Title: West Coast Regional Water Supply Authority vs. Freeman F. Polk
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Permanent Link: http://ufdc.ufl.edu/UF00051290/00001
 Material Information
Title: West Coast Regional Water Supply Authority vs. Freeman F. Polk
Alternate Title: West Coast Regional Water Supply Authority vs. Freeman F. Polk and SWFWMD. Deposition of Robert Perry about different groundwater computer models used in designing a model
Physical Description: 4p.
Language: English
Publication Date: Sept. 12, 1988
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
General Note: Box 3, Folder 1 ( SWF CONSUMPTIVE USE PERMIT APPLICATION (CUP) FORM ), Item 1
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051290
Volume ID: VID00001
Source Institution: University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text
2





2
)
3 WEST COAST REGIONAL WATER )
SUPPLY AUTHORITY, )
4 )
Petitioner,
5 *)
vs. ) CASE NO. 88-1169
6 )
FREEMAN F. POLK and SOUTHWEST )
7 FLORIDA WATER MANAGEMENT DISTRICT )
)
g Respondent. )

9

10


DEPOSITON OF: ROBERT PERRY
12
TAKEN: Pursuant to Notice by
13 Counsel for West Coast
and Freeman F. Polk
14
DATE: September 12, 1988
15
TIME: 9:35 a.m. 3:15 p.m.
16
PLACE: SOUTHWEST FLORIDA WATER
17 MANAGEMENT DISTRICT
2379 Broad Street
18 Brooksville, Florida

19 BEFORE: PATRICIA L. TOMORY
COURT REPORTER
20 NOTARY PUBLIC

21

22

23

24

25


BAY AREA REPORTING, INC.
412 East Madison Street, Suite 800, Tampa, Florida 33602






3


1 APPEARANCES:
EDWARD P. de la PARTE, JR., ESQUIRE
2 de la PARTE, GILBERT & GRAMOVOT, P.A.
705 East Kennedy Boulevard
3 Tampa, Florida 33602

4 Attorney for West Coast Regional
Water Supply Authority
5

6 THOMAS E. CONE, JR., ESQUIRE
Blain & Cone, P.A.
7 202 Madison Street
Tampa, Florida 33602
8
Attorney for Freeman F. Polk
9

10 BRAM D.E. CANTER, ESQUIRE
Haben & Culpepper, P.A.
11 306 North Monroe Street
Tampa, Florida 32302
12
Attorney for Southwest Florida Water
13 Management District

14
CHRISTOPHER P. JAYSON, ESQUIRE
15 4508 Central Avenue
St. Petersburg, Florida 33711
16
Attorney for Pinellas County
17

18 ALSO PRESENT: Rick Stebnisky, Hydrologist/J.B. Butler
and Associates, Inc.
19
INDEX
20
DIRECT EXAMINATION BY MR. de la PART 5
21
CROSS-EXAMINATION BY MR. CONE 147
22
STIPULATION 174
23
__ CERTIFICATE OF REPORTER 175
24

25


BAY AREA REPORTING, INC.
412 East Madison Street, Suite 800, Tampa, Florida 33602




29



1 Q. The only difference is being the difference in

2 storage?

3 A. Right.

4 Q. For those two nodes?

5 A. Yes.

6 Q. Okay. And what do you do when your lake is

7 smaller than the cell in your graph? How do you--

8 A. Well, you do have problems when you have lakes

9 smaller than your nodes, but if you design your model

10 correctly and have done forethought on it, then you would

11 have a node approximately the size of the lake, if you were

12 of interest in that particular lake.

13 Q. Let's say you were using one-square-mile cells?

14 A. Then you would have to go back and assume that

15 the effect would be the same as in the water table.

16 Q. And there wouldn't be that difference in storage

17 if you--

18 A. There wouldn't be that much difference if you're

19 talking about small lakes in a large node.

20 Q. You have mentioned some groundwater computer

C 21 models that you have used, and I think you've mentioned

22 the Prickett-Lonnquist Aquifer Simulation Model and the

23 FMcDonald-Harbaugh model, yAre there any other groundwater

24 computer models that you have utilized in your work?

25 A. I have used the Lou Motz coupled aquifer model.


BAY AREA REPORTING, INC.
412 East Madison Street, Suite 800, Tampa, Florida 33602




30



1 I use theacobHantush analytical solution)in a computer

2 model.

3 Q. Any others?

4 A. Those are the primary tools.

5 Q. Have you ever had-- Did you set up these models

6 yourself, or did you utilize models that had been set up by

7 others?

8 A. Could you clarify the question, what you mean,

9 what you're asking?

10 Q. Have you prepared the computer code yourself or

11 did you use computer code off the shelf or computer code

12 that was provided to you by others?

m 13 A. Again, I'm going to ask you to qualify specific

14 models.

15 Q. Okay. Well, the four that you've mentioned.

16 The Prickett-Lonnquist model, have you used computer code

17 for the Prickett-Lonnquist model off the shelf or provided

18 to you by Mr. Prickett, or did you yourself prepare the

19 code, modify the code, or what have you?

20 A. I have done both.

21 Q. Okay. How about the McDonald-Harbaugh models?

22 A. I have used Mr. Harbaugh's model off the shelf.

23 I have not modified or touched his coding, as such.

24 Q. How about the Lou Motz coupled aquifer model?

25 A. I have done that coding myself.


BAY AREA REPORTING, INC.
412 East Madison Street, Suite 800, Tampa, Florida 33602




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