with the information that 8 not be appropriate, but it seems like this is
9 I have available to me. 9 again result oriented. You started with the
10 Q. Did you study vegetation as it may 10 notion that overtopping was the answer, and
11 impact wave amplitude or period? 11 so --
12 A. I personally did not, but I know that 12 MR. MITSCH:
13 was considered as a factor in our wave modeling 13 Objection.
14 changes to roughness associated with different 14 EXAMINATION BY MR. BRUNO:
15 types of vegetation. 15 Q. -- we are now eliminating by exclusion
16 Q. Have you considered the contribution 16 without evaluating each one individually.
17 of the MRGO to the death or loss of vegetation 17 Isn't that what you're doing?
18 resultant from saltwater intrusion in 18 MR. MITSCH:
19 connection with your analysis of the degree to 19 Objection. Misstates what he
20 which the MRGO either did or did not affect 20 said.
21 waves? 21 A. No. Could you rephrase the question?
22 A. Well, we did look at different 22 EXAMINATION BY MR. BRUNO:
23 alternatives, and our assumption was that all 23 Q. Well, as I said, there's two ways to
24 the wetland change that has occurred since 24 approach a problem. One way is to identify
25 construction was attributed to the MRGO. Now, 25 each of the potential modes of failure,
Page 672 Page 674
1 I don't know whether that's a fact, whether one 1 evaluate them to determine whether or not those
2 can really attribute all the wetland change 2 are legitimate modes and then decide which one
3 that has occurred to the MRGO or to subsidence 3 is the most likely. The other possible way is
4 or to whatever other causative factor, but we 4 to say, okay, overtopping is the one, and then
5 did model alternatives where we used pre-MRGO 5 try to find a way to explain why the other ones
6 and current wetland conditions, and we 6 don't apply.
7 looked -- we factored in the changes that have 7 A. I don't have the expertise to look at
8 occurred regardless of their causative 8 foundational subsurface modes of failure. My
9 mechanism. 9 area of expertise is in areas that allow me to
10 Q. Now, based upon your testimony these 10 look at the two modes of failure that I've
11 past two days, am I given to understand that 11 concentrated on.
12 the only failure modes that you looked at were 12 Q. Isn't one mode of failure the
13 overtopping and front side attack by waves? 13 materials of construction of the levee?
14 A. These are the areas that I feel most 14 A. Well, I think the composition and
15 qualified based on my expertise to look at. 15 characteristics of the sediment in that levee
16 Q. Are these in your opinion the only 16 is a factor in its erodibility.
17 possible failure modes on those levees on Reach 17 Q. All right.
18 2? 18 A. But I can point to areas where soils
19 A. I think other modes are possible, 19 apparently of many different types were
20 unlikely in my opinion, because I believe the 20 severely degraded. And there's just very
21 overtopping was so dominant and so overwhelming 21 sparse data to really characterize the
22 that I think that was by far the dominant mode 22 erodibility of the sediments and how that
23 of failure along that Reach 2. 23 varies along the levee.
24 Q. Did you make a list of potential 24 And I don't consider the work done by
25 failure modes and sort of scratch them out one 25 ILIT to be done very well, and I don't consider
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1 the results to be of any real use. 1 uncertain as the Corps of Engineers says in the
2 Q. Would you agree that the evaluations 2 document?
3 that you've utilized were mostly qualitative 3 A. Um -- I think crude in the sense
4 methods? 4 there's a lot yet that remains to be learned
5 A. No. I think in previous answers I 5 about erodibility. But it's our current
6 have I think adequately described the 6 guidance, and it's what we use and it's what we
7 analytical analyses that I've done. 7 rely on, and -- you know, that's just what we
8 Q. All right. You've indicated that the 8 do.
9 grass cover present on the surfaces of the 9 Q. Okay.
10 earthen flood protection structures were an 10 A. But I would admit there's plenty of
11 important part of your forensic engineering 11 room to improve, and that's why we do research
12 analysis -- 12 in this area.
13 (Off the record.) 13 Q. In your analysis of the work done by
14 EXAMINATION BY MR. BRUNO: 14 Professor Bea, you say that there is a very
15 Q. The grass cover present -- you've 15 large number of potential limitations, flaws
16 indicated to us already that the grass cover 16 and defects. What are the potential
17 was a very important part of your forensic 17 limitations, flaws and defects in Bea 's work?
18 engineering analysis. Is it true that the 18 A. Well, let's go through -- I have a
19 height, density, root structure, substrate all 19 whole appendix on that subject. If you like,
20 affect the performance of grass cover? 20 we can go through item by item.
21 A. I think -- I mean, I can see where the 21 Q. All right.
22 grass cover certainly influenced the presence 22 A. It's Appendix D. I think your paging
23 or absence of a wave-induced erosion zone on 23 is different. It's 231 in my copy. Page 231.
24 the front side. I haven't made any statements 24 Q. I got it.
25 about the role of grass cover on the backside. 25 A. Would you like me to go through one by
Page 676 Page 678
1 The velocity regime, the overtopping rates, 1 one by one?
2 they were so large that I don't think grass 2 Q. Sure.
3 cover was much of a factor at all on the 3 A. Okay.
4 backside in those areas that were most heavily 4 Q. How -- are we going to the numbers?
5 degraded been Bayou Bienvenue and Bayou Dupre. 5 A. Yes. And I grouped the issues under
6 Q. You've already told us that local 6 velocity forcing as one set of issues, this
7 vegetation is an issue for Dr. Resio, not you. 7 lift off of grass turf as a set of issues, and
8 A. Yes. 8 then levee erosion would be a third set of
9 Q. All right. In the appendix to the 9 issues.
10 levee breach certification manual, again, it 10 Q. Okay.
11 says that current coastal engineering -- 11 A. So let's start with the velocity
12 A. I think that was levee certification 12 forcing.
13 ETL draft. 13 Q. All right.
14 Q. Yes. 14 A. The issue here is the LS-DYNA model
15 A. Okay. 15 has not to my knowledge been successfully
16 Q. Current coastal engineering design 16 applied to simulate wave breaking in the surf
17 practice is to use an overtopping discharge 17 zone and run-up overtopping of a sloping
18 rate threshold to define the onset of levee 18 coastal levee structure. It's not a commonly
19 damage. You've already told us that. 19 used technology that I've run across in the
20 A. Yes. 20 field of coastal engineering. I'm not aware
21 Q. They say, these overtopping rate 21 that it's been applied for this particular type
22 thresholds are rather crude and uncertain. 22 of application before.
23 Do you agree with that? 23 Q. Well, you don't use models for this
24 A. There's some uncertainty. 24 purpose at all in your work. You've already
25 Q. Are they, in fact, rather crude and 25 told me that. So what difference would it make
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1 if you haven't come across it or not? 1 A. Who's y'all?
2 A. It's used -- I know our structures and 2 Q. Y'all would be you and your brothers
3 geotech use it for blast load effects and 3 at the Corps.
4 structural analysis, but I'm saying for this 4 A. Dr. Resio -- his work involved
5 particular application of surf zone wave 5 application of COULWAVE.
6 transformation, breaking, run-up, overtopping, 6 Q. Didn't do it to the front side of the
7 under extreme waves and water levels, I have 7 levee for reasons that we haven't yet
8 never seen an application. That doesn't mean 8 discovered. Well ask him that on Monday, but
9 it's not out there -- 9 he didn't do that.
10 Q. Right. 10 A. Well, I'm sure the model calculates
11 A. -- but I haven't seen it. 11 information on the front side. I don't think
12 Q. All right. But the Corps uses 12 it was produced as output. But it does
13 LS-DYNA. 13 calculate wave characteristics and velocities
14 A. For other types of applications that 14 on the front side just like it does on the
15 have no relationship to the kind of processes 15 crest and on the backside.
16 that we're talking about here. 16 Q. What other models do what Bea wanted
17 Q. You say other models that simulate the 17 DYNA to do?
18 same processes and have a more extensive 18 A. COULWAVE. I think Bous2D would, but
19 experience base are applied and are available. 19 I'm not 100 percent certain on that. But
20 A. Yes. Like COULWAVE, this a valid -- I 20 COULWAVE definitely would do what he's done.
21 would consider that class of model, or other 21 Q. Okay. Who would we ask about Bous2D?
22 Boussinesq classes of models. But Corps has a 22 A. Um -- our proponent at Coastal and
23 model that's available, Bous2D. So there are 23 Hydraulics Lab is a man named Zeki Demirbilek.
24 other models that are available of this 24 In my view, COULWAVE is a bit more
25 Boussinesq class of model. 25 advanced than the model that --
Page 680 Page 682
1 Q. They're available, but apparently you 1 Q. All right. Okay.
2 guys decided not to use them. Right? 2 A. -- we have, the Bous2D model.
3 A. We use COULWAVE. It's our opinion 3 Q. Now, when you say LS-DYNA model is
4 that's -- 4 used to compute shear velocity, by Bea, or is
5 Q. Front side attack? You didn't use it 5 that what it's used for? I didn't understand
6 for that, right? 6 your sentence.
7 A. Could you rephrase the question? 7 A. You know, from Bea 's report -- which
8 Q. You didn't use those models to 8 one are you on, Item Number 1?
9 evaluate front side attack. Didn't do it. 9 Q. 2.
10 A. We -- 10 A. 2? It was my impression from his
11 Q. You said they're available, they're 11 model he somehow must be calculating a bottom
12 out there. 12 velocity and either the model calculates a
13 A. I'm talking about waive 13 shear velocity, um -- or he's coming up with a
14 transformation. That's the one I'm referring 14 shear velocity another way. It's a little
15 to. 15 unclear, but at the end of the day he comes out
16 Q. Well, you said something that would do 16 with a velocity that he then -- upon which he's
17 what LS-DYNA -- I'm sorry, maybe I got 17 then estimating, I believe, a shear stress, and
18 confused. You tell me that the purposes for 18 then he uses those shear stresses in, along
19 which Bob Bea used LS-DYNA, there are other 19 with a relationship between vertical erosion
20 models which would have done the same thing. 20 and either shear stress or shear velocity to do
21 Did I get that wrong? 21 his computations. If I remember, there was
22 A. COULWAVE would do the same kind of 22 some figures that on the horizontal axis had
23 calculations. COULWAVE is available. 23 shear velocity and some had shear stress, and
24 Q. Fine. But you all didn't use COULWAVE 24 it was a little bit difficult to determine
25 to do what he did. 25 exactly what he was doing, but I think he's
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Page 683 Page 685
1 calculating a velocity with the model. 1 Q. Good. You say rigorous validation
2 Q. So the first sentence is intended to 2 should be done to examine model skill in
3 describe what Bob Bea is doing? 3 predicting the hydrodynamic variables that are
4 A. It's my understanding, yes. 4 used in the erosion model, namely velocity --
5 Q. Well, you wrote the sentence. 5 okay. So you're saying this is some stuff hat
6 A. Yeah. I just said it's my 6 should be done, but you're really not saying
7 understanding. 7 that what he's done is wrong. Are you?
8 Q. It's your understanding of what you 8 A. No. Skeptical.
9 wrote? 9 Q. That's fair. I mean, but you can't
10 A. No, it's my understanding that the 10 say that his results are wrong. You can simply
11 LS-DYNA model is used to compute shear 11 say that there's no validation for the model,
12 velocity. 12 but you're not able to say that his results are
13 Q. All right. So you were referring to 13 inaccurate, can you?
14 Bea. And then you say, it's unclear if it's 14 A. I don't know. There's some strange
15 ever been validated for velocity profile 15 things in his results that lead me to be
16 predictions or bottom velocity predictions in 16 skeptical.
17 the surf zone. Unclear meaning? 17 Q. Okay. Have you read Bob Bea 's
18 A. It's not clear to me. I have no 18 deposition?
19 knowledge that that model has ever been 19 A. I've read the two documents that are
20 validated in terms of its skill to simulate the 20 referenced in my report.
21 bottom velocities at the bed that he's going to 21 Q. Well, weren't you on the computer
22 then use in his erosion modeling. 22 listening to his deposition?
23 Q. All right. And so in your opinion 23 A. No.
24 that means you can't use the model? 24 Q. Okay. And have you read his
25 A. I would never recommend we use a model 25 deposition?
Page 684 Page 686
1 that has not been validated. 1 A. If it's not one of those two documents
2 Q. I didn't ask you that. Does that mean 2 that are listed in our reference list I have
3 you can't use it? 3 not read it.
4 A. Sure, you can use it. I just -- I 4 Q. Okay. Well, because you seem to be
5 wouldn't put any confidence in the results if 5 asking questions in your Appendix D, and those
6 it hasn't been validated. 6 questions were asked of Bob Bea in his
7 Q. Well, the first time you use a model 7 deposition, so I would assume --
8 it hadn't been validated, has it? 8 A. Someone may have taken my appendix and
9 A. Yeah. In a research mode, sure. 9 used that as a basis for asking their own
10 Q. So -- 10 questions. I did not -- I was not logged into
11 A. This -- I don't think this is about 11 that process.
12 research. 12 Q. I didn't mean that. I mean, you have
13 Q. I thought everything the IPET folks 13 how is shear stress and shear velocity computed
14 did was research. 14 in the EFA erosion flume, question mark?
15 A. No, it was a forensic engineering 15 A. Uh-huh.
16 study. 16 Q. There's a series of questions. So I
17 Q. You told me you weren't doing a 17 would presume that you would like to have
18 forensic -- You're not a forensic engineer. 18 answers to those questions in order for you to
19 A. I didn't say that. I think I told you 19 complete your opinion. Or is your mind already
20 that -- 20 made up?
21 Q. You are a forensic engineer? 21 A. Well, um -- I guess it's made up in
22 A. -- in my view -- IPET was a forensic 22 the sense that I think the erosion modeling is
23 engineering study. 23 so bad and has such high degree of uncertainty,
24 Q. And you are a forensic engineer. 24 and some of his assumptions about how he's used
25 A. I'm not. I'm a coastal engineer. 25 a wave height from a spectral energy based
93 (Pages 683 to 686)

Page 687 Page 689
1 spectral model, and incorrectly related that 1 Q. How did you -- I know how you got to
2 significant height to the height of a 2 the trigger point, we've gone into detail
3 monochromatic wave, I think all those factors 3 there. But how did you reach the conclusion
4 cast so much uncertainty, and there are so many 4 that significant head cutting and degradation
5 other factors, that I don't believe the results 5 occurred due to overtopping lowering the wave
6 there I reviewed in those reports are accurate 6 crest at that point?
7 at all. 7 A. Well, I think if you looked through
8 Q. All right. So you asked these 8 that whole body of photographic evidence you
9 questions but you don't really care what the 9 see many great examples of head cutting in
10 answers are. 10 various stages, from things that are just
11 MR. MITSCH: 11 initiating on the backside to examples where
12 Objection. 12 the head cuts have advanced completely through
13 EXAMINATION BY MR. BRUNO: 13 the levee crest.
14 Q. Based upon what you've told me, it 14 Q. Well, I get that. You're looking at
15 doesn't matter what the answers are. 15 pictures again. But how did you determine that
16 A. If you would like to answer them for 16 that occurred at the 1 to 1.5-foot point? What
17 me, that will be fine. 17 was the scientific method utilized?
18 Q. Would it make a difference? 18 A. Well, I'll think we covered this
19 A. Um -- 19 yesterday.
20 Q. Probably not. 20 Q. Well, I thought yesterday we talked
21 A. I don't know. 21 about the trigger point.
22 MR. MITSCH: 22 A. No. We talked about -- if you recall,
23 Depends on what the answers are. 23 we were discussing how the overtopping rate is
24 A. Depends on what the answers to these 24 beginning, and once it begins and exceeds some
25 questions are. 25 of the thresholds in the current guidance, the
Page 688 Page 690
1 EXAMINATION BY MR. BRUNO: 1 assumption is erosion would have begun. And
2 Q. So that your opinion might change. 2 then when we got to rates that were as high as
3 Right? 3 those for which we defined the trigger point,
4 A. Um -- possible but unlikely. 4 the assumption was that at that point levee
5 Q. Well, that's what I just said, I 5 lowering would have begun.
6 thought, before your counsel gave me the 6 Q. Did I get this wrong? But I thought
7 answers, but -- 7 you said the trigger point was one foot below
8 A. Yeah, possible but unlikely. 8 the levee crest.
9 Q. So there's really no point in Bob Bea 9 A. That's correct. And if I recall, it
10 answering these questions because it's unlikely 10 corresponded to an overtopping rate of say .5
11 that you're going to change your opinion. 11 to 1 cfs per foot. That put us well into that
12 A. That would be for someone else to make 12 midpoint range of the damage according to our
13 that decision. 13 current guidance.
14 Q. Okay. Can you describe Resio's 14 Q. All right. Well, then, I'm confused
15 generic levee profile? 15 because you said the one foot was the trigger
16 A. I don't have it in my report. I 16 point which is the point where damage starts.
17 assume it's displayed in his report. I don't 17 And then in your report you --
18 know that for a fact. 18 A. No, the trigger point is the point at
19 Q. Did you provide any information in 19 which lowering of the levee crest starts. I
20 order for him to create his generic levee 20 believe erosion and damage to the levee would
21 profile? 21 have occurred earlier than that.
22 A. We've provided him with levee 22 Q. So at one foot, you said that that's
23 elevations. 23 when the top of the levee fell off.
24 Q. All right. 24 A. That's when the crest began to lower.
25 A. Levee crest elevations. 25 Q. And that's true everywhere where there
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Page 691 Page 693
1 was a breach. 1 Q. I know. I'm saying, you guys think
2 A. We assumed that was the case because 2 about the idea before you saw the plaintiffs'
3 we only located breaches in the HEC-RAS 3 reports about running these models with no MRGO
4 modeling where massive degradation of the levee 4 and putting the pre-MRGO topography and
5 actually occurred. 5 vegetation back in place?
6 Q. Okay. Are you familiar with the 6 A. I really can't recall the exact
7 changes that have been made to the ADCIRC SO8 7 process that led us to the alternative that we
8 by the LSU Hurricane Center? 8 simulated. There was discussion, I know, about
9 A. In what time frame? Any changes? 9 what those cases would be, but I don't recall
10 Q. Well, the changes that were made by 10 those conversations.
11 them for their use as they're currently using 11 Q. In your report, you say -- you
12 the SO8. 12 describe -- let me be precise -- MRGO, and you
13 A. No. 13 say it's --
14 Q. So you have no way to compare the SO8 14 A. Can you point me to somewhere in my
15 as used by Paul Kemp and/or Ivor van Heerden to 15 text?
16 the SO8 as you have used the SO8. 16 Q. Give me two seconds and I will.
17 A. I've not used SO8. 17 A. Okay.
18 Q. Okay. Well, you have no way to 18 Q. Yeah. Page 7. You say, the
19 compare what they did at all since you don't 19 channel -- you might be able to answer this
20 know what the changes are that they made. 20 without --
21 A. True. 21 A. Which paragraph?
22 (Brief recess.) 22 Q. The first one.
23 EXAMINATION BY MR. BRUNO: 23 A. Okay. Under scope of report?
24 Q. All right. I'm jumping around because 24 Q. Yes.
25 I'm trying to get as much done as I possibly 25 A. Okay.
Page 692 Page 694
1 can. 1 Q. You say, and historic changes to the
2 MR. MITSCH: 2 surrounding wetlands. Do you see that?
3 We're at seven hours now, so if 3 A. Yes.
4 you've got a question or two that you 4 Q. What does that refer to?
5 want to do, I'll let you do it, but -- 5 A. The historic changes would be those
6 MR. BRUNO: 6 changes that have occurred since construction
7 I have a lot of questions to do. 7 of the MRGO.
8 MR. MITSCH: 8 Q. Can you describe them to me?
9 Well -- 9 A. Well, I know in our analysis we I
10 EXAMINATION BY MR. BRUNO: 10 think settled upon -- if I recall correctly, a
11 Q. I have, if wave front erosion 11 1956 map was the basis for our determination of
12 occurred, would evidence of that be removed due 12 what the wetlands was like before, um -- the
13 to the high flows through the breaches that 13 MRGO --
14 occurred afterwards? 14 Q. All right.
15 A. Possibly. It would certainly depend 15 A. -- construction.
16 on the degree of degradation that's occurred. 16 Q. I know, but what kinds of things are
17 Q. Okay. Thank you. Did it occur to any 17 we talking about, I mean, exactly? Or can you
18 of your team to do a what we call a hurricane 18 tell me?
19 neutral MRGO or a model without the MRGO with 19 A. Well, certainly we looked at removing
20 the wetlands in place before the plaintiffs did 20 the channel.
21 so? 21 Q. Okay.
22 A. Um -- 22 A. Um -- we looked at the effect of a
23 Q. Did you understand my question? 23 changing wetland condition, um -- the 1956
24 A. Can you restate the question? I'm 24 condition versus the -- called the Katrina
25 just getting tired. 25 condition in 2005.
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Page 695 Page 697
1 Q. All right. Well, I'm trying to 1 Q. Well, can you tell me this: I know
2 understand what that means. For example, does 2 you just described it, but you didn't do it.
3 it mean that the land is higher or lower? 3 So who was the guy who was in charge of
4 A. Well, I can go back to the 4 evaluating just what it is is contemplated by
5 description. Let's go back to the description 5 H3?
6 of the alternatives. 6 A. The guy.
7 Q. Okay. 7 Q. Yeah. I mean, all you have is a
8 A. We can talk about my understanding of 8 description. Your papers are not going to help
9 those. 9 you, because the papers you told me are your
10 Q. I don't recall where that was. 10 best understanding of what H3 is. But who was
11 A. I am not the one who put together the 11 the person who then took that idea and put it
12 these different configurations, so I can't give 12 in a model? That's what I'm trying to figure
13 you much detail. 13 out. Who made the determination, okay, this is
14 Q. You figured my next question. 14 what we're going to do, we're going to do A, B,
15 A. Okay. You want to ask it? 15 C, D and E?
16 Q. Well, you answered it. 16 A. I don't recall who made the decision
17 A. Okay. 17 of what the wetland condition was that we were
18 Q. Who wrote it? I was going to ask you 18 going to use to represent the pre-MRGO
19 who wrote those descriptions? 19 construction condition. My understanding was
20 A. In my report? 20 that it was based on a 1956 map, and there were
21 Q. Well, I mean, just told me you 21 other people making that decision about what
22 didn't -- I'm sure you copied them. 22 that condition was. I was not one of them.
23 A. I wrote these descriptions, and I 23 MR. MITSCH:
24 think they were my understanding of the various 24 One or two questions to go, Joe,
25 cases. 25 because we're well beyond seven.
Page 696 Page 698
1 Q. Oh, you didn't get that verbatim from 1 EXAMINATION BY MR. BRUNO:
2 somebody who did it. 2 Q. All right. Well, certainly then if
3 A. No, I don't -- I don't recall getting 3 whoever it was that decided what the 1956 or
4 any standard kind of description. I think -- 4 '58 -- we don't know what date they picked --
5 we talked about them and we each of us had some 5 wetland conditions are wrong, then that would
6 understanding about them. And I think I've 6 influence obviously the outputs of all the
7 described -- 7 models, right?
8 Q. I guess I'm trying to understand what 8 A. Certainly determine on if there was an
9 you believe to be the -- in your words, the 9 error made what specifically the error would be
10 historic changes -- the historic changes to the 10 and where the error occurred in the system, and
11 surrounding wetlands. 11 with that information and only with that
12 A. Let's just say the changes to the 12 information could I contribute an opinion on
13 surrounding wetlands. It's the change that has 13 whether I think it would make any difference or
14 occurred in the period of time since 14 not.
15 construction of the MRGO. That's what we were 15 Q. All right. You say at Page 30 of your
16 trying to look at. 16 report, the most energetic wave conditions,
17 Q. Does the Corps regard those changes to 17 significant incident heights of four feet were
18 have been caused by the MRGO channel? 18 in the vicinity of Bayou Dupre. I just want
19 A. I don't know that. 19 you to define what you mean by energetic wave
20 Q. That's what I'm trying to -- 20 conditions.
21 A. I think sort of implicit in what we're 21 A. Higher than what's normally there.
22 doing here is the assumption that it has. I 22 Q. Well, you said most energetic. That's
23 question whether that's accurate, but I don't 23 why -- higher than --
24 know what the official Corps position is on 24 A. Can you point me to the text?
25 that. 25 Q. Page 30.
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Page 699 Page 701
1 A. Top paragraph? Second paragraph? 1 If we had a limit then we would have
2 Q. Top paragraph, last two sentences. 2 had a limit on Bea. I made the
3 The most energetic wave conditions. And then 3 argument to the Court there out to the
4 you, open parens, significant incident heights 4 be a limit. I was told no. So we'll
5 of four feet, close paren, were in the vicinity 5 have to reschedule.
6 of Bayou Dupre. 6 MR. MITSCH:
7 A. I think what I'm referring to here is 7 Make the same argument to the
8 sort of the highest wave conditions were in the 8 Court.
9 vicinity of Bayou Dupre, in terms of its 9 MR. BRUNO:
10 position along Reach 2. 10 All right, I will. Thank you. I
11 Q. Four feet was the highest, then? 11 will be more that pleased to.
12 A. Yeah. Approximately, yeah. 12
13 Q. All right. 13
14 A. At this particular time. 14
15 Q. Okay. 15
16 A. It's hard pulling values off of these 16
17 maps. 17
18 Q. All right. I'm just trying -- 18
19 A. I can only get approximate. 19
20 Q. -- to see what is the difference 20
21 between significant incident height and 21
22 significant wave height? 22
23 A. No difference. I just didn't have the 23
24 word wave in one of those two. 24
25 Q. Well, the reason I ask is because on 25
Page 700 Page 702
1 Page 32 you say the maximum values are seven 1 WITNESS' CERTIFICATE
2 feet. And then you say the most energetic wave 2
3 is four feet. So I got little confused. 3 I, BRUCE A EBERSOLE, do hereby
4 A. Well, that might be at a different 4 certify that the foregoing testimony was given
5 point in time. I think I'm describing how the 5 by me, and that the transcription of said
6 evolution of the wave heights is occurring with 6 testimony, with corrections and/or changes, if
7 time. 7 any, is true and correct as given by me on the
8 Q. Okay. So it's at that time. 8 aforementioned date.
9 A. At that time. 9
10 Q. All right, sir. That's not the most 10 ______________ _________________________
11 energetic wave, period, that's -- 11 DATE SIGNED BRUCE A EBERSOLE
12 A. No. It was at that point in time. 12
13 Q. Understood. 13 _______ Signed with corrections as noted.
14 MR. MITSCH: 14
15 All right. I think we're going 15 _______ Signed with no corrections noted.
16 to have to stop now. The witness is 16
17 really tired. 17
18 MR. BRUNO: 18
19 So am I. I'm exhausted. I'm 19
20 totally exhausted. 20
21 MR. MITSCH: 21
22 That's why we've got the 22
23 seven-hour limit. 23
24 MR. BRUNO: 24
25 We don't have a limit, Rupert. 25 DATE TAKEN: February 5th, 2009
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Page 703
1 REPORTER'S CERTIFICATE
2 I, JOSEPH A. FAIRBANKS, JR., CCR, RPR,
3 Certified Court Reporter in and for the State
4 of Louisiana, do hereby certify that the
5 aforementioned witness, after having been first
6 duly sworn by me to testify to the truth, did
7 testify as hereinabove set forth;
8 That said deposition was taken by me
9 in computer shorthand and thereafter
10 transcribed under my supervision, and is a true
11 and correct transcription to the best of my
12 ability and understanding.
13 I further certify that I am not of
14 counsel, nor related to counsel or the parties
15 hereto, and am in no way interested in the
16 result of said cause.
17
18
19
20
21
22
23 ____________________________________
24 JOSEPH A. FAIRBANKS, JR., CCR, RPR
25 CERTIFIED COURT REPORTER #75005
98 (Page 703)
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accumulation 520:5 521:22,24 322:24 agreed 322:2 386:18 387:6,15
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361:23 376:7 451:19,21 457:11 appendix 356:3 406:11 422:20 458:18 459:12,19
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analytical 598:14 686:18 687:10,15 appreciate 380:24 672:14 674:9,18 567:9 572:2,2
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analyzed 449:13 anyway 472:25 475:16 594:23,24 701:3,7 asks 443:11
560:18 598:22 604:17 617:17 673:24 argumentative aspect 436:20
and/or 691:15 635:18 653:5 approaching 389:16 561:13,16
702:6 APLC 319:8 429:17 526:24 armor 328:14 aspects 330:2
angle 475:16 apologize 420:24 527:1 578:10 arms 668:8 assembled 613:16
angles 494:16 421:3 523:4 appropriate 439:3 arpent 437:14 assess 327:11
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406:8 412:19,24 appear 326:24 514:3 518:23 455:12 assessment 376:10
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Page 706
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assume 364:5 454:16,22 456:7 455:16,22 662:19 563:5,15,16,18 661:11 664:3
383:7,9,11,12,14 456:13,21 458:6 662:22 678:20 564:4 568:5 665:18 672:10,15
391:5 405:19,20 558:25 560:16,17 axis 568:19 682:22 574:21 575:3 686:25 687:14
405:22 412:13,15 561:9,17 575:3,4 a.m 335:2 339:16 586:19 587:18 697:20
412:21 414:21 575:8,9 581:6,14 339:16 545:3 588:14,20 664:9 basic 361:25
556:14 557:6 592:16 594:18,19 584:7,23 585:20 675:25 676:4 basically 431:4
565:4 574:10 596:22 672:13 585:20,25 587:23 681:15 689:11 498:12
617:16 628:2 680:5,9 619:13 bad 378:7 564:16 basin 345:15
632:6 633:16 attempt 598:1 A11 357:17 645:7 686:23 basis 355:14
686:7 688:17 657:24 658:2,7 A18 357:17,20 balances 357:9 360:17 394:23
assumed 339:15 attempts 367:2 band 659:9,17 577:23 686:9
375:21 573:21 attention 330:2 B 660:19 694:11
582:7 691:2 544:15 566:2 B 321:6 391:22 bands 546:9 659:2 Bates 324:21,24
assumes 509:18 attorney 616:10 592:16 697:14 bankline 650:23 325:3
551:10 attribute 672:2 back 338:6 339:17 banks 352:9 353:15 bathymetry 387:23
assuming 388:23 attributed 591:17 340:8 342:7,15 496:1 Bayou 363:15,17
409:16 414:3 671:25 347:8,21 352:20 barely 584:17 363:17 364:8,8,12
430:7 611:11 attributes 498:24 355:13,23 358:11 bark 340:15 469:4 637:2 653:1
assumption 367:8 August 609:14 363:4 367:13 Baronne 319:4 653:5 676:5,5
640:1 671:23 author 369:24 370:16 386:21,24 Barracks 613:17 698:18 699:6,9
690:1,4 696:22 authored 370:3,5 388:8,15,16 390:4 613:24 620:6 Bea 330:22 677:14
assumptions authority 579:24 403:14 409:25 barrier 492:3 677:17 680:19
686:24 authors 326:6 411:8 412:17 base 509:12,13 681:16 682:4,7
asterisk 486:15 327:11 328:9,10 430:13 453:6,8 511:18 513:7 683:3,14 685:17
astonishing 466:23 330:13 457:12 462:13 522:19,22,22 686:6 688:9 701:2
astro 330:22 available 377:2 463:5 472:3 524:2 526:1 beach 345:1,2
astronomical 511:18 665:3 477:21 494:12 529:10 541:1,4,5 350:3,3 354:14,17
467:25 671:9 679:19,23 502:15 503:11,20 550:19 553:18 354:22 609:22,23
Atkinson 549:15 679:24 680:1,11 504:2 510:16 555:9,16,22 609:25 610:9,12
Atmospheric 372:3 680:23 516:24 520:18 599:20 645:4 610:17,20,20,24
attach 341:4 average 326:23 525:20,21 526:8 649:15 650:22 611:12 624:19,20
647:25 332:12,25 365:13 527:14 539:24 679:19 625:15 628:23
attached 323:14 365:14,16 366:20 540:4 545:14 based 328:24 629:1,5,9,10
341:7 356:12 411:25 420:4 550:12 559:18,19 333:19 362:4 630:5 632:3,10
362:6 368:19 552:2 567:19 559:20 562:9,11 376:6,12 420:4 633:7,9 635:12,12
408:2 450:12 569:4,22 570:4 570:2 571:15 423:1 431:3 636:4 638:22,23
472:1 532:7 648:4 572:25 573:25 586:12 588:5 434:22 437:22 bead 649:25 653:24
attack 329:23 574:13 582:20,22 604:2,7 609:3 490:17 508:13 654:2
342:5,12 345:7 631:1,7 636:6 616:15 617:23 513:10 561:18 beading 656:12,23
433:5 438:17 638:19 639:2,7,9 619:4,5,7 620:20 572:18 577:1,19 beads 648:12,19,23
439:9 440:12,19 averaged 568:25 621:10 622:4,6,10 583:7 584:1 649:23 651:8,10
440:20 441:9,18 627:6 622:16 623:8,20 589:19 598:12 651:18,19,21,21
441:20 442:4,24 averages 412:14 637:6,24 641:12 599:18,22,25 652:21 653:14,16

Page 707
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655:23 656:3,8,17 614:2 619:8 620:5 378:7 429:13 Borgne 411:16 breaches 318:4
bear 360:11 624:10 628:4 447:6 459:4 412:8 471:10,12 421:10 427:18
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619:21 658:3 660:11 585:15 622:15 497:13,22 513:10 490:1,2,9 491:5,7
bed 379:16 572:18 672:20 682:17 628:16 630:13 515:3 491:9,19 503:2
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began 430:20 696:9 bigger 407:7,8 Borne 411:15,20,21 618:18 691:3
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664:10 689:24 437:1,15 460:17 648:17,17,17,24 566:14,18,21 396:23 397:18
begun 586:8,18 460:24 487:14 648:25 651:24 682:11 683:16,21 403:23 416:17
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belief 443:17,22 624:4,8 682:24 Boulevard 319:10 463:18 504:23
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601:9 373:20,25 378:2 548:10 550:20 477:11 530:1,4,6 667:12
beliefs 443:12 378:22 425:4 blah 328:15,15,15 606:16 607:8 breaker 474:20
believe 326:2 449:15 465:21 blame 438:5 608:13 612:8 breakers 475:15
333:20 337:23 469:16 477:18 blank 431:7 bounds 416:14,17 breaking 354:14
344:8 369:9 398:1 511:17,19 514:23 blast 598:10 679:3 Boussinesq 662:25 397:23 406:23
405:17 413:10,18 642:20 658:24 blending 370:15 679:22,25 474:4 583:13
415:11 418:4 697:10 703:11 blobs 648:12 Bous2D 679:23 585:3,8 587:6
422:14,16 423:8 bet 386:4 blow 624:6,7 681:18,21 682:2 678:16 679:6
427:5 428:15,19 Betsy 470:10 blowing 528:6 box 320:6 656:9 breaks 345:4
430:4 439:2 better 359:14,24 624:10 boy 654:2 breakwaters 345:5
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443:11,12 444:17 394:6 408:6 474:4 655:16 348:22,25 349:5 Bretschneider
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456:16 457:21 477:22 484:3,7,9 480:18,22,24 352:17 353:7 Briaud 666:14,16
469:19 472:7 492:16 530:5 481:6 610:4 354:7 666:22
475:9,22 500:6 629:23 632:11,14 660:22 branches 346:15 bridge 635:25
505:16 506:24 634:21 651:9 blues 480:22 426:19 brief 508:6 569:14
510:14 513:15,19 662:2,4 board 431:7 breach 422:14,16 569:18 646:12
524:22 526:10 beware 598:7 boat 598:9 422:22,23 424:6 691:22
527:5,7,9 528:17 beyond 492:24 Bob 680:19 683:3 425:14,22 427:14 bring 486:2
559:2 560:19 556:2 697:25 685:17 686:6 503:5 504:9,11 bringing 346:15
565:12,20 574:7 bias 438:15 439:7 688:9 518:6,14,15,22,22 broad 407:15 461:5
577:19 580:11 439:14,19 440:1,4 body 353:9 531:24 519:5 520:5,10,13 596:12
581:5 589:2 444:6 689:8 521:15,18,20 brothers 681:2
592:18 594:24 Bienvenue 582:5 bolsters 529:16 526:2 614:4,4 brought 384:20

Page 708
385:10 464:3 403:16 408:4 build 439:1,2 calculations 326:3 581:2 687:9
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323:8 328:4 340:2 421:19 422:2,7,18 buildings 604:6 385:23 388:7,9 careful 326:12
371:24 373:9 429:20 430:25 built 350:16 413:4 393:7 559:8,10,13 579:12
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382:1 383:16 433:20 434:15 bulk 348:16 582:12,19 590:11 493:25
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392:5,8,13,17 438:1,21 439:16 609:20 612:11 626:19 631:18 Carillo 467:21
394:3,4 395:12 439:23 440:3,9,16 615:16,18 619:3 646:16 680:23 carried 330:1,7,10
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430:19 433:12 445:4,10,17,21 bunch 559:5 598:8 call 344:13,20 410:15 427:13
436:6 439:24 446:1,4,24 450:15 619:5 348:18 394:3,6,12 442:25 443:16
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447:22 465:5,21 462:25 463:25 buoy 372:4 538:10 550:10 447:24 450:4
466:8 485:2,6 465:14,20 466:21 bush 557:16 610:19,20 643:11 473:4 500:8,24
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490:8 507:22 488:16 494:5 572:7 602:24 692:18 509:12,13,16
512:5 516:15,18 497:1,5 499:14,18 buy 641:5 called 329:13 349:7 511:18,24 513:7
516:21 531:12 504:18,22 505:3 360:14,15 373:11 522:19,20,22,22
532:19 549:7 507:10,16,20 C 408:9,18 421:6 522:24 524:2
552:13,19,22 508:7 509:1 512:3 C 319:8,9 332:1,7 432:5 472:23 526:1 529:10
554:21 566:10 512:13 513:4 332:11 566:19 476:22 694:24 541:2,4,5 550:19
573:22 577:24 519:17,21,25 697:15 calling 348:23 550:22 553:18,25
581:1 595:6 524:4 532:10,14 CAHILL 319:14 648:23 649:25 555:9,11,16,22
603:10 604:9 532:18 533:6 calculate 358:5 Calls 437:3 439:11 557:1,10 558:14
614:21 617:1 541:16 542:16 360:14,15 366:24 canal 318:4 425:3 558:14 570:20
618:1,6,15 620:12 543:14,18 544:5 367:24 392:18 427:17 460:25 574:14 599:15,23
621:10 624:3 544:12,14,17,21 393:3,10,13,17 489:25 498:12 609:16 630:2
625:4 632:9 544:23 546:19,21 565:16,16,19 503:16 508:3,18 636:17 645:4
638:17 646:14 547:3,9 552:17 585:16 601:14 510:16 511:19 649:15,15 650:22
702:3,11 560:11,14 561:15 681:13 512:9,18,19,22 652:2,2 654:20
Bruno 319:2,3 564:22 565:3,7,25 calculated 378:4 513:3 515:1,7 691:2
321:5 323:7,17 566:3,23 578:17 389:22 527:6 516:1,8,14 517:24 cases 503:12
326:20 335:14,18 622:12,21 623:2 565:13 584:18 518:11 520:4,10 511:24 519:4
341:9,12,13,20 624:25 625:3 calculates 681:10 524:22 526:19 520:12 524:3
352:14,24 353:14 646:13 648:6 682:12 528:9 529:7,23 536:16 538:23
356:14 357:15,21 652:16 660:6 calculating 395:7 617:23 665:9 539:8 655:25
358:1 362:8 668:1 673:14,22 516:7,9,19 576:25 candidly 620:18 693:9 695:25
368:22 371:7 675:14 687:13 682:11 683:1 capable 375:20 cast 687:4
389:13,17,19 688:1 691:23 calculation 339:17 488:20 catastrophic
390:14,19 392:16 692:6,10 698:1 339:21 342:20 capture 474:3 432:16,25
392:23 396:3 700:18,24 701:9 365:2 386:17 651:4,5 causative 672:4,8
397:20 398:8 Bruno's 341:14 393:22 583:23 capturing 654:16 cause 428:13
399:20 400:19,21 brush 557:16 598:24 601:24 Cardone 661:19 430:12,21 441:6
402:9,13,21 403:8 596:12 605:18 610:3 care 465:2,6 494:24 449:11,13 470:5

Page 709
560:2,2 577:3 690:11 671:14 672:7 414:11 415:1,4 377:4

581:9 592:16 challenging 351:11 691:7,9,10,20 478:9 486:7,8 City 319:11
593:19 595:19 627:22 694:1,5,6 696:10 491:12 509:4 Civil 318:4 320:3
703:16 Chalmette 361:23 696:10,12,17 551:15 566:5 322:6
caused 374:12 363:9 482:7 702:6 577:25 580:14,19 Clarify 642:10
421:10 422:16 chance 518:25 changing 405:20 580:22 586:12 CLARK 319:16
423:2 429:1 555:17 579:23 406:18 409:19 648:7 651:20 class 345:14 679:21
490:15 533:18 580:1 414:25 509:22 654:7,12 679:25
575:9 577:15 change 333:9 339:2 555:16 557:17,18 charts 325:18 classes 679:22
696:18 380:19 404:17 557:22 558:6,8 410:4,5,17,22 classic 344:12
causes 431:9 405:10,21 407:9 615:2 694:23 413:2 549:10 classical 344:13
439:21 407:12 422:10 channel 397:1,3,4,7 check 331:14 clay 328:18,20,23
causing 471:7,7 470:6,18,19,22 401:22,23 403:15 339:17 340:8,24 328:25 559:15
498:7 483:1 499:2 460:13 467:23 340:25 341:16 577:5 584:2
CCR 318:24 500:10 503:6,7,8 468:9,11 470:15 375:8 407:23 587:13 599:1
322:22 703:2,24 523:18 551:24 470:16,20,21 462:21 526:8 601:5 664:24
CDT 543:21 558:14,18,19,20 471:3,13 497:24 541:24 573:5 cleanup 578:1
CEERD-HF 323:2 558:21,24 564:8 498:3 509:18 612:25 613:1 clear 458:3 507:22
CEM 409:11 574:19 590:10,13 520:20 522:25 checked 466:12 563:15 575:7
Center 691:8 590:16 591:3,4,18 523:1,2,4 551:10 checking 337:13 655:18,18 683:18
central 487:15 593:7,8,17,17,18 650:2,6 651:4,6 340:21 clearly 495:19
491:8 544:18 593:20 596:17 652:3 654:4,4,5 checks 357:9 497:7 542:25
545:3 582:23 601:19 607:24 693:19 694:20 Chef 603:19 611:1 581:4
certain 325:24 608:14,15,16,17 696:18 chief 345:25 346:4 climatology 356:18
353:2 355:13 630:13,16 640:13 chapter 325:8,11 347:17,25 348:3,5 clip 356:21
413:8 438:7 439:1 640:25 641:25 325:13 327:16 348:20,21,25 clipped 357:14
439:5 491:8 657:1 671:24 charactered 573:4 349:1,5,6,18 clips 356:16
597:19 598:1 672:2 688:2,11 characteristics 352:16 353:6 clock 334:17
608:23 681:19 696:13 537:13 557:13 choice 668:11 close 332:1 380:14
certainly 384:2 changed 364:19 659:3,10 667:9 chose 492:13 385:15 387:8
413:9 426:4 642:7 377:14 422:10 668:18 674:15 564:16 565:1,5 473:13 606:2
665:23 675:22 515:22,23 519:4 681:13 chosen 328:21 637:1 652:20
692:15 694:19 558:22 597:17 characterization CHRISTOPHER 654:17 699:5
698:2,8 598:2 607:23 657:16 320:13,22 closer 507:11 598:5
CERTIFICATE changes 460:13 characterizations chronology 597:2 619:12 628:8
702:1 703:1 470:10 471:14 658:13 circles 648:14 645:20,24 658:3
certification 670:1 481:16 491:12 characterize 649:7 656:11,13 closest 411:4 633:8
676:10,12 498:21 500:9,14 355:22 453:24 circulation 345:15 closing 469:4
Certified 318:25 501:7 503:3 674:21 345:22 354:12 closure 497:25
322:23 703:3,25 516:12 517:4 characterized circumstances coast 350:1,22
certify 702:4 703:4 518:1 520:21 384:23 401:17 396:18 475:13 476:2,4
703:13 521:6 525:7 536:8 593:17 cite 325:15 663:7 527:13
cetera 327:21 554:18,20 555:9 characterizing 663:13 666:20 coastal 344:23
476:15 549:11 557:18,22 558:15 453:19,21 cited 324:10,17 345:16 346:1
551:1 572:6,6 558:16 591:16 charge 426:13,17 472:11 576:8 348:22 349:18,20
606:7 596:20 602:13 697:3 634:13 349:22,23 350:15
cfs 588:10,11 618:4,18 657:11 chart 410:5,6 414:8 citizens 376:25 350:18,25 351:1,4

Page 710
351:5,16,24 352:1 come 367:14 compares 363:7 641:13 647:5,17 381:19 382:3
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354:7,15,18,25 439:13 449:16 368:5 388:6 computer 386:6,7 395:20 400:14
408:10,13 428:15 471:4,11 472:5 503:18 504:1 391:25 393:23 401:7,16 403:19
428:23 473:23 500:22 504:17 511:10 557:10 405:11,21 413:4 434:11,12 460:16
474:15 475:18 588:4 601:6,7 632:20 414:13 643:9 497:21 501:9
676:11,16 678:18 614:23 623:8 comparison 358:24 685:21 703:9 503:14 509:14
678:20 681:22 647:8,24 679:1 367:21 377:9 concentrated 536:9,12,14 562:1
684:25 comes 384:8 543:5 674:11 571:4 577:21,21
coastline 345:11 414:18 476:17 comparisons concept 325:23 577:22 597:6
coefficient 326:23 527:13 540:24 550:13 661:12 concern 467:5,11 599:10 606:16
343:4 601:11 619:5,7 complete 361:15 467:13,15 668:25 658:25 663:21,22
coefficients 327:5 620:17 623:15,18 420:4 686:19 669:3 663:23 664:2,10
476:14 635:2 647:25 completed 461:16 concerned 439:4 672:6 698:5,16,20
coincide 654:6 682:15 completely 377:11 470:24 699:3,8
coleads 365:11 coming 357:2 412:16 461:13 conclude 552:15 confidence 508:17
collect 496:2 471:18 484:14 689:12 concluded 666:11 515:1 637:17
collected 599:25 536:14 583:18,21 completeness conclusion 423:8 684:5
Collins 468:25 588:15 614:13 356:23 423:16,17 427:16 confident 599:12
color 430:13 623:11 653:1 complicated 427:17,18,22,25 configurations
478:11,15 480:16 682:13 390:22 442:7 430:1 449:16 695:12
483:10 491:24 comment 390:13 535:6 558:1 500:23 503:3 confined 471:3
540:23 541:22 394:15 422:12 component 351:6 504:8 519:3 520:9 confirm 324:13
542:6 543:2 432:20 433:9 352:10 460:21 529:20 534:1 326:5,8 364:1
547:17,20 549:10 439:13 440:2 461:3 535:19 572:25 574:20,20 425:9 464:12
643:24 645:17 443:3,20 499:22 597:19 601:19 629:8 confirmation
651:20 499:23 562:11 components 537:12 638:14 689:3 413:14
coloration 485:16 661:17 composition 665:4 conclusions 377:5 confirmed 359:20
489:1 491:12 commissioned 674:14 451:14 478:1 confluence 468:7
colored 480:12 469:8 471:22 comprised 665:13 571:17 574:2 confounded 450:17
482:6 491:19 commonly 678:18 comprising 663:24 concrete 328:14 confused 369:18
colors 395:15 compadres 505:10 664:17,21 concur 430:18 522:18 575:21
478:14,22 479:20 compare 362:2 computational concurred 430:16 640:10 646:23
479:21 480:18 367:2,16,17 368:1 344:9 430:19 680:18 690:14
486:16,23 506:19 380:15 388:16 computations condition 351:9 700:3
506:19 547:22 396:5 410:6 358:4 469:12 504:3,5 509:17,19 confusing 474:7
645:8 648:24 420:15 540:14 527:24 682:21 530:1,4,6 533:20 553:17
660:14 544:25 546:8 compute 682:4 551:12 608:13 connected 496:4
column 365:15 571:11 580:25 683:11 665:20 694:23,24 connection 447:24
582:22,24 583:2,6 581:2,3 612:15 computed 357:7 694:25 697:17,19 450:3 495:23
583:17,19,23 630:23 632:22 358:16 366:9,12 697:22 497:13,15 501:7
604:9 691:14,19 366:15,18 604:1 conditions 351:10 501:18 508:10
columns 339:20 compared 357:8 604:11 605:22 355:25 358:21 512:24 513:1
combination 358:15 368:7 625:1,24 626:2,6 359:6,7,10 360:3 671:19
331:10 528:5 396:7 418:1 626:13,17,22 361:11 367:17,18 connectivity 498:2
combined 360:17 538:17 540:10 627:2 637:5,9 368:6 374:14 connects 468:8
495:23 497:11 547:12 556:23 639:22,24 640:17 377:10,12 378:5 consider 351:23

Page 711
352:2 353:20 continue 403:23 cool 383:20 506:19 343:11 385:5 covers 324:18
382:22 404:23 continued 403:25 copied 369:12 536:20 563:25,25 329:23 330:3
405:3 430:3 439:3 continuous 654:4 416:2,4 695:22 564:17 565:10 co-leaders 426:21
449:8 537:4 contour 547:25 copies 408:25 576:3,13 578:2 create 439:7 528:8
656:12 663:1 548:4 637:4,11,12 421:4 579:21,25 583:5 688:20
665:23 666:3,6 637:17 639:15 copy 420:25 472:2 583:19,21 589:14 created 374:14
669:18 674:24,25 643:17 509:7 568:14 601:12 631:20,21 379:1 384:22
679:21 contouring 548:16 578:3 677:23 631:22 658:21 401:16 477:15
considerable 585:2 549:4 core 629:24 661:25 662:23 643:1
658:22 contours 541:18 Corps 347:13 664:3,6,14 679:20 creating 528:6
consideration 545:13 546:8,9 348:16 350:9,17 680:3,22,23,24 crest 385:3 451:17
434:11 547:11,23,23 358:2,10 360:14 681:5,18,20,24 536:18,25 563:13
considerations 548:11 549:1 360:15 367:13 counsel 322:3 564:3 567:17
434:23 638:8,13 385:22 389:21,22 390:17 688:6 568:5 569:20
considered 378:25 contrary 512:14 396:7 408:5 438:3 703:14,14 574:21 582:3,6
382:24 521:10 contribute 404:3 438:24 455:13 count 487:8,9 586:5,7,17 588:2
582:9 671:13,16 449:23,24 591:1,4 458:12 459:6 635:4 615:21 664:8
consistent 341:15 592:3 593:1,5 600:20 670:6,20 counterintuitive 670:9,23 681:15
341:18 354:19 594:20 595:20 677:1 679:12,22 433:13,21 688:25 689:6,13
364:15 407:1 596:2,11 698:12 681:3 696:17,24 couple 361:25 690:8,19,24
423:19 533:22 contributed 426:4 correct 354:24 380:25 crested 620:7,10
642:1 658:1 592:17 593:21 355:18 364:5 course 344:7 621:5
consistently 609:11 contributes 590:25 415:22 417:20,21 345:17 389:3 cresting 615:21
627:20 contributing 418:24 462:6,10 406:25 434:17 criteria 587:13
CONSOLIDATED 347:12 429:25 509:24,25 510:8 589:12 599:21
318:5 591:12 510:21 526:10 Court 318:1,25 critical 467:23
constant 409:17 contribution 561:10,13 564:2 322:23 701:3,8 495:22 582:5
411:24 412:13,15 423:23 424:10,12 625:16 629:12 703:3,25 657:14
412:22 414:1,3 424:19 427:4 636:19 638:10 cover 326:24 crude 475:21 476:1
constructed 459:7 491:17,18 535:20 690:9 702:7 327:12,20,21,23 676:22,25 677:3
construction 350:4 539:10 591:21,22 703:11 327:24 328:11,17 cubic 586:9 587:10
458:13 460:15 592:9 671:16 correcting 625:1 328:25 332:5,12 cumulative 337:10
520:23 534:25 contributions 625:19 339:19 417:5 339:19 583:24
670:13 671:2,25 370:9,14,15 correction 362:24 421:23 506:9 585:11 586:19
674:13 694:6,15 536:23 639:10 534:25 582:18,20 587:20
696:15 697:19 contributor 427:1 corrections 702:6 582:21 589:13 curious 393:14
consulted 666:13 452:20 702:13,15 647:25 663:25 440:18 564:11
contacts 656:15 conversations correctly 388:24 664:17,18 665:19 611:6
contained 370:22 352:20 693:10 569:8 573:5 670:11,25 675:9 current 345:22
contains 361:8 conversion 363:1 694:10 675:15,16,20,22 376:17 381:16
contemplated convert 334:14 correspond 420:1 675:25 676:3 392:7 408:9,11,13
697:4 362:22 543:22 coverage 330:5 409:12 418:19
contend 439:19 converted 363:1 corresponded covered 327:15 428:23 449:14
contents 457:17 converting 339:9 690:10 328:18,20 463:7 586:13 672:6
context 458:11 convince 574:24 corroborated 539:13 548:21,22 676:11,16 677:5
630:7 632:19 convoluted 452:12 564:12 559:15 584:2 689:25 690:13
659:14 452:13 COULWAVE 598:18 689:18 currently 345:24

Page 712
348:18 349:13 646:19 698:4 384:5 387:3,11,13 415:4 509:9 562:15

419:8 691:11 702:8,11,25 388:22 400:1 denigrating 424:3 575:11 598:13
currents 599:12 dated 358:13 432:4 406:24 407:17 dense 484:4 651:23 654:19
curve 610:4,5 datum 362:25 522:19 554:5 density 675:19 664:7 683:3
curves 408:18 364:20,21 365:6 deep-water 345:13 dep 341:3 688:14 693:12
409:5,8,9,11 datums 365:8 defects 677:16,17 Department 694:8
412:12 414:2,6 DAVID 320:12 defer 447:19 539:6 318:13 320:2 described 514:9
568:19 569:6 day 346:6 378:14 580:1 450:3 471:23 563:22 654:24
cut 417:3 512:5 506:25 530:16 deficiency 524:10 depend 498:22 656:18 675:6
642:14 654:5 551:4 574:10 524:11 692:15 696:7 697:2
cute 641:7 613:7,12 682:15 define 676:18 dependent 442:10 describes 389:22
cuts 689:12 Daylight 545:3 698:19 555:15 describing 347:7
cutting 689:4,9 582:24 defined 401:23 depends 405:14 417:21 623:14
CV 343:24 days 613:11 672:11 402:25 495:25 613:7 670:8,22 648:18 700:5
cyclonic 409:18 deal 327:16 447:7 690:3 687:23,24 description 474:5
cynic 597:25 576:19 633:2 defining 403:19 depiction 510:3 475:12 545:14
cynical 642:15 637:10 definitely 432:23 deponent 322:10 604:3 695:5,5
deals 356:9 457:7 454:8 579:16 deposition 318:11 696:4 697:8
D dealt 456:15 614:13 681:20 322:4,14 325:20 descriptions
D 321:1,6 532:3,4 death 671:17 degradation 430:6 341:5 499:16 695:19,23
532:21 677:22 December 382:1 556:20 558:23 611:21 685:18,22 design 329:11,11
686:5 697:15 460:2 598:13 560:20 597:11,14 685:25 686:7 329:13 346:19
damage 350:4 decide 340:3,4 614:5 657:14 703:8 350:10,13,22
354:16 448:8 535:18 594:15 658:11 689:4 DEPO-VUE 351:7,11,24
449:12 586:11,14 674:2 691:4 692:16 320:25 354:15 355:12,14
586:21 599:5,17 decided 424:12 degraded 551:1 depth 329:4 365:13 355:15,21,24,25
666:5 669:22 430:10 477:10 665:15 674:20 365:14,16 366:21 358:17,21,22,25
676:19 690:12,16 522:6 553:6 676:5 379:12 383:24 359:5,6,8,9,11,24
690:20 593:16 642:12 degrades 670:7,21 384:2,8 386:22 360:2,13,18 361:5
damages 380:21 680:2 698:3 degrading 597:10 387:5 391:22,23 361:7,10,18,21
damaging 588:13 decides 442:23 597:12 392:2 396:18 362:13,23 363:1
dark 480:22 576:11 degree 490:15 397:25 398:7 367:10,19 368:6,7
darker 481:6 deciding 531:8 502:21 525:1 400:23 403:24 375:21 378:5,25
648:24,25 decimal 334:9 533:17 671:19 404:18 405:10,10 380:6,9,16 382:5
data 328:24 331:20 decision 443:3 686:23 692:16 406:4,5,23 407:18 382:12,17 386:13
333:20 425:4 627:23 636:10,14 degrees 530:16 410:2,9 411:3,6 389:20 394:23
510:2 516:16 688:13 697:16,21 Delft 330:11 411:15,22,24 395:7,21 400:12
530:8 542:24 decrease 521:19,22 609:13 616:16 412:13,15,20,22 407:20 408:8,14
545:15 549:8,12 521:23 delta 371:23 372:2 413:25 414:1,3,14 409:23 421:9
549:14,16,24,25 decreased 478:8 delve 580:3 604:6 414:19 415:5 423:4 428:24
550:7 562:21 481:11 521:16 delved 355:20 554:4,6,15 555:5 433:11 434:9,10
599:25 600:4,6 642:6,9 Demirbilek 681:23 584:13 434:21 435:14
613:15 621:12 decreases 657:6 demonstrate 483:4 depths 329:3 398:3 436:17,17,18
634:20 642:11,21 decree 522:4 612:2 618:20 399:11 554:16 440:6,7,8 487:24
642:23 658:20 deep 353:21 372:2 demonstrated derived 342:17 488:4 586:11
665:3 674:21 387:8 397:7 468:9 410:3 describe 327:19 587:12 589:21
date 323:19,19 deeper 344:21 demonstrates 357:1 454:21 600:19,21 676:16

Page 713
designation 472:25 devastated 489:20 699:20,23 682:24 333:2 503:19

designed 350:23 develop 346:10 differences 364:21 dig 353:7,15 579:17 689:23
355:8 377:20 347:12 425:2 395:4 418:20 digest 670:19 discussion 326:15
378:1,8 388:9 developed 430:15 474:12 478:6,7 digress 508:8 392:10 411:21
400:1 431:15 472:23 584:1 486:10 538:19 dike 330:10 525:15 530:10
432:14,21,22 599:21 657:16 550:4 552:21 dikes 330:9 577:23 579:14
433:6,9,16,24 658:14,14 570:21 583:11 dimensions 332:18 590:25 693:8
435:12,23 436:9 developer 651:14 601:23 627:1,1,7 500:6 display 542:23
436:15 438:5,25 developing 346:9 630:6 632:19 dip 527:5,8 528:1,2 displayed 688:17
488:5 573:20 346:12 350:9 634:14,15 635:19 528:3,10,13 529:2 dispute 594:10
designers 355:17 425:24 474:25 637:20 659:25 529:2,12 530:7 disregard 480:1
362:4 394:18 development different 330:8 dipped 528:18 493:18
420:7 436:10,12 476:23 495:21 351:14 376:9 direct 543:5 663:9 dissimilar 394:17
designing 346:25 497:9 667:8 388:23 390:7,10 directed 569:11,16 dissipation 404:1,4
349:25 350:20 668:17 392:11 405:22 570:2 557:23
despite 643:7 device 668:23 413:12,19 419:20 direction 379:21,22 distance 332:20
destruction 429:1 669:1,4,8 422:9,20 429:17 386:22 390:5 336:8,11 338:3
429:25 449:18 diagonal 413:21,21 438:20 441:14 391:20 537:19,21 353:2 399:14,15
601:22 diagram 478:11 458:24 464:19,19 537:22,23,25 399:16,17,19
detail 455:12 478:9 dictate 512:21 464:25 465:15 619:8 401:21 404:7
484:2 489:15 dictated 497:19 467:13 473:2,3 directional 418:10 524:8 606:10,10
665:7 689:2 537:5 496:13,16,25 420:20 538:1 distinct 461:14
695:13 differ 419:7 505:25 535:5 directly 540:2 501:22,24 517:6
detailed 375:25 difference 364:18 540:19 541:13,19 director 349:12,14 distinction 429:4
426:9 484:8 395:10 400:12 541:20,23 542:13 349:16 distinguish 330:21
details 473:22 410:7 418:17 542:23 543:2 disagree 372:13,24 535:4,10 547:16
474:14 475:10,17 419:15 429:10,11 547:11 548:9,21 395:3 444:12 distinguished
475:24 484:15,19 429:13 440:11 548:22,25 549:1,2 452:14 454:7 604:4
539:7,8 579:25 441:10 451:16 554:18,20 555:8,9 498:23 581:9 distribution 643:13
determination 473:21 474:10,11 555:11,13 557:12 disagreeing 372:20 643:25
342:21 694:11 474:13 490:22 558:10 568:20 disappears 330:23 district 318:1,2
697:13 491:10,11,15 571:19 573:23 discarded 559:6 352:21 358:24
determine 353:3 506:15,23 511:5,7 574:1 576:11 discharge 538:5,6,9 359:19 361:10
374:13 378:23 511:11 521:17 580:20 582:21 538:11 676:17 divide 605:5
388:10 410:7 522:15 523:19,24 601:18 603:24 discharged 438:10 624:22 625:18
425:15 449:15 526:17 529:18 604:13,15 610:21 discount 635:1 626:24 647:3,6,10
517:25 518:18 550:9 552:7,23 618:17,22,24 discounting 577:12 divided 605:6,9
535:16,19,24 557:11 592:14,15 627:9,17 633:20 discovered 681:8 625:21
536:1 537:7 564:1 592:23 605:3,8,12 671:14,22 674:19 discrepancies division 320:3
579:20 581:19 607:6,22 625:17 677:23 695:12 606:19 660:24 346:1,4,8 347:16
650:6 674:1 628:21,23 629:2 700:4 discuss 328:22 347:25 348:3,5
682:24 689:15 629:10 630:3,8 differentiate 391:14 392:11,14 349:1,6 477:17
698:8 633:6,22 634:1,2 545:12 410:18 485:2 540:8 661:20
determined 534:5 634:4,9,10 636:3 differently 531:10 577:18 602:13 document 323:10
559:5 599:9 647:3 654:9 597:21 601:25 discussed 587:18 323:20,22,25
determining 328:2 660:15 678:25 difficult 372:22 669:19 324:3,6,14,15
419:5 687:18 698:13 404:10 530:19 discussing 328:11 325:5,6,9,10,16

Page 714
325:25 326:25 Don 477:4,6 631:13 drinks 505:11 697:15 460:12,21 461:8,9
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359:15,22,25 door 395:12,13 528:3 608:1 390:25 401:16 462:9 493:8 503:1
360:10,20 361:17 doors 395:15 driving 438:2 414:19 465:17,22 514:10 517:4
363:25 364:3 dot 334:4 451:14 556:11 466:1,2 473:18 520:20 556:4,7,9
373:1,16 381:23 double 630:3 608:3 657:13 492:15 496:14 596:17 618:17
389:9,9,20 408:12 634:10 641:2 drop 616:5 512:20 575:9,10 694:22
431:23 442:1 double-check dropped 615:14 575:20 596:22 effective 573:4
450:14 456:18 324:12 620:13 654:24 669:19 effectively 555:4
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465:16 466:16 downrush 569:7 620:10 early 351:22 effort 424:19
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657:17 658:15 574:15 623:20 614:10 624:2 477:17 539:11
670:1,3 677:2 Dr 330:22 343:12 due 371:22 372:1 earthen 329:6,9 597:22 598:4
documented 354:2 393:6,6 404:4 527:9 568:4 350:23 598:15 efforts 417:15
430:12 474:23 394:7,12,13,19 585:8 664:23 665:21 667:9 eight 337:5 529:23
598:12 599:8 395:2,18 396:8,15 666:5 673:3 689:5 668:18 669:11,16 644:24
658:24 670:16 396:15 398:14 692:12 675:10 eighteen 422:8
671:5 413:10,14 415:20 dug 330:8 ease 347:20 either 345:6 371:10
documents 347:13 415:23,24 416:9,9 duly 323:5 703:6 easier 333:7 457:4 470:5
355:14,21 361:5 416:11 417:1,9,12 dune 350:4 easiest 410:13 497:25 503:5
361:14 436:18 417:15,18,18 Dupre 582:5 637:2 easily 525:21 520:7 533:12
450:19 455:16 426:9 447:20 652:6,13,17 653:1 east 363:14,16 544:11 563:25
464:25 685:19 452:22 453:20 653:5 676:5 364:7 371:22 592:16 595:14
686:1 538:20,21 539:7 698:18 699:6,9 372:1 422:23 610:17 651:25
doing 324:12 564:21 565:2,9 duration 342:5,12 460:24 471:18 656:17 671:20
335:17 347:10 576:16 579:23 534:24 563:11 478:14,23 479:1,4 682:12,20
352:18 385:22 600:9 651:12,16 588:25 589:3 479:21,23 489:25 elapsed 338:4
394:7 405:14 655:6 656:23 663:21 670:11,25 491:6 610:25 elevation 329:5
447:12 452:21 662:4,24 664:5 Dutch 385:7 624:20 625:15 363:23 366:3,6,8
509:5 516:9,11 666:13,16,22 398:15 584:1 638:22 665:8,12 366:11 483:16,17
517:1,9 521:11 676:7 681:4 600:20,24 664:19 eastern 318:2 536:25 582:3,8
525:20 527:21,22 draft 465:3,4,17,22 664:24 665:24 460:23 602:9 608:12
586:21 607:15 466:1,2 676:13 Duval 318:6 427:21 easy 356:15 447:11 elevations 468:16
625:6 626:10,12 drag 514:7 DYER 320:12 504:23 478:6 486:10
626:19,20 627:20 drainage 624:5 DYNA 681:17 Ebersole 318:11 488:7 502:17
629:25 647:15 draining 624:1 dynamic 351:9 323:1 373:10 506:16,18,20
650:8 673:17 dramatically dynamics 343:22 382:1 392:5,9 522:15 539:19
682:25 683:3 497:24 571:19 D-2 532:19 533:3,5 394:3 407:22 541:3,20 617:4
684:17 696:22 657:12 533:7 456:20 702:3,11 688:23,25
dollars 596:16 draw 571:17 D-4 533:5 economics 434:24 eleven 337:4 613:5
dominant 430:5 572:25 574:1 D.C 320:8 edge 411:20 650:17 614:10,12,20
446:16 449:17 665:17 edited 323:25 615:24 616:1,4,8
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672:21,22 drawn 652:22 E 318:10 321:1,1,6 editing 370:14 623:21,25 645:1,2
dominate 563:18 dredged 665:13 321:6 332:6,14,19 EFA 669:2 686:14 645:3,14
dominated 533:12 drew 653:22 656:9 332:21,23 336:8 effect 455:4,7 eliminate 481:23

Page 715
498:2 528:10 385:22 389:21 446:14 448:24 611:20 673:16 697:4

529:1,12 554:17 677:1 449:25 533:1,13 establishes 556:2 evaluation 353:1
eliminated 497:25 English 482:7 534:22 559:2 estimate 383:18 382:25 426:15,18
529:2 entered 486:5 574:25 575:1 392:4 418:5 428:4 456:7 458:4
eliminating 411:21 entering 461:1 577:4,16 580:24 424:23 492:7 459:8 461:14,15
673:15 471:9 484:25 581:10,14,17,20 513:16 514:3,17 538:15 560:15
elimination 509:22 entire 374:24 581:23 582:14,17 516:17 571:16 572:19
else's 440:1 600:18 399:16,17 558:7 583:24 584:19 583:7,18,20 evaluations 675:2
ELWOOD 319:8,9 607:23 609:4 585:10,11,17,21 603:12 610:7 event 533:10
employee 549:17 640:2 585:23 586:19,23 639:24 642:20 593:24 597:8
encapsulated entitled 356:6 587:17,20 588:20 644:2 events 495:22
598:20 361:22 457:18 589:6,11 590:14 estimated 647:20 497:10
encountered 427:6 566:6 593:19,25 599:1,3 estimates 385:6 eventually 404:5
encourage 655:5 entrance 514:15 599:23 600:10,12 419:6,7 479:7 614:9
ended 424:12 638:8 530:3,6 601:2,21,22 664:1 515:4 520:3 Everybody 504:24
639:19 641:15 environment 664:23 665:25 631:14 658:24 evidence 322:15
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Page 716
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Page 717
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Page 718
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Page 719
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Page 720
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Page 726
literature 330:1 638:3,6,7 655:10 513:6 518:10 689:7 694:19,22 635:4 650:1
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Mexico 372:6,18 352:12 353:11 391:22,25 393:8 500:19,20 506:22 moved 399:7
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Page 729
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nearshore 354:12 526:25 527:3 451:16,18 501:20 595:3 600:23 700:6

Page 730
ocean 344:19,20 369:7,21,24 480:18 481:4 600:3,10 602:4,21 656:24,25 674:5

345:15,15 375:18 370:12 371:8,18 483:13 485:19 603:18,19 604:21 one's 571:12
477:16 661:19 372:7,19 375:3 486:14 487:22 604:23 605:1,25 online 496:22
Oceanographic 378:6,15 379:11 488:17 489:14,17 606:4,5 609:24 onset 663:25
372:3 379:13,15,20,22 492:9 493:4 495:1 611:5 612:25 676:18
oceanography 381:3,14 382:8 495:9,15 498:4,13 613:14 614:1,18 onshore 569:11
345:12,14 383:7,16 384:4,16 499:5 501:15 615:11 616:9,15 open 429:22 498:3
odd 650:14,14 385:2 386:20 502:6,7,10 504:5 616:25 617:6,10 512:24 513:1
offense 595:8 387:10,16 388:6 504:8 505:9,12,13 617:16 620:8 609:13 699:4
offer 376:8,9 388:12,20 391:18 507:4 508:4,4,20 621:6,12 623:23 operate 328:1
428:16 391:21 393:9,20 509:2 510:1,19 624:17,19 627:10 operated 476:20
offering 427:11,12 393:25 394:10,14 511:2,14 513:5,18 628:19 632:17 opinion 376:7
OFFICE 319:2 397:2,14,21 398:9 513:24 514:16 633:4 635:24 423:1 427:11,12
offices 318:12 398:18 399:1,3,5 515:8,9 517:15,25 636:12,16 639:6,6 427:20 430:15,20
official 696:24 399:6,9,25 400:3 518:6,15,17,21 642:19 644:16 446:13 500:18,19
officiated 322:24 400:8 401:10 521:4 522:17 645:12 646:1,2,11 501:2 574:11
offshore 398:12,13 402:3,24 403:18 523:10,10,12 648:7,9,10,22 592:24 663:4
398:14 404:23 404:17 405:20 525:23,24 526:23 649:8,9,24 650:20 668:23 672:16,20
405:3,5 570:2 408:3,22,24 527:11,23 529:3 650:25 653:12 680:3 683:23
oftentimes 654:25 411:11 412:21 529:15 530:15,18 657:7 658:9 686:19 688:2,11
oh 324:21 333:16 413:7 414:5,9,10 531:4,15 532:17 660:17 661:3,9 698:12
342:25 357:20 414:24 415:2,8 532:20,22 533:22 662:5 663:3 opportunities
453:16 514:21 416:10 417:4 536:3,21 538:2,5 665:16 666:7 557:9
552:7 553:25 418:7,22 420:23 538:11,11,14 668:12 673:5 opposed 429:5,15
646:20 649:17 421:7 422:3,13 539:9,12,18 540:9 674:4 676:15 662:13
696:1 424:10,25 426:17 540:13,17,20,25 677:9 678:3,10 opposite 483:9,11
okay 324:12 326:4 428:2 433:2 438:2 541:7 543:3,7,8 681:21 682:1 option 340:13
326:16,21 327:6,9 440:10 443:10 543:24 545:4,7,17 685:5,17,24 686:4 orange 656:13,14
329:19 330:20 447:9 448:4,11 546:15 548:19 688:14 691:6,18 oranges 632:21
332:17 333:21 450:16,18 451:3 549:22 550:2,19 692:17 693:17,23 649:1
334:11 335:9,21 451:23 452:1 551:14,19 553:25 693:25 694:21 orbital 562:2,5
337:1 338:6 339:7 453:13 454:13,20 554:10,11 557:2,5 695:7,15,17 563:8 569:2
341:8 342:2,11,20 455:11,20,23 559:16 561:16 697:13 699:15 571:23 573:7
343:6,20,20 456:19 457:14,16 566:7,24,25 700:8 order 358:5 419:9
344:15 347:3,11 457:23 459:6,12 567:25 568:8,11 old 386:13 622:15 424:9 461:6 470:9
348:4,7,10 349:7 459:21,23 460:1,3 568:13,18 572:10 OLINDE 320:15 535:16,24 560:15
350:11 351:25 460:9 461:5 462:2 572:16 573:20 omitted 475:12 561:7 563:6 564:1
352:3 354:5,19 462:11 463:17 574:6 575:5,15 once 492:21 507:5 590:15 617:13
355:3,3,11 356:1 464:1,5,21 466:6 576:23 577:1,9 511:25 516:5 647:5 661:7
356:13,15,19,24 466:25 467:14,20 578:15,21 579:1 535:18 538:24 686:18 688:20
357:3,4,17,25 468:12,18 469:3 579:19 580:5,13 540:21 567:9 organizing 370:15
359:8 361:12 469:14 470:25 580:19 581:7,12 589:12 592:7 oriented 673:9
362:12,15,19,20 471:20 472:1,5,10 581:16,24 585:24 593:16 597:10 origin 457:24
363:3,8,10,11,13 472:16,19 473:5 586:7,25 587:1 618:5 627:3 original 322:9
364:4,11,14 365:1 475:1,24 476:17 589:5 590:2 664:10 689:24 324:9 355:21
365:12,20 367:11 478:3,13,24,24 591:24 594:8 ones 326:24 380:2 362:23 363:3
367:11 368:9 479:5,13,18 480:7 596:10 598:6 422:9 455:21 391:11 472:22

Page 731
504:3 overflow 460:16 689:5,23 690:10 578:19,21,22 663:20

originally 418:15 588:1,3 Overview 432:4 579:2,4 580:18 parameters 398:22
579:6 overstates 510:15 overwhelmed 602:20,21 603:17 423:12 509:21
Orleans 318:14 overtop 490:19 377:11 609:19,21 622:25 511:4 537:5 538:4
319:5,18 374:25 overtopped 435:16 overwhelming 624:21 630:24 576:14
457:20 463:11 435:20,21,23 672:21 636:15 637:25 Pardon 368:25
468:21 478:13,23 436:9,11,23 491:2 o'clock 334:13 643:2 649:16,21 500:17 519:8
479:1,4,21,23 overtopping 335:1 337:4,4 649:22 655:3,12 534:3
491:4,6 496:4 375:20 419:3,4,10 424:7 519:6 663:9,10,11 664:1 paren 332:1 699:5
610:25 665:12 419:11 421:10 526:21,24,25 665:6 677:23 parens 699:4
oscillate 562:9 422:17 428:1,22 527:3 540:11,15 693:18 698:15,25 Paris 363:12,14,14
ought 656:22 429:1 430:11,20 540:15 543:21,21 700:1 363:16,16,16
outcome 419:5 432:15,24 434:1 544:13,25 613:10 pages 368:16 364:7 588:16
442:25 447:2 436:25 440:12,20 617:21 369:13 408:25 628:20 629:4,9,11
500:11,11 558:23 441:5 449:11,16 430:14 466:13 630:5 635:25
558:24 592:6 449:23 460:16 P 467:7 549:11 637:3,12
outcomes 442:9 461:12,18,23 P 322:1 660:11 part 322:14 421:2
501:4 502:14 501:9 533:1,12,13 pad 334:7,8 paging 356:17 426:2,24 428:19
outer 401:3,24 533:15 534:2,6,22 page 321:3,8 677:22 432:21,23 433:4
Outlet 450:22 534:24 536:23 324:17,21,24 painting 395:15 434:7 439:15
454:24 455:8 538:4,9,12 556:10 325:2,3 327:7,8 paper 326:9 327:13 477:8 527:9 534:7
457:19 459:1,9 556:12,18,20 329:10 331:25 340:19 342:8,9,16 597:22 635:15
460:12 463:10 558:13,20 559:19 333:4 334:20 406:6 407:24 636:13 657:25
output 334:23 568:4 575:6,11,17 341:21,24 343:23 458:17 464:15 675:11,17
385:1 416:7 425:1 575:20 577:15,21 355:5 357:17 466:11 474:14 PARTICIPATING
495:5 539:1 579:14,15,17,18 362:7,10 363:7 486:17 489:4,6 320:18
681:12 580:24 581:6,9,17 369:1,2,3,4,15,18 490:9,10 566:1 particular 346:16
outputs 405:22 581:22 582:13 369:20 371:24 papers 455:6 697:8 358:12 408:17
495:11 546:23 583:20 584:15,16 372:1 381:18,22 697:9 448:16 451:1
549:3 565:10 585:9 586:8,15,17 382:2 407:25,25 paragraph 355:5 458:23 492:5
640:12 698:6 587:10 588:9,10 412:6 416:3 421:1 369:22 370:17,18 499:21 532:21
outside 479:10 588:12,15 589:9 421:5 431:16,19 374:18,19 382:2,3 541:14 606:8
482:1,8 489:10 590:23 591:2,5,13 432:8,10 460:5 460:7 464:18 638:1 650:7
491:22,23 493:2,7 591:19 592:17 467:3,8,12 473:11 466:12 467:2,10 658:19 667:3
493:16 494:6,13 593:21 594:1,20 473:12,13 501:11 467:15 468:12 668:22,25 678:21
495:3 614:14 596:22 597:8,9,12 503:17 506:14 469:7,9 473:9 679:5 699:14
615:7,14,23 616:7 597:13 599:4,15 507:14,17 516:24 495:17 496:8 particularly 439:20
617:12 620:13 599:16 601:21 520:18 522:11 532:19 533:3 547:13
651:21 630:15 631:18 523:11 525:12,17 566:14,18,22,25 parties 322:3
overall 637:18 642:7 657:13 525:18,20 532:9 663:16 693:21 703:14
overestimate 511:5 664:10,11,13 533:5,7 539:20 699:1,1,2 parts 434:3,5
511:9 523:15,17 666:4,5 669:21 543:13,20,23 paragraphs 466:13 passage 563:12
overestimates 670:7,8,11,21,22 545:5 546:17 566:19 567:20 568:1
627:14 670:25 672:13,21 550:17,18 562:16 parallel 649:14 passed 426:7,8,10
overestimation 673:3,10 674:4 562:19 566:13,16 parameter 401:12 454:3,6
511:13,15,16 676:1,17,21 567:14 568:12 404:18 406:7 passes 569:15
524:25 678:17 679:6 572:14 578:13,16 573:16 589:21 623:21

Page 732
passing 569:20 peer 602:22 378:24 379:7 422:12 693:5

616:24 617:20 people 350:5 380:8,10 383:25 pertubations places 518:9
619:11 353:24 433:15,23 384:14,25 386:18 670:12 671:1 plains 473:23
pattern 636:19,22 490:4 697:21 388:8,10 392:19 phenomena 344:1 474:15 475:18
637:18,24 638:16 people's 435:5,11 393:3,11,14 394:2 phone 394:3 544:8 plaintiff 449:5
patterns 545:23 435:19 394:5,16,17 395:5 photo 588:16,19 581:5
548:18 639:15,17 perceived 439:14 403:1 404:13 photographic plaintiffs 319:1
643:17 657:6 percent 325:24 407:4,9 414:15 665:18 689:8 452:4,16 454:17
Paul 320:5 606:14 470:22 526:9 415:18,21 417:9 photographs 559:5 500:22 520:3
611:8 691:15 605:3,8,11,12,13 417:22 418:6,17 559:12 561:7,8 521:23 530:2,10
paving 588:14 606:7,7,7 625:22 418:19,20,21 577:10 531:5 575:2,7
PAVLICK 320:23 625:23 626:24 419:12,12,16,17 phrase 567:5,6 581:8 606:25
Pay 544:15 627:1 628:22,23 419:21,24 420:2,3 phrases 662:15,19 692:20 693:2
paying 566:2 629:2,4,5,10 420:12,13,22,22 662:21 plan 477:13
PBL 476:18 630:8 636:3,9 493:12 537:17,19 Physical 345:12 plane 417:25 418:5
peak 355:6 380:12 639:11,12,21 537:21,25 558:10 physically 526:16 418:9
418:18 419:16,17 641:1,1,25 642:1 558:15 568:2 527:7 554:9 Planetary 476:18
419:24 420:2,8,14 642:3,4 646:6,24 569:14 570:16,22 physics 513:21 477:10
420:16,22 469:23 647:11,11 661:8,8 570:24 571:9,12 514:8 629:22,25 Planning 407:20
470:8 513:14 681:19 571:13,19,21 pick 410:5 413:23 408:7
514:2,14,20 percentage 330:4 572:21,23 573:4,8 545:1 635:24 plans 346:10
524:12,18 526:20 491:11 573:13,16,17,18 650:16 656:24 Plaquemines
526:21 562:2 percentages 330:5 573:18,19 574:19 picked 569:8 375:18
563:5,8 567:20,25 perception 486:22 577:16 578:5,9,20 582:21 698:4 play 446:11 471:4
569:10 570:16 perform 433:24 593:11 596:16 picking 434:3,5 571:10
572:25 573:13,14 435:12 469:11 671:11 696:14 615:25 plays 383:24
573:15,17,19,25 performance 421:6 700:11 picks 650:15 467:24
578:23 607:14,24 421:15 425:19 periods 375:4,12 pictograms 550:3 pleas 353:13
608:6 609:1 610:5 426:3,11,22 375:21 382:6 picture 544:4 545:2 please 323:12,18
610:6 612:18 437:24 447:15 395:22 401:19 574:3 373:23 375:10
613:5,16,18,21 448:6,12,23 416:6 418:11 pictures 598:23,23 377:22 394:20
614:16,16 616:2,3 452:24 458:5 420:5,6 558:13 689:15 408:24 432:12
617:25 621:5 598:15 665:7,12 568:1 571:23 piece 340:19 441:13,22 451:19
626:2,5 631:15,24 665:21 667:9 573:21 574:18 352:19,22 406:6 468:5 490:25
636:20 638:14 668:18 669:10,15 578:23 464:14 486:17 534:11 642:10
639:14,16 640:6 675:20 periphery 460:17 489:4,6 595:24 659:7 663:9
640:21 641:13 performed 431:14 permanent 497:25 636:9 667:12 669:13
643:13 660:13 432:14 433:6,15 permissible 342:5 Pilarczyk 323:25 pleased 701:11
661:8 433:23 435:11,15 342:12 325:5,7,14 plenty 677:10
peaked 621:24 435:18 436:8,15 permitted 322:5 place 359:11 plot 568:24 630:24
peaks 526:19 580:8 438:4,25 468:20 person 479:25 398:19 437:25 637:25 645:11
607:16,22 610:8 665:20 669:9,14 697:11 478:7,9 486:11 plots 543:1,2 578:7
610:13 626:13 perimeter 615:7 personally 350:21 499:6 511:21 plotting 542:22,22
627:12 639:22,24 period 337:24 611:15 658:22 518:25 541:15 plug 640:10,11
640:8 641:13,15 349:24 350:11 671:12 558:6 585:3 587:6 plugged 640:12
644:21 647:18,20 365:25 366:14 perspective 499:21 587:17 588:9 plus 331:13 483:1
peck 420:6 375:19 378:4,20 pertains 318:7 624:1 692:20 538:3 559:23

Page 733
585:14 627:21 490:20 492:1,18 673:25 677:15,16 675:9,15 486:25 492:16

point 336:6 339:25 policy 352:25 potentially 449:24 presented 373:18 526:22 539:6
340:11 343:9 Pontchartrain pouring 614:6 373:24 381:9 558:4 562:5,8
372:7 384:19 351:3 356:4,7 Powell 661:19 449:21 586:18 588:17
398:16 401:23 361:21 468:2 powerful 570:25 presume 604:16 590:22 629:5
403:22 412:2 473:24 474:16 Poydras 318:13 607:16 608:24 631:16 636:7
420:18 431:17 475:19 495:24 319:17 611:1 686:17 651:12 652:20
435:16,19 465:4 497:14 512:25 practice 409:23 presumes 554:5 687:20
465:25 474:1 514:1,9,12,15,21 428:24 449:14 pretty 364:15 problem 346:16
490:14 529:16 515:6 524:13,14 676:17 474:24 484:7 370:24 371:11
551:16,16 552:23 527:1,10 528:5,7 practices 600:21 504:21 584:11 429:5,6,14,16,21
552:25 563:11 530:3,7 pre 484:2 522:19 590:5 619:8 622:5 430:10 445:1
569:8,9 570:1 poor 326:23 332:12 642:23 623:10 636:23 449:21 492:12
575:5 577:4 586:8 332:25 precise 613:11 639:18 652:3,24 495:15 505:2
587:20 588:9,18 portion 651:6 693:12 prevent 497:21 508:5 518:12
589:9 594:14 portions 491:3,4,8 precisely 412:5 previous 453:7 618:12 638:18
604:8 608:20 posed 627:22 546:5 548:15 459:14 468:13,19 673:24
610:25 621:3,19 position 465:22 611:13 468:23 472:12 problematic
624:12 633:21 553:9 594:5 preconstruction 637:7 675:5 402:18
634:25 635:18 696:24 699:10 500:5 pre-Katrina problems 629:14
638:7 641:10,11 positive 478:5 predicted 418:15 347:21 348:11 Procedure 322:6
650:13 652:10 480:25 486:10 660:12,15 pre-MRGO 504:6 proceed 326:15
653:15 674:18 567:17 predicting 506:8 509:19 672:5 process 331:21
688:9 689:2,6,16 possibility 429:24 685:3 693:4 697:18 358:18,25 360:9
689:21 690:3,4,7 430:3,8 463:1 prediction 386:6 primarily 346:17 382:17 430:5
690:16,16,18,18 595:21 386:14 526:4 347:4 350:21 433:10 436:18
693:14 698:24 possible 434:22 634:21 354:21 423:1 440:7 442:7
700:5,12 463:14 514:24 predictions 477:4 424:5 470:15 446:16 476:23
pointed 553:1,2 527:8 532:23 519:24 520:1 524:12 561:18 477:19 521:10
pointing 415:3 534:19 535:10 683:16,16 599:19,19 600:15 534:22 535:6
652:7 629:19 643:10 predicts 640:5 primary 451:12 592:8,20,20
points 578:9 634:6 654:17 658:20 predominant 534:1 474:11,12 534:6 594:12 595:22
634:6,7,23 635:3 672:17,19 674:3 558:13 539:22 596:1,25 598:14
640:13,19 644:2 688:4,8 prefer 463:5,16 principal 354:10 600:1 686:11
646:16 647:17 possibly 407:10 preparation 448:3 principle 434:8,21 693:7
polder 422:13 595:11 691:25 667:4 printed 371:14 processes 345:1
442:10 460:17,24 692:15 prerogative 325:22 430:12 348:22 349:18,23
461:2 484:20,25 post 449:4 presence 351:14 prior 509:14 352:16 353:7
486:6,16,23 490:4 post-Katrina 379:19 469:24 567:16 579:13,15 354:7,15,18 395:8
490:6 500:12 347:19 470:4,16 481:10 579:18 396:12 533:2
511:21 613:2,6 post-storm 642:23 481:17 482:16,21 probably 342:7,8 581:25 598:14
614:7 615:9,13,14 potential 328:12 495:22 498:3,9 347:16 370:13 679:15,18
615:22 616:7 387:4,5 431:9 522:7 670:11,25 376:1 386:4 produce 351:10
619:23 623:25 439:21 449:11,13 675:22 392:13 404:2 548:25
638:4 458:14 462:5 present 320:11 405:6 411:4,16 produced 358:20
polders 484:5 531:18 577:7,14 351:13 500:8 420:21 466:1 359:4 367:17
485:16 489:13 669:23 672:24 524:2 551:4 658:4 467:3 476:7 368:1,7 378:22

Page 734
389:21 390:2 protected 533:14 purpose 327:13 325:9 358:7,9 692:4,23,24

399:22 453:10 533:16 535:1 331:19 337:12 372:8 375:9 695:14 696:23
460:16 519:2 588:14 670:10,12 376:19,21 377:3 378:13 387:2,18 questioning 347:20
521:25 661:23 670:24 671:1 433:22 435:4 387:25 390:1,16 questions 361:25
681:12 protecting 345:6 479:8,14 480:3,5 393:10 394:1,9 380:25 416:21,24
produces 654:25 protection 345:8 490:7 493:22 395:16 397:13 440:6 452:11
producing 519:1 345:25 350:1,20 494:8 553:7 612:1 398:11 399:10 456:10,11 465:16
597:8 355:1 385:24 678:24 400:17,18,22 466:7,20 484:8
products 661:22 407:20 408:7,15 purposes 322:5 402:15,18,20,23 488:7 501:1
professional 432:15,24 459:3 549:24 619:1 404:10,11 406:1 592:12 593:12
446:13 482:9 496:1 533:9 657:1 662:1 409:1 412:24 595:7,10,13,23
Professor 488:4,11 598:16 665:22 680:18 413:1,3 417:6,19 598:8 659:7
488:18 498:16,23 667:10,10 668:19 pursuant 322:7 424:18 433:8 667:11 686:5,6,10
502:22 505:21 669:11,16 675:10 put 323:9 345:2 434:19 438:20,22 686:16,18 687:9
506:13,22 507:23 protections 346:25 356:16 361:13,24 441:14,21,22,23 687:25 688:10
509:3 521:25 protective 366:6 368:24 416:2 442:1,20 443:11 692:7 697:24
600:5 677:14 prove 429:5,15 458:11 497:3 444:13 446:7 quickly 351:23
profile 683:15 provide 350:4 562:13 572:18 448:15 451:19,21 477:8,19
688:15,21 497:12 583:5 596:9 603:18 451:24 453:3,7 quite 351:10,23
program 346:11 626:7 641:20 630:6 632:18 454:18 457:11 381:19 382:4
393:23 670:3 647:16 661:21 639:1,4 657:8 458:9,25 461:7 395:20 401:8
programs 346:9 688:19 684:5 690:11 465:5 474:8 480:6 471:14 495:18
progress 664:11 provided 361:9 695:11 697:11 480:8 484:2,3 502:11 514:6
project 367:19 417:1 424:20 putting 637:14 485:14 487:9 552:3 556:10
393:5 432:24 538:21 693:4 490:25 494:10,14 558:15 570:25
projects 346:11,12 549:16 557:8 P.E 318:11 323:1 494:18,19,21 589:7 591:19
346:12,14 350:1 588:6 666:16 p.m 613:19,25 500:25 502:16 620:17 657:8
350:20,20 354:16 688:22 619:12,18,19 505:4,6 508:9 quoting 359:2
proof 521:20 providing 432:15 620:7 623:22 510:9 515:19 644:11
propagate 468:10 prudent 447:25 624:11 518:4,23 519:16
498:11 public 373:18,24 P.O 320:6 521:3 522:13 R
propagating 397:3 publication 323:20 531:17 534:4,10 radiation 474:5
397:4 470:15 377:3 602:23 Q 535:21,23 536:11 raise 402:7 558:3
558:2 612:9 publicly 377:2 qualified 672:15 544:7,9,20 549:8 606:25 628:7
propagation publish 455:6 qualitative 675:3 552:18 555:25,25 raising 402:10
354:13 409:21 published 376:25 quality 330:3,5 556:1,1,1,2 557:14
467:25 558:1 430:13 457:3 332:5 346:7 572:23 581:18 ran 418:2 563:25
588:8 578:6 669:25 513:11,11 587:13 592:11,25 593:4 633:6
proper 496:5 pull 335:11 539:23 670:13 671:2 593:15 594:16,17 range 333:14,16,19
properties 588:23 540:4 545:18 quantifies 331:20 595:19 596:3,5,11 375:19 398:7
670:10,24 546:1,2 549:17 quantitative 542:2 596:14,19,21 411:10 586:14
proponent 595:14 554:19 598:6 665:20,25 666:6 597:1 605:19 610:15 628:16
681:22 pulled 325:15 667:8 668:17 607:1 609:8 628:2 644:8 660:24
proportional 573:6 539:15 669:10,15,24 628:6 649:12 661:1,5 690:12
propose 376:8 pulling 507:14,17 quantities 634:12 662:2,4 667:13,18 ranged 363:2
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Page 735
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Page 736
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Page 737
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responded 376:23 517:23 520:6,8 345:9,19,24 453:23 454:10,22 563:3 564:3,15
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responses 344:23 571:18 572:24 354:5,23 355:11 462:2,7 463:17,24 575:25 576:10,14
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responsible 346:7 609:15 630:22 361:17 362:2,12 475:8 476:5 580:5,13 582:1
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Page 738
617:15,17,19 450:22 454:24 654:13,14 678:19 628:23 693:2 676:11 677:1

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Page 739
440:17,24 560:1 second-to-last 543:6,9,10,20 374:6,8,11,17 700:1

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Page 748
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BRUCE EBERSOLE (VOL II) February 5, 2009

IN RE: KATRINA CANAL BREACHES CIVIL ACTION

JOHNS PENDLETON COURT REPORTERS 800 562-1285

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