KTR00149

OWEN, GIB A.
10/16/2008
Page 1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: KATRINA CANAL BREACHES * CIVIL ACTION

CONSOLIDATED LITIGATION * NO. 05-4182
* Consolidated
PERTAINS TO: * SECTION K(2)
*
MRGO, ROBINSON * JUDGE DUVAL
(No. 06-2268) *
* MAG.WILKINSON
*
* * * * * * * * * * * * * * * **
Videotaped Deposition of UNITED

STATES OF AMERICA, BY AND THROUGH THE UNITED
STATES ARMY CORPS OF ENGINEERS, through its
designee, GIB A. OWEN, taken in the
above-entitled cause, pursuant to the
following stipulation, before Dawn H. Hymel,
Certified Court Reporter, at the U.S. Army
Corps of Engineers, 7400 Leake Avenue, New
Orleans, Louisiana, on Thursday, the 16th of
October, 2008, commencing at 10:10 a.m.
Johns Pendleton Court Reporters 800 562-1285

OWEN, GIB A.
10/16/2008
Page 2 Page 4
1 APPEARANCES: 1 INDEX
2 Appearing on Behalf of Plaintiffs:
3 (Via Teleconference)
2 PAGE
O'DONNELL & ASSOCIATES, PC 3 EXAMINATION BY:
4 PIERCE O'DONNELL, ESQ. 4 Mr. O'Donnell 6
550 South Hope Street 5
5 10th Floor
Los Angeles, CA 90071
6 EXHIBITS
6 -and- 7
J. ROBERT WARREN, II, ESQ. 8 30(b)(6)
7 Katrina Canal Breaches Consolidated 9 1 Greater New Orleans HSDRRS
Litigation
8 Plaintiff's Litigation Coordinator Status-June 2008 11
855 Baronne Street 10
9 New Orleans, Louisiana 70113 2 Solicitation, Offer and Award 18
-and- 11
10 SHER, GARNER, CAHILL, RICHTER,
KLEIN & HILBERT, LLC 3 Performance Evaluation of the
11 BY: MATTHEW CLARK, ESQ. 12 New Orleans and Southeast
909 Poydras Street Louisiana Hurricane Protection
12 28th Floor
New Orleans, Louisiana 70112
13 System 56
13 14 4 Decision Record and IER #11 80
14 15 5 IER #11 Tier 2 Borgne 102
Appearing on Behalf of the United States of 16 6 Notice of Availability and
15 America:
16 U.S. DEPARTMENT OF JUSTICE Clean Water Act Public Notice 104
CIVIL DIVISION 17
17 BY: MICHELE S. GREIF, ESQ. 7 HSDRRS 2008 Facts and Figures 130
1331 Pennsylvania Avenue, NW 18
18 Room 8022S, National Place
Washington, DC 20004 8 Project Fact Sheet 138
19 -and- 19
UNITED STATES DEPARTMENT OF JUSTICE 9 MRGO Impacts and Restoration
20 CIVIL DIVISION, TORTS BRANCH
BY: JACK WOODCOCK, ESQ.
20 Options 144
21 Post Office Box 888 21 10 MRGO Reevaluation Study 146
Benjamin Franklin Station 22
22 Washington, DC 20044 23
23
24 24
25 25
Page 3 Page 5
1 Appearing on Behalf of the U.S. Army Corps of 1 STIPULATION
Engineers:
2 2 It is stipulated and agreed by and
U.S. ARMY CORPS OF ENGINEERS 3 between all parties that this deposition is
3 New Orleans District
BY: DAVID R. DYER, ESQ.
4 hereby being taken for all purposes pursuant
4 Post Office Box 60267 5 to the Federal Rules of Civil Procedure.
New Orleans, Louisiana 70160-0267 6 All formalities, with the exception of
5
6 7 the reading and signing of the deposition by
ALSO PRESENT: 8 the witness, are waived.
7
KEN HART-Hart Video
9 All objections, except those as to the
8 ROBIN SMITH 10 form of the question and the responsiveness of
CONOR KELS 11 the answer, are reserved until the deposition
9 ROBERT NORTHEY
PAUL LEVINE 12 is used or sought to be used in evidence.
10 13 MR. HART:
11
REPORTED BY:
14 This is the videotaped deposition of
12 15 Gib Owen. This deposition is being taken at
DAWN H. HYMEL 16 the Corps of Engineers, located at 7400 Leake
13 Certified Court Reporter #81016
14 17 Avenue in New Orleans, Louisiana. Today's
15 18 date is October 16th, 2008.
16
17 19 My name is Ken Hart. I'm a
18 20 Certified Legal Video Specialist with Hart
19
20
21 Video. The court reporter is Dawn Hymel with
21 22 Johns Pendleton & Associates.
22 23 Would counsel please introduce
23
24 24 themselves?
25 25 MS. GREIF:
2 (Pages 2 to 5)
OWEN, GIB A.
10/16/2008
Page 6 Page 8
1 Michele Greif for the United States. 1 Q. Fisheries. Okay. Do you have any
2 MR. WOODCOCK: 2 engineering background?
3 Jack Woodcock, the United States. 3 A. No, sir.
4 MR. DYER: 4 Q. Okay. Urban planning background?
5 David Dyer, Corps of Engineers. 5 A. No, sir.
6 MR. CLARK: 6 Q. Okay. Oceanography background?
7 Matthew Clark, plaintiffs. 7 A. No, sir.
8 MR. WARREN: 8 Q. Okay. You have been designated by the
9 Robert Warren, plaintiffs. 9 defendant in this case to be what we call a
10 MR. HART: 10 Rule 30(b)(6) witness on three topics. Are
11 Would the court reporter please 11 you familiar with that?
12 swear in the witness? 12 A. Yes, sir.
13 MR. O'DONNELL: 13 Q. And have you looked at topics 31, 32 and
14 Pierce O'Donnell for the plaintiffs 14 33?
15 Robinson. I'll be doing the examination. 15 A. Have I? No.
16 -0- 16 MS. GREIF:
17 GIB A. OWEN, 7400 Leake Avenue, New 17 I don't think --
18 Orleans, Louisiana, 70160, after having been 18 A. I don't believe so.
19 duly sworn, testified as follows: 19 MR. O'DONNELL:
20 EXAMINATION BY MR. O'DONNELL: 20 Michele, if I may, I'll just
21 Q. Good morning, sir. How are you? 21 summarize what the three topics are that I'm
22 A. Just fine. How are you today? 22 going to examine about this morning. Is that
23 Q. Would you state your -- I'm doing fine. 23 okay?
24 Would you state your name and spell it for the 24 MS. GREIF:
25 record? 25 That's fine.
Page 7 Page 9
1 A. Sure. It's Gib A. Owen, and it's G-i-b, 1 BY MR. O'DONNELL:
2 A is the middle initial, Owen, O-w-e-n. 2 Q. 31 is the analyses, studies, reports, and
3 Q. And how are you employed, sir? 3 decision making concerning Army Corps's
4 A. I work for the U.S. Army Corps of 4 conceptual plan to construct a MRGO/GIWW surge
5 Engineers as a biologist. 5 barrier as detailed in the Army Corps's
6 Q. And are you in the New Orleans District? 6 Greater New Orleans Hurricane and Storm Damage
7 A. Yes, sir. 7 Risk Assessment (sic) System, 100-year Design
8 Q. And how long have you worked for the Army 8 Plan, Map downloaded from, and then there's a
9 Corps? 9 website.
10 A. Going on eight years. 10 You're familiar with that posting on the
11 Q. Okay. And briefly, what's your college 11 website, are you not, sir?
12 or post-college education? 12 A. Yes, sir.
13 A. I have a B.S. degree in marine biology 13 Q. Are you the one who posted it?
14 from Texas A&M University. 14 A. I'm the person that runs the web. I
15 Q. And when did you get that? 15 have somebody actually manages it, but I get
16 A. 1985. 16 most of the material up there.
17 Q. And when did -- What did you do before 17 Q. Yeah. I know about that. I barely know
18 you joined the Corps? 18 how to turn on a computer myself. I suspect
19 A. I worked two years for NOAA as a marine 19 you know more.
20 mammal biologist in the Bering Sea. And then 20 Your second topic, sir, again, is
21 I did thirteen years with the State of Florida 21 study -- analyses, studies, reports, and
22 as a biologist. 22 decision making concerning the Army Corps's
23 Q. And what was your specialty in the State 23 conceptual plan to construct flood protection
24 of Florida? What did you concentrate on? 24 along Reach 2 of the MRGO (Upper St. Bernard
25 A. Fisheries. 25 Levee and Lower St. Bernard Levee) ranging in
3 (Pages 6 to 9)
OWEN, GIB A.
10/16/2008
Page 10 Page 12
1 height from 26 and a half feet to 29 feet as 1 more detailed map with photo inserts.
2 detailed in, again, the same 100-year Design 2 A. Right.
3 Map. 3 Q. Do you see that?
4 Are you familiar with that subject, sir? 4 A. We don't have the back page. We just
5 A. I believe so. I'm not -- I'm a little 5 have the front page.
6 confused what you're -- Are you talking 6 Q. Okay. Well, we probably won't talk much
7 about -- You're not talking about the IHNC 7 about at all the back page. I'm interested in
8 surge barrier anymore at that point? 8 the front page.
9 Q. I'm also talking about -- No, I'm talking 9 First of all, tell me what the generic
10 about the raising of the so-called levees in 10 title or name is for the project you're
11 the upper and St. Bernard levee region. 11 working on that relates to our topic today.
12 A. Oh, okay. Yes, sir, I am. 12 A. Well, the over, the overall is the
13 Q. Yeah. And we're going to get to the map 13 Hurricane Storm Damage Risk Reduction System.
14 just momentarily. 14 Q. Is that the HSDR --
15 A. Okay. 15 A. Yes, RRS.
16 Q. The third, 33 topic is, again, analyses, 16 Q. -- RS?
17 studies, reports, and decision making 17 A. Yeah. And then we --
18 procedures regarding the Seabrook surge 18 Q. When was that -- Go ahead.
19 barrier. 19 A. I'm sorry. No, that's fine. Go ahead.
20 You're familiar with that? 20 Q. When was that project initiated or
21 A. Yes, sir. 21 conceived or when did it start?
22 Q. Okay. Tell me what your duties and 22 A. It would have come out of the
23 responsibilities are with regard to what I 23 authorization, the fourth supplemental
24 believe is called by the Corps -- 24 authorization that came out of Congress in, I
25 Withdrawn. 25 believe it was early 2007.
Page 11 Page 13
1 Let's mark as Exhibit 1 for the Owen -- 1 Q. Was this a project that the Corps had
2 for the 30(b)(6) deposition, if we may, this 2 proposed to Congress for authorization?
3 map, if you're familiar. I'm holding it up. 3 A. I don't know. I mean, it's the 100-year
4 A. Yes, sir. 4 protection plan.
5 Q. Do we have a copy? Do we have one there? 5 Q. Okay. This is a component of the
6 MR. WOODCOCK: 6 100-year protection plan or is this the
7 How old is this one? 7 protection plan itself?
8 MS. GREIF: 8 A. This is the 100-year protection plan.
9 Yes. 9 Q. Okay. And has Congress -- You mentioned
10 A. Yeah. 10 authorization in early 2000 (sic). Has
11 BY MR. O'DONNELL: 11 Congress appropriated funds to implement this,
12 Q. Do you have the pretty color version? 12 this project?
13 A. Yep, sure do. 13 A. Yes, sir.
14 Q. Good. I picked this up in your lobby on 14 Q. And how much has Congress appropriated to
15 Leake Avenue a few weeks ago, so I appreciate 15 date, to your knowledge?
16 it. So we've marked as Exhibit 1, does yours 16 A. To my knowledge, right now we have been
17 say June 2008 at the top, sir? 17 appropriated 16.8 billion dollars.
18 (Off-the-record discussion). 18 Q. And is this money now being spent?
19 A. Excuse me. I'm sorry. I was asking 19 A. Yes, sir.
20 Michele something. Can you say that again? 20 Q. Is some of the money being spent on
21 Q. At the top of Exhibit 1, does it say 21 projects involving repairing damaged levees
22 Status-June 2008? 22 from Katrina?
23 A. Yes, sir. 23 A. Yes, sir.
24 Q. Great. Okay. So we're working from the 24 Q. And that part of the project or one part
25 same document. And on the back page there's a 25 of the project, as I understand it, has been
4 (Pages 10 to 13)
OWEN, GIB A.
10/16/2008
Page 14 Page 16
1 known variously as Task Force Guardian or Task 1 ourselves on this, this map. Is this the most
2 Force Hope or both? 2 recently released map, sir?
3 A. Right. Well, Task Force Guardian was a 3 A. To my knowledge, it is.
4 project that ran for the first year after, 4 Q. Okay. Let's look at the dotted line
5 after Katrina. It actually ended in June of 5 where there's an arrow that comes out with a
6 2006. They were the ones that came in and did 6 legend, IHNC Surge Reduction Barrier.
7 the immediate repairs -- 7 Do you see that?
8 Q. Okay. 8 A. Yes, sir.
9 A. -- to bring the system up to what was 9 Q. And it says, construct interim barrier
10 damaged, bring it back to what it was before 10 across MRGO/D -- GIWW, and then it says
11 it was damaged. 11 design-build contract awarded, right?
12 Q. And is that project completed now? 12 A. Correct.
13 A. For the most part. I believe there are 13 Q. Okay. Now, first explain to me what is
14 some ongoing action, like real estate actions 14 meant by interim barrier.
15 and that, but -- 15 A. The project is a two phase, the -- as
16 Q. Okay. 16 it's explained in the Tier 2 document that's
17 A. -- the construction pieces have been done 17 out, has been out recently for the public
18 for a while. 18 review.
19 Q. And what was initiated after that? 19 Q. That's in a public comment situation now?
20 A. After that, we went into starting to do 20 A. The public comment period has ended and
21 authorized repairs that Congress authorized, 21 we just have not -- the Colonel has not made a
22 we call it the third supplemental, that 22 decision, final decision yet on it, but it --
23 authorized to bring the project, I think they 23 Q. Have the responses to comments been
24 call it restore and replace or accelerate to 24 published?
25 complete, so we started that. 25 A. No.
Page 15 Page 17
1 Q. Is that Task Force -- Is that Task Force 1 Q. So there's no record, there's no record
2 Hope? 2 of a decision yet?
3 A. Task Force Hope is the programmatic 3 A. Correct. We're actually doing a decision
4 manager of that project. 4 record, but that has not been signed yet.
5 Q. Okay. So -- All right. There's more 5 Q. Okay. Fine. So tell us the two phases,
6 than one project under Hope? 6 would you, please, for what I'll call the
7 A. Well, I mean, they're the programmatic, 7 surge barrier?
8 overseeing the whole hurricane storm damage, 8 A. Sure. The first phase would be to have
9 so you have the authorized to complete, but 9 an interim level of protection in place by
10 you also have then the 100-year that came in 10 2009, which will be basically a wall going
11 on top of that. 11 across the two mile opening with some gates,
12 Q. Okay. And you're involved with the 12 and then the final construction would be
13 100-year? 13 finished on, with everything on schedule, in
14 A. I'm involved with both of them. 14 2011, to bring it up to the full elevation
15 Q. Okay. What are your responsibilities on 15 that's being planned.
16 the 100-year plan? 16 Q. What is the ultimate elevation goal?
17 A. I'm the overall team leader for the 17 A. To my knowledge, in the document, I
18 environmental compliance effort. 18 believe that we reference it as 24 to 26
19 Q. And that would have involved the two 19 elevation.
20 environmental documents we're going to talk 20 Q. And how high, how high will the interim
21 about today, which are IER #11 and IER #11 21 be?
22 Tier 2 Borgne? 22 A. In the document we reference it at 20.75.
23 A. Correct. 23 Q. Now, that contract has been awarded, I
24 Q. Okay. Fine. And -- Okay. Let's look at 24 understand?
25 Exhibit 1 for a moment and kind of orient 25 A. Right. It was a design-build contract,
5 (Pages 14 to 17)
OWEN, GIB A.
10/16/2008
Page 18 Page 20
1 and it was awarded back early in this year. 1 estimated cost is approximately 675.2 million?
2 Q. I'm showing you what was produced by 2 A. Correct.
3 Robin Smith. It's called Solicitation, Offer 3 Q. And on top of that is a 20.245 million,
4 and Award, Contract Number W912P8-08-C-038 4 what's called base fee. Do you see that?
5 (sic). I'm going to mark this as 30(b)(6) No. 5 A. Yes, sir.
6 2. 6 Q. What is a base fee?
7 Do you have that there, sir? 7 A. I do not know.
8 A. Yes, sir. 8 Q. Does it maybe have something to do with
9 Q. Is this the design-build contract that 9 the contractor's profit?
10 was awarded? 10 A. I don't know. That would be a
11 MS. GREIF: 11 contracting question.
12 Take your time. 12 Q. Okay. And that's not your bailiwick,
13 A. Yeah, I don't know. 13 correct?
14 MS. GREIF: 14 A. Correct. That's right.
15 If you don't know, you don't know. 15 Q. Okay. Can you just -- By the way, has
16 A. I don't know if it's the full contract 16 the location where this dotted line on Exhibit
17 or, or just part of it or whatever. 17 1 is indicated now the site that's been
18 BY MR. O'DONNELL: 18 selected for the barrier?
19 Q. Okay. So this is what was produced. 19 A. It is the recommended proposed action
20 We'll deal with this as best we can. 20 that was in the IER Tier 2 document.
21 A. Okay. 21 Q. And as I recall, we'll go through this
22 Q. If you go to Page 2, it appears that the 22 briefly a little later in the morning, there
23 contract has been awarded to Shaw 23 were like four or five, six alternative
24 Environmental & Infrastructure, Inc. in New 24 locations. I think it was five locations
25 Orleans? 25 considered.
Page 19 Page 21
1 A. That is correct. 1 A. There were five.
2 Q. Okay. And that's a company that's part 2 Q. And this ultimately was the preferred or
3 of The Shaw Group? 3 recommended one?
4 A. As far as I know, yeah. 4 A. That's correct.
5 Q. Okay. All right. And if we go down to 5 Q. Now, you were involved with those
6 paragraph number 22 in the middle, it says 6 environmental assessments as the team leader,
7 amount, and it has, it's estimated to be 7 correct?
8 $695,489,766? 8 A. That's -- Yes, sir.
9 A. That's correct. 9 Q. Who did you work with, other than the
10 Q. And does that cover both phases? 10 environmental team, in coming up with the
11 A. Yes, sir. That was the initial cost when 11 alternatives? Were there other people in the
12 this was awarded. It covered both phases. 12 Corps, like engineers or hydrologists,
13 Q. And if we go to the third page, there's 13 hydraulics people, oceanographers? Tell me
14 some detail, and we're told that the estimated 14 how that team came together.
15 cost, and I'll round the numbers, is about 15 A. Okay. We have a full team, we call them
16 675.2 million, correct? 16 a project delivery team. It would -- It would
17 A. 675 or 695? 17 have members of your, your, your engineering
18 Q. Well, no, the -- No, before we get to -- 18 group, various members from that, you would
19 A. I'm up at the very top. I'm sorry. 19 have real estate, you have office of the
20 Q. Before we get to the total, Page 3, 20 counsel, relocation specialists, quite a,
21 middle of the page, there's an estimated cost 21 quite a number of Corps people involved. We
22 base fee subtotal, et cetera. 22 also had a team of, we call it the interagency
23 Do you see that? 23 team, which is all of our resource agencies,
24 A. Yeah, I see it now. All right. 24 U.S. Fish & Wildlife, National Marine
25 Q. So before we get to the base fee, the 25 Fisheries Service, local -- the LA Department
6 (Pages 18 to 21)
OWEN, GIB A.
10/16/2008
Page 22 Page 24
1 of Natural Resources, groups like that. We 1 general vicinity?
2 also went and had, I believe, two public 2 A. No, not really.
3 meetings and asked the public, you know, what 3 Q. Was it post-Katrina, to your knowledge?
4 they thought, which alternatives they would 4 A. Not -- Not that I know of. I hadn't
5 like to see us look at. 5 been -- I hadn't been party to any discussions
6 Q. And let me ask, and I take it, you said 6 pre-Katrina on putting anything out there.
7 your project delivery team had engineering, 7 Q. All right. So the first time you knew of
8 real estate, counsel. What was the fourth 8 anything, it was after Katrina and sometime in
9 thing? 9 March of 2007?
10 A. It would have relocation specialists on 10 A. Correct.
11 it. It would have had contracting, you know, 11 Q. Do you have any knowledge of when the
12 pretty much somebody from every discipline of 12 earlier providence of this project was or its
13 the Corps was represented. 13 origins or shall we just assume that it began
14 Q. I take it environmental, environmental 14 sometime in early '07?
15 was on there, right? 15 MS. GREIF:
16 A. Yes, sir. 16 Objection.
17 Q. Who was the -- Who is the head of the 17 MR. O'DONNELL:
18 project delivery team with all these different 18 All right. Withdrawn. That was --
19 components? 19 Sustained. Lousy question.
20 A. That would be Ron Elmer. He's the senior 20 BY MR. O'DONNELL:
21 project manager. 21 Q. Do you have any knowledge about whether
22 Q. Is he a civilian employee or a Corps 22 or not, prior to March 2007, the Army Corps
23 officer? 23 first considered putting some kind of a surge
24 A. He's a -- He's a civilian. 24 reduction barrier in this vicinity?
25 Q. Okay. And he's in the New Orleans 25 A. No, sir, I do not.
Page 23 Page 25
1 District? 1 Q. That's the first time you were involved,
2 A. Yes, sir. 2 right?
3 Q. And is he an engineer or what is he? 3 A. That's correct.
4 A. I believe he is an engineer. 4 Q. Have you read any documents that suggest
5 Q. Okay. When, to your knowledge, did the 5 that the idea itself predated March '07?
6 Corps first begin the process of analyzing and 6 A. No, not really.
7 evaluating a possible surge reduction barrier 7 Q. Do you have any -- And I think you said
8 in this general vicinity of where the five 8 you have no knowledge that it began before
9 alternatives were considered? 9 Katrina in late August, 2005?
10 A. We -- We started the formal NEPA process 10 A. That's correct.
11 in March of '07 when we, when we started our 11 Q. Okay. So, to your knowledge, at least
12 alternative arrangements. At that point we 12 your involvement began in March of 2007, that
13 started scoping meetings and stuff and started 13 was the first meeting?
14 asking people what they would like to see, 14 A. That's when we officially launched the
15 what alternatives they would like to see 15 NEPA process. I mean, we'd been working
16 investigated. 16 issues in that, but that's when we really
17 Q. In your experience, is it typical that 17 started trying to put any alternatives
18 when a project is being conceptualized, I'll 18 together for each one.
19 say, that the NEPA component comes in early? 19 Q. When did you start working -- When did
20 A. It's one of the very first pieces that 20 you start working issues relating to the surge
21 you start with, yes, sir. 21 reduction barrier?
22 Q. Okay. Do you know where the actual idea 22 A. It would have been about that time when
23 in the Corps initiated, even before you became 23 we actually started focusing on what the
24 involved, that we might want to consider 24 alternatives would have been, or are.
25 putting a surge reduction barrier in this 25 Q. Okay. When did you first go public that
7 (Pages 22 to 25)
OWEN, GIB A.
10/16/2008
Page 26 Page 28
1 you were -- that the Corps was considering an 1 Seabrook opening.
2 IHNC surge reduction barrier? 2 Q. Okay. So the IHNC is a broader encompass
3 A. It would have been around the March '07 3 because it also, in your view, picks up the
4 time frame. We had nine scoping meetings and 4 Reach 1 GIWW?
5 we went out at that point and started, you 5 A. Correct. And that's also a segment of
6 know, saying, here's what we think we may want 6 the MRGO channel in that area, also.
7 to build or what some alternatives may be, and 7 Q. Right. Which I think we sometimes call
8 then asked the public for their input. 8 Reach 1? You've heard that expression, --
9 Q. Okay. I notice that it's labeled IHNC 9 A. Yes, sir.
10 Surge Reduction Barrier. Is it fair to assume 10 Q. -- Reach 1? Reach 2 would be the part
11 that IHNC is the acronym for Inner Harbor 11 that goes generally southeast where the
12 Navigational Canal? 12 channel meets the GIWW, correct, towards the
13 A. That's true. 13 Gulf Outlet?
14 Q. Sometimes known as the Industrial Canal? 14 A. That's correct.
15 A. The Industrial Canal is a piece of it. 15 Q. All right. Now, what was the purpose
16 It's closer back up to the -- between the lock 16 of -- What is the purpose of constructing the
17 and the Seabrook opening. 17 IHNC surge reduction barrier?
18 Q. Let's go to the map, Exhibit 1, if you 18 A. The purpose of that barrier would be to
19 would, please, and we see to the left of where 19 protect the major populous of New Orleans from
20 the dotted line is, I see the words IHNC 20 a 100-year storm event.
21 inserted twice. 21 Q. And by storm event, you mean what we call
22 Do you see that? 22 a hurricane?
23 A. Yes, sir. 23 A. Correct.
24 Q. Is that stretch from Lake Pontchartrain 24 Q. Okay. Now, tell us what the nomenclature
25 down to where the GIWW Reach 1 comes into the 25 100-year storm event means.
Page 27 Page 29
1 T, is that general area what you consider the 1 A. It's -- I mean, that's more of an
2 IHNC? 2 engineering term, but it's, it's basically a
3 A. Yeah, basically anything to the west of 3 calculated event that's going to produce a
4 the two IHNCs you see would be what we would 4 certain size wind and surge event.
5 consider the overall IHNC. It's a compos -- 5 Q. For purposes of this barrier and the
6 It's a complex of the Industrial -- The 6 100-year storm event, what winds, what maximum
7 Industrial Canal and the GIWW and the MRGO 7 wind speeds are assumed?
8 make up the IHNC. 8 A. I do not know.
9 Q. Okay. That's fair. But to the south of 9 Q. What surge levels are assumed?
10 the T, I'll call it the T where the GIWW hits 10 A. The barrier is being built to handle
11 the western side of the IHNC there, the water 11 about a 24 to 26 foot surge, it's estimated.
12 goes south to the Mississippi River, correct? 12 Q. Excuse me?
13 There's a channel? 13 A. That's -- That's what they've estimated
14 A. Correct, there's a, there's a lock there 14 from the modeling.
15 called the IHNC lock. 15 Q. Okay. And, in fact, you told me that
16 Q. And we see it in purple, right, pointing 16 when it's finally completed, it will have a 24
17 to a yellow structure? 17 to 26 foot flood elevation, right?
18 A. Correct. 18 A. That's correct.
19 Q. Now, is that segment there also 19 Q. All right. Tell me a little bit about --
20 considered part of the IHNC? 20 I know you're not an engineer, but let's go to
21 A. Yes, sir. 21 the map, Exhibit 1, if we would, and let's
22 Q. Okay. So what part would you isolate to 22 start up at the GIWW part of the dotted line.
23 be just the Industrial Canal? 23 Do you see that?
24 A. It would be basically from the yellow dot 24 A. Where at?
25 marking the lock straight up towards the 25 Q. I'm on map -- the map.
8 (Pages 26 to 29)
OWEN, GIB A.
10/16/2008
Page 30 Page 32
1 A. Okay. 1 Q. Just a description. I know you're not an
2 Q. The dotted line, which is the barrier, 2 engineer, but you've described it, I know, in
3 right? 3 your environmental documents.
4 A. Right. Okay. 4 A. Right. The proposed plan is to build
5 Q. And I'm starting up in the northern side 5 approximately a two mile long structure. It's
6 where there's a little black line across the 6 a floodwall structure. It's using 66 inch, 66
7 GIWW. 7 inch concrete piles. It will have two
8 Do you see that? 8 navigable gates in it. One of them will cross
9 A. Right at the top of the dotted, red 9 the GIWW. Actually, I'm sorry, it will have
10 dotted line? 10 actually three navigable gates. One is the
11 Q. Yes, sir. 11 GIWW primary. As part of the interim measures
12 A. Okay. 12 they're going to build, they're looking to
13 Q. Do you see that black line? 13 build a 150 foot barge gate that would be in
14 A. Yes, sir. 14 operation for the first couple of years during
15 Q. It's to the, just to the east of Michoud. 15 the interim protection, and then that possibly
16 Do you see that? 16 might be left open during nonstorm season to
17 A. Yes, sir. 17 allow clear water flow. Your third structure
18 Q. All right. Tell me what that black line 18 is a navigable structure at Bayou Bienvenue,
19 indicates. 19 and that was mainly for smaller recreational
20 A. It's basically marking where the Reach -- 20 traffic, maybe some small commercial boats
21 We divided these all up into project reaches, 21 coming in and out of the bayou.
22 so that's just documenting that reach. 22 Q. And it's smaller recreational as opposed
23 Q. Okay. Is there going to be a structure 23 to deep draft ships because Congress has now
24 of some kind in that general vicinity? 24 deauthorized the MRGO for deep draft
25 A. There -- There will be floodwalls tying 25 navigation, correct?
Page 31 Page 33
1 into the existing levee in that area or 1 A. Correct. The crossing across the MRGO
2 floodwalls in that area. 2 would be closed completely with a floodwall.
3 Q. And the same thing, if we go to the south 3 There would be no opening there at all.
4 extremity of your dotted line, there's another 4 Q. So at Bayou Dupre, there will be no
5 black line. 5 opening?
6 Do you see that? 6 A. Bayou Dupre is farther down on the levee.
7 A. Right. Correct. 7 That would have a gate. But at -- Bayou
8 Q. What does that -- What does that depict? 8 Bienvenue would be right out in the middle of
9 A. Again, that's just the -- That's the 9 the, almost out in the middle of the red line
10 southern side of what we're looking at as the 10 structure for the IHNC. There would be no
11 IHNC surge barrier reach or project, and that 11 structure at all at the MRGO. It would be a
12 would tie into the earthen levee that's there 12 floodwall.
13 for the St. Bernard loop, the Chalmette loop. 13 Q. Okay. So if I -- if I'm in my little
14 Q. Is that what we call the upper 14 motorboat and I'm down, say, Bayou Mercier,
15 St. Bernard levee? 15 Mercier, is it Mercier? Do you see that?
16 A. I haven't heard that, so I don't know. 16 A. Mercier, yeah.
17 Q. Okay. Now, generally, and I've read the 17 Q. Okay. You see that? I'd like to go
18 environmental documents, we'll get to them, 18 north up to the GIWW. Once this project is
19 but generally describe for us, if you would, 19 finally completed, will my boat be able to go
20 please, what the barrier is going to be 20 all the way up to MRGO?
21 constructed out of and how do ships make their 21 A. No, it will -- it will come up to the
22 way through the barrier on either the GIWW or 22 barrier and you would have to, actually, you
23 the MRGO? Let's start with the general design 23 would have to come out somewhere prior, prior
24 of it. 24 to getting up that far in the old channel out
25 A. Okay. It's -- 25 into Lake Borgne and join with the Bayou
9 (Pages 30 to 33)
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10/16/2008
Page 34 Page 36
1 Bienvenue and then come up through it, through 1 Q. Okay. So I basically, I basically have a
2 the new gate that would be built. 2 permanent structure where the black line is
3 Q. All right. So my little, my little 3 below Bayou Bienvenue. Let's move north again
4 boat's put-putting up the MRGO in a generally 4 now to the GIWW, okay?
5 northwestern direction, I eventually want to 5 A. All right.
6 get to Paris Road, let's say, bridge, okay? 6 Q. What kind of a gated structure will be
7 A. Okay. 7 there to allow shipping to --
8 Q. So what am I going to do? I'm going 8 (unintelligible).
9 to -- I'm going to -- Am I going to take a 9 THE COURT REPORTER:
10 right turn into the -- into Lake Borgne? 10 Can you repeat the question? We
11 A. Correct. You would need to go out into 11 have --
12 Lake Borgne and in -- On the map, right above 12 A. We have an announcement.
13 where you see the elevation 26 and a half to 13 BY MR. O'DONNELL:
14 28 feet in green, -- 14 Q. What's this, the blue plate special in
15 Q. Yes. 15 the cafeteria?
16 A. -- you can see a little bit of a channel 16 A. I think it's the Blood Fair or the Health
17 forming. 17 Fair.
18 Q. I do. 18 THE COURT REPORTER:
19 A. If you -- If you follow that channel up 19 Could you please repeat the
20 to where the arrow connects the red line, -- 20 question? I couldn't hear it.
21 Q. I do. 21 MR. O'DONNELL:
22 A. -- that -- right in that area there would 22 I'll be happy to.
23 be a gate, 56 feet wide, that would be the 23 BY MR. O'DONNELL:
24 Bayou Bienvenue gate. 24 Q. Let's proceed back up now the dotted line
25 Q. And then I go through that gate, which is 25 to the northeast to where we have our little
Page 35 Page 37
1 ordinarily closed or open? 1 black line again on the GIWW.
2 A. It would normally be open except during 2 Do you see that, Mr. Owen?
3 an event. 3 A. Yes, sir.
4 Q. Okay. So I go through there and then I 4 Q. Okay. What -- Obviously you want ships
5 hang a left, if you will, and I go into Bayou 5 to pass through. What kind of a gated
6 Bien -- then I can go in that little waterway, 6 structure will be up there?
7 and then continue up the MRGO channel to the 7 A. Okay. Initially there will be a 150 foot
8 GIWW? 8 barge gate built that would be built within
9 A. Correct. 9 the -- this year, so that traffic could
10 Q. Okay. Is there any dredging that's going 10 continue through there for the next year or
11 to be part of this longer term project or is 11 two. Just to the north of it would be a 150
12 the MRGO going to be maintained in what it is 12 foot permanent gate that would allow the
13 now, post-Katrina, in terms of depth? 13 shallow draft traffic to go east and west on
14 A. I mean, the channel from the confluence 14 the Intracoastal Waterway.
15 of the GIWW south has been deauthorized, so 15 Q. Is that the width of the GIW there, GIWW
16 there is no plan to do any further maintenance 16 in that location, about 150 feet?
17 there. 17 A. That's the authorized width of the
18 (Interruption). 18 channel in that area. The channel right now
19 A. The MRGO channel that is part of the GIWW 19 is actually much wider than that.
20 there to the, farther to the west, would be 20 Q. So what are we going to do about the --
21 continued to be maintained as a deep draft. 21 A. There will be a --
22 Q. Because that's still open to shipping, 22 Q. -- difference between a hundred --
23 right? 23 A. There will be a, from the -- When the
24 A. Correct. The deep draft people could 24 gate -- Where the gate is, 150 feet from there
25 still come up to the Michoud slip and canal. 25 on to the shoreline will be floodwall.
10 (Pages 34 to 37)
OWEN, GIB A.
10/16/2008
Page 38 Page 40
1 Q. Got it. Okay. So whatever widening has 1 feet. A good part of it is marsh, so that's
2 occurred, that will be made up by a permanent 2 going to be fairly shallow. You're going to
3 floodwall, correct? 3 have some open water areas that have subsided
4 A. Correct. 4 that will be a little bit deeper.
5 Q. Will that floodwall also be 24 to 26 feet 5 Q. Is there any -- Does any part of the
6 high? 6 HSDRRS involve wetlands restoration?
7 A. Yes, sir. 7 A. No, sir.
8 Q. Okay. And I take it that the gate will 8 Q. Or is it merely, merely the construction
9 remain in an open position unless and until 9 of the physical barrier?
10 there's a storm event? 10 A. The -- I mean, we will be building the
11 A. That's correct. 11 barrier. Now, we will be restoring marsh or
12 Q. And this gate, is it a hydraulic, I'm 12 whatever as part of our mitigation efforts for
13 using my hands, it has hinges that open and 13 what we destroy, but that's not -- It's
14 close, or how does it work? 14 strictly a mitigation effort. It's not --
15 A. It's a -- It will be some sort of a 15 It's not an ecosystem restoration effort.
16 sector gate. We've not identified the final 16 Q. I understand that. So a more
17 design on it, but it -- I'm trying to look on 17 comprehensive ecosystem restoration is not
18 one of the back pages to see if they -- If you 18 part of this budget?
19 look on the back page on the Harvey Canal 19 A. That's correct.
20 sector gate, it's at the bottom, you could see 20 Q. There's other projects underway or
21 a similar type, what a sector gate would look 21 studies, I understand it, the LCA project, for
22 like. It has -- 22 example, and others, that are focusing on that
23 Q. I see. 23 effort?
24 A. -- two rounded gates that would come out 24 A. That's correct.
25 and close in the center. It's -- 25 Q. Okay. Fine. You said that the final
Page 39 Page 41
1 Q. I got it. 1 constructed barrier will be approximately 24
2 A. There is no final design yet since this 2 to 26 feet high because the modeling showed
3 is a design-build. 3 that that would be appropriate in the event of
4 Q. Okay. But there are precedents for how 4 a 100-year event, correct?
5 to build this, I take it, in the Corps's 5 A. That -- That is my understanding, yes,
6 engineering history? 6 sir.
7 A. Oh, yes. 7 Q. Okay. What modeling was done to get to
8 Q. Okay. And how far back do these kind of 8 that conclusion?
9 gated structures go, to your knowledge, how 9 A. I -- I do not know that.
10 many decades? 10 Q. Who did the modeling?
11 A. I don't know. A lot. We've been 11 A. I don't know for sure. I would imagine
12 building gates for many, many years. 12 it was mostly ERDC, although it may have been
13 Q. Decades? 13 some of our in-house folks, too.
14 A. Decades. 14 Q. What's ERDC?
15 Q. Okay. And -- Okay. Let's go back to the 15 A. It's our research lab in Vicksburg,
16 front page now of Exhibit 1, if you would, 16 Mississippi.
17 please, sir. 17 Q. Can you -- What's the -- What's the
18 A. Okay. 18 acronym?
19 Q. What is the approximate depth of the 19 MR. WOODCOCK:
20 water across where the dotted line is in Lake 20 Engineering Research Development --
21 Borgne? 21 A. It's what? Engineering Research --
22 A. The red line itself? 22 MS. GREIF:
23 Q. Yeah. What's the approximate depth of 23 Development.
24 the water there? 24 A. -- Development Center.
25 A. It probably ranges between four to eight 25 MS. GREIF:
11 (Pages 38 to 41)
OWEN, GIB A.
10/16/2008
Page 42 Page 44
1 Yeah. 1 hurricane protection project was already --
2 BY MR. O'DONNELL: 2 had already constructed floodwalls and stuff
3 Q. Is that the facility in Vicksburg? 3 in the area.
4 A. Yes, sir. 4 Q. Right. But there was no surge barrier as
5 Q. Okay. And your understanding is the 5 part of that project, correct?
6 modeling was done there? 6 A. No. Correct. The surge barrier is
7 A. My understanding is they did some of it. 7 replacing those floodwalls or augmenting
8 Some of it, I believe, was done in-house. 8 those, those floodwalls that were already
9 They may even have had some of it done 9 there.
10 elsewhere. I don't know. 10 Q. Providing augmented or supplemental
11 Q. Do you know where else they had it done? 11 levels of protection?
12 A. No, sir. 12 A. Right. It will provide a higher level of
13 Q. Do you know where I can find those models 13 protection with the surge barrier, correct.
14 or the results of that modeling? 14 Q. And the concept is that if we build a
15 A. I would assume Mr. -- Mr. Elmer ought to 15 surge barrier and keep surge out of this area,
16 be able to provide that. 16 we won't need to build as high a floodwalls
17 Q. Do you know whether they've been posted 17 along the GIWW or IHNC?
18 on a website or are available to the public 18 A. That's correct. I mean, and that was
19 anywhere? 19 what we looked at in the initial Tier 1
20 A. I -- I do not know that. 20 document, was rebuilding all that parallel
21 Q. Have you seen the modeling results at 21 protection versus doing a surge barrier.
22 least? 22 Q. But the Corps has concluded that the most
23 A. No. I mean, we were just given the 23 effective means to protect the population and
24 elevations. 24 property in this area is the construction of
25 Q. Okay. But they, they, they, they, they 25 this surge reduction barrier?
Page 43 Page 45
1 emanate from whatever conclusions came out of 1 MS. GREIF:
2 the modeling results, right? 2 Objection.
3 A. That's correct. 3 A. The --
4 Q. Okay. Have you studied any Corps reports 4 BY MR. O'DONNELL:
5 or studies that had pre -- prior to Hurricane 5 Q. You can answer.
6 Katrina studied the option of putting some 6 A. Okay. We -- We use a number of criteria.
7 kind of a surge barrier in this general 7 I mean, risk and reliability was one that came
8 vicinity? 8 out of the engineering group. We used cost.
9 A. No, sir. 9 We had the environmental impacts. They had
10 Q. Are you aware that this concept goes back 10 scheduled duration. Through a delivery
11 to the 1960s? 11 process, we came to a conclusion that a surge
12 A. I knew there were various barrier studies 12 barrier there was better than, than rebuilding
13 looked at all over the whole system, but I've 13 the existing protection.
14 never been involved in any of the specific 14 Q. If we assume that March 2007 was
15 ones or read any of the reports. 15 approximately the beginning of a process
16 Q. Would it be fair to say that the Corps 16 leading to the ultimate construction, and
17 initiated this surge reduction barrier project 17 we'll just assume that because that's the only
18 because of the results of Hurricane Katrina? 18 date we have from you, the completion target
19 A. I mean, we already had a project in 19 date is approximately when?
20 place. We just came up with an alternative of 20 A. June of 2011.
21 how to bring it to this new 100-year level 21 Q. So it spans a little more than four
22 that Congress has authorized. 22 years, right?
23 Q. Pre-Katrina, what project was, quote, 23 A. Correct.
24 already in place? 24 Q. So the Corps believes that, that in a
25 A. The Lake Pontchartrain and vicinity 25 little over four years from initial concept,
12 (Pages 42 to 45)
OWEN, GIB A.
10/16/2008
Page 46 Page 48
1 study process to actual completion and 1 Q. And one of the things they look at is
2 providing the full protection is a process 2 prior experience that the Corps has had with
3 that spans over four, a little over four 3 these kinds of structures?
4 years? 4 A. I would assume so.
5 A. I did -- I didn't understand the question 5 Q. Okay. Can you identify other places in
6 in that one. I'm sorry. 6 the United States where the Corps has built
7 Q. The project from, I'll assume its 7 generally comparable surge reduction barriers?
8 earliest stages, maybe not the very earliest, 8 A. I'm not aware of -- I don't know.
9 but its earliest stages in March 2007 to the 9 Q. Okay. But they have built floodgates on
10 targeted completion of June '11 is a little 10 other bodies of water in the, in the historic
11 more than four years? 11 past you've told me, correct?
12 A. Yes, sir. 12 A. Right. We built floodgates. We built a
13 Q. At a cost slightly under 700 million 13 lot of locks.
14 dollars? 14 Q. And floodgates and locks are somewhat
15 A. That -- That cost has actually risen 15 analogous because it has, it has to do with
16 since then, but that was the initial cost 16 the movement of vessels through an area of
17 awarded. 17 water, correct?
18 Q. It's risen since April 3, 2008, which 18 A. Correct.
19 says -- which is on Page 2 of -- Page 1 of 19 Q. Okay. On risk, in the risk and
20 Exhibit 1 indicates what the date issued was? 20 reliability aspect of these criteria, is
21 A. Yes, sir. 21 the -- is this where the computer modeling on
22 Q. How much? 22 surge height is done, in this component?
23 A. I believe -- 23 A. No, sir. That would have been done as a
24 Q. I'm sorry. Go ahead. 24 separate piece. Risk and reliability tries to
25 A. I believe in the Tier 2 document we talk 25 look at just certain factors, you know, as I
Page 47 Page 49
1 about it being 822 million, and that, that 1 said, how many openings, how long is it, you
2 number may still continue to change. It's a 2 know, is there more risk associated with it.
3 cost -- It's a cost plus contract. 3 Q. So when these criteria are applied to
4 Q. We better hurry up and get this sucker 4 various alternatives, right, that's what you
5 built, right? 5 do?
6 A. We're -- We're working on it. 6 A. Right.
7 Q. Okay. That's only a fraction of the 700 7 Q. There's already been a scientific
8 billion bailout, so I wouldn't worry too much 8 assessment that we need to plan for surge that
9 about it, but -- 9 could get as high in a 100-year event of 24 to
10 The -- Okay. So we have a slightly more 10 26 feet, correct?
11 than four year process going on here. Let's 11 A. Correct.
12 go through the criteria. The first one you 12 Q. Okay. Now, let me digress for a moment.
13 identified, sir, was, I believe, risk and 13 If we look at Reach 2 of the MRGO, --
14 reliability? 14 A. Okay.
15 A. That's correct. 15 Q. -- we see -- Let's take the three colored
16 Q. What does that generally entail? 16 boxes right to the right of Bayou Mercier. Do
17 A. It would generally entail trying to 17 you see that?
18 ascertain some kind of, of idea of what the 18 A. Yes, sir.
19 risk of a structure would be. You know, is it 19 Q. And I see in the green box 26.5 to 28
20 a mile long or is it ten miles long? How many 20 feet. Do you see that?
21 openings would it have? And then tied with 21 A. Yes, sir.
22 that is the reliability of it. You know, is a 22 Q. What does that mean?
23 levee stronger than a floodwall? Is a gate 23 A. That is the established height for this
24 stronger? And that's done through the 24 structure to be in 2057.
25 engineering group that does that piece of it. 25 Q. 2057?
13 (Pages 46 to 49)
OWEN, GIB A.
10/16/2008
Page 50 Page 52
1 A. Yes, sir. 1 Mercier, do you have any idea of what
2 Q. And how about the 19.5 to 21.6 brown 2 approximately the 2011 goal is for the height
3 band, what year is that goal? 3 of the earthen levees there?
4 A. That is the current elevation of the 4 A. No, sir, I don't.
5 area, and that's the red line. That's not the 5 Q. How would I determine that? Is there
6 surge barrier, because it's not there, but -- 6 another document or map or person?
7 Q. No, I understand that, but currently the 7 A. We -- Yeah, Chris Gilmore is the project
8 Corps has determined that the existing earthen 8 manager for the St. Bernard Parish, and we
9 berms or levees there vary between 19 and a 9 also are preparing an IER for that area right
10 half and 21.6 feet? 10 now that would have it in it.
11 A. That's correct. 11 Q. Has that been published yet?
12 Q. And what's the 16.0 to 17.0 in the blue 12 A. No, sir, it has not.
13 box? 13 Q. Do you know, sir, when it might be coming
14 A. That's what the elevation would have been 14 out?
15 pre-Katrina. 15 A. I believe it's scheduled right now for
16 Q. Okay. So do I understand correctly that 16 around March of '09.
17 the Corps thinks raising these earthen levees 17 Q. Okay. Are there any preliminary
18 along this part of Reach 2 to the 26 and a 18 documents available to the public which give
19 half to 28 foot level will take almost fifty 19 us some kind of the scoping of it?
20 years? 20 A. I don't know. We could check with Chris
21 A. Well, it will be built in lifts. They -- 21 Gilmore.
22 They -- They've established a height that it 22 Q. All right. If you might do that, that
23 will need to be to for the 2011 100-year and 23 would be great. But again, I understand what
24 they would build to that, and then they would 24 the concept is, but whatever heights these
25 have lifts over the, whatever number of years 25 earthen levees along Reach 2 are built to,
Page 51 Page 53
1 needed due to subsidence to keep it at that -- 1 it's based on the modeling that you've told me
2 Q. So is the 2 -- Is the 2011 goal the brown 2 about earlier?
3 numbers, 19 and a half to 21.6? 3 A. That's correct.
4 A. That's the current elevation. This 4 Q. Let's talk about that a little bit more.
5 doesn't show what the current goal would be 5 Let's -- First of all, tell me what your
6 for 2011. 6 understanding of surge is, storm surge.
7 Q. Is it somewhere between the 19 and a half 7 A. My understanding, strictly from a
8 and 26 and a half? 8 biologist's standpoint, would be just the
9 A. It's somewhere in there. It varies by 9 height of the water coming in during an event.
10 reach, and I really don't know what, what it 10 Q. Does it also include the waves that are
11 would be in that area initially. 11 generated?
12 Q. But it's going to take approximately 12 A. Yes, sir.
13 fifty years to get to the 26 and a half to 28 13 Q. Okay. Now, where, in terms of where
14 feet which would presumably deal with the, 14 we've located -- you've located the surge
15 with the 24 to 26 feet of estimated surge in a 15 barrier along the dotted line of Exhibit 1,
16 100-year event? 16 where is the Corps assuming the surge is
17 A. Well, not, not necessarily. Again, it 17 coming from?
18 goes to whatever, whatever the 2011 elevation 18 A. The modeling, I think, believe -- I
19 might be, say, 26 and a half, so they might 19 believe most of the modeling is saying it's
20 build that and then just maintain that for 20 coming from Lake Borgne.
21 fifty years. In some reaches it might be 21 Q. Across that area that used to have
22 lower, that they just continually build due to 22 marshland and is now intermittent into the
23 what they're projecting as sea level rise and 23 barrier and into the mouth there, the gate?
24 subsidence. 24 A. Well, any -- any -- anything to the --
25 Q. So this area just to the -- near Bayou 25 any area possibly to the east would, would
14 (Pages 50 to 53)
OWEN, GIB A.
10/16/2008
Page 54 Page 56
1 come to that point if it was being -- if the 1 available on, say, the Corps's website or
2 surge was being pushed to the west. 2 somewhere else?
3 Q. Okay. And is the Reach 2 of the MRGO 3 A. I believe it is available through the
4 also a contributor to surge? 4 IPET reports and on the IPET website.
5 A. The channel itself -- 5 Q. Okay. So the modeling that is being used
6 Q. Yeah. 6 for this surge reduction barrier has its
7 A. -- or -- 7 origins in the IPET work that was done?
8 Q. In the Corps's assumptions. 8 A. That was my understanding, yes, sir.
9 A. I -- I don't know what the Corps's 9 Q. And do you know whether --
10 assumption is on that. 10 MR. O'DONNELL:
11 Q. Okay. Well, you agree with me that Reach 11 Let's mark as an exhibit the next
12 2 does extend from the Gulf of Mexico up into 12 exhibit, Rob, the excerpts that we have from
13 the, up to the heart of New Orleans at the 13 the March 26, 2007 final IPET. Do you have
14 GIWW, correct? 14 that?
15 A. Yes, sir. 15 MR. WARREN:
16 Q. Okay. And that it's tidal, there's tidal 16 Yes.
17 flow, correct? 17 MR. O'DONNELL:
18 A. Correct. 18 Let's mark that as 30(b)(6) No. 3,
19 Q. And that during hurricanes, water does 19 may we? And I'd like to suggest at this point
20 come up the MRGO Reach 2? 20 we take about a five minute, ten minute
21 A. There would be some water initially until 21 bathroom break, if that's okay, Mr. Owen.
22 the water topped the current elevation of the 22 THE WITNESS:
23 levee or the marsh in the area, and then it 23 That's fine.
24 would, it would be free flowing across the 24 MR. O'DONNELL:
25 whole area. 25 Everybody get up and stretch, and
Page 55 Page 57
1 Q. Correct. Including if the barrier, if 1 when you come back in your seat and give me
2 the earthen berm was 16 feet and the water was 2 the high sign that we're ready to go, we will
3 higher, it would overtop the berms, correct? 3 go, and I'll pick up with this document, okay?
4 A. If -- The 16 feet no longer exists today. 4 MR. HART:
5 The current elevation is 19 and a half to 21. 5 Off the record.
6 If you had a surge higher than that, it would 6 (A recess was taken).
7 overtop. 7 MR. HART:
8 Q. And there was surge higher than 16 or 17 8 We're back on the record.
9 feet during Katrina, was there not? 9 BY MR. O'DONNELL:
10 A. That is my understanding. 10 Q. Mr. Owen, I've put before you what we've
11 Q. Okay. Now, do you know from your study 11 marked as the 30(b)(6) Exhibit No. 3. Do you
12 of this matter whether any surge during 12 see that?
13 Katrina reached the 24 to 26 feet height in 13 A. Yes, sir.
14 the area where the dotted line for the surge 14 Q. And I saved a couple of trees, hopefully,
15 barrier is located? 15 by only taking some excerpts from this
16 A. I do not know that. 16 incredibly large volume of work.
17 Q. Okay. And again, can you give me even an 17 A. Yep.
18 approximation of what wind speed is assumed 18 Q. Just for the record, this is the Army
19 for the modeling that led to the estimate of 19 Corps of Engineers logo on the upper left and
20 surge of 24 to 26 feet? 20 it is the Performance Evaluation of the New
21 A. I do not know that, either. It was a 21 Orleans and Southeast Louisiana Hurricane
22 variety. They modeled 142 storms of various 22 Protection System, Final Report of the
23 sizes and strengths. 23 Interagency Performance Evaluation Task Force,
24 Q. Do you know whether any of that modeling 24 Volume IV - The Storm, dated March 26, 2007,
25 data, the assumptions, methodology is 25 and it bears the word Final.
15 (Pages 54 to 57)
OWEN, GIB A.
10/16/2008
Page 58 Page 60
1 Do you see that? 1 Q. And do you have any understanding of what
2 A. Yes, sir. 2 these models are?
3 Q. This is in shorthand known as the IPET 3 A. Absolutely not.
4 report, sir? 4 Q. Okay.
5 A. Yes, sir, one, at least a portion of it. 5 A. Sorry.
6 Q. No, no, I understand that it's only an 6 Q. Well, it makes at least two of us.
7 excerpt from one Volume IV, correct? 7 A. Yeah.
8 A. Correct. 8 Q. I've read this section and essentially
9 Q. Have you seen the entire final report? 9 the IPET team determined that wave and surge
10 A. I've seen it piled up. I've never read 10 were important elements with regard to what
11 it. 11 happened in Katrina and certain remedial
12 Q. Do you know if any human being has ever 12 measures and so they did a bunch of testing or
13 read it? 13 modeling, correct?
14 A. I'm not for sure of that. 14 A. That's -- That's my understanding, yes,
15 Q. I'm sure the authors did. And is it your 15 sir.
16 understanding that the genesis of the storm 16 Q. And they report that modeling in their
17 surge reduction barrier, at least in part, is 17 report, correct?
18 because of the IPET report? 18 A. Again, I haven't read it, so I don't
19 A. From glancing through this, I haven't 19 really know a hundred percent what they have
20 seen this before, but in glancing through it, 20 in there.
21 I see where on the second page they do 21 Q. I think you said earlier that it's your
22 reference some of the storm surge barrier type 22 understanding that some of the modeling that
23 stuff. 23 was the basis for the 24 to 26 foot surge
24 Q. Okay. 24 assumption came from IPET's studies, correct?
25 A. Even on the third page. 25 A. That is correct.
Page 59 Page 61
1 Q. Okay. Let's go to -- Again, this is an 1 Q. Are you aware of any additional studies
2 excerpt after the cover page for Volume IV, 2 done by the Corps or any Corps contractors
3 I'll designate that we have pages Roman 3 after these IPET modeling -- this IPET
4 IV-134, Roman-IV 135, Roman IV-136, and then 4 modeling was done that was used in making the
5 we skip to Roman IV 258. Do you see that? 5 24 to 26 foot surge assumption?
6 A. Yes, sir. 6 A. There has been ongoing modeling since,
7 Q. Go to page Roman IV dash, I'll just call 7 since the IPET and on. I couldn't tell you
8 it 136, we're in Volume IV throughout, and at 8 what it has been, but that -- You know, they
9 the very bottom it says Wave and Storm Surge 9 took the IPET stuff, built on that with new
10 Modeling Sensitivity Tests. 10 modeling or additional modeling, and came up
11 Do you see that? 11 with these, the final elevations.
12 A. Yes, sir. 12 Q. Okay. Let's -- At the bottom of Page
13 Q. I've only got two lines of this because 13 134, it's the second page of the excerpts that
14 the next page goes to a different point, but I 14 comprise Exhibit 3. Do you see that?
15 just want to reference what you said earlier. 15 A. The pink box?
16 It appears that the IPET team, in fact, did 16 Q. I'm in the section, Influence of the MRGO
17 wave and surge modeling tests, correct? 17 on Storm Surge in New Orleans Vicinity. Do
18 A. That -- That is my understanding, yes, 18 you see that, Page 2?
19 sir. 19 A. Yes, sir.
20 Q. And according to this introduction on the 20 Q. Okay. The second paragraph states, from
21 two sentence -- two lines I have, a number of 21 the perspective of long wave propagation, of
22 the tests included WAM, all caps W-A-M, 22 which the tide and storm surge are examples,
23 S-T-W-A-V (sic), STWAVE, and ADCIRC, 23 the critical section of the MRGO is Reach 1,
24 A-D-C-I-R-C, models, correct? 24 the section of waterway where the GIWW and
25 A. That's correct. 25 MRGO occupy the same channel (see Figure 93).
16 (Pages 58 to 61)
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10/16/2008
Page 62 Page 64
1 Do you see that? 1 A. Yes, sir.
2 A. Yes, sir. 2 Q. Okay. You're aware of the Bay of Fundy
3 Q. And that's the stretch you identified 3 effect? You've heard of that before?
4 earlier and, in fact, on the map there's an 4 A. Yes, sir.
5 arrow pointing to what I believe is about a 5 Q. And I've just generally described it,
6 six mile stretch of the GIWW-MRGO Reach 1. 6 right?
7 Do you see that? 7 A. Right.
8 A. Yes, sir. 8 Q. Large body of water being channeled into
9 Q. Okay. So one of the concerns that led to 9 a smaller area?
10 the -- that has led to the construction of 10 A. Yes, sir.
11 this surge barrier is that along this Reach 1, 11 Q. Right. That phenomenon's been known for
12 during a hurricane, surge will channel down 12 a long time, has it not?
13 that waterway, correct? 13 A. Yes, sir.
14 MS. GREIF: 14 Q. Okay. Fair to say that phenomenon was
15 Objection. 15 known before 1958?
16 A. Yes. Yes, sir, water would enter from 16 A. I wouldn't know.
17 Lake Borgne into that Reach 1 and, and 17 Q. Okay. When were you born?
18 possibly from Lake Pontchartrain. 18 A. 1958.
19 BY MR. O'DONNELL: 19 Q. Okay. Well, fair enough. Let's skip a
20 Q. And, by the way, Lake Borgne, while it's 20 couple sentences on Page 135. It states, as a
21 called Lake Borgne, is really an arm of the 21 result of this hydraulic connection, the storm
22 Gulf of Mexico, correct? 22 surge experienced with the IHNC and Reach 1
23 A. Yes, sir. 23 (GIWW/MRGO) is a function of storm surge in
24 Q. Okay. Now, it continues, it is through 24 both lakes; a water level gradient is
25 this channel, Reach 1, that Lake Pontchartrain 25 established within the IHNC and Reach 1 that
Page 63 Page 65
1 and Lake Borgne are hydraulically connected to 1 is dictated by the surge levels in both lakes.
2 one another via the IHNC, correct? 2 This is true for both low and high amplitude
3 A. It is -- It is one of the connections, 3 storm surge conditions.
4 yes, sir. 4 Do you see that?
5 Q. Yes. There's also connections through 5 A. Yes, sir.
6 the Rigolets and Chef Menteur, correct? 6 Q. Okay. So I take it one of the objects of
7 A. Yes, sir. 7 this surge barrier is to reduce the amplitude
8 Q. In fact, that's what the next sentence 8 of the surge and the waves that would go
9 says, so I'll skip that. Okay. It does -- It 9 through Reach 1 in, in a hurricane?
10 does say the IHNC is the smallest of the three 10 A. Yes, sir.
11 connections, right? 11 Q. And then as a result of reducing the
12 A. It is -- It is the smallest. Yeah, I see 12 amplitude of the waves, the surge and the
13 where you're saying. Yes, sir, it does say 13 waves, you would decrease the risk that the
14 that. 14 water would rise and overtop the existing
15 Q. And by smallest, it means the narrowest, 15 levees, correct?
16 correct? 16 A. Yes, sir.
17 A. Yes, sir. 17 Q. Or be of such force that it could, in
18 Q. The passes are wider than 150 to 200 18 fact, harm the levees, correct?
19 feet, correct? 19 A. I -- I don't understand what you mean by
20 A. Yes, sir. 20 force.
21 Q. Okay. Now, there's a phenom -- There's a 21 Q. Let -- Let me go to the IPET report. The
22 well-known phenomenon, is there not, when a 22 IPET report elsewhere concludes that there
23 volume of water is channeled or sent through a 23 were breaches of -- in a couple locations on
24 confined area, if there's sufficient volume, 24 the east and west side of the IHNC during
25 the water will tend to rise, correct? 25 Katrina.
17 (Pages 62 to 65)
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10/16/2008
Page 66 Page 68
1 You're generally familiar with that, 1 A. Correct.
2 right? 2 Q. -- as the winds swept in?
3 A. Yes, sir. 3 A. Right.
4 Q. And that led to flooding, right? 4 Q. So one of the goals in erecting this
5 A. Yes, sir. 5 surge protection barrier in the location it's
6 Q. Just checking. Okay. 6 being constructed is to reduce or minimize the
7 A. Yeah. 7 surge that could impact levees along the IHNC
8 Q. And by reducing this -- Let me back up. 8 in the event of a hurricane
9 The surge that comes off of Lake Borgne 9 A. Yes, sir. I mean, the goal, the goal of
10 unimpeded by any barrier goes down the 10 the barrier is to keep water out, entirely out
11 GIWW/MRGO Reach 1 and can go either north 11 of that area --
12 and/or south at that point along the IHNC, 12 Q. Right.
13 correct? 13 A. -- during an event.
14 A. Yes, sir. 14 Q. So -- So the water would stay essentially
15 Q. And we know during Katrina that in fact 15 at a very low and nonthreatening level?
16 happened, right? 16 A. Correct. You would have -- You'd have
17 A. Yes, sir, it filled up the whole Reach 1. 17 whatever came from your rainwater or your --
18 Q. In fact, in the initial hours of Katrina, 18 any of the pumping stations filling up that
19 water -- the water from Lake Borgne did not 19 basin, but not, not from the surge.
20 enter the IHNC because of the water that was 20 Q. But not a dramatic increase like occurred
21 emanating off of Lake Borgne coming down the 21 during Katrina, correct?
22 Reach 1 and going north on the IHNC, correct? 22 A. Correct.
23 A. You said -- 23 Q. Fair. Okay. Good. Then I want to focus
24 Q. Do you know that? 24 on the paragraph below Figure 3 (sic). I'll
25 A. You said it didn't enter from Lake 25 break it up a little bit. IPET states, quote,
Page 67 Page 69
1 Borgne? 1 to prevent storm surge in Lake Borgne from
2 Q. That water -- That -- Back up. The 2 influencing the water levels experienced in
3 source of the water in the IHNC in the early 3 the IHNC or GIWW/MRGO sections of waterway,
4 stages of Katrina was the water that came down 4 flow through Reach 1 channel must be
5 Reach 1 and not water off of Lake Borgne. Do 5 dramatically reduced or eliminated, either by
6 you agree with that? I'm sorry. Back up. I 6 a permanent closure or some type of structure
7 misspoke. Withdrawn. Okay. 7 that temporarily serves to eliminate this
8 It's a problem with an English major 8 hydraulic connectivity. The presence of an
9 asking a scientist questions, but I'll try 9 open channel is the key factor.
10 again. 10 Do you see that?
11 It is -- It is understood, commonly 11 A. Yes, sir.
12 understood, including by IPET, that the 12 Q. So what is now being constructed by the
13 essential, essential dynamic that occurred in 13 Corps as depicted on Exhibit 1, the IHNC surge
14 the early hours of Katrina, water came off of 14 reduction barrier, is, in fact, that type of a
15 Lake Borgne, down the Reach 1, and went then 15 structure recommended by IPET?
16 north and south along the IHNC. 16 A. It is what we are recommending. I mean,
17 Is that generally your understanding? 17 it's not under construction yet because it
18 A. Yes, sir. I mean, I think what you're 18 hasn't -- there hasn't been a final decision
19 asking then is that later on Lake 19 by the Colonel, but you are correct, I mean,
20 Pontchartrain played more of an issue as the 20 that would be meeting what they are
21 winds changed and stuff. 21 referencing.
22 Q. Correct. Exactly. 22 Q. Assuming -- Assuming the Colonel approves
23 A. Right. That's my understanding. 23 what's been recommended at sometime, and given
24 Q. And the water level rose in Lake Borgne 24 the fact that the design-build contract is
25 and came in, correct, -- 25 awarded, I assume, depending on that
18 (Pages 66 to 69)
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10/16/2008
Page 70 Page 72
1 determination, the barrier that's going to be 1 you know, what's the best way to address the
2 constructed is the kind of barrier recommended 2 fix for that area or to, or to prevent future
3 by IPET? 3 problems in that area.
4 A. It would appear so. 4 Q. Because if all you did was construct the
5 Q. Okay. It goes on to say, the hyd -- 5 IH -- IHNC surge reduction barrier that's now
6 Again, I'm on Page 135, Volume IV of Exhibit 6 awaiting final approval, but no barrier was
7 3, the final IPET report, quote, the hydraulic 7 put out at Seabrook, during a storm there
8 connectivity existed prior to construction of 8 would be potential of storm surge now to enter
9 the MRGO, due to the presence of the GIWW 9 the IHNC and the GIWW through, I'll call it,
10 channel. 10 the back door of Lake Pontchartrain, correct?
11 Do you see that? 11 A. That would be correct, which would mean
12 A. Yes, sir. 12 that we would then have to build more of that
13 Q. If the hydraulic connectivity between 13 parallel protection higher or not -- They
14 Lake Pontchartrain and Lake Borgne is 14 would have -- Whatever the modeling showed.
15 eliminated at a point within Reach 1, which is 15 Q. So that's now being evaluated, those
16 what the surge barrier seeks to do, correct? 16 alternatives?
17 A. I believe we are just outside of Reach 1 17 A. The alternatives that will -- for the
18 where we're proposing the action. 18 barrier itself are what are being evaluated
19 Q. Okay. Tide or surge to the west of this 19 now, are being formulated.
20 point will become primarily influenced by 20 Q. Has the Corps -- Has the Corps -- Has the
21 conditions at the IHNC entrance, entrance to 21 Corps made a decision, with accompanying
22 Lake Pontchartrain. 22 environmental documentation, that the most
23 Do you see that? 23 advantageous alternative is to build the
24 A. Yes, sir. 24 Seabrook surge barrier?
25 Q. And tide and -- or storm surge to the 25 A. Yes, sir.
Page 71 Page 73
1 east of this point will be primarily 1 MS. GREIF:
2 influenced by conditions in Lake Borgne. 2 Objection.
3 Have I read that correctly? 3 BY MR. O'DONNELL:
4 A. Yes, sir. 4 Q. Has that decision been made?
5 Q. Now, going back to the Exhibit 1, the 5 MS. GREIF:
6 map, we see that the HSDRRS project also 6 Objection. Go ahead.
7 contemplates, if approved, a surge barrier at 7 A. Yes, sir, that's, that's the findings in
8 Seabrook, correct? 8 the Tier 1 report.
9 A. Yes, sir. 9 BY MR. O'DONNELL:
10 Q. And one primary purpose of such a surge 10 Q. Okay. That's what I thought. So if
11 barrier at Seabrook would be to prevent storm 11 these two surge barriers are completed, there
12 surge emanating off of Lake Pontchartrain from 12 would have been, in effect, barriers or surge
13 entering the IHNC? 13 seals that would protect the IHNC/GIWW with a
14 A. Yes, sir. 14 barrier on the eastern perimeter that we've
15 Q. And what is the status of that project 15 discussed and a barrier along Lake Borgne,
16 right now, sir? 16 Lake Pontchartrain, correct?
17 A. We're in the initial phases of, of 17 A. Correct. You would -- You would have
18 evaluating the reasonable alternatives that 18 that, plus you would have the existing systems
19 could be built in the area selected in the 19 still in place, also, at a lower elevation.
20 Tier 1 document for further evaluation. 20 Q. The LPV system improved under the 2011
21 Q. And this would also appear to be 21 plan, correct?
22 responsive to the concerns expressed in IPET 22 A. Under -- Under what it is today, it would
23 that I just read, correct? 23 be maintained, so you would have --
24 A. I don't know if it's in response to it, 24 Q. Right.
25 but, I mean, it is -- the modelers are seeing, 25 A. -- that at a lower level and the two --
19 (Pages 70 to 73)
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10/16/2008
Page 74 Page 76
1 Q. Finally, the -- in terms of any storm 1 BY MR. O'DONNELL:
2 surge that might emanate from the Mississippi 2 Q. Okay. Do you know where those points
3 River, the IHNC lock serves as a impediment, 3 are?
4 an impediment, correct? 4 A. No, sir.
5 A. Yes, sir. 5 Q. Let's go back to Page 136 just for a
6 Q. Okay. On Page 136 of Volume IV, Exhibit 6 moment. The next paragraph after that lengthy
7 3, there's a lengthy paragraph that begins, 7 one begins, the hurricane protection levees.
8 most concern seems to be focused on MRGO/Reach 8 Do you see that?
9 2. 9 A. Yes, sir.
10 Do you see that? 10 Q. And I'll just read the sentence. The
11 A. Yes, sir. 11 hurricane protection levees along the south
12 Q. Have you ever read this paragraph before? 12 side of Orleans Parish and the eastern side of
13 A. No, sir. 13 St. Bernard Parish along MRGO, which together
14 Q. Okay. Then I'm not going to ask you very 14 are referred to as a funnel, can locally
15 many questions about it. 15 collect and focus storm surge in this vicinity
16 Do you know whether any of the post-IPET 16 depending on wind speed and direction. This
17 modeling that's been done by the Corps has 17 localized focusing effect can lead to a small
18 focused on what influence, if any, Reach 2 is 18 increase in surge amplitude. Strong winds
19 in the event of a storm and surge? 19 from the east tend to maximize the local
20 A. I -- I don't know that. 20 funneling effect.
21 Q. You understand there's a difference 21 Do you see that?
22 between surge and waves during a hurricane? 22 MS. GREIF:
23 A. Yes, sir. The waves would be on top of 23 A small, a small local increase.
24 your surge. 24 A. Yes.
25 Q. And waves can have a destructive effect 25 MR. O'DONNELL:
Page 75 Page 77
1 in terms of flood protection barriers, can 1 What did I say?
2 they not? 2 MS. GREIF:
3 A. Yes, sir. 3 You just left out the word local.
4 Q. Particularly, for example, earthen flood 4 BY MR. O'DONNELL:
5 levees, like those constructed along Reach 2 5 Q. Strong winds from the east tend to
6 of the MRGO? 6 maximize the local funneling effect. And
7 A. I don't -- I don't know that I could 7 yeah, it says, can lead to a small local
8 answer that. 8 increase in surge amplitude. I'm sorry.
9 Q. Okay. Beyond your pay grade? 9 Let's go back to the map, Exhibit 1. The
10 A. Well, it's more of an engineering call on 10 funnel that's being described here is
11 what it would do for a levee. 11 generally the V that comes together at the
12 Q. Do you know whether any of the plan 12 GIWW just to the west of where the dotted line
13 that's being undertaken with regard to the 13 is? Is that the funnel?
14 earthen levees along the Reach 2 of the 14 A. It would actually be the entire levee on
15 St. Bernard region contemplate not only 15 the MRGO side and the entire levee on the
16 raising them in height or elevation, but also 16 St. Bernard.
17 armoring them at all? 17 Q. And so in terms of the funnel, we're
18 A. There is some discussion of armoring at 18 talking about, again, what we call the Bay of
19 critical points, transitions, and any area 19 Fundy effect, where a large volume of water
20 that is identified through the engineering 20 off of Lake Borgne gets reduced and
21 team as being a critical point that would need 21 concentrated into the smaller area there at
22 armoring. 22 the confluence of the GIWW and Reach 2?
23 THE COURT REPORTER: 23 A. That's correct.
24 Critical point what? 24 Q. Okay. And I take it that the funneling
25 A. Critical point that would need armoring. 25 effect was taken into consideration in the
20 (Pages 74 to 77)
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10/16/2008
Page 78 Page 80
1 design and construction of the surge reduction 1 remember if the -- how it rated with the risk
2 barrier for the IHNC? 2 and reliability piece.
3 MS. GREIF: 3 Q. Okay. But anyway, it was not selected,
4 Objection. 4 and the one that we see with the dotted line
5 A. Yes, sir. Of the five alternatives, they 5 was selected, correct?
6 all -- many of them had different elevations 6 A. That's correct.
7 they would be built due to that effect. 7 Q. Let's go to these two environmental
8 BY MR. O'DONNELL: 8 documents. I'm going to ask that we first
9 Q. Okay. And was the 24 to 26 foot 9 mark what I believe is first in time, it's the
10 elevation the highest alternative studied? 10 Decision Record, Individual Engineering (sic)
11 A. No, sir. The ones farther to the west 11 Report #11, Improved Protection on the Inner
12 had higher elevations. 12 Harbor Navigation Canal, IER #11, which I
13 Q. And why was that? 13 believe was issued around March 14, '08.
14 A. Because you're, you're narrowing it down 14 May we mark that as the next exhibit in
15 further and further each time. 15 order, which I believe will be 30(b)(6) No. 4?
16 Q. Therefore, the surge amplitude is higher? 16 MR. O'DONNELL:
17 A. Correct. 17 Is that correct, Madam Reporter?
18 Q. Right. Again, confining it to a smaller 18 THE COURT REPORTER:
19 and smaller area? 19 Yes, it is.
20 A. That's correct. 20 MR. O'DONNELL:
21 Q. So the maximum, the most feasible, one of 21 Thank you.
22 the factors in terms of feasibility was 22 BY MR. O'DONNELL:
23 putting it where it is now, correct? It 23 Q. Do you have that in front of you, sir?
24 didn't have to be as high as it would be if it 24 A. Yes, sir, I do.
25 was located further west? 25 Q. Can you -- And it says Decision Record.
Page 79 Page 81
1 A. Correct. There were -- There were three 1 Can you explain to me just generically what
2 more alternatives to the west of this one 2 this document is?
3 looked at and each one of them had a 3 A. This is a -- an alternative NEPA
4 progressively higher elevation. 4 arrangement compliance document. It would be
5 Q. What was the highest of the three? 5 similar to an EIS or an environmental
6 A. I -- I don't know. It is in the IER Tier 6 assessment.
7 2 document, but I don't remember off the top 7 Q. Okay. And this was the one that was
8 of my head. 8 completed as a result of the process that you
9 Q. Well, we'll get to that a little bit 9 became involved with in approximately March of
10 later. And there was one structure to the 10 '07?
11 west, to the east of where the one was finally 11 A. That's correct.
12 sited? 12 Q. Correct me if I'm wrong, but this was
13 A. Right. Alternative five was to the east. 13 quite a very positive achievement to get all
14 Q. How much further east than where the 14 of this done in one year, was it not, based on
15 dotted line is that was selected? 15 your own experience?
16 A. It -- I think -- It probably was about a 16 A. I certainly believe so.
17 half a mile to three-quarters of a mile to the 17 Q. If your boss is there, I'm recommending a
18 east. 18 pay increase, but I must tell you that from
19 Q. Do you know why that was not selected 19 reading a lot of environmental documents in
20 versus the one that was? 20 this case, I thought it was done with great
21 A. It -- It had a lot more environmental 21 dispatch and care. So for what it's worth as
22 impacts. We would have been enclosing a lot 22 a taxpayer, I'll pass that along.
23 more wetlands. We would have also had a lot 23 A. Okay. Appreciate that.
24 more direct impacts to wetlands because it's 24 Q. Okay. Let's -- Let's understand. A
25 just a longer run. Cost was higher. I don't 25 decision was made that we might want to, we
21 (Pages 78 to 81)
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10/16/2008
Page 82 Page 84
1 might want to do something about surge 1 Reach 1 and GIWW -- Reach 1 and IHNC?
2 reduction for the IHNC. Let's look at how we 2 A. It's on your, on your Exhibit 1, it would
3 might do that. And ultimately five 3 be basically the entire red line that you see.
4 alternatives were selected and evaluated in 4 Q. Got it. The whole LPV?
5 this environmental assessment, correct? 5 A. Right.
6 A. In this document, we looked at areas -- 6 Q. Okay. And you said there was a third
7 Q. I'm sorry. You're right. 7 option this evaluated, as well?
8 A. Yeah, in the Tier 1 we looked at the 8 A. You would have had a nonstructural
9 various areas where, where a barrier or 9 alternative that looked at raising the homes,
10 parallel protection or the nonstructural 10 the businesses, the infrastructure in the
11 alternative could be done for Seabrook and for 11 area.
12 IHNC. 12 Q. I have a hunch that one was not -- didn't
13 Q. I jumped the gun. I apologize. That's 13 go very far.
14 the second document. 14 A. It was very expensive.
15 A. Right. 15 Q. Okay. And then the parallel protection
16 Q. Let's go through what the, kind of the 16 option was ultimately not selected, either,
17 three conceptual approaches would be. One you 17 correct?
18 said was a barrier, right? 18 A. Correct.
19 A. Right. 19 Q. Okay. Although you said, as part of
20 Q. Or some sort of -- At some location? 20 other projects, there is restoration and
21 A. Right. We had three different locations 21 elevation going on over time of the LPV
22 that we looked at barriers. 22 structures?
23 Q. And where were they? 23 A. Right. They are -- They are still doing
24 A. Basically the one, the one you see now, 24 work on those to maintain them at the
25 which is what we called Borgne 1, which is 25 elevation that was authorized pre-Katrina.
Page 83 Page 85
1 east of the Paris Road bridge, and then we had 1 Q. Okay. Great. Can you show me where in
2 an area, Borgne 2, further to the east, and 2 Exhibit 4, the decision record of March 14,
3 then an area out right on the edge of Lake 3 '08, there's any discussion of surge levels?
4 Borgne, partially into Lake Borgne, was Borgne 4 A. In the decision record itself?
5 3. 5 Q. Yeah, we'll start with that. Because I
6 Q. Okay. And which one was selected 6 think you told me going into this
7 finally? 7 environmental assessment the engineers and the
8 A. Borgne 1. 8 modelers had already given you an assumption
9 Q. And is Borgne 1 what we basically have 9 that, at least in this one location which was
10 today? 10 ultimately selected, you'd have surge of 24 to
11 A. Borgne 1 is -- We have five alternatives 11 26 feet, and at areas further west of that you
12 within Borgne 1 that have been refined down to 12 would actually have it higher.
13 the recommended action. 13 Do you remember that discussion we had?
14 Q. Were those five alternatives done in the 14 A. Yes, sir.
15 second tier document or the first tier? 15 Q. Can you show me where in Exhibit 4
16 A. They were done in the second tier. 16 there's any discussion of those levels?
17 Q. All right. We'll get to that in a 17 A. Not right off the top of my head. There
18 moment. Now, in Tier 1, we had a barrier with 18 may be some discussion in the main document.
19 three different concepts of where it would be 19 I don't believe it's in the decision record
20 located. You also said there was parallel 20 itself.
21 protection? 21 Q. Okay. The decision record itself is
22 A. Correct. We would have restored what was 22 about six pages, right? And it precedes a
23 there today to whatever the 100-year height 23 document called Final Individual Environmental
24 would have been, or would be determined. 24 Report #11?
25 Q. And that would have been along, what, 25 A. Yes, sir.
22 (Pages 82 to 85)
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10/16/2008
Page 86 Page 88
1 Q. Now, what -- Generically, what is the 1 system fails, unquote.
2 purpose of the record, of the decision record, 2 Do you see that?
3 which I see was signed by the Colonel, Alvin 3 A. Yes, sir.
4 Lee, District Commander, on March 14, '08 as 4 Q. And that was one of the concerns that the
5 we look at Page 6? 5 IPET report documents, that during Katrina
6 A. Right. 6 there were catastrophic failures of some
7 Q. What is the purpose of this document? 7 portions of the system, correct?
8 A. The purpose of the decision record is to 8 A. Yes, sir.
9 document the Colonel's decision that he is 9 Q. All right. The final sentence of this
10 making. 10 paragraph now on Page 6 says, quote, the
11 Q. Okay. Sort of the reasoning for the 11 proposed action of storm surge protection
12 ultimate decision he made? 12 structures would instead provide a first line
13 A. Right. It gives some of his basic 13 of storm surge defense, providing risk
14 rationale, but it just basically lays out what 14 reduction redundancy for many miles of levees
15 his decision is. 15 and floodwalls.
16 Q. And ultimately he endorsed the Borgne 1 16 Do you see that?
17 option? 17 A. Yes, sir.
18 A. Yes, sir. 18 Q. What does risk reduction redundancy mean?
19 Q. Okay. Let's go to, if you would, please, 19 A. The fact that you have an existing
20 Page 5 of the document, the record of 20 parallel protection system in now that's being
21 decision. 21 maintained to the authorized height or the
22 A. Okay. 22 height it's at now, by adding a new barrier in
23 Q. And at the bottom of the page the Colonel 23 front of it, it makes a redundancy. It makes
24 states, quote, last paragraph, and it goes on 24 it two layers instead of just a single point
25 to Page 6, Page 5, quote, construction of 25 of attack.
Page 87 Page 89
1 storm surge protection structures was selected 1 Q. So along the GIWW/IHNC, you would never
2 in lieu of raising the existing storm damage 2 have to worry that much about the integrity of
3 risk reduction system (formerly known as the 3 those structures if the water in, in the GIWW
4 Hurricane Protection System or HPS) to the 4 and IHNC was not at all affected by storm
5 100-year level of protection alternative for 5 surge because of your barriers at Seabrook as
6 several reasons. 6 well as the IHNC surge reduction barrier we're
7 So he first tells us he's decided to go 7 talking about, correct?
8 with the, with the surge structures versus the 8 A. Basically, if you kept the surge out, you
9 alternative of raising the levees basically, 9 would -- there wouldn't be any force or stress
10 correct? 10 put on those barriers to have a -- you
11 A. Yes, sir. 11 wouldn't have the risk that you would have of
12 Q. Then he goes, he says, the expanded 12 a failure.
13 footprint required to raise the existing storm 13 Q. And the accent's on stress. The
14 damage risk reduction system along the IHNC 14 structure shouldn't have any problem during a
15 and GIWW could have adverse socio -- 15 hurricane because rainfall, according to the
16 socioeconomic impacts, affecting adjacent 16 studies, wouldn't have enough of an influence
17 homes and houses. 17 to adversely affect the structures, correct?
18 A. Yes, sir. 18 A. As far as I know. I mean, I haven't -- I
19 Q. Okay. Et cetera. Okay. Secondly he 19 don't know what the rainwater models showed,
20 says, I'm shorthanding, and there could be 20 what the loading in that area would be.
21 problems with such a system because of 21 Q. Okay. Now, let's go to the final IER
22 subsidence and damage from storm surges, 22 #11, which starts after Page 6. Do you see
23 quote, retaining a level of risk and 23 that?
24 uncertainty with potentially catastrophic 24 A. Yes, sir.
25 consequences resulting if any portion of the 25 Q. And let's go to the Table of Contents, if
23 (Pages 86 to 89)
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10/16/2008
Page 90 Page 92
1 we would, please, which is little i. You're 1 number, I've been waiting to find the number,
2 pretty familiar with this document because you 2 we got one, next sentence, observed peak water
3 were one of the principal architects of it, 3 levels in the IHNC during Hurricane Katrina
4 correct? 4 indicate a maximum water level gradient of
5 A. Yes, sir. 5 three feet between the intersection of the
6 Q. Okay. Can you show me, laser beam in on 6 GIWW and Lake Pontchartrain.
7 this, can you show me where in this Table of 7 Do you see that?
8 Contents I'd find surge assumptions or model 8 A. Yes, sir.
9 results? 9 Q. Does that mean that there was an increase
10 A. No. 10 in water level of about three feet?
11 Q. Can we go to those? 11 A. I believe that's what it's saying.
12 A. I would guess possibly under Significant 12 Q. Okay. Then it says, also, model analyses
13 Resources, 3.2.1 under Hydrology possibly. 13 of conditions during that event suggests that
14 Q. Let's go there. Let's look at Page 35, 14 waves up to four feet high occurred within the
15 if we may. 3.2.1.1 under Hydrology, there is 15 IHNC.
16 a discussion of existing conditions, correct? 16 Do you see that?
18 Q. And we see a discussion of paragraph two, 18 Q. Now, if I do the math correctly, the
19 hydrological connection. Let's go to the next 19 water level rises three feet, then on top of
20 page, if you would. Let's go to the paragraph 20 that there's another four feet of waves,
21 that begins on Page 36, modeling conducted by 21 correct?
22 IPET. 22 A. That is what that is basically saying,
23 Do you see that? 23 yes, sir.
24 A. Yes, sir. 24 Q. Okay. Again, English major, but I think
25 Q. In the third sentence of this paragraph 25 four and three is seven, right?
Page 91 Page 93
1 it states, quote, the IPET models suggest that 1 A. That -- That would have been if it all
2 the levees along the GIWW/MRGO can locally 2 occurred at the same time. Your four foot
3 enhance storm surge in this vicinity depending 3 waves might not have occurred at the same time
4 on wind speed and direction, with strong winds 4 you had a full three foot change in the
5 from the east tending to maximize the local 5 elevation.
6 effect, and a citation. 6 Q. Then again, there may have been
7 Do you see that? 7 interludes when they did occur together,
8 A. Yes, sir. 8 right?
9 Q. However, the models also suggest that the 9 A. It could have, yes.
10 increase in storm surge amplitude due to this 10 Q. Okay. And we know that there was
11 effect is, is small. 11 overtopping along Reach 1 during Katrina,
12 Do you see that? 12 correct?
13 A. Yes, sir. 13 MS. GREIF:
14 Q. And the next paragraph tells us, quote, 14 Objection.
15 during major storm events, storm surges can 15 A. I'm not for sure, to be honest.
16 propagate north into Lake Borgne. 16 BY MR. O'DONNELL:
17 That's presumably from the Gulf of 17 Q. Do you know whether there was overtopping
18 Mexico, right, sir? 18 along Reach 1 on any -- on the north or south
19 A. Yes, sir. 19 side during Katrina?
20 Q. And then -- And are then redirected west, 20 A. Not -- Not that I know of. I know we had
21 converging into the IHNC and resulting in high 21 the breaches that we discussed earlier, but
22 water levels and large waves. 22 I'm not aware of the overtopping.
23 Do you see that? 23 Q. Do you know whether there was any
24 A. Yes, sir. 24 overtopping along the IHNC in the same -- in
25 Q. And then the next, finally I find the 25 the Lower Ninth Ward area during Katrina?
24 (Pages 90 to 93)
OWEN, GIB A.
10/16/2008
Page 94 Page 96
1 A. I'm not aware of that. 1 section there's any other discussion of surge
2 Q. There were two breaches on the east side 2 or wave modeling in this report?
3 and two on the west side of the IHNC during 3 A. I don't believe there is. We -- We
4 Katrina, correct? 4 didn't get into a lot of the engineering in
5 A. I think that's correct. There were 5 the -- You know, this is a document for the
6 breaches. I think two, two and two was 6 public to understand, so we try not to get too
7 correct, I believe. 7 into the engineering aspects of it.
8 Q. Okay. 8 Q. Well, is there any discussion -- Is there
9 MR. HART: 9 any discussion in the document that, in fact,
10 Excuse me. 10 we are analyzing alternatives, including an
11 BY MR. O'DONNELL: 11 alternative that would give a 24 to 26 foot
12 Q. And on the eastern side they're sometimes 12 surge protection?
13 called the north breach and the south breach? 13 A. I do not believe we got into that level
14 A. I haven't heard it called that, but -- 14 of detail in the Tier 1 document.
15 MR. HART: 15 Q. Go, if you would, to Page 4, numbered
16 Excuse me. We need to go off the 16 Page 4 on the bottom of Exhibit 4, which is
17 record to change tapes. This is the end of 17 the Final IER section, and you'll see a
18 Tape 1. We're going off the record. 18 Section 1.1, Purpose and Need for the Proposed
19 (Off-the-record discussion). 19 Action.
20 MR. HART: 20 Do you see that?
21 This is the beginning of Tape 2. 21 A. Hang on. You're talking about -- Okay.
22 We're back on the record. Please continue. 22 Yes, sir.
23 BY MR. O'DONNELL: 23 Q. I'm in the Final Section 1.1.
24 Q. All right. Just to clarify, as part of 24 A. Yes, sir.
25 the deauthorization report recommendations, a 25 Q. Purpose and Need for the Proposed Action.
Page 95 Page 97
1 saltwater intrusion barrier is being 1 Do you see that?
2 constructed along Reach 2 of the MRGO, is it 2 A. Yes, sir.
3 not, sir? 3 Q. And essentially the first sentence says,
4 A. A -- A rock barrier is being -- has been 4 the purpose of this proposed action is to
5 approved to be put in to stop navigation. One 5 improve hurricane protection on the IHNC,
6 of the benefits of it will be to limit 6 right?
7 saltwater intrusion. 7 A. Yes, sir.
8 Q. And the hope is that by limiting 8 Q. Then the next sentence says, and I'll
9 saltwater intrusion, over time there may be at 9 read the complete sentence, quote, the overall
10 least the beginning of a process of wetlands 10 purpose of the project is to provide a
11 restoration to the north of that area? 11 comprehensive, integrated protection system
12 A. It was just one of the benefits that 12 that would reduce the imminent and continuing
13 would come out of, out of placing a barrier 13 threat to life, health, and property posed by
14 there to stop the navigation. I don't know 14 flooding from hurricanes and other tropical
15 that we've -- I don't know that we've 15 storm events.
16 theorized that we're going to see wetlands 16 Do you see that?
17 restoration due to it. 17 A. Yes, sir.
18 Q. It's just a collateral benefit? 18 Q. Now, I take it that the Corps is aware
19 A. Yes. 19 that historically during hurricanes there have
20 Q. It wasn't the primary purpose, I take it? 20 been surge levels that threatened life, health
21 A. No. The primary purpose of the barrier 21 and property?
22 is to stop navigation from using the channel. 22 A. Yes, sir.
23 Q. Okay. Since we did, in fact, find some 23 Q. Including Katrina?
24 information about testing, I'm not sure, do 24 A. A Katrina-type storm, yes, sir.
25 you know whether beyond this 3.2.1.2 hydrology 25 Q. Okay. Let's go to the next sentence.
25 (Pages 94 to 97)
OWEN, GIB A.
10/16/2008
Page 98 Page 100
1 This purpose would be achieved by providing a 1 A. I do not know.
2 100-year level of hurricane protection. 2 Q. It's sort of like a hurricane cocktail,
3 I think you said the 100-year level is, 3 right, they took 142 -- I'm not being silly,
4 is assumed or designed a hurricane with 4 maybe I am, but somehow they come up with
5 certain wind speed and certain surge levels, 5 something that they're comfortable with in
6 correct? 6 terms of how they would characterize this
7 A. It was -- It was -- It was what we 7 storm, right?
8 discussed earlier about the 142 model storms 8 A. I would -- I would believe they were
9 they ran, and they -- and then from that they 9 trying to come up with a representative sample
10 came up with the 100-year elevation that they 10 of the storms that could come to the area in a
11 then gave us to use. 11 given year.
12 Q. In fact, in the next paragraph it states, 12 Q. Who at the Corps would know what that
13 quote, the term, quote, 100-year level of 13 ultimate 100-year hurricane, what its
14 protection, unquote, as it is used throughout 14 parameters are in terms of wind speeds or
15 this document, refers to a level of protection 15 ranges of wind speeds and surge ranges?
16 that reduces the risk of hurricane surge and 16 A. I -- I believe that would be Nancy
17 wave-driven flooding that the New Orleans 17 Powell.
18 Metropolitan Area has a one percent chance of 18 Q. Now, and she's in the hydrology and
19 experiencing each year. 19 hydraulic section, she's the chief?
20 Do you see that? 20 A. Yes, sir.
21 A. Yes, sir. 21 Q. Okay. I think she may be deposed in
22 Q. Now, that's a statistical description. 22 another room in your building as we speak.
23 In fact, it could happen two years from now or 23 A. Yes, sir.
24 it could happen 102 years from now or maybe 24 Q. We're double-teaming you guys today. Let
25 never happen at all in a hundred years, right? 25 me ask you a question. The 24 to 26 foot
Page 99 Page 101
1 A. That -- That is correct. That's why 1 surge assumption, is that, is that surge plus
2 we've been trying to get away from the word 2 wave run-up?
3 100-year level and use the one percent chance, 3 A. Yes, sir.
4 because you have a one percent chance every 4 Q. So, again, it would be like the four feet
5 year of that event happening. 5 plus the three feet we saw a few minutes ago?
6 Q. And this is not something that's 6 A. That is correct.
7 predicated on some Saffir-Simpson Category 1 7 Q. You want to know what is the estimated
8 to 5 scale, correct? 8 maximum height that the water gets either
9 A. That is correct. 9 because it rises or it has waves being whipped
10 Q. Now, if you -- If we knew, which we 10 up by the wind on top?
11 don't, for today, what wind levels were 11 A. Correct. I mean, I don't -- I don't know
12 assumed, you could go to the Saffir-Simpson 12 that number. I just have the total number.
13 chart, which is -- whose categories are 13 The hydrologist would be able to tell you what
14 calibrated based on ranges of wind speeds, 14 part was wave, which part was surge.
15 correct? 15 Q. But you add them up because you're
16 A. Yes, sir. 16 interested in the top, highest estimated peak
17 Q. Okay. But you don't know what wind 17 of the water because if, if, if you've only
18 levels were assumed here? 18 built five feet above the normal water level
19 A. Well, again, there's 142 storms, so there 19 without a storm and it's going to seven or
20 were various wind levels, various storm surge 20 eight feet, you're going to have overtopping,
21 levels. You know, each storm had a different 21 right?
22 speed, surge, wind level, everything. 22 A. That would be correct.
23 Q. Well, did they take the average, the 23 Q. Okay. And you may also have integrity
24 mean, the median of 142? Do you know how they 24 problems with failure because of overtopping,
25 got there? 25 right?
26 (Pages 98 to 101)
OWEN, GIB A.
10/16/2008
Page 102 Page 104
1 A. I mean, you're more of an engineering 1 Notice of Availability. Do you have that?
2 piece, but I know most of our systems are 2 A. We're looking here.
3 being engineered to allow some overtopping in 3 MR. WARREN:
4 case there is a bigger event. 4 Is Page 2 of that document, Pierce,
5 Q. Because we saw during Hurricane Gustav, 5 the Clean Water Act?
6 if you watched the news, that they had put 6 MR. O'DONNELL:
7 concrete sidewalks, or, yeah, I'll call them 7 Yes. Page 1 is -- This is the way I
8 concrete sidewalks, on the IHNC so that if the 8 printed it off the Internet. It's called
9 water spilled over, there was no scouring, 9 Notice of Availability.
10 correct? 10 A. Yes, sir.
11 A. Correct. It hit that hardened surface 11 BY MR. O'DONNELL:
12 instead of hitting an earthen and it 12 Q. The second page is the Clean Water Act,
13 dissipated the energy and so you didn't have 13 Section 104 (sic) document.
14 the erosion. 14 A. Yes, sir.
15 Q. So there's no hydraulic cannonballs or 15 Q. Do you have the Notice of Availability as
16 anything being thrown over the side, right? 16 the first page?
17 A. I guess. 17 A. Yes, sir.
18 Q. Withdrawn. You don't have to accept that 18 Q. And then let's make this Notice of
19 characterization. That was more of the 19 Availability plus the Clean Water Act Section
20 English major. 20 404, which ends with the signature by
21 Let me see if I have anything else on 21 Elizabeth Wiggins, Chief of Planning Division,
22 this document. I don't think I do. 22 let's make this entire document No. 6 to this
23 Let's mark as, I believe it's Owen No. 5, 23 deposition.
24 the other thick environmental document. It 24 MR. O'DONNELL:
25 won't be Owen 5. It's Rule 30(b)(6) No. 5 in 25 May we, Madam Reporter?
Page 103 Page 105
1 the Owen deposition. And this document is 1 THE COURT REPORTER:
2 dated August 20, 2008. It's on Department of 2 Yes.
3 the Army, New Orleans District, Corps 3 BY MR. O'DONNELL:
4 stationery, and the first page is Notice of 4 Q. And Mr. Owen, I'm going to start with
5 Availability. The next page is something 5 Exhibit 6 first, if I may, okay?
6 about the Clean Water Act, which goes for 6 A. Yes, sir.
7 several pages. 7 Q. Were you -- Were you -- Were you also
8 A. What -- I'm sorry. What are -- I don't 8 honchoing the draft IER report on Tier 2
9 think I'm matching up with you. 9 Borgne?
10 Q. I'm trying to figure out the document, 10 A. I was the overall team leader on this
11 but the first section I have is about eight or 11 effort, yes, sir.
12 ten pages called Notice of Availability. Do 12 Q. Which is Exhibit 5, the thick document,
13 you see that? 13 right?
14 A. Oh, okay. Hang on. That's not what we 14 A. Yes, sir.
15 were handed. 15 Q. All right. Exhibit 6, first page is
16 Q. Were you handed -- Were you handed the 16 Notice of Availability. What is this
17 August 2008 draft IER? 17 document?
18 A. Yes, sir. 18 A. This -- This is a letter that we send out
19 Q. All right. Why don't we just -- We'll 19 to the public, I believe our mailing list
20 mark that Owens (sic) 5, okay. I mean, 20 right now is about 1,300 people, that tells
21 30(b)(6) No. 5, okay? 21 them that a draft environmental impact or
22 A. Okay. 22 individual environmental report is available
23 Q. And then let's mark the thinner document, 23 for them to review during a thirty day comment
24 which Rob should have there, which is the 24 period.
25 document, it's about ten pages, beginning 25 Q. Okay. And that was sent out on August
27 (Pages 102 to 105)
OWEN, GIB A.
10/16/2008
Page 106 Page 108
1 20th? 1 floodwall north of the GIWW to the levee on
2 A. Yes, sir. 2 the west side of the MRGO.
3 Q. And the comment period ended around 3 That's what you basically described to us
4 September 20th? 4 earlier, correct?
5 A. It was scheduled -- It was scheduled to 5 A. Yes, sir.
6 end on the -- It ended on the 19th of 6 Q. Okay. It says, the flood protection
7 September. 7 would cross the GIWW, Bayou Bienvenue, the
8 Q. I see all comments should be sent to one 8 MRGO, and the Golden Triangle marsh between
9 Mr. Gib Owen, right? 9 these waterways.
10 A. Yes, sir. 10 Do you see that?
11 Q. Did you receive many comments on this? 11 A. Yes, sir.
12 A. We had five or six total parties respond. 12 Q. Back to Page, Exhibit 1, the colored
13 Q. Five or six? 13 map, --
14 A. Parties would, you know, provide 14 A. Okay.
15 comments. 15 Q. -- can you show me where on Exhibit 1 the
16 Q. And you prepared responses to those 16 Golden Triangle is as referenced in Exhibit 6?
17 comments? 17 A. The Golden Triangle locally is basically
18 A. We have not yet. 18 from the western shore, edge of Lake Borgne
19 Q. Okay. Tell me what the rest of this 19 where you start seeing the yellow marsh come
20 Exhibit 6 is, the Clean Water Act, Section 104 20 in, --
21 (sic), Rivers and Harbors Act, Section 10, 21 Q. Yes.
22 Public Notice. 22 A. -- and then it goes all the way almost to
23 A. This is a public notice that also went 23 the V of the, where the MRGO and the GIWW, you
24 out with the other one to the 1,300 people. 24 can see just a little bit of yellow marsh
25 Well, it was available for them to download 25 still at that point.
Page 107 Page 109
1 off the Internet or to ask for a hard copy. 1 Q. Yes.
2 This is a notice that says we have performed a 2 A. That whole area is locally called the
3 Clean Water Act, Section 404(b)(1) evaluation 3 Golden Marsh. The Golden Triangle. I'm
4 of the project, and lays out basically the 4 sorry.
5 findings of that and asks -- It also has its 5 Q. So essentially from where the dotted line
6 own stand-alone thirty day public comment 6 is up to the V?
7 period. 7 A. Well, that -- No, I mean behind the
8 Q. All right. And does the Exhibit 5 deal 8 dotted line there's still a little bit that
9 with both of these requirements, both an 9 comes almost right into where the two touch,
10 environmental assessment and the Clean Water 10 where MRGO and the GIWW would, would match up.
11 Act analysis? 11 There's just a little tiny area, little area
12 A. The Exhibit 5 does have the Clean Water 12 of marsh still there, and then all the way
13 Act information rolled into it -- 13 back out.
14 Q. Okay. 14 Q. Going east, how far does the Golden
15 A. -- as part of the evaluation. 15 Triangle go east? Does it go beyond where the
16 Q. Okay. There is a -- On Page 2 of Exhibit 16 dotted line is, the barrier?
17 6, which is the first page of the Clean Water 17 A. Yes, sir, it goes all the way to the --
18 Act public notice, down at the bottom there's 18 where you see the open water of Lake Borgne
19 one paragraph, well, there's a section called 19 starting.
20 Description of Action. 20 Q. All right.
21 Do you see that? 21 A. The yellow --
22 A. Yes, sir. 22 Q. So it's, it's from the curved area of
23 Q. It says, the proposed action consists of 23 Lake Borgne proceeding west into the triangle
24 the construction of two miles of new flood 24 at the confluence of the GIWW and Reach 2?
25 protection extending from the Michoud 25 A. Yes, sir.
28 (Pages 106 to 109)

OWEN, GIB A.
10/16/2008
Page 110 Page 112
1 Q. Okay. Now, let's look just briefly at 1 right?
2 the map and look at the area of wetlands 2 A. Yes, sir.
3 between the Reach 2 GIWW and what the dot -- 3 Q. Okay. Continuing, a sector gate and
4 and where I believe is the 40 Arpent Canal. 4 adjacent barge swing gate on the GIWW, and
5 Do you see that? 5 that's the one you described earlier, correct?
6 A. I'm not -- Oh, you're talking behind the 6 A. Yes, sir. That's the two gates that
7 Mississippi River levee? 7 would be at the GIWW.
8 Q. Yeah, behind the MRGO outlet on Reach 2, 8 Q. For most of the time, in normal weather
9 the southwest side, do you see that? 9 conditions, it remains open, but it can be
10 A. Yes, sir. 10 closed quickly in the event of a storm?
11 Q. There's marsh or -- 11 A. Correct.
12 A. Right. 12 Q. Okay. About how long does it take to
13 Q. -- something, might not be marsh, that 13 close it, do you know, approximately?
14 extends generally westward until it meets the 14 A. My understanding is that they are asking
15 civilized or the populated area along what's 15 that it be able to be closed within thirty
16 known as the 40 Arpent Canal. 16 minutes, --
17 Do you see that? 17 Q. Okay.
18 A. Yes, sir. 18 A. -- on a thirty minute notice.
19 Q. My understanding is that area of marsh is 19 Q. Continuing, and a concrete floodwall
20 described as the Central Wetlands Unit? 20 across the marsh. And the height of that, I
21 A. Yes, sir. 21 believe, is going to be 24 to 26 feet?
22 Q. Okay. And going back to Page 2 of 22 A. Yes, sir.
23 Exhibit 6 where there's a description of the 23 Q. Okay. And do you know how far down into
24 action, the project, the third sentence says, 24 the marsh it's going to go?
25 the project would consist of a braced concrete 25 A. Some of the numbers I've seen show them
Page 111 Page 113
1 wall across the MRGO. 1 going, the pilings themselves are about 200
2 What is a braced concrete wall? 2 feet long. So if it's 26 feet out of the
3 A. It's what they're -- What they're 3 ground, then it's a hundred and -- just under
4 proposing to build is a concrete floodwall 4 180 feet.
5 vertical with bracing behind it of, of more 5 Q. That's pretty deep, isn't it?
6 pilings -- 6 A. Yes, sir.
7 Q. Got it. 7 Q. But the land, the soil there is pretty
8 A. -- coming up from behind it. 8 spongy, right, and not terribly stable?
9 Q. Which adds more strength and stability to 9 A. It is marsh. I don't -- I don't know
10 the structure? 10 what's underlying, you know, the geology under
11 A. That would be my understanding, yes, sir. 11 it, but the top layer would be, certainly be
12 Q. Okay. Continuing in that sentence, a new 12 mostly marsh and be spongy.
13 flood control structure on Bayou Bienvenue, 13 Q. Is it going to be braced, as well?
14 Bayou Bienvenue. 14 A. That -- That whole wall is then braced,
15 What is the general nature of that flood 15 yes, sir.
16 control structure? Is that one that opens and 16 Q. Like the one across the MRGO itself?
17 closes? 17 A. Yes, sir, the whole wall, except for the
18 A. That was the structure we discussed 18 gates, will be braced the whole two miles.
19 earlier that's going to be 56 feet wide. It 19 Q. Okay. And the floodwall itself will be
20 would stay open except during an event. 20 about 350 feet wide, correct?
21 Q. That's the one sort of in the middle of 21 A. That -- That is the channel that's being
22 the dotted line? 22 dredged in there. The wall itself is only 66
23 A. It's right where the arrow comes in. 23 inch pilings.
24 Q. Got it. That's where our little boat had 24 Q. The pages are unnumbered. Would you go
25 to go through as it proceeded north-northwest, 25 to the page three from the back? It begins at
29 (Pages 110 to 113)
OWEN, GIB A.
10/16/2008
Page 114 Page 116
1 the top, during the advanced measures. 1 says, modeling results.
2 A. Yes, sir. 2 Do you know what modeling that is?
3 Q. Okay. Let's turn now -- Oh, by the way, 3 A. Where are we at? I'm sorry.
4 this is signed by a -- Exhibit 6 is signed by 4 Q. Page 48.
5 someone, Elizabeth Wiggins, Chief of the 5 A. At the very top? Okay.
6 Planning Division. Is she in New Orleans? 6 Q. Direct impacts, second sentence, first
7 A. Yes, sir. She's my supervisor. 7 paragraph says, modeling has shown. Do you
8 Q. Okay. Let's go to Exhibit 5, if we may, 8 see that?
9 which is the IER #11 Tier 2 Borgne, dated 9 A. Yes, sir.
10 August 2008. Do you see that? 10 Q. Next sentence that begins, modeling
11 A. Yes, sir. 11 results, do you see that?
12 Q. Were you the chief honcho on this 12 A. Yes, sir.
13 environmental document, as well? 13 Q. Do you know what modeling that refers to?
14 A. I was the team leader, yes, sir. 14 A. Again, it goes back to the hydraulic
15 Q. Okay. Can you tell me whether there's 15 modeling that's been done by Nancy Powell or
16 any additional discussion in this document 16 ERDC.
17 about the height of assumed surge and waves? 17 Q. And perhaps even IPET?
18 A. I would believe there would be some under 18 A. And possibly, yeah, as the basis of IPET.
19 the, again, under the 3.2.1, Hydrology, which 19 Q. Okay. The last sentence of the first
20 is on Page -- 20 paragraph on page 48 says, quote, for all
21 Q. Let's go -- 21 locations, modeling scenarios indicated that
22 A. -- 45. 22 changes in velocities and water levels
23 Q. Let's go to Page 45 then. Thank you. A 23 diminished on both sides of the structures at
24 very quick perusal of Page 45, 46, 47, 24 distances from the structure on the order of
25 suggests that perhaps this discussion, 25 twice the width of the structure.
Page 115 Page 117
1 existing conditions, might mimic what we saw 1 Can you explain that to me?
2 in the earlier report. 2 A. They basically are talking about the
3 A. Yes, sir. I mean, that's -- 3 water flows through the gates, that the -- as
4 Q. I didn't -- I didn't mean that as a 4 you move away from the gates, they're trying
5 criticism, by the way. 5 to basically say how quickly that water energy
6 A. Well, no, that's because it's the 6 would dissipate. It wouldn't -- You know, how
7 existing conditions, so it's the same. 7 fast the current would drop off.
8 Q. Right. 8 Q. And it says -- I don't understand what
9 A. It would be basically the same for both 9 they mean by the order of twice the width of
10 documents. 10 the structure. Oh, I take it. So if you have
11 Q. That's the background against which 11 a structure that's 150 feet wide, you would
12 you're making proposals, correct? 12 expect a significant diminution about 300 feet
13 A. Yeah. Well, it's laying out the 13 away?
14 foundation of what's there today. 14 A. That's correct.
15 Q. All right. Let's start on Page 48. 15 Q. Okay. Not bad for an English major, huh?
16 And at the top of the page we see in bold, 16 I'm just kidding.
17 Proposed Action, Alternative 4a. 17 Next paragraph, Hydrology, on Page 48 of
18 Do you see that? 18 Exhibit 5, hydrology modeling examined
19 A. Yes, sir. 19 fifty-two locations on the flood side (east)
20 Q. Is that the ultimate configuration that 20 and protected side (west) of the proposed
21 has been recommended to the Colonel? 21 alignment, and I guess we look at Figure 24 --
23 Q. Under direct impacts to hydrology in the 23 Q. -- two pages hence? And that tells us
24 second sentence of the first paragraph, it 24 various locations where they modeled, correct?
25 states, modeling has shown. Next sentence 25 A. Yes, sir. It's points where they
30 (Pages 114 to 117)
OWEN, GIB A.
10/16/2008
Page 118 Page 120
1 collected data. 1 approaches the IHNC, citing another Corps
2 Q. Right. Oh, we finally found a lot of 2 study, 2008d, right?
3 modeling numbers. I guess I should be happy. 3 A. Yes, sir.
4 Let's go to Page 52, if you would, please. 4 Q. We go to Page 48, 248 again, the
5 A. All right. 5 reference section, we see that 2008d is a
6 Q. The last paragraph before you get to the 6 document called Water Level Rise for Different
7 italicized Indirect Impacts to Hydrology 7 Lake Borgne Barrier Alignments.
8 begins, surge modeling and flood risk 8 A. Yes, sir.
9 assessment. 9 Q. Is that also an internal Corps study?
10 Do you see that? 10 A. I couldn't tell you if it was done by the
11 A. Yes, sir. 11 Corps itself or done by a contractor. I don't
12 Q. And then there's a (USACE 2007e). Can 12 know.
13 you tell me what document that's referencing? 13 Q. But it's something the Corps used in this
14 Oh, do I have to look at the back for 14 analysis?
15 references? 15 A. Yes, sir.
16 A. Yes, sir. 16 Q. And generally what that sentence I read
17 Q. All right. Let's do that. USAC is, of 17 describes is the funneling effect of the
18 course, Army Corps, right? 18 larger volume of water into the more narrow
19 A. Yes, sir. 19 corridor, right?
20 Q. You go to Page 248, 2007e is described as 20 A. Yes, sir.
21 HPO Storm Protection Alternatives to Surge 21 Q. Let's go, if you would, thank you, sir,
22 Modeling Study, Draft Report. 22 to Page 53 of the document, the next section,
23 Do you see that? 23 and there we have something called, italicized
24 A. Yes, sir. 24 near the top of the page, Cumulative Impacts
25 Q. Is that a public document 25 to Hydrology.
Page 119 Page 121
1 A. I don't know, to be honest. 1 Do you see that?
2 Q. If a document is referenced in an 2 A. Yes, sir.
3 environmental document like this, does that 3 Q. And this seems to be some conclusions
4 mean that it would be available to the public 4 that have been reached based on the modeling,
5 upon request? 5 and let me read this sentence. By providing a
6 A. I believe it, it typically would be, yes, 6 storm surge barrier across the Golden Triangle
7 sir. 7 marsh, the incremental effect of the proposed
8 Q. Okay. Do you know who did this? What 8 action, in combination with other projects in
9 does HPO stand for? 9 the vicinity (discussed in section 4.0) would
10 A. That is, we call it, it's the Hurricane 10 significantly reduce the effect of surges from
11 Protection Office. It's a -- It's a group 11 extreme events up to the 100-year level and
12 within our, the Corps of Engineers here at 12 beyond.
13 this building that's working on certain 13 Do you see that?
14 aspects of the hurricane system. 14 A. Yes, sir.
15 Q. And they document their modeling results 15 Q. I take it that's considered beneficial,
16 in this 2000, 27 -- 2007e document, correct? 16 right? That's a good thing?
17 A. Yes, sir. 17 A. Yes.
18 Q. Okay. And then, let me read the whole 18 Q. Next sentence, this would result in
19 sentence, Page 52, surge modeling and flood 19 further enhancement of the entire proposed
20 risk assessment of the project area, citing 20 100-year hurricane and storm damage risk
21 (USACE 2007e), continuing, demonstrates that 21 reduction system throughout the area.
22 surge height increase -- surge height 22 Do you see that?
23 increases as it moves from east to west in the 23 A. Yes, sir.
24 Borgne complex, due to the narrowing of the 24 Q. And again, the reference is on Page 248,
25 corridor between GIWW and the MRGO as it 25 just so we keep the citation in our mind, the
31 (Pages 118 to 121)
OWEN, GIB A.
10/16/2008
Page 122 Page 124
1 citation is 2008b, and that is your prior 1 let's get this thing done, it's important to
2 study of IER report #11, correct? 2 protecting the people of greater New Orleans?
3 A. Yes, sir. 3 A. We are doing a deliberate approach, but
4 Q. Okay. So would it be fair to say, from 4 it is -- We're trying very hard to do it as
5 the conclusion articulated, which I just read 5 fast as possible.
6 under Cumulative Impacts to Hydrology here on 6 Q. Okay. And one indicia of the fact that
7 Page 53 of Exhibit 5, that the Corps has 7 you're working under exigent or urgent
8 concluded that the IHE -- IHNC storm surge 8 circumstances is that you have issued a
9 reduction barrier that we've been discussing 9 design-build contract, correct?
10 is an important and integral component to 10 A. Correct.
11 improving flood protection for greater New 11 Q. Ordinarily, without exigent circumstances
12 Orleans? 12 such as you have here, you would have a
13 A. Yes, sir. 13 contract issued for a design, right?
14 Q. Is there a sense of urgency in the Corps 14 A. Possibly. This -- This is the first
15 in trying to get this project done from start 15 design-build project ever done by the Corps
16 to finish in a little over four years? 16 for civil works, so it could possibly have
17 MS. GREIF: 17 occurred under a normal situation, also.
18 Objection. 18 Q. So it's unprecedented?
19 A. Absolutely. We're working under 19 A. It is unprecedented.
20 emergency alternative arrangements. You know, 20 Q. What other changes in the normal planning
21 we've set very aggressive schedules to get 21 and bidding and construction process have been
22 these things done. 22 initiated by the Corps for this project?
23 BY MR. O'DONNELL: 23 A. I don't know that I can answer that. I
24 Q. If you had not been working in an 24 mean, we have the alternative arrangements
25 emergency mode, how long would the planning 25 from the environmental standpoint, but, and
Page 123 Page 125
1 process alone have taken for a project like 1 then the design-build, but other than that, I
2 this, in your experience, just the plannings 2 don't know that there's been any other
3 phase? 3 changes.
4 A. If we did not have alternative 4 Q. From what you've said, it would be fair
5 arrangements in place? We would have been 5 to conclude, would it not, that the
6 writing an EIS for the entire Lake 6 construction of the IHNC surge reduction
7 Pontchartrain and vicinity project. It would 7 barrier is a top priority for the Army Corps
8 have been probably, a minimum of probably 8 of Engineers to protect greater New Orleans
9 seven years. 9 from hurricane storm (sic)?
10 Q. Okay. And then there would have been the 10 MS. GREIF:
11 construction and implementation phase beyond 11 Objection.
12 that, right? 12 A. The whole -- The whole system is our
13 A. That's correct. 13 priority. This is one piece of that system.
14 Q. Okay. So it would be fair to say that 14 BY MR. O'DONNELL:
15 this -- the storm surge reduction barrier 15 Q. This piece is --
16 piece of the 100-year plan is done -- being 16 A. It's a critical piece because it does
17 done with a sense of urgency and with unusual 17 protect a large portion of the population.
18 alacrity? 18 Q. It's a critical piece and, among your
19 A. I don't know what the word you just used 19 priorities, it is certainly one of your top
20 was. 20 priorities?
21 Q. Speed. 21 A. We'd --
22 A. Speed, yes, sir. 22 MS. GREIF:
23 Q. With an -- Speed. 23 Objection.
24 A. Yes, sir. 24 A. I'm sorry. We have not set any
25 Q. It's not all due deliberate speed, it's 25 priorities. They're all -- All the projects
32 (Pages 122 to 125)
OWEN, GIB A.
10/16/2008
Page 126 Page 128
1 are being moved as fast as possible. 1 That's fine with me.
2 BY MR. O'DONNELL: 2 MR. HART:
3 Q. All priorities are considered equal? 3 Off the record.
4 A. In the case of this, yes. 4 MR. O'DONNELL:
5 Q. Withdrawn. Okay. And here -- here -- 5 All right. Thank you.
6 Here's the point I'm making. The Corps 6 (A recess was taken).
7 believes, as you said, this IHC -- IHNC surge 7 MR. HART:
8 reduction barrier is so critical to the 8 We're back on the record.
9 overall hurricane protection, hurricane and 9 BY MR. O'DONNELL:
10 storm risk reduction system for New Orleans, 10 Q. Mr. Owen, just before the break, you
11 that it's proceeding at a very rapid pace? 11 described the sense of urgency that the Corps
12 A. The entire hurricane protection system is 12 has for the overall 100-year protection plan,
13 proceeding at a rapid pace. This is just -- 13 including the IHNC surge barrier component.
14 This -- This is one piece of that overall 14 Do you recall that?
15 system. 15 A. Yes, sir.
16 Q. Well, from planning, initiation of 16 Q. Do you know why the Corps did not have
17 planning, environmental documentation to 17 that sense of urgency prior to Hurricane
18 hopefully completed construction, we're 18 Katrina?
19 talking about a period of a little over four 19 MS. GREIF:
20 years, correct? 20 Objection.
21 A. For the entire system. 21 A. I -- I -- I don't know.
22 Q. Right, including this barrier? 22 BY MR. O'DONNELL:
23 A. Including this barrier, yes, sir. 23 Q. What was it about Hurricane Katrina that
24 Q. You said under normal, normal, not 24 precipitated this accelerated process?
25 emergency circumstances, just the planning 25 MS. GREIF:
Page 127 Page 129
1 process alone for this kind of a barrier might 1 Objection, foundation.
2 take seven years? 2 A. Eighty -- Eighty percent of the city was
3 A. If we were writing a normal environmental 3 destroyed due to Katrina.
4 impact statement, I would, I would say on 4 BY MR. O'DONNELL:
5 average they probably take at least seven 5 Q. So the Corps has concluded that this
6 years. 6 100-year protection plan, including the IHN
7 Q. And then the construction of this would 7 (sic) surge barrier is an important project to
8 take at least another number of years, right? 8 help prevent that from ever occurring again?
9 A. Number of years, yes, sir. 9 MS. GREIF:
10 Q. But the process has been conflated, and I 10 Objection.
11 don't mean that pejoratively, I'm happy you're 11 A. It's certainly a project to reduce the
12 doing it, although I live in Los Angeles, the 12 risk of that happening or the level of damage.
13 process has been conflated for the entire 13 BY MR. O'DONNELL:
14 system, including the surge reduction barrier, 14 Q. Never can be a guarantee, but they
15 to a much shorter period of time, and in the 15 believe it measurably and significantly will
16 case of this barrier, about a four year plus 16 reduce the risk of another drowning of New
17 time? 17 Orleans like happened in Katrina, correct?
18 A. That's correct. 18 MS. GREIF:
19 MR. O'DONNELL: 19 Objection.
20 Why don't we take another break and 20 A. That's the basic premise of what we're
21 we'll move on to another area, and we're 21 trying to do, yes, sir.
22 making good progress and I still hope to honor 22 BY MR. O'DONNELL:
23 my goal of getting out of here within about an 23 Q. Well, you'd agree that eighty percent of
24 hour from now. Is that all right? 24 the city and St. Bernard was inundated with
25 THE WITNESS: 25 floodwaters, right?
33 (Pages 126 to 129)
OWEN, GIB A.
10/16/2008
Page 130 Page 132
2 Q. It would be not unfair to characterize it 2 Q. But when the, when the hurricane reached
3 as drowning, is it? 3 New Orleans, it was certainly not Category 5
4 MS. GREIF: 4 strength, was it?
5 Objection. 5 A. The next line down says it was 127 miles
6 A. It's not a word I would use. 6 an hour winds. I don't -- Whatever that would
7 BY MR. O'DONNELL: 7 be on the Saffir-Simpson would be that.
8 Q. Okay. Well, again, I'm the English lit 8 Q. Well, but that's at Louisiana landfall,
9 major, you're the scientist, so I will move 9 that's not in New Orleans and St. Bernard, you
10 on. 10 would agree?
11 Let's go to another exhibit we sent down 11 A. I guess, yes, sir.
12 to New Orleans ahead of time. I'm going to 12 Q. The wind speed as the, as the hurricane
13 mark this as the next in order. This is a 13 approached New Orleans and St. Bernard was
14 document from the Corps dated (sic) New 14 below 127 miles per hour, was it not?
15 Orleans Hurricane and Storm Damage Risk 15 A. I do not know that.
16 Reduction System, 2008 Facts and Figures as of 16 Q. Okay. The next bullet point is, maximum
17 August 28, 2008, and I believe that will be 17 surge of 28 to 30 feet along the Mississippi
18 30(b)(6) Exhibit No. 7, Madam Reporter? 18 coast.
19 THE COURT REPORTER: 19 Do you see that?
20 Yes. 20 A. Yes, sir.
21 BY MR. O'DONNELL: 21 Q. That was not the surge level at Reach 2
22 Q. Do you have that, sir? 22 or IHNC, was it?
23 A. Yes, sir. 23 A. Not that I'm aware of.
24 Q. Okay. And you've seen this before? 24 Q. But then it says, 75 to 80 percent of New
25 A. I -- I believe so. 25 Orleans was flooded. Let's go to, the
Page 131 Page 133
1 Q. This is a Army Corps New Orleans District 1 document is not numbered, but it is the
2 document, is it not? 2 seventh page. It has a financial table at the
3 A. Yes, sir. 3 top. It says, Present, dot, dot, dot,
4 Q. What's the purpose of a document like 4 Funding.
5 this, facts and figures? Is this for public 5 Do you have that page?
6 consumption? 6 A. Yes, sir.
7 A. It probably was put out mainly for our 7 Q. I'm going to follow up on some points you
8 leadership in -- in -- as a talking point type 8 made just a few minutes ago. In the middle of
9 thing so they had the right statistics and 9 the page is a bold heading called IHNC Surge
10 numbers to use. 10 Reduction Contract Awarded in April 2008.
11 Q. But it would be fair to say that the 11 Do you see that?
12 Corps prepares this and certainly strives to 12 A. Yes, sir.
13 be as accurate as possible on what it says in 13 Q. And that's the same -- And part of that
14 a document like this, does it not? 14 surge reduction is the barrier, the surge
15 A. Yes, sir. 15 reduction barrier for the IHNC we've been
16 Q. Okay. Now, on the first page under Item 16 discussing this morning?
17 2, we see some facts and figures about 17 A. Yes, sir.
18 Hurricane Katrina. Do you see that? 18 Q. Okay. And that's the contract that's
19 A. Yes, sir. 19 been awarded?
20 Q. It says, point one, more than 1,500 lives 20 A. Yes, sir, that's the design-build
21 were lost. Is that -- Is that what it says? 21 contract.
22 A. Yes, sir. 22 Q. The now 800 and some million dollar
23 Q. Then it says, Category 5 strength less 23 contract design and build issued to the Shaw
24 than twelve hours before landfall. Do you see 24 entity?
25 that? 25 A. Yes, sir.
34 (Pages 130 to 133)
OWEN, GIB A.
10/16/2008
Page 134 Page 136
1 Q. And the first bullet says that this IHNC 1 build has already been set up, they just need
2 surge protection barrier, surge reduction 2 to do the final process and issue a Notice to
3 barrier, I'm sorry, is, quote, linchpin of the 3 Proceed.
4 HSDRRS-essential to providing 100-year level 4 Q. Go two pages hence in Exhibit No. 7 to
5 of protection, right? 5 what is unnumbered Page 9, please.
6 A. Yes, sir. 6 A. All right.
7 Q. And by linchpin, I assume they're trying 7 Q. In the middle of the page under Future,
8 to suggest that it's a fundamental, integral, 8 dot, dot, dot, is a bold, quote, "Advance
9 critical component? 9 Measures", unquote, for IHNC Surge Barrier.
10 A. Yes, sir. 10 Do you see that?
11 Q. Next point, which I didn't know, by the 11 A. Yes, sir.
12 way, it is the largest design-build civil 12 Q. What does advance measures mean?
13 works project in Corps history. 13 A. That is the, what we discussed earlier as
14 A. That's correct. And that's just that 14 the interim measures, the work that they want
15 piece, so when you look at the overall thing, 15 to have in place between now and next
16 it's really big. 16 hurricane season.
17 Q. Right. Yeah, it's 18 billion you told 17 Q. Oh, is that the barge, barge gate?
18 me, something like that? 18 A. It's the barge gate and bringing that
19 A. Yeah, 16.8 billion. 19 wall to 20.75 elevation by, by hurricane
20 Q. 16.8. And we're pretty confident that, 20 season.
21 that's what's been appropriated, we may need 21 Q. Well, there won't actually be a surge
22 some more money before we're finished, right? 22 barrier across the whole Lake Borgne
23 A. I -- Hopefully not. 23 marshland, will there?
24 Q. Well, the history of the LPV from 1965 to 24 A. That -- That is the goal, to have that
25 Katrina was a history of escalating costs 25 whole barrier in place, but only to elevation
Page 135 Page 137
1 beyond the original projected costs, wouldn't 1 20.75.
2 you agree? 2 Q. Got it. And then eventually to 24 to 26
3 A. The costs increased over the years, yes, 3 feet?
4 sir. 4 A. Yes, sir.
5 Q. And that's already what's happened to 5 Q. When will the final decision be made on
6 this particular IHNC surge reduction barrier, 6 the actual height?
7 it's grown from 695 million dollars when the 7 A. The height has been made. It's -- I
8 contract was issued to now, what did you say, 8 don't -- I don't know why they call it, but
9 800 and what million? 9 they've been giving it out in that range, and
10 A. I believe it's 822. It's in the IER 2 10 if you look at the actual design, it's
11 document or the Tier 2 document. 11 scalloped like a castle top, so some of it's
12 Q. Okay. 822 million. And -- Okay. The 12 at 26 and some of it's at 24. That's why
13 third bullet on Page 7 of Exhibit 7, it says, 13 they've been giving --
14 I'm sorry, the fourth bullet, IHNC surge 14 Q. It's variegated, if you will?
15 reduction project reduce, will reduce surge 15 A. Yes.
16 risk for New Orleans East, Lower Ninth Ward, 16 Q. It's different heights?
17 Metro New Orleans, and St. Bernard Parish. 17 A. Yes.
18 Do you see that? 18 Q. Would that -- You had a nice description,
19 A. Yes, sir. 19 what's that phenomenon called, where --
20 Q. And finally, the construction is to begin 20 A. I mean --
21 in the fall of this year. 21 Q. You used the word --
22 Is that still on target once the Colonel 22 MS. GREIF:
23 makes his decision? 23 Scalloped?
24 A. I believe so. The -- The -- When the 24 A. It's just kind of -- It would be kind of
25 Colonel makes his decision, since a design- 25 like scalloped or whatever, you know, it goes
35 (Pages 134 to 137)
OWEN, GIB A.
10/16/2008
Page 138 Page 140
1 up and down. I mean, it's like the top of a 1 Borgne.
2 castle turret. 2 And that, you told me earlier, is the
3 BY MR. O'DONNELL: 3 primary goal, correct?
4 Q. Right. Not unlike what we see on the 4 A. Yes, sir.
5 Corps logo, right? 5 Q. Now, it says that this new feature, this
6 A. Yes, sir. 6 barrier for the IHNC, was authorized by
7 Q. Okay. I'll deem that to be merely 7 Congress in 2006.
8 coincidental. 8 Was that authorization in the wake of a
9 A. It had to do with overtopping issues and 9 Corps recommendation for this project?
10 stuff. 10 A. The authorization was -- The 2006
11 Q. I understand that. The IHNC surge 11 authorization was for us to build the 100-year
12 barrier, under that headline on Page 9, we see 12 system, so this is just --
13 the construction, it just says, hopefully 13 Q. And was a -- Was a component part of that
14 begins in the fall of this year and it's 14 plan given to Congress this barrier somewhere
15 completed for the hurricane season in 2011, 15 in this region for the IHNC?
16 right? 16 A. I -- I don't know. I didn't -- I -- I --
17 A. Yes, sir. 17 I don't know.
18 Q. Let's mark as 30(b)(6) Exhibit No. 8 a 18 Q. If it's an integral component part, it
19 three page document known as Project Fact 19 might be fair, we can go look at it, it would
20 Sheet. 20 be fair to assume it was part of that
21 Do you have that, sir? 21 proposal?
22 A. Yes, sir. 22 A. Well, I mean, I don't know whether it
23 Q. Okay. Exhibit 8 is an Army Corps Project 23 specifically was ever given to Congress or
24 Fact Sheet. You've seen this before? 24 whatever. I mean, we looked at parallel
25 A. I do not believe so. 25 protection and made that choice in the IER
Page 139 Page 141
1 Q. Okay. Let me just ask you a couple 1 Tier 1 document to, to go towards the barrier.
2 questions. In the middle of the first page 2 Q. It would be fair to say whenever,
3 under the bold headline of Purpose, do you see 3 whenever it was done, this IHNC surge barrier
4 that? 4 was recommended to Congress and has been
5 A. Yes, sir. 5 approved by Congress?
6 Q. And third sentence, I think, maybe 6 A. I -- I don't know that.
7 fourth, it says, quote, the Inner Harbor 7 Q. Okay.
8 Navigation Canal, (IHNC), surge barrier is a 8 A. Congress authorized us to build the
9 new feature, authorized by Congress in 2006, 9 100-year system of which this is -- this area
10 that will reduce the risk of storm damage to 10 is a feature of that system. I don't know
11 some of the region's most vulnerable areas, 11 that they specifically went to say, go build a
12 dash, dash, New Orleans East, Metro New 12 barrier.
13 Orleans, the Ninth Ward and St. Bernard 13 Q. Or whether that was an itemized component
14 Parish. 14 of whatever plan was put before Congress
15 Do you see that? 15 before authorization of the HSDRRS, correct?
16 A. Yes, sir. 16 A. Yes, sir, I don't -- I don't know that.
17 Q. What do they -- What is meant by, by most 17 Q. Okay. Let's go to the second page of
18 vulnerable areas? They mean from storm 18 this document. There's a bold section called
19 flooding? Is that -- Is that a fair 19 Benefit to the Community and Project Features.
20 assumption? 20 Do you see that?
21 A. Yes, sir, they're, they're some of the 21 A. Yes, sir.
22 very lowest areas of the city in elevation. 22 Q. The second paragraph in that section
23 Q. Okay. And then it says, this project 23 says, the breaches in the IHNC.
24 aims to protect these areas from storm surge 24 Do you see that?
25 coming from the Gulf of Mexico and Lake 25 A. Yes, sir.
36 (Pages 138 to 141)
OWEN, GIB A.
10/16/2008
Page 142 Page 144
1 Q. The third sentence of this paragraph 1 Objection.
2 states, quote, recognizing the vulnerability 2 A. I -- I haven't read anything that, that
3 of the areas near the IHNC, the Corps is 3 said that.
4 requiring that this initiative include 4 BY MR. O'DONNELL:
5 expedited surge reduction measures that can be 5 Q. You've never seen any pictures of
6 in place by the 2009 hurricane season. 6 President Johnson's plane flying over New
7 Do you see that? 7 Orleans or St. Bernard and all the flooding?
8 A. Yes, sir. 8 A. Yes, sir, I have seen that, but I didn't
9 Q. And that expedited process is the one 9 know what part of the city or anything. I --
10 you've described for us this morning, correct? 10 Q. But some portions of this vulnerable area
11 A. The -- What they specifically reference 11 were severely flooded during Hurricane Betsy,
12 there are the interim measures or the advance 12 right?
13 measures we just discussed a minute ago. 13 A. I -- I don't know. What I'm saying is,
14 Q. Okay. And that's what you hope to have 14 the pictures I saw were somewhere in the New
15 done by next year, correct? 15 Orleans area was flooded. I'm not -- I'm just
16 A. Yes, sir. 16 saying I don't know specifically where the
17 Q. 2009? 17 areas that flooded were.
18 A. Yes, sir. 18 Q. Okay. Let's go to another document which
19 Q. And then ultimately the full megillah, 19 we sent down. It's the MRGO Impacts and
20 the full implementation of the IHNC surge 20 Restoration Options, Exhibit 9.
21 reduction barrier hopefully completed in 2011? 21 A. All right.
22 A. Yes, sir. 22 Q. This is a document we got, I believe,
23 Q. Okay. Again, the next paragraph, in 23 from the Corps somewhere, and I believe it's a
24 summary, there's a reference to some of the 24 slide show.
25 region's areas most vulnerable to flooding, 25 Have you ever seen this before?
Page 143 Page 145
1 and that was the areas that we described 1 A. I believe this is -- was given to me last
2 earlier, correct? 2 night to look at.
3 A. Yes, sir. 3 Q. Did you enjoy it?
4 Q. Now, the vulnerabilities of this area 4 A. In my spare time, yeah, it was
5 that's described here, New Orleans East, Metro 5 interesting.
6 New Orleans, Ninth Ward and St. Bernard 6 Q. Okay. Go to -- It's unnumbered, but go
7 Parish, the vulnerability of these areas to 7 to the eighth page of the document. It's a
8 flooding was known by the Corps for a long 8 section called public concerns frequently
9 time before Katrina, correct? 9 voiced include.
10 MS. GREIF: 10 A. Yes, sir.
11 Objection. 11 Q. The second bullet says, citizens are
12 A. I -- I don't know that. 12 worried about the potential for increased
13 BY MR. O'DONNELL: 13 threats of hurricane surges traveling up the
14 Q. Well, there was flooding of this region 14 channel and flooding low-lying areas in
15 notoriously during Hurricane Betsy, was there 15 St. Bernard and Orleans Parish.
16 not? 16 Do you see that?
17 A. I -- I don't know that. I wasn't here at 17 A. Yes, sir.
18 that time. 18 Q. Have you been aware -- Are you aware that
19 Q. In your studies and research and 19 such concerns were expressed by citizens prior
20 environmental reviews, you've not come across 20 to Hurricane Katrina?
21 facts that indicate that there was significant 21 A. Yes, sir.
22 flooding in much of this region during 22 Q. And have such concerns been reflected in
23 Hurricane Betsy in 19 -- 1965 or '6, whenever 23 any of the comments you received on any of the
24 it was? 24 two environmental documents we've marked in
25 MS. GREIF: 25 this deposition?
37 (Pages 142 to 145)
OWEN, GIB A.
10/16/2008
Page 146 Page 148
1 A. I do not believe so. 1 which, by the way, has the Bates MRGO_CEI_
2 Q. Okay. Do you know what response, if 2 0009364 on the first page, if you go one, two,
3 any -- 3 three, four pages in, unnumbered, but it's the
4 THE COURT REPORTER: 4 fourth page, there is a section, Need for
5 I'm sorry. I couldn't hear your 5 Action.
6 question. When the paper rattled, I couldn't 6 Do you see that?
7 hear you. 7 A. Hang on. Let me make sure I'm on the
8 BY MR. O'DONNELL: 8 same page.
9 Q. I'm referring again to the quote I just 9 Q. The fourth page of the document.
10 made about citizens being worried about the 10 A. It's actually our third page.
11 potential for increased threats of hurricane 11 Q. I'm sorry. Need for Action, you got
12 surge traveling up the channel and flooding 12 that?
13 low-lying areas in St. Bernard and Orleans 13 A. Yes, sir. It's our third page in the
14 Parishes. 14 document.
15 Do you know what response, if any, the 15 Q. Okay. Now, it begins with a, a, a
16 Corps gave to those citizens prior to Katrina? 16 bullet, increased maintenance costs. Do you
17 A. Not prior to Katrina, no, I do not. 17 see that?
18 Q. Well, after Katrina, they decided to 18 MS. GREIF:
19 expand the hurricane protection system by 19 No.
20 including an IHNC surge reduction barrier and 20 A. No.
21 a barrier at Seabrook, correct? 21 MS. GREIF:
22 A. We -- Yes, sir. 22 That's the second page. That's
23 Q. I'd like to mark as the next exhibit in 23 the --
24 order, which I believe should be No. 10, the 24 A. That's our second page.
25 final document I believe we have there, which 25 BY MR. O'DONNELL:
Page 147 Page 149
1 is known as the Mississippi River Gulf Outlet 1 Q. I'm sorry. I tried -- Yeah, I
2 Reevaluation Study, June 26, 2002. 2 probably -- Forgive me. I probably have two
3 A. That's actually what I saw last night. 3 cover pages. Let me just take one out.
4 Q. Did you get a chance to take a look at 4 So the first page of this document,
5 this, sir? 5 Exhibit 10, will be the Bates number I
6 A. Yes, sir. 6 mentioned, the second page is the Need for
7 Q. I believe this is a Corps of Engineers 7 Action, increased maintenance costs.
8 PowerPoint again. Had you seen this before 8 Do you have that, sir?
9 last night? 9 A. Yes, sir.
10 A. No, sir. 10 Q. We're literally on the same page now.
11 Q. Now, tell me what your understanding is 11 Thank you. Let's go to the third page then.
12 of a Army Corps reevaluation study. Do you 12 The -- The discussion continues why there's a
13 know what it is? 13 need for action, and do you see the second
14 A. It would be a -- It would be a 14 bullet, environmental and flood control
15 reevaluation of an authorized federal project. 15 issues?
16 Q. With an eye towards either seeking 16 A. Yes, sir.
17 amendments or deauthorization or what? 17 Q. And the reevaluation study, in part, is
18 A. It would be towards whatever Congress 18 going to focus on four environmental and flood
19 authorized you to reevaluate, depending on 19 control issues, correct?
20 what type of study it was. 20 A. Yes, sir.
21 Q. In any event, the Army Corps, prior to 21 Q. They include saltwater intrusion?
22 Katrina, was engaged in a reevaluation study 22 A. Yes, sir.
23 of the MRGO, correct? 23 Q. Right?
25 Q. Now, in this PowerPoint presentation, 25 Q. Which was made possible by the
38 (Pages 146 to 149)
OWEN, GIB A.
10/16/2008
Page 150 Page 152
1 construction and ongoing operation of MRGO, 1 already had a witness.
2 right? 2 MR. O'DONNELL:
3 A. Yes, sir. 3 I didn't ask him --
4 Q. Secondly, shoreline erosion, which 4 MS. GREIF:
5 occurred throughout the life of the MRGO, 5 Go ahead.
6 correct? 6 MR. O'DONNELL:
7 A. You're talking about erosion along the 7 Who's the witness?
8 channel? Yes, sir. 8 MS. GREIF:
9 Q. The widening of the channel through, 9 Greg Miller, I think, testified to
10 through erosion. 10 the reevaluation study.
11 A. Yes, sir. 11 MR. O'DONNELL:
12 Q. Which not only widened the banks, but 12 I can't hear you. I'm sorry.
13 also had the effect of killing wetlands on the 13 MS. GREIF:
14 adjacent area, right? 14 It was Greg Miller, I believe, who
15 MS. GREIF: 15 testified about this.
16 Objection. 16 BY MR. O'DONNELL:
17 A. There were -- Yeah, there were wetlands 17 Q. Okay. Well, let me ask this witness this
18 that were lost as the channel widened. 18 question. Were any of the studies, analyses
19 BY MR. O'DONNELL: 19 or modeling that was done in connection with
20 Q. Thirdly, the reevaluation, reevaluation 20 the reevaluation study, which is referenced in
21 study is going to focus on the loss of coastal 21 Exhibit 10, used by you or your project team
22 wetland, right? 22 with regard to the IHNC surge reduction
23 A. Yes, sir. 23 barrier planning?
24 Q. And finally, they're going to focus on a 24 A. From looking through this, the
25 concern about increase in hurricane storm 25 PowerPoint, on -- about midway through,
Page 151 Page 153
1 surge, right? 1 there's some, some discussion of habitat loss
2 A. That, yeah, according to what it says 2 maps and habitat type. We may have used some
3 here. 3 of that in our background. I don't know a
4 Q. Associated with the MRGO, because this is 4 hundred percent, but we may have pulled some
5 a MRGO study, right? 5 of that.
6 A. That would be my take. Again, this is 6 Q. Have you ever seen -- I'm sorry. You may
7 the first -- I saw this for the first time 7 have used some of that as background
8 last night. 8 information?
9 Q. Okay. 9 A. Well, we may have used it as part of
10 MS. GREIF: 10 setting up the existing conditions, the
11 Okay. Could we go off the record? 11 background information to write our existing
12 MR. HART: 12 conditions.
13 Off the record. 13 Q. Okay. Toward the back of this study
14 MR. O'DONNELL: 14 there are discussions of various plans under
15 Sure. 15 consideration for further study, including a
16 (A recess was taken). 16 total closure plan, a partial closure plan, et
17 MR. HART: 17 cetera.
18 We're back on the record. 18 Did any of that information that was
19 BY MR. O'DONNELL: 19 developed as part of the MRGO reevaluation
20 Q. Sir, the -- Have you ever seen this -- Do 20 study get used by you or your team in planning
21 you know if there ever was a final MRGO 21 for the IHNC surge reduction barrier?
22 reevaluation study completed by the Corps? 22 A. Not that I'm aware of.
23 MS. GREIF: 23 Q. Okay. Is the IHNC surge reduction
24 Objection. Mr. Owen isn't here to 24 barrier that we've been talking about this
25 testify about the reevaluation project. We 25 morning 100 percent federal funded?
39 (Pages 150 to 153)
OWEN, GIB A.
10/16/2008
Page 154 Page 156
1 A. I believe so, yes. 1 this process, counsel?
2 Q. So there's no local participation, to 2 (Off-the-record discussion).
3 your knowledge? 3 MS. GREIF:
4 A. There may be a local participation with 4 Thirty days.
5 real estate, but other than that, I believe 5 MR. O'DONNELL:
6 it's all hundred percent federal. 6 I'd ask our reporter to expedite
7 Q. So the 807 million dollars that's the 7 this in the next 24 hours because it's -- I'm
8 current estimate for this project is all 8 going to be using it for something that's
9 federal funding? 9 being filed in the near future. Is that
10 A. The 822 million that's on the table right 10 possible, Mrs. Reporter?
11 now is all federal funding, yes, sir. 11 THE COURT REPORTER:
12 Q. Do you know why it's all federal funding 12 I'll try my very best.
13 and not a shared percentage with local 13 MR. O'DONNELL:
14 sponsors? 14 Rob, would you have it e-mailed to
15 A. It came under congressional authority. 15 you and then forward it to Andy and me?
16 Q. Okay. But is there something about 16 MR. WARREN:
17 that -- The MRGO is a federal facility, right? 17 Yes.
18 A. Not -- I mean, most of MRGO has been 18 MR. O'DONNELL:
19 deauthorized now and is no longer a federal 19 If you -- If you get it done by the
20 project. 20 end of Friday, it would be helpful.
21 Q. Prior to its deauthorization, the MRGO 21 THE COURT REPORTER:
22 was a federal project, right? 22 Okay.
23 A. Yes, sir. 23 THE WITNESS:
24 Q. The record reflects that over the course 24 Reviewing it?
25 of a period of time between 1966 up to the 25 MR. O'DONNELL:
Page 155 Page 157
1 time of Katrina, the Army Corps considered the 1 No, no, not reviewed, not your
2 potential of putting some sort of a surge 2 review.
3 barrier in the general vicinity where the 3 THE WITNESS:
4 current one is located. 4 I wanted to make sure I knew what I
5 Are you aware of any of those 5 was getting into.
6 considerations that were done historically 6 MR. O'DONNELL:
7 prior to Katrina? 7 No, no, no, you have a more
8 A. No, sir, I'm not. 8 leisurely pace. I just need the transcript.
9 Q. You've not seen any of those documents? 9 THE WITNESS:
10 A. No, sir. 10 Okay.
11 MR. O'DONNELL: 11 MR. O'DONNELL:
12 I want to thank you. My time is up 12 Rob, would you bird-dog that for us,
13 and I thank you for yours, as some commentator 13 buddy?
14 says, Paul Harvey, I think, and I appreciate 14 MR. WARREN:
15 your cooperation. 15 Yes.
16 Does counsel for the United States 16 MR. O'DONNELL:
17 have any questions? 17 Well, thank you, my friends. I'm
18 MS. GREIF: 18 sorry I don't get to have lunch with you guys,
19 No, I don't. 19 but it's nice seeing you even by video.
20 MR. O'DONNELL: 20 Mr. Owen, thank you and good luck to
21 Okay. So we have a procedure where 21 you. As a citizen, I appreciate all the good
22 you're going to get the deposition and look at 22 work you're doing.
23 it and change yeses to nos or whatever you 23 THE WITNESS:
24 want to do, free to do, and then, what's the 24 All right. Thank you very much.
25 procedure, how long do we give the witness for 25 MR. HART:
40 (Pages 154 to 157)
OWEN, GIB A.
10/16/2008
Page 158 Page 160
1 Off the record. 1 CERTIFICATE
2 (Whereupon, the deposition concluded at 2
3 1:30 p.m.) 3 This certification is valid only for a
4 4 transcript accompanied by my original
5 5 signature and original blue stamp on this
6 6 page.
7 7 I, Dawn H. Hymel, Certified Court Reporter
8 8 in and for the State of Louisiana, as the
9 9 officer before whom this testimony was taken,
10 10 do hereby certify that GIB A. OWEN, after
11 11 having been duly sworn by me upon authority of
12 12 R.S. 37:2554, did testify as hereinbefore set
13
13 forth in the foregoing 158 pages; that this
14
14 testimony was prepared and transcribed by me
15 or under my personal direction and
15
16 supervision; and is a true and correct
16 17 transcript to the best of my ability and
17 18 understanding; that I am not related to
18 19 counsel or to the parties herein, nor am I
19 20 otherwise interested in the outcome of this
20 21 matter.
21 22
22 23 ______________________________
23 DAWN H. HYMEL, #81016
24 24 Certified Court Reporter
25 25
Page 159
1 WITNESS' CERTIFICATE
2
3
4 I, GIB A. OWEN, do hereby certify that
5 the foregoing testimony was given by me, and
6 that the transcription of said testimony, with
7 corrections and/or changes, if any, is true
8 and correct as given by me on the
9 aforementioned date.
10
11 _______________ ________________________
DATE SIGNED SIGNATURE
12
13
14 _____Signed with corrections as noted.
15
16 _____Signed with no corrections noted.
17
18 DATE TAKEN: October 16, 2008
19
20
21
22
23
24
25
41 (Pages 158 to 160)

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OWEN, GIB A.

IN RE: KATRINA CANAL BREACHES * CIVIL ACTION

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Johns Pendleton Court Reporters 800 562-1285

28 (Pages 106 to 109)

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Johns Pendleton Court Reporters 800 562-1285

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Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

Johns Pendleton Court Reporters 800 562-1285

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