STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
SUGAR CANE GROWERS COOPERATIVE OF )
FLORIDA, a Florida Agricultural )
Cooperative Marketing Association, ) CASE NOS. 92-3038
ROTH FARMS, INC., and ) 92-3039
WEDGWORTH FARMS, INC., ) 92-3040
)
and )
)
FLORIDA SUGAR CANE LEAGUE, INC.; )
UNITED STATES SUGAR CORPORATION; )
and NEW HOPE SOUTH, INC., )
) ____________________
and )
FLORIDA FRUIT AND VEGETABLE ) DEPOSITION
ASSOCIATION, LEWIS POPE FARMS, )
W.E. SCHLECHTER & SONS, INC., and ) OF
HUNDLEY FARMS, INC., )
) CHRISTOPHER B. CRAFT
Petitioners, ) ____________________
)
vs. )
)
SOUTH FLORIDA WATER MANAGEMENT )
DISTRICT, an Agency of the State )
of Florida, )
)
Respondent, )
)
and )
)
MICCOSUKEE TRIBE OF INDIANS OF )
FLORIDA, the UNITED STATES OF )
AMERICA, and FLORIDA DEPARTMENT OF )
ENVIRONMENTAL REGULATION, and the )
FLORIDA WILDLIFE FEDERATION, )
)
Intervenors. )
___________________________________)
AT DURHAM, NORTH CAROLINA
NOVEMBER 11, 1992 - 9:00 A.M.
REPORTED BY: PAMELA S. LILES
CAROLYN Y. HALL & ASSOCIATES
DR. CRAFT PAGE A
APPEARANCES:
FOR THE PETITIONERS:
MR. RICK BURGESS
PEEPLES, EARL & BLANK
215 SO. MONROE STREET
SUITE 350
TALLAHASSEE, FLORIDA 32301
TELEPHONE: (904) 681-1900
FOR THE
RESPONDENT-INTERVENOR:
MS. SUZAN HILL PONZOLI MR. LEE M. KILLINGER
ASSISTANT U.S. ATTORNEY ASSISTANT GENERAL COUNSEL
SOUTHERN DISTRICT OF FLORIDA STATE OF FLORIDA
155 SOUTH MIAMI AVENUE DEPARTMENT OF ENVIRONMENTAL
SUITE 627 REGULATION
MIAMI, FLORIDA 33130 TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAD
TELEPHONE: (305) 536-4425 TALLAHASSEE, FLORIDA 32399
TELEPHONE: (904) 488-9730
FOR DUKE UNIVERSITY:
MR. RALPH L. McCAUGHAN
KING, WALKER, LAMBE & CRABTREE
SUITE 100, 3708 MAYFAIR STREET
POST OFFICE BOX 51549
DURHAM, NORTH CAROLINA 27717-1549
TELEPHONE: (919) 493-8411
ALSO PRESENT:
MR. RONALD D. JONES, Ph.D.
FLORIDA INTERNATIONAL UNIVERSITY
MR. JIM GRIMSHAW, Ph.D.
SOUTH FLORIDA WATER
MANAGEMENT DISTRICT
MR. SAM ELSSWICK, PARALEGAL
MR. ROBERT KADLEC
DR. CRAFT PAGE B
T A B L E O F C O N T E N T S
E X A M I N A T I O N I N D E X
DEPONENT - CHRISTOPHER BRUCE CRAFT - 11/11/92
EXAMINATION BY: PAGES
MS. PONZOLI 2-104
-------------------------------------------------------
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #1 SUBPOENA DUCES TECUM - DR. CRAFT 6
EXH. #2 RESUME OF DR. CRAFT 7
EXH. #3 GREEN FOLDER MARKED "N&P DATA" LOOKING 8
AT PEAT ACCRETION AND NUTRIENT
ACCUMULATION IN AREAS 2A, 3, 3A AND 2B
EXH. #4 DATA COLLECTED FROM 2A AND 3A 9
SPECIFICALLY CATIONS AND METALS MEASURED
EXH. #5 MANUSCRIPT THAT HAS BEEN ACCEPTED BY 16
ECOLOGICAL APPLICATIONS ON PEAT ACCRETION
AND NUTRIENT ACCUMULATION IN THE NORTHERN
AND CENTRAL EVERGLADES
EXH. #6 DATA USED IN THE MANUSCRIPT 21
EXH. #7 FIGURES THAT GO IN THE MANUSCRIPT 21
EXH. #8 LATITUDE AND LONGITUDE COORDINATES 22-23
FOR VARIOUS SOIL CORES
EXH. #9 PRELIMINARY CORES COLLECTED SOUTH OF 25
THE HILLSBORO CANAL
DR. CRAFT PAGE C
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #10 VEGETATION SPECIES COMPOSITION ALONG 26
A GRADIENT THROUGH ENRICHED AREA TO
THE UNENRICHED AREA DONE MAY OF '92
EXH. #11 (SAME AS EXHIBIT #10) 26
EXH. #12 GRADIENT DATA - CORES COLLECTED IN 28
CONSERVATION AREA 2A BY DR. CRAFT
AND LORI SUTTER
EXH. #13 GRAPHS OF CESIUM DATA FROM 1990 CORES 28
ON THE GRADIENT
EXH. #14 FILES RELATING TO PHOSPHORUS ACCUMULATION 29
DATA ON GRADIENT TO PHOSPHORUS CONCEN-
TRATIONS IN SURFACE WATER
EXH. #15 MORE GRADIENT CORES COLLECTED BY 30
DR. CRAFT AND LORI SUTTER - TAKEN 44
3/4 OF KILOMETER BELOW HILLSBORO CANAL
AND PARALLEL TO THE GATES
DISKETTE FILE OF DR. CRAFT
SAS DATA SETS/PROGRAMS RELATING TO THE
FERTILIZER STUDY
EXH. #36 BIOMASS DATA, WATER LEVEL DATA, pH 32-33
OXYGEN CONDUCTIVITY DATA
EXH. #37 PART OF DATA SET NUMBER IN THIRTY-SIX 33
EXH. #38 FERTILIZER BIOMASS DATA 33
EXH. #39 WATER CHEMISTRY DATA, PHOSPHATE, 33
AMMONIUM, NITRATE
EXH. #40 SAME AS EXHIBIT #39 33
EXH. #41 INTERMEDIATE WATER CHEMISTRY DATA 34
EXH. #42 DR. CRAFT THINKS THIS IS INTERMEDIATE 34
DATA ON PHOSPHATE, AMMONIUM AND NITRATE
EXH. #42A CALLED "EVERGLADES." 1990 DATA 36
DR. CRAFT PAGE D
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #43 EVERGLADES 2. SOME OF '90 DATA 35
COLLECTED ON THE GRADIENT
EXH. #44 CATIONS. BASE CATIONS AND METAL DATA 37
'89 AND '90 DATA
EXH. #45 GRADIENT WITH DATA FROM THREE TRANSECTS 37
AND CESIUM GRAPHS - '91 DATA
EXH. #46 REPEATED CORES ON THE GRADIENT IN '91 37
EXH. #47 DISK USED IN ANNUAL REPORT RELATING 38
TO GRADIENT STUDY
EXH. #48 FERTILIZER DIVISION - PROPOSAL 38
EXH. #49 FERTILIZER - ANNUAL REPORT 38
EXH. #50 FERTILIZER STUDY - FIRST YEAR'S 38
BIOMASS DATA
EXH. #51 INITIAL WATER CHEMISTRY DATA 38
EXH. #52 WATER DATA FROM MIXED SITE 39
EXH. #53 SAYS "FERT DATA" 39
EXH. #54 WATER CHEMISTRY DATA FROM 39
FROM FERTILIZER STUDY
EXH. #55 INTERMEDIATE DRAFT OF CONTRIBUTION 39
TO 1991 ANNUAL REPORT
EXH. #56 GRAPHS THAT GO WITH 1991 ANNUAL REPORT 40
EXH. #57 GRAPHS THAT GO WITH 1991 ANNUAL REPORT 40
EXH. #58 INTERMEDIATE DRAFT OF ANNUAL REPORT 40
FOR 1990 (ROUGH DRAFT)
EXH. #59 SEMINARS - SLIDES OF TALKS GIVEN 41
BY DR. CRAFT
DR. CRAFT PAGE E
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #60 SEMINARS TWO. SLIDES FROM SEMINARS 41
EXH. #61 SEMINARS THREE. SLIDES FROM SEMINARS 41
EXH. #62 SWS - SLIDES FOR SOCIETY OF 42
WETLANDS SCIENTISTS
EXH. #63 DELTA GRAPH - SOFTWARE PACKAGE USED 42
TO MAKE GRAPHS
EXH. #64 "FERT MANUSCRIPT" DRAFT SIMILAR TO 42
CHAPTER 7
EXH. #65 GRADIENT MANUSCRIPT 42
EXH. #66 GRADIENT MANUSCRIPT TWO 43
EXH. #67 "N AND P" - MANUSCRIPT THAT'S BEEN 43
ACCEPTED BY ECOLOGICAL APPLICATIONS
EXH. #68 SUPPORTING GRAPHS AND TABLES THAT GO 43
WITH THE MANUSCRIPT
"GRADIENT" FOLDER
EXH. #16 MANUSCRIPT FOR THE GRADIENT (REVISED) 47
EXH. #17 SUPPORTING INFORMATION TO CALCULATE 47
AREA OF ENHANCED PHOSPHOROUS ACCUMULATION
IN CONSERVATION AREA 2A
EXH. #18 DATA AND STATISTICS TO SUPPORT 48
MANUSCRIPT ON THE GRADIENT
EXH. #19 RAW DATA FROM GRADIENT USED IN MANUSCRIPT 48
EXH. #20 FIGURES THAT GO WITH GRADIENT PAPER 48
"FIELD FERTILIZATION" FOLDER
EXH. #21 PROPOSAL BEFORE WORK WAS DONE 48
EXH. #22 ADDENDUM TO PROPOSAL WRITTEN BY VYMAZAL 48
DR. CRAFT PAGE F
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #23 BROMIDE TRACER DATA TO DETERMINE 48-49
RETENTION TIME OF THE FERTILIZER
"FERTILIZER DATA" FOLDER
EXH. #24 FERTILIZER BIOMASS DATA AND STATISTICS 49
EXH. #25 FERTILIZER STUDY AND COMPUTER OUTPUT 49
"FERTILIZER MS" FOLDER
EXH. #26 DRAFT OF THE MANUSCRIPT 50
EXH. #27 ASSOCIATED FIGURES AND BLACK & WHITE 50
PHOTOGRAPHS
"GREENHOUSE FOLDER"
EXH. #28 SAWGRASS AND PHOSPHOROUS EXPERIMENT 51
UNDERTAKEN BY LORI SUTTER - PROPOSAL
EXH. #29 SAWGRASS CATTAIL COMPETITION STUDY 51
"MANUSCRIPTS" FOLDER
EXH. #30 MANUSCRIPT WRITTEN BY DR. RICHARDSON 54
AND DR. CRAFT - PRESS, 1992
EXH. #31 MONTHLY & QUARTERLY REPORTS FOR PROJECT 55
"SFWMD" FOLDER
EXH. #32 DISTRICT EXPERIMENTS 56
EXH. #33 LITIGATION FOLDER 57
EXH. #34 AGRICULTURAL BEST MANAGEMENT PRACTICES 57
EXH. #35 PROPOSAL TO STUDY MERCURY 58
NOTESBOOKS AND SLIDES
"EVERGLADES, CATIONS (TOTAL)"
EXH. #69 HOW YOU CALIBRATE ATOMIC ABSORPTION UNIT 59
AND PARAMETERS REQUIRED FOR MEASURING
DIFFERENT ELEMENTS
EXH. #70 IRON AND MANGANESE DATA, '89-'90 CORES 59
DR. CRAFT PAGE G
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #71 DATA FOR BASE CATIONS AND ALUMINUM 60
EXH. #72 CATION DATA FROM PRELIMINARY CORES 60
EXH. #73 CATION DATA, SODIUM AND CALCIUM 60
"EVERGLADES C&N" NOTEBOOK
EXH. #74 RUNS OF INTERNAL STANDARDS TO 61
CALIBRATE INSTRUMENT
EXH. #75 TOTAL CARBON AND NITROGEN DATA 61
EXH. #76 ORGANIC C, SAMPLES OF MEASURABLE 62
CARBONATES
"EVERGLADES P" NOTEBOOK
EXH. #77 RACK OF SAMPLES, SHEET TELLING HOW 63
WEIGHED OUT (PHOSPHORUS)
EXH. #78 RESULTS OF REPLICATE SAMPLES 65
AND INTERNAL LAB STANDARDS
EXH. #79 OVEN-DRIED WEIGHTS 66
EXH. #80 TOTAL PE CONCENTRATION IN SOILS 66
EXH. #81 ORGANIC PHOSPHORUS SAMPLES 66
EXH. #82 CALCIUM PHOSPHATE FRACTION SAMPLE 66
"FERTILIZER-SOILS VEGETATION, WATER LEVELS"
EXH. #83 DATES RE: APPLYING FERTILIZER 67
EXH. #84 PRETREATMENT DATA FOR SAWGRASS SITE 68
EXH. #85 PRETREATMENT BIOMASS DATA-MIXED SITE 68
EXH. #86 PRETREATMENT BIOMASS DATA-SLOUGH SITE 68
EXH. #87 PRETREATMENT DATA CARBON & NITROGEN 69
CONTENT OF PLANT SAMPLES COLLECTED
DR. CRAFT PAGE H
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #88 SOILS-HOW PLOTS ARE LAID OUT, AND 69
SOIL DEPTHS TO BEDROCK, ETC.
EXH. #89 WATER LEVEL DATA FROM ALL THREE SITES 70
"FERTILIZER, WATER CHEMISTRY, AND FIGURES"
EXH. #90 WATER CHEMISTRY DATA 71
EXH. #91 FIGURES PRETREATMENT STANDING CROP 72
BIOMASS, STEM COUNTS
"FERTILIZER DRY WEIGHT N,P"
EXH. #92 SUMMARY OF RESULTS OF ANALYSIS OF 72
VARIANTS FROM FIRST YEAR OF BIOMASS DATA
EXH. #93 FIRST YEAR OF DRY WEIGHT DATA 72
EXH. #94 CONTINUATION OF SAME DATA, DRY WEIGHT 72
EXH. #95 PHOSPHORUS CONCENTRATION IN PLANT TISSUE 73
EXH. #96 RAW DATA SETS AS UPDATED 73
"FERTILIZER STUDY 1992"
(CONTAINS CRAFT EXHIBITS #97 - #101)
EXH. #101 DOCUMENT IN FRONT POCKET OF NOTEBOOK 74
CHECK SHEET OF WEIGHTS OF SAMPLES
EXH. #97 WATER SAMPLES AFTER FERTILIZER APPLIED 74-75
EXH. #98 SOILS DATA FROM 1992 75
EXH. #99 1992 BIOMASS DATA AND DRY WEIGHT DATA 75
EXH. #100 PRELIMINARY BELOW GROUND BIOMASS DATA 75
"PLANT TISSUE" NOTEBOOK
EXH. #102 NITROGEN PHOSPHORUS CONTENT OF VEGETATION 76
EXH. #103 FIGURES GRAPHING DATA IN EXHIBIT #102 77
DR. CRAFT PAGE I
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
"EVERGLADES CESIUM" NOTEBOOK
EXH. #104 RAW COUNT DATA FOR CESIUM 79
EXH. #105 INTERMEDIATE DATA DERIVED FROM #104 79
"CESIUM COUNTING" NOTEBOOK
EXH. #106 DATE ON INCREMENT WEIGHTS (GOES 80
WITH PREVIOUS NOTEBOOK)
"Pb 210" NOTEBOOK
EXH. #107 SUMMARY OF PROTOCOLS FOR WORKING WITH 81
RADIOACTIVITY IN THE LAB
EXH. #108 LEAD 210 DATA 81
EXH. #109 ANOTHER WAY TO COUNT LEAD 210 BY 81
DIRECT GAMMA COUNTING
EXH. #110 INVOICES FOR THINGS BOUGHT RELATING 81
TO DOING LEAD 210 WORK
EXH. #111 INFORMATION ON HOW TO DO POLLEN ANALYSIS 81
NOTEBOOK OF SLIDES
(GROUPED BY TALK GIVEN BY DR. CRAFT)
EXH. #112 PEAT ACCRETION NUTRIENT ACCUMULATION TALK 84
EXH. #113 ORGANIC AND INORGANIC CARBON ACCUMULATION 85
EXH. #114 EFFECTS OF AGRICULTURAL RUNOFF ON NUTRIENT 85
ACCUMULATION IN THE EVERGLADES
EXH. #115 WATER QUALITY IN THE EVERGLADES 85
EXH. #116 HISTORICAL AND RECENT RATES OF PEAT 86
ACCRETION IN THE EVERGLADES
EXH. #117 EFFECTS OF AGRICULTURAL DRAINAGE ON 87
PEAT ACCRETION NUTRIENT ACCUMULATION
EXH. #118 FEW SLIDES ON SPECIES COMPOSITION ON 87
THE GRADIENT AND TISSUE N AND P
COMPOSITION
DR. CRAFT PAGE J
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
EXH. #119 EFFECTS OF NITROGEN AND PHOSPHORUS 87
ADDITIONS ON PLANT COMMUNITIES -
PRELIMINARY DATA FROM FERTILIZER STUDY,
PRETREATMENT DATA
EXH. #120 EFFECT OF N AND P ON THE EVERGLADES PLANT 88
COMMUNITIES, SWS 1992 MEETING
EXH. #121 SAS OUTPUT WATER LEVELS IN FERTILIZER 89
PLOTS FOR 1990 - 1992
EXH. #122 SAS RESULTS ON pH OXYGEN AND CONDUCTIVITY 89
FROM THE FERTILIZER PLOTS
EXH. #123 COMPUTER OUTPUT FOR THE NITROGEN AND 89
PHOSPHORUS CONTENT OF PLANT TISSUE IN
THE FERTILIZER STUDY.
EXH. #124 SURFACE AND PORE WATER, AMMONIUM, NITRATE 90
PHOSPHATE DATA FROM THE FERTILIZER STUDY
EXH. #125 STATISTICAL ANALYSES OF BIOMASS DATA FROM 90
THE FIRST YEAR OF THE STUDY
EXH. #126 DR. CRAFT NOT SURE WHAT THIS IS. LOOKS 91
LIKE A PAPER OF JAN VYMAZAL, OR SOMETHING.
-------------------------------------------------------
SIGNATURE PAGE FOR DEPONENT 104
CERTIFICATION OF COURT REPORTER 105
STIPULATIONS
IT IS HEREBY STIPULATED AND AGREED BETWEEN THE
PARTIES TO THIS ACTION, THROUGH THEIR RESPECTIVE
COUNSEL OF RECORD:
(1) ON MOTION OF COUNSEL FOR THE RESPONDENT-
INTERVENOR, THE DEPOSITION OF DR. CHRISTOPHER BRUCE
CRAFT MAY BE TAKEN BEGINNING AT OR AROUND 9:00 A.M.
ON NOVEMBER 11, 1992, AT THE HILTON HOTEL, DURHAM,
NORTH CAROLINA, BEFORE PAMELA S. LILES, A NOTARY
PUBLIC.
(2) SAID DEPOSITION SHALL BE TAKEN FOR THE
PURPOSE OF DISCOVERY OR FOR USE AS EVIDENCE IN THIS
ACTION, OR FOR BOTH PURPOSES, OR FOR ANY OTHER PURPOSE
PERMITTED BY THE FEDERAL RULES OF CIVIL PROCEDURE.
(3) ANY OBJECTION OF ANY PARTY HERETO AS TO
NOTICE OF THE TAKING OF SAID DEPOSITION OR AS TO THE
TIME OR PLACE THEREOF, OR AS TO THE COMPETENCY OF THE
PERSON BEFORE WHOM THE SAME SHALL BE TAKEN, ARE HEREBY
WAIVED.
(4) THE FEDERAL RULES OF CIVIL PROCEDURE SHALL
CONTROL THE TAKING OF SAID DEPOSITION AND THE USE
THEREOF IN COURT.
(5) OBJECTIONS TO QUESTIONS AND MOTIONS TO STRIKE
ANSWERS NEED NOT BE MADE DURING THE TAKING OF THIS
DEPOSITION, BUT MAY BE MADE FOR THE FIRST TIME DURING
THE PROGRESS OF THE TRIAL OF THIS CASE, OR AT ANY
PRETRIAL HEARING HELD BEFORE ANY FEDERAL COURT JUDGE
FOR THE PURPOSE OF RULING THEREON, OR AT ANY OTHER
HEARING OF SAID CASE AT WHICH SAID DEPOSITION MIGHT BE
USED, EXCEPT THAT AN OBJECTION AS TO THE FORM OF A
QUESTION MUST BE MADE AT THE TIME SUCH QUESTION IS
ASKED OR OBJECTION IS WAIVED AS TO THE FORM OF THE
QUESTION.
(6) THAT THE SIGNATURE OF THE WITNESS TO THE
TRANSCRIPT OF HIS TESTIMONY IS HEREBY REQUIRED.
(7) EXCEPT AS WAIVED BY THESE STIPULATIONS, THE
PROVISIONS OF THE FEDERAL RULES OF CIVIL PROCEDURE
SHALL APPLY TO THE TAKING OF SAID DEPOSITION AND AS TO
ITS SUBMISSION TO THE RESPECTIVE DEPONENT,
CERTIFICATION, AND FILING WITH THE APPROPRIATE NOTICING
ATTORNEY.
- - - - - - - - - - - - - - - - - - - - -
DR. CRAFT PAGE 2
WHEREUPON,
CHRISTOPHER BRUCE CRAFT,
HAVING BEEN FIRST DULY SWORN,
WAS EXAMINED AND TESTIFIED
AS FOLLOWS:
EXAMINATION BY MS. PONZOLI:
Q. SIR, WOULD YOU PLEASE STATE YOUR NAME AND TITLE
FOR THE RECORD, PLEASE.
A. I'M CHRISTOPHER BRUCE CRAFT.
Q. AND I BELIEVE IT'S DR. CRAFT, IS IT NOT?
A. I'M A RESEARCH ASSISTANT PROFESSOR.
Q. IT'S PROFESSOR CRAFT?
A. YOU CAN CALL ME DR. CRAFT, PROFESSOR CRAFT,
MR. CRAFT, I REALLY DON'T---
Q. YOU DO NOT CARE?
A. NO, I DON'T REALLY---
Q. OKAY.
A. ---IT DOESN'T REALLY MATTER TO ME.
Q. OKAY. I'LL CALL YOU DR. CRAFT, IF THAT'S
ACCURATE.
A. OKAY.
Q. DR. CRAFT, WOULD YOU PLEASE STATE YOUR ADDRESS FOR
THE RECORD, PLEASE.
A. THIS IS MY PERSONAL HOME ADDRESS, OR MY---
DR. CRAFT PAGE 3
Q. YOU CAN GIVE YOUR WORK ADDRESS, THAT'S FINE.
A. OKAY. DUKE WETLANDS CENTER, SCHOOL OF THE
ENVIRONMENT, DUKE UNIVERSITY, DURHAM, N.C., 27706.
Q. THERE'S NO PARTICULAR STREET ADDRESS OR BUILDING
FOR -- IS THAT THE SCHOOL OF THE ENVIRONMENT?
A. IF YOU MAIL ME SOMETHING AND PUT THAT ADDRESS, IT
WILL GET TO ME.
Q. AND YOUR PHONE NUMBER, PLEASE, SIR.
A. 919 684-2619.
Q. ALL RIGHT. FOR THE RECORD, DR. CRAFT, I AM SUZAN
HILL PONZOLI. I'M AN ASSISTANT UNITED STATES
ATTORNEY, AND I REPRESENT THE UNITED STATES IN
THIS STATE ADMINISTRATIVE PROCEEDING.
YOU HAVE BEEN SUBPOENAED TO PROVIDE YOUR
RESEARCH RECORDS FOR THE WORK THAT YOU HAVE DONE
WITH THE DUKE WETLANDS CENTER IN CONJUNCTION WITH
DR. RICHARDSON, WHO HAS BEEN LISTED AS AN EXPERT
WITNESS FOR ONE OF THE SIDES IN THIS ACTION.
AND SO, AS I THINK YOU'RE VERY WELL AWARE, WE'VE
ASKED TO SEE YOUR RESEARCH RECORDS AND WE WILL BE
TAKING YOUR DEPOSITION SUBSEQUENTLY ON THE WORK
THAT YOU HAVE DONE IN CONJUNCTION WITH
DR. RICHARDSON.
I'D LIKE TO HAND YOU -- WELL, FIRST OF ALL,
DR. CRAFT PAGE 4
DR. CRAFT, HAVE YOU EVER HAD YOUR DEPOSITION TAKEN
BEFORE?
A. NEVER.
Q. ALL RIGHT. AS I'M SURE COUNSEL HAS TOLD YOU, I
WILL BE ASKING YOU, TODAY, QUESTIONS ABOUT YOUR
DOCUMENTS, SUBSEQUENTLY QUESTIONS ABOUT YOUR
SUBSTANTIVE WORK. IF YOU DO NOT UNDERSTAND MY
QUESTION, IT'S IMPORTANT THAT YOU INDICATE TO ME
THAT YOU DID NOT UNDERSTAND THE QUESTION, BECAUSE
THE WAY THE PROCESS WORKS, ONCE YOU ANSWER, IT IS
ASSUMED THAT YOU DID UNDERSTAND THE QUESTION.
A. OKAY.
Q. SO, I WOULD ASK YOU TO PLEASE INDICATE, AND I
WOULD TRY TO FRAME A BETTER AND MORE APPROPRIATE
QUESTION SO THAT YOU COULD UNDERSTAND.
A. (NODS AFFIRMATIVELY.)
Q. WOULD YOU LIKE US TO HAVE PEOPLE TO INTRODUCE
THEMSELVES ON THE RECORD, OR HAVE YOU MET
EVERYONE?
A. THAT WOULD BE OKAY. THAT WOULD BE FINE. I'D LIKE
TO DO IT AGAIN.
Q. ALL RIGHT. I HAVE WITH ME HERE TODAY TWO DOCTORS,
ALSO WHO ARE TO HELP ME WITH THE RATHER COMPLEX
SCIENCE THAT YOU HAVE BEEN INVOLVED WITH. THERE'S
DR. CRAFT PAGE 5
DR. BOB KADLEC IS WITH ME AND DR. RON JONES.
DR. JIM GRIMSHAW IS HERE ON BEHALF OF THE WATER
MANAGEMENT DISTRICT. AND I'LL LET THE OTHER
COUNSEL INTRODUCE THEMSELVES.
MR. KILLINGER: MY NAME IS LEE
KILLINGER, AND I'M HERE FOR THE FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION.
MR. BURGESS: RICK BURGESS, PEEPLES,
EARL & BLANK, ON BEHALF OF THE FLORIDA SUGAR
CANE LEAGUE, UNITED STATES SUGAR CORPORATION,
AND NEW HOPE SOUTH.
MR. McCAUGHAN: RALPH McCAUGHAN,
FOR DUKE UNIVERSITY ON BEHALF OF THE
WITNESS.
Q. (BY MS. PONZOLI) DR. CRAFT, WE HAVE BEEN MARKING
FOR IDENTIFICATION A NUMBER OF THE RECORDS THAT
YOU PRODUCED IN RESPONSE TO THE SUBPOENA. I WOULD
LIKE, FIRST, TO HAND YOU EXHIBIT -- CRAFT EXHIBIT
NUMBER ONE AND ASK YOU IF YOU'VE SEEN THIS
DOCUMENT BEFORE.
(THEREUPON, WITNESS REVIEWS DOCUMENT.)
A. YES, I'VE SEEN IT.
Q. ALL RIGHT. DO YOU KNOW WHAT IT IS?
A. IT'S A SUBPOENA.
DR. CRAFT PAGE 6
Q. ALL RIGHT. IT IS A SUBPOENA DUCES TECUM FOR
CERTAIN DOCUMENTS. DID ANYONE HELP YOU ASSEMBLE
YOUR DOCUMENTS IN PREPARATION FOR TODAY,
DR. CRAFT?
A. NO. I PULLED THEM OUT OF THE FILE IN PRETTY MUCH
THE ORDER THAT YOU HAVE RECEIVED THEM IN.
Q. ALL RIGHT. THEN LET ME ASK YOU, HAVE YOU READ
THROUGH THE REQUEST FOR THE DOCUMENTS VERY
CAREFULLY?
A. YES, I'VE READ IT A COUPLE OF TIMES.
Q. ALL RIGHT. AND DID YOU READ THROUGH THE
DESCRIPTION OF WHAT THE DOCUMENTS WERE THAT WAS
FAIRLY EXTENSIVE?
A. THE NUMBER SIX HERE, OR JUST EVERYTHING?
Q. NO, IT'S UNDER DEFINITIONS "a" A DOCUMENT
INCLUDED---
A. OKAY.
Q. ---YOU KNOW, PRETTY MUCH ANYTHING THAT YOU'VE EVER
JOTTED ANYTHING DOWN ON, A DISK OR A NOTE PAD IN
REGARD TO YOUR RESEARCH IN THE FLORIDA EVERGLADES
ON BEHALF OF THE DUKE WETLANDS CENTER.
A. YES, I BROUGHT EVERYTHING I HAVE RELATING TO MY
WORK ON THE EVERGLADES.
Q. OKAY. ALL RIGHT. THAT'S REALLY THE BOTTOM LINE
DR. CRAFT PAGE 7
QUESTION. HAVE YOU PRODUCED HERE TODAY---
A. RIGHT.
Q. ---VIRTUALLY EVERYTHING THAT YOU HAVE---
A. UH-HUH (YES).
Q. ---IN REGARD TO THAT RESEARCH?
A. YES.
Q. ALL RIGHT. THEN I'D LIKE TO BEGIN IDENTIFYING
THOSE DOCUMENTS. I'M GOING TO HAND YOU CRAFT
EXHIBIT NUMBER TWO, AND ASK YOU TO PLEASE IDENTIFY
IT.
A. IT'S MY RESUME.
Q. ALL RIGHT. AND IS THAT A CURRENT UP-TO-DATE
RESUME, DR. CRAFT?
A. WITHIN FIVE OR SIX MONTHS---
Q. ALL RIGHT.
A. ---IT'S MY LATEST ONE.
Q. SURE. IS THERE ANYTHING YOU WOULD ADD TO THAT, IF
YOU DID IT LIKE YESTERDAY OR TODAY?
A. I DON'T THINK SO.
Q. ALL RIGHT, THANK YOU.
MS. PONZOLI: I'D LIKE THE RECORD TO
REFLECT THAT WE HAVE A NUMBER OF FOLDERS,
AND THAT THEY'RE SORT OF -- I GUESS THE
GREEN-TYPE THAT HANG WITHIN A FOLDER FILE.
DR. CRAFT PAGE 8
WE'VE ASKED THAT THEY BE DUPLICATED WITH THE
MARKING IDENTIFICATION, THE FIRST BEING THE
N AND P DATA. AND THEN WITHIN EACH
INDIVIDUAL GREEN FOLDER, THERE ARE MANILLA
FOLDERS WITH DEPOSITION EXHIBIT NUMBERS
REFLECTED ON THEM, AND WE WILL BE ASKING
DR. CRAFT TO IDENTIFY FOR US WHAT EACH OF
THESE ARE.
Q. (BY MS. PONZOLI) DR. CRAFT, I'M GOING TO HAND YOU
THE GREEN FOLDER MARKED N AND P DATA WITH THE
FIRST EXHIBIT NUMBER THREE IN IT, AND ASK YOU IF
YOU CAN IDENTIFY, FIRST, WHAT THE N AND P DATA
ARE, AND THEN WHAT DEPOSITION EXHIBIT NUMBER THREE
IS.
A. OKAY. THE N AND P GREEN FOLDER IS THE FIRST WORK
I DID WHEN I STARTED AT DUKE, LOOKING OVERALL AT
PEAT ACCRETION AND NUTRIENT ACCUMULATION IN
CONSERVATION AREAS 2A, 3, 3A AND 2B.
Q. ARE THEY REFLECTED AS TO WHICH CONVERSATION AREA
ON THOSE DOCUMENTS, DR. CRAFT?
A. YES. BUT IT MIGHT TAKE A LITTLE BIT OF
INTERPRETATION BY SOMEBODY OTHER THAN ME.
Q. BY SOMEONE OTHER THAN YOU?
A. NO. BY ME. I'M SORRY.
DR. CRAFT PAGE 9
Q. OKAY. CAN YOU HELP US, BECAUSE WE WILL BE WORKING
WITH YOUR DATA, HOW WE WILL KNOW AS WE WORK OUR
WAY THROUGH THAT DATA WHETHER WE ARE LOOKING AT 2A
DATA, 3A DATA, OR 2B.
A. OKAY. THE ONES THAT SAY 10A AT THE TOP ARE IN
CONSERVATION 2A SOUTH OF THE S-10 STRUCTURES. THE
ONES THAT SAY WCA-2B ARE FROM 2B. THE REMAINING
ONES ARE ALL FROM 3A.
Q. ALL RIGHT. IS THAT THE SUM TOTAL OF CRAFT EXHIBIT
NUMBER THREE?
A. UH-HUH (YES).
Q. ALL RIGHT. YOU HAVE IN FRONT OF YOU, I BELIEVE,
CRAFT EXHIBIT NUMBER FOUR, ALSO. CAN YOU IDENTIFY
THAT COMPOSITE EXHIBIT?
A. OKAY. THIS IS DATA COLLECTED, AGAIN, FROM 2A AND
3A, BUT SPECIFICALLY CATIONS THAT WE MEASURED AND
METALS THAT WE MEASURED---
MR. BURGESS: CATIONS,
C-A-T-I-O-N-S.
A. ---BASE CATIONS, LET'S SAY THAT.
Q. ALL RIGHT. ARE THEY, AGAIN, MARKED IN THE SAME
WAY AT THE TOP SO THAT WE CAN DETERMINE WHETHER
WE'RE LOOKING AT 2A OR 3A DATA?
A. NO. THIS IS MORE HANDWRITTEN -- WELL, THEY ARE
DR. CRAFT PAGE 10
MARKED IN THE SAME WAY, BUT THE DATA THAT ACTUALLY
IS IN HERE IS ALSO -- THE ACTUAL RAW DATA IS BACK
IN EXHIBIT THREE WITHIN THESE OVERALL BIG DATA
SETS.
Q. COULD YOU MOVE THROUGH THEM, THOUGH, AND GIVE US
SOME IDENTIFYING -- ARE YOU ABLE TO TELL WHEN WE
LOOK AT IT---
A. YEAH.
Q. ---WHICH ONE IT IS?
A. WELL, THIS IS -- THESE ARE JUST FIGURES OF CALCIUM
IN THE SOIL, MICROGRAMS PER GRAM. THESE ARE JUST
GRAPHS -- THESE ARE JUST THE GRAPHS OF THE CATION
AND METAL DATA, WHICH ARE DERIVED FROM THIS DATA,
WHICH IS DERIVED FROM THE DATA FROM HERE.
Q. ALL RIGHT. TO THE EXTENT YOU CAN, WHEN YOU SAY
"THIS," WHEN WE GET TO A FLAT RECORD ONE DAY, IT
WON'T HELP US. THE GRAPH DATA IS INTERMEDIATE
DATA BETWEEN RAW DATA AND THE DATA REFLECTED IN
CRAFT NUMBER THREE, IS THAT ACCURATE?
A. LET'S BACK UP---
Q. THREE---
A. ---NUMBER THREE IS THE RAWEST OF THE RAW.
Q. ALL RIGHT.
A. WELL, MAYBE NOT THAT RAW, BUT IT'S PRETTY RAW.
DR. CRAFT PAGE 11
Q. OKAY.
A. THIS IS MORE TAKING THIS DATA, CONDENSING IT, SO
THAT I COULD LOOK AT IT AND GRAPH IT. SO, THIS
IS MORE INTERMEDIATE FROM THE RAW, BUT BEFORE WE
START ACTUALLY TRYING TO ASSIMILATE IT, AND WRITE
ABOUT IT.
Q. ALL RIGHT. THAT'S THE FIRST PAPER-CLIPPED GROUP
OF GRAPHS?
A. OKAY. AND THIS IS -- ARE YOU READY FOR NUMBER
TWO?
Q. YES, SIR. THE SECOND PAPER-CLIPPED GROUP OF DATA
ARE THE---
A. IS -- THIS IS JUST -- THIS IS ALSO DATA -- IT'S
JUST HANDWRITTEN -- THAT WAS IN THE RAW DATA FROM
CONSERVATION AREA 2B, BUT THE AVERAGE CATION AND
METAL CONCENTRATIONS IN THOSE 2B CORES.
Q. 2A OR 2B?
A. THIS IS 2B.
Q. OKAY. ON THE GRAPHS, WERE THE GRAPHS CLEAR AS TO
WHICH AREA THEY WERE REFLECTING?
A. YEAH. IF YOU CAN SEE, WE'VE BROKEN IT INTO
NORTHERN AND CENTRAL EVERGLADES.
Q. SO, THEY'RE LABELED---
A. RIGHT.
DR. CRAFT PAGE 12
Q. ---THEY'RE LABELED WATER CONSERVA---
A. ENRICHED, UNENRICHED IN 2A; CONSERVATION AREA 2B;
CENTRAL EVERGLADES IS CONSERVATION AREA 3A.
Q. OKAY. WILL THAT CENTRAL REMAIN A SIMILAR TERM
THROUGHOUT YOUR DOCUMENTS IF WE---
A. I THINK SO.
Q. ---SAID THAT?
A. I THINK SO.
Q. OKAY. ALL RIGHT.
A. SO, WE'VE DONE THIS ONE.
Q. YES, SIR.
A. ALL RIGHT. THIS IS THE NEW -- THE METAL AND
CATION ACCUMULATION RATE DATA FOR THESE CORES.
AND, AGAIN, THIS IS DERIVED FROM SOME OF THE RAW
DATA IN THE FIRST FOLDER.
Q. IS THIS INTERMEDIATE---
A. THIS IS FOR ALL THE SITE---
Q. ---IS IT INTERMEDIATE DATA?
A. YEAH. THIS IS THE INTERMEDIATE STAGE HERE.
Q. OKAY.
A. THIS -- YEAH.
Q. AND YOU'RE NOT APPLYING ANY STATISTICAL
MANIPULATIONS TO THIS DATA, AS IT APPEARS?
A. WELL, WE'RE TAKING MEANS AND STANDARD ERRORS,
DR. CRAFT PAGE 13
THAT'S THE EXTENT OF IT.
Q. OKAY.
A. NOT A WHOLE LOT TO DO THERE.
Q. OKAY.
A. THIS IS INTERMEDIATE DATA, METAL CONCENTRATIONS,
CATION CONCENTRATIONS AT ALL THOSE SITES. AND,
IN FACT -- WELL, I THINK THAT'S WHAT IT IS. I
THINK THE GRAPHS ARE DERIVED FROM THIS EXACT PAGE
OF DATA HERE.
Q. AND IT'S LABELED "MEAN"?
A. IT'S LABELED "MEAN CESIUM CONCENTRATIONS," WHICH
IS NOT -- IS INCORRECT, BECAUSE THESE ARE
OBVIOUSLY METAL CONCENTRATIONS AND CATION
CONCENTRATIONS.
Q. I WOULD ASK YOU WHERE A TITLE IS NOT EXACTLY WHAT
IT APPEARS, IF YOU WOULD POINT THAT OUT TO US, SO
WE WON'T BE---
A. THIS IS DEFINITELY -- I MEAN, I'LL SCRATCH IT OUT,
BECAUSE IT DOESN'T MEAN ANYTHING TO ME EITHER.
Q. OKAY.
MR. KADLEC: THEY'RE FROM CESIUM
CORES, PRESUMABLY.
WITNESS: RIGHT.
MS. PONZOLI: RIGHT. RIGHT.
DR. CRAFT PAGE 14
MR. KADLEC: ARE THOSE VERTICALLY
INTEGRATED?
WITNESS: THESE ARE VERTICALLY
INTEGRATED TO THE DEPTH OF WHERE THE
CESIUM MAXIMUM OCCURS.
MS. PONZOLI: OKAY.
A. OKAY. THESE ARE SOME MORE RAW DATA FROM
CONSERVATION AREA 2B. THESE WERE CORES COLLECTED
A YEAR -- THESE WERE SORT OF LIKE CORES COLLECTED
A SECOND TIME AROUND TO GET A BETTER IDEA OF
WHAT'S OCCURRING DOWN THERE.
Q. ARE THEY LABELED, ALSO?
A. YEAH, THEY'RE LABELED, AND THEY HAVE LIKE A
NUMBER 2, MEANING THAT THESE WERE COLLECTED, LIKE,
A YEAR LATER.
Q. RIGHT.
A. THESE WERE NOT THE FIRST, ORIGINAL CORES.
Q. AND BOTH OF THOSE, YOU HAVE TWO PAPER-CLIPPED
GROUPS TOGETHER.
A. YEAH. THIS IS CORE, REP 1 CORE---
Q. RIGHT.
A. ---THIS IS REP 2 CORE.
Q. ALL RIGHT. AND THEY'RE LABELED REP 1 AND REP 2?
A. YEAH, R1.
DR. CRAFT PAGE 15
Q. OKAY. I CAN'T SEE THAT FAR, I'M SORRY.
A. WELL, HERE, I CAN---
Q. THAT'S ALL RIGHT; THAT'S ALL RIGHT. I TELL YOU
IT'S FINE; THAT'S FINE. THESE ARE NOT MY REGULAR
GLASSES; I CAN'T SEE VERY WELL.
A. OKAY. I'LL HAVE TO TAKE A LOOK AT THIS. THESE
ARE -- THIS IS JUST THE DEPTH DISTRIBUTION OF
CATIONS INTEGRATED IN THE PROFILE FOR THOSE SITES,
THOSE NORTHERN AND CENTRAL SITES.
Q. AGAIN, ARE THEY LABELED?
A. WELL, YEAH, THEY'RE MEANS AND STANDARD ERRORS FOR
CATIONS BY DEPTH. SO, WHAT WE DID, IF WE
COLLECTED TWO CORES FROM 2B, THIS IS THE AVERAGE
FOR THE DEPTHS, LIKE AVERAGES OF THE TWO.
AND I'M NOT SURE WHAT THIS IS. OKAY, THESE
ARE SOME MORE DATA. THIS IS ACTUALLY IRON AND
MANGANESE. THIS GOES ALONG WITH THIS, AND I'D
HAVE TO ACTUALLY LOOK CLOSER TO SEE HOW THEY
DIFFER.
Q. LET ME ASK YOU THIS, DR. CRAFT, ARE YOU ABLE TO
TAKE YOUR DISKS, WHICH YOU HAVE ALSO PRODUCED FOR
US, AND MATCH THEM WITH THESE FOLDERS EASILY? I
MEAN, I'M NOT ASKING YOU TO GO, LIKE---
A. NOT REALLY VERY READILY. I MEAN, I CAN FIND -- IF
DR. CRAFT PAGE 16
I HAVE SOMETHING HERE AND I NEED TO PRINT IT OUT,
I CAN USUALLY FIND IT IN FIVE OR TEN MINUTES.
Q. ALL RIGHT.
A. SOMETIMES I CAN GO RIGHT TO IT.
Q. BUT YOU WOULD HAVE TO HAVE THOSE ALL, OR YOU WOULD
GO TO THE HARD DRIVE AND JUST CALL THEM UP, AND
PLAY WITH IT?
A. RIGHT. BUT SOME STUFF I'VE WORKED WITH MORE
RECENTLY THAN OTHER STUFF, SO, YOU KNOW, I MAY
HAVE TO GO SPEND A LITTLE BIT OF TIME LOOKING.
THAT'S IT.
Q. THE NEXT FOLDER, DR. CRAFT, IS ALSO LABELED N AND
P, AND INSIDE THAT FOLDER WE HAVE CRAFT EXHIBITS
NUMBER FIVE, SIX AND SEVEN. I WOULD ASK YOU TO
PLEASE IDENTIFY IN SEQUENCE NUMBER FIVE.
A. OKAY. NUMBER FIVE IS THE MANUSCRIPT THAT HAS BEEN
ACCEPTED BY ECOLOGICAL APPLICATIONS ON PEAT
ACCRETION AND NUTRIENT ACCUMULATION IN THE
NORTHERN AND CENTRAL EVERGLADES.
Q. ECOLOGICAL APPLICATIONS IS A SCIENTIFIC---
A. IT'S A JOURNAL, RIGHT.
Q. OKAY. ALL RIGHT. NOW, CAN YOU TELL ME WHICH
CHAPTER -- IS THIS ONE OF THE CHAPTERS IN THE
ANNUAL REPORTS?
DR. CRAFT PAGE 17
A. THIS MAINLY CAME FROM, I THINK, THE FIRST ANNUAL
REPORT, THE '90.
Q. OKAY.
A. BUT, YOU KNOW, THIS IS MUCH MORE REFINED DATA.
Q. ALL RIGHT.
A. THIS IS THE DISTILLED STUFF HERE.
Q. BUT IT'S THE SAME DATA, JUST WORKED FOR---
A. TO MAKE IT ACCEPTABLE FOR JOURNAL PUBLICATION,
BASICALLY.
Q. ALL RIGHT. CAN YOU TELL ME JUST GENERALLY HOW
MANY DIFFERENCES WE WILL FIND BETWEEN YOUR FIRST
ANNUAL REPORT AND THAT MANUSCRIPT?
A. WHAT DO YOU MEAN BY DIFFERENCES?
Q. DO YOU COME TO DIFFERENT CONCLUSIONS?
A. OH, NO, SAME CONCLUSIONS.
Q. OKAY. IS THE FORMAT JUST SIMPLY IN MORE OF AN
ACCEPTABLE FORMAT TO A---
A. IT'S CON---
Q. ---SCIENTIFIC JOURNAL?
A. ---IT'S CONDENSED---
Q. OKAY.
A. ---BECAUSE A LOT OF TIMES REPORTS, YOU CAN WRITE
HUNDREDS OF PAGES; BUT WHEN YOU SEND THAT TO A
JOURNAL, THEY'RE GOING TO MAKE YOU CUT IT DOWN TO
DR. CRAFT PAGE 18
TEN PAGES. SO, THAT'S BASICALLY WHAT HAS HAPPENED
HERE.
Q. OKAY. IT'S A CONDENSED VERSION?
A. (NODS AFFIRMATIVELY.)
Q. HAVE THERE BEEN ANY REVISIONS AND DRAFTS OF THAT?
A. WELL, YEAH, THROUGHOUT THE -- SURE, THERE'S BEEN
LOTS; YOU KNOW, IT'S BEEN REVISED TWO OR THREE
TIMES.
Q. DID YOU RETAIN THOSE REVISIONS AND DRAFTS?
A. NO.
Q. OKAY. YOU -- WERE THERE ANY -- HAVE THERE BEEN
ANY REVIEWS, TO DATE, OF IT?
A. YOU MEAN -- WHAT KIND OF REVIEW, OR HOW DO YOU
MEAN?
Q. ANY KIND OF REVIEW. HAS ANYONE REVIEWED---
A. SURE.
Q. ---THAT DOCUMENT FOR YOU?
A. IT HAS BEEN REVIEWED BY THREE ANONYMOUS REVIEWERS
WITH THE JOURNAL, AND WE HAD IT REVIEWED BY A
COUPLE OF PEOPLE IN THE WETLANDS CENTER BEFORE WE
SENT IT OUT.
Q. WHERE ARE THOSE ANONYMOUS REVIEWS?
A. I DON'T HAVE THEM ANYMORE.
Q. YOU DO NOT RETAIN THOSE ANONYMOUS REVIEWS OF YOUR
DR. CRAFT PAGE 19
PAPER?
A. HUH-UH (NO). ONCE I MAKE THE CHANGES AND SEND IT
BACK OUT, THAT KIND OF STUFF, THAT'S AN ITERATION,
IT'S IN THE PAST.
Q. WHEN DID YOU GET RID OF THOSE ANONYMOUS REVIEWS,
DR. CRAFT?
A. WELL, THEY OCCUR AT WHATEVER TIME I MAKE THE
CHANGES, AND SEND IT ON.
Q. WHEN WAS THE LAST CHANGE MADE?
A. I BELIEVE THAT WAS PROBABLY BACK IN AUGUST.
Q. AND DID YOU DISPOSE OF THAT ANONYMOUS REVIEW IN
AUGUST?
A. IT'S GONE, YEP.
Q. BUT DID YOU DISPOSE OF IT IN AUGUST?
A. WHAT DO YOU MEAN DISPOSE? EXACTLY WHAT---
Q. DID YOU GET RID OF IT; DID YOU THROW IT AWAY IN
AUGUST?
A. DID I PUT IT IN THE TRASH, OR IN THE RECYCLING
BIN?
Q. ANYWHERE.
A. YEAH, IT WENT TO THE RECYCLING BIN.
Q. IN AUGUST?
A. I THINK SO.
Q. THEN LET ME BE MUCH MORE EXPLICIT, DR. CRAFT. DID
DR. CRAFT PAGE 20
YOU THROW AWAY IN ANY MANNER, SHAPE OR FORM, ANY
OF THE REVIEWS FOLLOWING THE TIME YOU RECEIVED THE
UNITED STATES SUBPOENA---
A. NO.
Q. ---DUCES TECUM?
A. NO. THIS IS -- THIS WAS THREE MONTHS AGO.
Q. WERE ALL THREE OF THEM DISPOSED OF IN AUGUST?
A. ALL THREE WHAT?
Q. YOU SAID THERE WERE THREE ANONYMOUS REVIEWS.
A. WELL, THAT, THEY CAME BACK A YEAR AGO OR MORE.
Q. THE THREE DID?
A. YEAH, OR BACK WHEN -- IT'S BEEN SIX OR EIGHT
MONTHS.
Q. DID YOU DISPOSE OF THOSE IN THE CLOSE TIME FRAME
OF THE TIME YOU RECEIVED THEM?
A. YEAH, WITHIN A MONTH. AFTER I MAKE THE CHANGES, I
SEND IT BACK AND MOVE ON.
Q. ALL RIGHT. IT'S BEEN ACCEPTED, I ASSUME, YOU
SAID?
A. YES.
Q. OKAY. AND DO YOU HAVE ANY IDEA WHEN IT WILL BE
PUBLISHED?
A. 1993.
Q. IS THAT AN ANNUAL PUBLICATION?
DR. CRAFT PAGE 21
A. NO. IT'S FOUR OR SIX TIMES A YEAR, BUT IT'S A --
YOU KNOW, IT'S A WAYS AWAY; IT WAS ONLY ACCEPTED
THREE MONTHS AGO.
Q. OKAY. ALL RIGHT. THE NEXT DOCUMENT, CRAFT
EXHIBIT NUMBER SIX.
A. THIS IS JUST DATA USED IN THE MANUSCRIPT, AND
THERE'S LOTS OF DIFFERENT THINGS IN HERE.
Q. ARE THOSE -- THOSE ARE EFFORTS AT REFINING THE
DATA FOR THAT MANUSCRIPT?
A. RIGHT. THIS IS JUST LOOKING AT THE DATA MORE IN
DEPTH, DECIDING WHAT TO PUT IN THE PAPER.
Q. OKAY. ALL RIGHT. CRAFT EXHIBIT NUMBER SEVEN.
A. THESE ARE THE FIGURES -- WHICH I WOULD LIKE Y'ALL
TO TAKE VERY GOOD CARE OF SINCE I BROUGHT ALL MY
DOCUMENTS -- THAT GO TO THE MANUSCRIPT.
Q. UH-HUH (YES).
A. SO, THESE REQUIRE -- EVENTUALLY, THE JOURNAL WILL
ASK ME FOR THEM, AND I WILL BE HAPPY TO SEND THEM
THIS AS LONG AS THEY DON'T HAVE ANY SMUDGE MARKS
ON THEM.
Q. OKAY. I THINK -- I WOULD SUGGEST THAT YOU PUT A
YELLOW STICKY ON THE FRONT OF THAT, AND TELL THEM
TO BE ESPECIALLY CAREFUL. I---
A. WELL, MAYBE I'LL COPY THESE MYSELF JUST TO BE SURE
DR. CRAFT PAGE 22
THAT NOBODY SCREWS UP.
Q. DO YOU HAVE THE ABILITY OVER LUNCH OR SOMETHING?
I MEAN, I HATE TO BE RESPONSIBLE FOR PEOPLE I
DON'T EVEN KNOW NOT SMUDGING UP.
A. ALL RIGHT. BUT SINCE YOU'RE ASKING FOR THE
DOCUMENTS, YOU OUGHT TO BE RESPON -- OR SOMEBODY
OTHER THAN ME OUGHT TO BE RESPONSIBLE.
Q. THAT'S FINE, I'LL BE RESPONSIBLE. JUST LEAVE
THEM THERE, DR. CRAFT. THAT'S ALL IN THAT FILE
THERE.
A. THAT'S IT. I MEAN, IF YOU WANT, I CAN MAYBE COPY
THEM TONIGHT. BUT, YOU KNOW, THOSE I HAVE HIGH
PRIORITY FOR.
Q. IF IT'S ACCEPTED, WHY HAVE THE FIGURES NOT YET
BEEN SENT?
A. BECAUSE THEY ASK FOR THEM ONCE I THINK THE
MANUSCRIPT GETS TYPESET. THEY DON'T WANT YOU TO
SEND THE FIGURES UNTIL THEY REQUEST THEM.
Q. THE NEXT GREEN FOLDER HAS BEEN LABELED EVERGLADES
-- IS LABELED -- EXCUSE ME -- EVERGLADES
COORDINATES, AND IT WILL BE CRAFT EXHIBIT NUMBER
EIGHT. I'D ASK YOU TO IDENTIFY THAT, PLEASE,
DR. CRAFT.
A. WELL, THESE ARE THE LATITUDE AND LONGITUDE
DR. CRAFT PAGE 23
COORDINATES FOR THE VARIOUS SOIL CORES I'VE
COLLECTED OVER THE PAST THREE OR THREE AND A
HALF YEARS.
Q. ARE THESE AT ALL EXPERIMENTAL SITES?
A. THESE ARE AT SITES I'VE WORKED ON, THAT I'VE BEEN
INVOLVED IN.
Q. WHICH INCLUDE?
A. WELL, THE GRAY -- WELL, BASICALLY, WHAT WE'VE
TALKED ABOUT UP TO NOW. THAT'S CONSERVATION AREAS
2A, 2B, 3A AND THE GRADIENT.
Q. ALL RIGHT. THIS IS THE GRADIENT STUDY, THE
FERTILIZER STUDY, AND THEN ALL THE N AND P WORK
THAT YOU DID IN THE BEGINNING?
A. NOT THE FERTILIZER STUDY.
Q. YOU'VE DONE NO WORK AT THE FERTILIZER STUDY?
A. I HAVE TAKEN NO PEAT CORES TO MEASURE ACCRETION AT
THE FERTILIZER STUDY.
Q. SO, THE LONGITUDE AND LATITUDE FOR THOSE ARE NOT
PRESENT THERE?
A. NO.
Q. OKAY. ARE THEY LABELED AS TO WHICH WORK YOU WERE
DOING?
A. WELL, THEY GIVE, AGAIN, IDENTIFYING THINGS. 10A
OBVIOUSLY IS A TRANSECT SOUTH OF THE 10A STRUCTURE
DR. CRAFT PAGE 24
ON THE GRADIENT. 10C, 10D, THE SAME FOR THEM.
CONSERVATION AREA 3A, PRETTY STRAIGHTFORWARD. THE
SAME SORTS OF THINGS. I THINK THE OLD DATA IS IN
THE BACK HERE.
Q. OKAY. HOW ARE YOUR COORDINATES DETERMINED,
DR. CRAFT?
A. WELL, ORIGINALLY, THEY WERE DETERMINED BY LORAN-C.
RECENTLY, WE HAVE REMEASURED THEM USING THE GPS
SYSTEM.
Q. OKAY. AND SO I TAKE IT BOTH LORAN AND GPS ARE
REFLECTED THERE?
A. YEAH.
Q. THE NEXT GREEN FOLDER IS 2A PRELIMINARY DATA. I'M
GOING TO ASK YOU TO PLEASE IDENTIFY CRAFT EXHIBIT
NUMBER NINE. I HAVE A QUESTION REGARDING THE GPS.
WAS THAT DIFFERENTIAL GPS?
A. AS OPPOSED TO WHAT KIND OF GPS?
Q. WELL, DO YOU UNDERSTAND WHAT DIFFERENTIAL GPS IS?
A. NO, I DON'T KNOW WHAT IT IS.
Q. OKAY.
A. BUT IS THERE A DIFFERENCE?
Q. I'M DON'T KNOW, DR. CRAFT, I'M NOT A SCIENTIST;
I'M A LAWYER.
A. UH-HUH (YES).
DR. CRAFT PAGE 25
Q. WHAT IS THE ACCURACY, DR. CRAFT, OF THE GPS
SYSTEM, PLUS OR MINUS?
A. I DON'T KNOW THE ANSWER TO THAT.
Q. OKAY. DID YOU DO THE GPS WORK, YOURSELF?
A. NO, WE HAD SOMEBODY DO THAT FOR US.
Q. WHO WAS THAT?
A. WHOEVER THE HELICOPTER PILOT WAS WHO TOOK US OUT.
Q. OKAY. IS THIS A DIFFERENT PERSON EACH TIME?
A. IT CAN BE.
Q. ALL OKAY. RIGHT. HAVE WE FINISHED WITH CRAFT
EXHIBIT NUMBER EIGHT?
A. I DON'T BELIEVE YOU'VE ASKED ME ABOUT THIS ONE
YET---
Q. OKAY. THAT'S NUMBER NINE---
A. ---THIS IS NINE.
Q. ---I'VE HANDED YOU NUMBER NINE. OKAY. LET'S
IDENTIFY CRAFT EXHIBIT NUMBER NINE, PLEASE.
A. THESE WERE PRELIMINARY CORES COLLECTED SOUTH OF
THE HILLSBORO CANAL, I BELIEVE, IN 1989, THE FALL
OF 1989, BUT I'M NOT A HUNDRED PERCENT SURE ON
THAT.
Q. ARE THEY IDENTIFIED WITHIN THE DOCUMENT AS TO
LOCATION?
A. EXCUSE ME?
DR. CRAFT PAGE 26
Q. CAN YOU TELL WHERE THE PRELIMINARY CORES WERE,
FROM THE DOCUMENTS?
A. FROM THE COORDINATES, YOU CAN GET THAT
INFORMATION.
Q. ALL RIGHT. IS THERE ANY IDENTIFICATION AS TO 3A,
3B, ETCETERA?
A. THIS IS ALL 2A.
Q. ALL RIGHT. DR. CRAFT, WHO DID THE CESIUM DATA
THAT'S ON HERE?
A. I DID.
Q. OKAY. I'M LOOKING AT A GREEN FOLDER THAT SAYS,
VEGETATION, AND I WOULD ASK YOU TO IDENTIFY CRAFT
EXHIBIT NUMBER TEN AND CRAFT EXHIBIT NUMBER ELEVEN
THAT ARE CONTAINED IN IT, DR. CRAFT.
A. OKAY. THIS IS A SPECIES COMPOSITION ALONG---
Q. IS THAT CRAFT NUMBER TEN?
A. RIGHT. BOTH OF THESE ARE. THEY ARE THE
VEGETATION SPECIES COMPOSITION IN THAT ENRICHED
AREA, OR ACTUALLY ALONG A GRADIENT THROUGH THE
ENRICHED AREA TO THE UNENRICHED AREA---
Q. AND---
A. ---THIS ONE SAYS 1992, SO THIS WAS DONE THIS
SUMMER. AND I HAVE THE DATE SOMEWHERE IN HERE; IT
WAS DONE IN MAY OF '92.
DR. CRAFT PAGE 27
Q. THIS IS IN WATER CONSERVATION AREA 2A?
A. 2A, RIGHT.
Q. IS THIS ALL 2A IN CRAFT TEN AND ELEVEN?
A. YES.
Q. OKAY.
A. I'M PRETTY SURE, LET ME LOOK. YEAH. SAME
INFORMATION, BUT DONE TWO YEARS PREVIOUSLY IN
1990.
MR. BURGESS: 1990 IS WHAT,
EXHIBIT ELEVEN?
WITNESS: CORRECT.
Q. (BY MS. PONZOLI) ALL RIGHT. SPECIES COMPOSITION
ENRICHED AND UNENRICHED ALONG THE GRADIENT '90 AND
'92, RIGHT?
A. RIGHT.
Q. OKAY. THE GREEN FOLDER NEXT IS -- GOING BACK TO
TEN AND ELEVEN, DR. CRAFT, SPECIES OF WHAT?
A. PLANTS -- PLANT MACROPHYTES.
Q. ALL RIGHT. NO PERIPHYTON, NOTHING LIKE THAT?
A. NO.
Q. OKAY. THE GREEN FOLDER NEXT IS THE GRADIENT DATA,
AND INSIDE OF THAT GREEN FOLDER WE HAVE CRAFT
EXHIBITS TWELVE, THIRTEEN, FOURTEEN AND FIFTEEN,
AND I WOULD ASK YOU TO PLEASE IDENTIFY BY EXHIBIT
DR. CRAFT PAGE 28
EACH MANILLA FOLDER, STARTING WITH CRAFT COMPOSITE
EXHIBIT NUMBER TWELVE.
A. OKAY. THESE ARE SOME CORES THAT WE COLLECTED LAST
SUMMER ALONG THE GRADIENT IN CONSERVATION AREA 2A.
THEY'RE TO SORT OF FOLLOW UP OUR INITIAL SAMPLES
THAT WERE COLLECTED IN 1990.
Q. THESE ARE SOIL CORES, DR. CRAFT?
A. RIGHT.
Q. OKAY. DID YOU PULL THESE YOURSELF?
A. UH-HUH (YES).
Q. DID YOU HAVE ASSISTANCE IN DOING THEM?
A. YES.
Q. WHO WAS THAT?
A. IT WAS, I BELIEVE, LORI SUTTER.
Q. OKAY. IS THAT ALL THAT'S IN CRAFT EXHIBIT NUMBER
TWELVE?
A. RIGHT.
Q. CRAFT EXHIBIT NUMBER THIRTEEN, WHAT IS -- CAN YOU
IDENTIFY THAT?
A. THESE ARE GRAPHS OF THE CESIUM DATA FROM THE 1990
CORES ON THE GRADIENT---
Q. OKAY.
MR. BURGESS: I THINK THIS MIGHT
BE FOR ONE OF US.
DR. CRAFT PAGE 29
(THEREUPON, MR. BURGESS
LEAVES THE ROOM.)
A. ---WE GET SOME PRETTY NICE PROFILES SOMETIMES;
SOMETIMES NOT SO NICE.
MS. PONZOLI: DR. CRAFT, I THINK MR.
BURGESS WOULD LIKE ME TO WAIT UNTIL HE
RETURNS.
WITNESS: OKAY.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER, AND
A SHORT BREAK WAS TAKEN.)
MS. PONZOLI: SHALL WE GO BACK ON
THE RECORD.
EXAMINATION BY MS. PONZOLI CONTINUES:
Q. WE HAD FINISHED -- HAD WE FINISHED NUMBER -- CRAFT
EXHIBIT NUMBER THIRTEEN, DR. CRAFT?
A. RIGHT, THE CESIUM.
Q. OKAY. WOULD YOU IDENTIFY CRAFT EXHIBIT NUMBER
FOURTEEN, PLEASE.
A. THIS IS A FILE WHERE WE'RE TRYING TO JUST RELATE
OUR PHOSPHORUS ACCUMULATION DATA ON THE GRADIENT
TO PHOSPHORUS CONCENTRATIONS IN SURFACE WATER.
DR. CRAFT PAGE 30
Q. AND IS THIS 1992 DATA?
A. YES.
Q. OKAY. AND THERE IS NO 1990 REFLECTED IN THERE?
A. DEFINITELY NOT. THIS IS ALL---
Q. OKAY. AND IS THAT RAW DATA THAT'S IN THERE?
A. IT'S RAW AND MEDIUM DATA.
Q. AND I SAW SOME GRAPHS OR CHARTS, ARE THOSE
CONSIDERED MEDIUM?
A. WELL, THESE ARE ACTUALLY SOME DISTRICT DOCUMENTS
THAT I HAVE COPIES OF.
Q. OH, ALL RIGHT.
A. SO -- BUT THEY RELATE TO THIS PARTICULAR QUESTION.
Q. OKAY. ALL RIGHT, THANK YOU. ALL RIGHT. CRAFT
EXHIBIT NUMBER FIFTEEN IS WHAT?
A. THESE ARE MORE GRADIENT CORES COLLECTED THIS
SUMMER. AND WE'RE JUST IN THE PROCESS OF
ANALYZING THESE, BUT WE DO HAVE THE CESIUM DATA
ON THEM, SO, THAT'S THE ONLY THING IT REALLY HAS
IN HERE.
Q. OKAY. ALL RIGHT. AND THAT FINISHES THAT GREEN
FOLDER?
A. RIGHT.
MS. PONZOLI: ALL RIGHT. IT HAS BEEN
AGREED AMONG COUNSEL THAT WE WILL MOVE NOW TO
DR. CRAFT PAGE 31
THE DISKS THAT DR. CRAFT HAS PROVIDED TODAY
IN ORDER TO IDENTIFY THOSE DISKS AND SO THAT
WE CAN SEND THEM OUT TO BE DUPLICATED FOR THE
VARIOUS PARTIES WHO WOULD LIKE A COPY, AND
THEY CAN BE RETURNED TO DR. CRAFT AS RAPIDLY
AS POSSIBLE.
WITNESS: HOW FAST WILL THAT BE, CAN YOU
GIVE ME AN -- I MEAN, WE'RE NOT---
MR. BURGESS: TWENTY-FOUR HOURS.
WITNESS: OKAY. SOUNDS GOOD TO ME.
MR. McCAUGHAN: TOMORROW MORNING.
WITNESS: THAT SOUNDS GOOD. OKAY.
Q. (BY MS. PONZOLI) I'M HANDING YOU, DR. CRAFT, YOUR
DISKETTE FILE, AND BECAUSE I WON'T BE HANDING YOU
EACH INDIVIDUAL DISK, YOU SHOULD READ INTO THE
RECORD BOTH THE DIVIDERS, SUCH AS THE SAS DATA,
AND THEN IF YOU WILL, PLEASE, JUST READ INTO THE
RECORD THAT -- CRAFT EXHIBIT NUMBER THIRTY-SIX,
READ THE TITLE OF YOUR DISK. IF IN ORDER FOR US
TO UNDERSTAND WHAT IS ON YOUR DISK, IT WOULD BE
NECESSARY FOR YOU TO FURTHER IDENTIFY IT, THEN I
WOULD ASK THAT YOU PLEASE DO THAT, AND JUST WORK
YOUR WAY THROUGH THE DISKETTE FILE, AND THEN WE'LL
TURN IT OVER TO THE PARALEGALS TO HAVE IT
DR. CRAFT PAGE 32
DUPLICATED.
A. OKAY. SO, YOU WANT ME TO IDENTIFY THE DIVIDER
AND---
Q. AND THE DISK THAT---
A. ---THE DISKS.
Q. THAT'S EXACTLY RIGHT. THE DISKS THAT FALL BEHIND
IT.
A. OKAY, THAT'S FINE. I UNDERSTAND.
Q. ALL RIGHT.
A. OKAY.
Q. SO, YOU WILL BE DOING ESSENTIALLY MOST OF THE
TALKING.
A. THE FIRST DIVIDER IS SAS, ET AL. THESE ARE SAS
DATA SETS, MAYBE SOME PROGRAMS. AND THESE -- ALL
THIS DATA BASICALLY RELATES TO THE FERTILIZER
STUDY.
Q. YES, SIR.
MR. McCAUGHAN: GO THROUGH IT.
A. THE FIRST DISK IS SELF-EXPLANATORY, BIOMASS DATA.
THIS IS NUMBER THIRTY-SIX.
Q. FOR THE RECORD -- YOU WILL BE SURPRISED,
DR. CRAFT, WHEN YOU READ YOUR DEPOSITION, IT
DOESN'T COME OUT THE WAY YOU THINK -- YOU NEED TO
SAY CRAFT EXHIBIT NUMBER THIRTY-SIX IS WHATEVER IT
DR. CRAFT PAGE 33
WAS.
A. OKAY. I'M NOT -- THIS IS MY FIRST EXPERIENCE SO
YOU'LL HAVE TO BEAR WITH ME.
Q. CERTAINLY. AND I'M NOT COMPLETELY FAMILIAR WITH
THIS METHOD OF REPORTING, BUT I AM TOLD BY THE
COURT REPORTER THAT YOU AND I ARE TALKING
SIMULTANEOUSLY AND THAT IT'S GOING TO CAUSE LARGE
PROBLEMS ON THE RECORD, SO, WE SHOULD BOTH OF US
TRY TO AVOID THAT.
A. OKAY. FIRST DISK, NUMBER THIRTY-SIX, BIOMASS
DATA, WATER LEVEL DATA, pH OXYGEN CONDUCTIVITY
DATA, ALL RELATING TO THE FERTILIZER STUDY.
Q. OKAY.
A. NUMBER THIRTY-SEVEN IS, AGAIN, WATER LEVEL, pH
OXYGEN CONDUCTIVITY DATA. IT'S PROBABLY A PART OF
THE DATA SET NUMBER IN NUMBER SIX, MAYBE LIKE SOME
OF THE EARLY SAMPLES WE COLLECTED.
THIRTY-EIGHT IS A -- I THINK RELATES TO THE
FERTILIZER BIOMASS DATA.
THIRTY-NINE IS WATER CHEMISTRY DATA,
PHOSPHATE, AMMONIUM, NITRATE. ALL THIS IS IN THE
FERTILIZER STUDY.
FORTY IS THE SAME AS THIRTY-NINE, MORE
PHOSPHATE, MORE AMMONIUM, MORE NITRATE.
DR. CRAFT PAGE 34
Q. ARE THERE TIME FRAMES ASSOCIATED WITH THESE
DR. CRAFT?
A. I BELIEVE THAT THE DATA SET WAS SO BIG WE HAD TO
SAVE IT ON TWO DISKS. SO THE FIRST ONE MAY HAVE,
LIKE, TWELVE MONTHS OF DATA, AND THE NEXT ONE MAY
HAVE THE NEXT EIGHT MONTHS, OR SOMETHING LIKE
THAT.
Q. SO, THIRTY-NINE WOULD BE TWELVE MONTHS, AND
THEN---
A. WELL, I REALLY -- I'D HAVE TO LOOK AT THE DISK TO
ACTUALLY SEE. I MEAN, MY FEELING IS YOU COMBINE
THESE TWO AND YOU'LL HAVE THE WHOLE DATA SET.
Q. THIRTY-NINE AND FORTY?
A. RIGHT.
Q. OKAY.
A. FORTY-ONE, I THINK AGAIN IS -- THIS IS SORT OF
INTERMEDIATE WATER CHEMISTRY DATA THAT COMES OUT
OF THE INSTRUMENT THAT ANALYZES IT, AND THIS HAS
SOME MONTHS; IT LOOKS LIKE JULY OF '90 THROUGH
JANUARY OF '92.
FORTY-TWO, I'M NOT EXACTLY SURE WHAT'S ON IT,
BUT IT'S MORE, I THINK, INTERMEDIATE DATA, AND
IT'S ON PHOSPHATE, AMMONIUM AND NITRATE IN THE
FERTILIZER STUDY.
DR. CRAFT PAGE 35
Q. OKAY. AND WAS FORTY-ONE ON THE FERTILIZER STUDY,
ALSO?
A. YES. ALL OF THESE DISKS UP TO NOW ARE FERTILIZER
STUDY.
Q. OKAY.
A. ARE YOU READY?
Q. I'M READY.
A. OKAY. SO, NOW WE GO TO THE SOILS DATA, AND THIS
IS THE CORES WITH THE PEAT ACCRETION AND THE
NUTRIENT CONCENTRATIONS. THE FIRST CORE IS
EVERGLADES, AND I BELIEVE THIS IS THE EARLIEST
DATA I COLLECTED. IT HAS THE DATA -- THE DATA ON
HERE RELATES TO THE N AND P FOLDERS.
Q. THIS IS 1990 IN ALL PROBABILITY?
A. YEAH. THAT'S NUMBER FORTY-TWO.
NUMBER FORTY-THREE IS CALLED EVERGLADES TWO.
I THINK IT HAS SOME OF THE '90 DATA ON IT, AND
IT HAS THOSE -- SOME OF THOSE EARLY CORES WE
COLLECTED ON THE GRADIENT FROM 19 -- AGAIN, 1990,
I THINK.
MR. KILLINGER: COULD WE BACK UP FOR
A SECOND, SUZAN?
MS. PONZOLI: YES.
MR. KILLINGER: I THINK THAT WE HAD
DR. CRAFT PAGE 36
A FORTY-TWO "A."
MS. PONZOLI: OH, I'M SORRY.
WITNESS: THERE'S A FORTY-THREE. THERE
IS A FORTY-TWO "A."
MS. PONZOLI: IT'S THE DIVIDER ITSELF, I
THINK, OR SOMETHING.
WITNESS: MAYBE THEY'RE DIVIDERS.
MR. KILLINGER: NO.
WITNESS: WELL, LET'S BACK UP HERE.
MR. KILLINGER: THE EVERGLADES DISK, I
BELIEVE, IS FORTY-TWO "A."
WITNESS: IT IS.
MR. KILLINGER: I JUST WANTED TO MAKE
THAT CLEAR ON THE RECORD. THAT'S ALL.
WITNESS: ALL RIGHT. OKAY.
Q. (BY MS. PONZOLI) I'M CONFUSED NOW. FORTY-TWO
WAS---
A. LET'S BACK UP.
Q. YEAH.
A. FORTY-TWO IS FERTILIZER STUFF, PHOSPHATE,
AMMONIUM, NITRATE.
WE GO TO SOILS NOW. AND FORTY-TWO "A" IS
CALLED EVERGLADES, AND IT'S THAT 1990 DATA.
Q. OKAY.
DR. CRAFT PAGE 37
A. FORTY-THREE IS EVERGLADES TWO, AND IT IS MORE 1990
DATA.
NUMBER FORTY-FOUR, CATIONS. AND THIS IS
THE BASE CATIONS AND METAL DATA FROM, AGAIN,
CONSERVATION AREAS 2A, 2B, 3A.
FORTY-FIVE IS THE GRADIENT WITH THE DATA FROM
THE THREE TRANSECTS, AND IT ALSO HAS SOME CESIUM
GRAPHS ON IT.
Q. AND THE DATE OF THE WORK ON FORTY-FOUR, DO YOU
RECALL?
A. LET ME BACK UP. AGAIN, THAT'S '90 DATA.
Q. THAT'S '90 DATA?
A. YEAH.
Q. AND THEN FORTY-FIVE IS?
A. IS '91 DATA.
Q. OKAY. THANK YOU.
A. ACTUALLY, I THINK FORTY-FOUR IS '89 AND '90 DATA.
Q. OKAY.
A. AND, LET'S BACK UP. AND FORTY-FIVE IS ACTUALLY
'90 DATA.
Q. OKAY. VERY GOOD.
A. OKAY. NUMBER FORTY-SIX, THESE WERE REPEATED CORES
THAT WE WENT BACK TO ON THE GRADIENT IN '91 AND
RE-SAMPLED SEVERAL LOCATIONS.
DR. CRAFT PAGE 38
OKAY, FORTY-SEVEN IS, I THINK, A DISK THAT
WE USED IN THE ANNUAL REPORT THIS YEAR
SPECIFICALLY RELATING TO THE GRADIENT STUDY.
Q. AND THIS IS JUST WHAT ON THE GRADIENT -- THIS IS
'92, AND, WHAT, ALL TYPES OF INFORMATION?
A. MAINLY SOILS. AND I THINK IT'S MAINLY THE PEAT
ACCRETION -- IT CORRELATES -- WELL, YEAH, IT'S
MAINLY THE PEAT ACCRETION DATA AND THE NUTRIENT
DATA.
OKAY, WE MOVE TO THE FERTILIZER DIVISION NOW.
NUMBER FORTY-EIGHT IS FERTILIZER, AND I BELIEVE
THIS HAS THE PROPOSAL ON IT.
FORTY-NINE IS ANNUAL REPORT, FERTILIZER, AND
THIS RELATES TO WHAT'S IN THIS YEAR'S ANNUAL
REPORT. THIS IS PROBABLY THE CHAPTER THAT GOES
ALONG WITH THAT. IT'S AN INTERMEDIATE STAGE, BUT
IT LED UP TO THAT.
Q. YOU CAN JUST KEEP GOING.
A. OKAY. NUMBER FIFTY, FERTILIZER STUDY. IT SAYS
"EVERGLADES NUTRIENT STUDY," BUT IT'S THE
FERTILIZER STUDY. AND THIS IS THE FIRST YEAR'S
BIOMASS DATA.
FIFTY-ONE IS MORE FERTILIZER. AND THIS IS
SOME OF THE INITIAL WATER CHEMISTRY DATA THAT WE
DR. CRAFT PAGE 39
STARTED TO LOOK AT, AND THIS IS FROM TWO OF THE
THREE SITES, SAWGRASS AND THE SLOUGH.
FIFTY-TWO IS MORE WATER FERTILIZER WATER
DATA, BUT THIS IS JUST FROM MIXED SITE.
Q. THESE ARE -- DID YOU SAY THESE WERE '92?
A. THIS IS PROBABLY '90 AND '91. THIS IS SOME OF THE
EARLY DATA.
Q. OKAY.
A. FIFTY-THREE JUST SAYS "FERT DATA," AND I WOULD
HAVE TO LOOK IN IT TO SEE WHAT'S ON IT.
Q. THAT'S FINE, IF YOU DON'T RECALL.
A. AND FIFTY-FOUR IS MORE WATER CHEMISTRY DATA,
AGAIN, AMMONIUM, NITRATE, PHOSPHATE FROM THE
FERTILIZER STUDY. AND IT LOOKS LIKE IT'S FROM
DATA SPECIFICALLY FROM LIKE AUGUST OF '91. AND
THERE MAY BE MORE ON IT.
Q. OKAY.
A. OKAY. WE'LL MOVE TO THE ANNUAL REPORT
SUBDIVISION. NUMBER FIFTY-NINE IS PROBABLY AN
INTERMEDIATE DRAFT OF WHAT I CONTRIBUTED TO THE
1991 REPORT.
MR. KILLINGER: FIFTY WHAT?
MR. BURGESS: FIFTY WHAT?
MS. PONZOLI: IT MUST BE FIFTY---
DR. CRAFT PAGE 40
WITNESS: FIFTY-FIVE.
MR. KILLINGER: YEAH, OKAY.
MS. PONZOLI: FIFTY-FIVE, YEAH.
WITNESS: I'M SORRY. YOU'VE GOT ALL
THESE CRAZY NUMBERS.
Q. (BY MS. PONZOLI) OKAY. SO, FIFTY-FIVE IS UNDER
THE ANNUAL REPORT, AND IT'S WHAT YOU CONTRIBUTED
TO 1990---
A. ONE.
Q. 1991.
A. FIFTY-SIX ARE THE GRAPHS THAT GO WITH THE 1991
ANNUAL REPORT.
Q. THEY'RE YOUR CONTRIBUTIONS?
A. RIGHT. FIFTY-SEVEN ARE MORE GRAPHS TO THE 1991
REPORT.
Q. AGAIN, YOURS?
A. RIGHT. ALL THIS STUFF IS MINE.
Q. ALL RIGHT. OKAY. YOU WOULD NOT BE DOING WORK FOR
OTHER PEOPLE, YOU WOULD NOT BE GRAPHING OTHER
PEOPLE'S WORK?
A. NO. HUH-UH (NO).
Q. OKAY.
A. FIFTY-EIGHT IS PROBABLY THE INTERMEDIATE DRAFT OF
THE ANNUAL REPORT FOR 1990.
DR. CRAFT PAGE 41
Q. INTERMEDIATE REPORT MEANING WHAT?
A. MEANING IT'S PROBABLY A ROUGH DRAFT. IT MAY EVEN
BE THE FINAL DRAFT. I'M NOT EXACTLY SURE. BUT A
LOT OF TIMES I WORK ON A DISK, AND THEN TRANSFER
IT TO THE HARD DRIVE FOR THE FINISHED COPY. BUT
IT MAY BE THE ACTUAL, YOU KNOW, VERBATIM OF WHAT'S
IN THAT REPORT THAT I CONTRIBUTED.
OKAY. WE GO TO SEMINARS. NUMBER FIFTY-NINE
JUST SAYS "SEMINARS." AND THESE ARE SLIDES --
COMPUTER GENERATED SLIDES OF -- FROM TALKS THAT I
HAVE GIVEN.
NUMBER SIXTY, SEMINARS TWO, MORE SLIDES, FROM
MORE SEMINARS.
Q. YOU DON'T RECALL WHICH ONES, YOUR SOCIETY OF
WETLANDS SCIENTIST, OR INTECOL, YOU'RE NOT SURE
WHICH?
A. YOU COULD LOOK AND SEE IN THE DISKS AND FIGURE --
YOU KNOW, AND EASILY FIGURE OUT WHAT GOES TO WHAT,
ESPECIALLY SINCE EACH OF THESE PROGRAMS PROBABLY
HAS A TITLE SLIDE TELLING YOU WHERE, YOU KNOW,
WHAT THE TALK WAS.
Q. OKAY.
A. SEMINARS THREE, AGAIN HAS MORE SEMINARS THAT I'VE
GIVEN, SLIDES FOR THEM.
DR. CRAFT PAGE 42
NUMBER SIXTY-TWO IS "SWS," AND THIS IS
PROBABLY THE SLIDES FOR THAT SOCIETY OF WETLANDS
SCIENTISTS TALK.
Q. SIXTY-TWO?
A. RIGHT. SIXTY-THREE SAYS DELTA GRAPH, AND THESE
ARE JUST A -- THIS IS A SOFTWARE PACKAGE THAT I
USE TO MAKE GRAPHS, AND IT PROBABLY HAS GRAPHS
FROM THE GRADIENT STUDY, AND FROM THE FERTILIZER
STUDY.
WE GO TO ANOTHER SUBDIVISION, MANUSCRIPTS.
NUMBER SIXTY-FOUR, THE "FERT MANUSCRIPT." THIS IS
THE DRAFT THAT'S SIMILAR TO WHAT'S IN CHAPTER
SEVEN, BUT IT'S PROBABLY BEEN -- IT'S BEEN REFINED
A LITTLE BIT IN HOPES TO SEND IT OUT TO A JOURNAL
SOON.
Q. OKAY. THAT ONE HAS NOT BEEN SUBMITTED FOR
PUBLICATION?
A. NO. HUH-UH (NO).
Q. OKAY.
A. NO, IT'S NOT READY TO GO. SIXTY-FIVE IS THE
GRADIENT MANUSCRIPT. AGAIN, IT'S BEEN REVISED
SOME AS COMPARED TO WHAT'S IN THE ANNUAL REPORT,
AND WE HOPE TO SEND THIS OUT TO A JOURNAL IN THE
NEAR FUTURE. SO IT'S A DRAFT, ALSO.
DR. CRAFT PAGE 43
Q. IS IT IN MORE FINAL FORM THAN THE NUMBER
SIXTY-FOUR?
A. THEY'RE REALLY ABOUT EQUAL. THEY'RE REALLY ABOUT
THE SAME STAGE. I NEED TO HAVE MY CO-AUTHORS LOOK
AT, REVIEW THEM, AND SEND IT OUT AFTER I CHANGE --
YOU KNOW, MAKE THE COMMENTS AND STUFF.
Q. OKAY.
A. SIXTY-SIX IS GRADIENT MANUSCRIPT TWO, AND THIS
PROBABLY HAVE SUPPORTING TABLES AND GRAPHS THAT GO
WITH THE GRADIENT.
SIXTY-SEVEN, N AND P, AND THIS RELATES TO THE
MANUSCRIPT -- THIS IS THE MANUSCRIPT THAT'S BEEN
ACCEPTED BY ECOLOGICAL APPLICATIONS. THE
MANUSCRIPT IS ON THIS N AND P DISK.
Q. AND THAT'S THE FINAL ONE THAT YOU PRODUCED IN HARD
COPY?
A. RIGHT. AND THE LAST, BUT NOT LEAST DISK, NUMBER
SIXTY-EIGHT, MORE N AND P, WHICH HAS THE
SUPPORTING THE GRAPHS AND TABLES AND THAT SORT OF
THING THAT GOES WITH THE MANUSCRIPT.
Q. AND THAT CONCLUDES YOUR DISKETTE FILE, DR. CRAFT?
A. THAT'S IT.
MS. PONZOLI: ALL RIGHT. I WOULD
SUGGEST WE GO OFF THE RECORD.
DR. CRAFT PAGE 44
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
MS. PONZOLI: I'D LIKE TO GO BACK ON
THE RECORD.
WE HAVE DECIDED OFF THE RECORD THAT
MR. KILLINGER, THE ATTORNEY FOR D.E.R. IS
WILLING, WHEN WE BREAK FOR LUNCH, TO DRIVE
THE ASPEN PARALEGAL, MR. ELSSWICK, OVER TO
OBTAIN THE DISKS AND DELIVER THEM TO THE
COPIER SERVICE, SO THERE'LL BE AS LITTLE
DELAY IN GETTING THEM TO THE COPIER AS
POSSIBLE.
Q. (BY MS. PONZOLI) DR. CRAFT, RETURNING TO THE HARD
COPY FILES THAT WE'VE BEEN IDENTIFYING. CRAFT
NUMBER FIFTEEN, I WOULD LIKE TO ASK YOU IF YOU
COULD TELL US WHERE THESE CORES WERE TAKEN THAT
ARE IN THAT EXHIBIT?
A. WELL, ACCORDING TO THE STATEMENT HERE, THEY WERE
TAKEN THREE-QUARTERS OF A KILOMETER BELOW THE
HILLSBORO CANAL, AND PARALLEL TO THE GATES.
Q. AND THERE WERE ONLY TWO OF THESE TAKEN, IS THAT
ACCURATE?
DR. CRAFT PAGE 45
A. THERE WERE THREE, BUT WE HAVEN'T GOT THE THIRD
ONE. WE DON'T HAVE ANY OF THE CESIUM DATA FOR
IT YET.
Q. OKAY. OKAY. DO YOU KNOW WHEN---
A. THAT'S VERY PRELIMINARY DATA RIGHT THERE. I MEAN,
YOU CAN'T DO ANYTHING WITH IT BECAUSE IT'S AN
INCOMPLETE DATA SET.
Q. DO YOU KNOW WHEN THE OTHER WILL BE ARRIVING?
A. NOT FOR A WHILE, BECAUSE OUR GAMMA COUNTER IS
BROKE, AND I'VE GOT TO PROBABLY GET IT FIXED,
WHICH WILL TAKE A COUPLE OF MONTHS.
Q. OKAY.
A. SO, WE ARE DOWN, SO TO SPEAK, WITH RESPECT TO
THAT.
Q. ALL RIGHT. I THINK YOU HAVE USED THE TERM THAT
SOME OF THE DATA WAS WELL-PROCESSED, WAS THAT
ACCURATE?
A. I DON'T THINK I SAID THAT.
Q. OKAY. ALL RIGHT. I THINK YOU HAD INDICATED THAT
THERE MIGHT BE OLDER DATA. THERE CERTAINLY WAS
'90 DATA, '89 DATA---
A. SURE.
Q. ---WASN'T THERE?
A. YES.
DR. CRAFT PAGE 46
Q. OKAY. PRESENTLY WHAT ARE YOU ANALYZING IN THE
LABORATORY, WHAT DATA WOULD BE ANALYZING NOW?
A. WE ARE WORKING ON THE PHOSPHORUS CONCENTRATIONS
FOR THOSE CORES THAT YOU JUST ASKED ME ABOUT---
Q. OKAY.
A. ---AND THE VOLT DENSITY. THE CESIUM IS DOWN UNTIL
WE GET THE INSTRUMENT FIXED.
Q. OKAY.
A. ON THE FERTILIZER STUDY, WE HARVESTED 1992 DATA,
AND SO WE'RE IN THE PROCESS OF WEIGHING, GRINDING,
WEIGHING MORE, WORKING THAT DATA UP BASICALLY.
Q. OKAY. ARE THOSE -- THE WORKING OF THAT DATA, IS
THAT REFLECTED SOMEWHERE EITHER IN THESE GREEN
FOLDERS, OR IN THE NOTEBOOKS?
A. YEAH. IT'S -- WELL, YOU SAW THE GRADIENT DATA IN
THE FOLDER AS IT STANDS NOW---
Q. RIGHT.
A. ---THOSE THREE CORES -- OR TWO CORES. AND THE
FERTILIZER DATA FROM 1992 IS ACTUALLY IN ONE OF
THE NOTEBOOKS OVER HERE.
Q. OKAY. WE'LL IDENTIFY THAT AS WE GET TO IT.
A. OKAY.
Q. OKAY. ALL RIGHT. I'M GOING TO HAND YOU THE NEXT
GREEN FOLDER WHICH IS ENTITLED GRADIENT, AND IT
DR. CRAFT PAGE 47
CONTAINS CRAFT EXHIBITS SIXTEEN, SEVENTEEN,
EIGHTEEN, NINETEEN AND TWENTY, AND ASK YOU WOULD
YOU PLEASE, IN TURN, IDENTIFY THOSE COMPOSITE
EXHIBITS, BEGINNING WITH CRAFT EXHIBIT NUMBER
SIXTEEN.
A. OKAY. NUMBER SIXTEEN IS THE MANUSCRIPT FOR THE
GRADIENT, WHICH -- AS I TALKED ABOUT EARLIER -- IS
IN -- IT'S VERY SIMILAR TO WHAT'S IN CHAPTER
SEVEN, BUT IT'S BEING REVISED AND HOPED TO BE SENT
OUT IN THE NEXT MONTH, I HOPE.
NUMBER SEVENTEEN IS SOME SUPPORTING
INFORMATION TRYING TO CALCULATE THE AREA OF
ENHANCED PHOSPHOROUS ACCUMULATION IN CONSERVATION
AREA 2A.
Q. THE DATE?
A. EXCUSE ME?
Q. WHAT IS THE DATE, THE SUPPORTING INFORMATION? IS
THAT 1992 INFORMATION?
A. OH, THIS IS '92.
Q. OKAY, THANK YOU.
A. WELL, THE CORES ARE COLLECTED AS EARLY AS '90, BUT
IT'S -- YOU KNOW, IT'S IN THE -- 1992 IS OUR GOAL
TO GET IT ACTUALLY WRITTEN UP.
Q. OKAY.
DR. CRAFT PAGE 48
A. NUMBER EIGHTEEN, DATA AND STATISTICS THAT SUPPORT
THE MANUSCRIPT ON THE GRADIENT.
NUMBER NINETEEN IS THE RAW DATA FROM THE
GRADIENT THAT'S USED IN THE MANUSCRIPT, BUT THIS
IS THE REALLY, YOU KNOW, THE PRELIMINARY STUFF.
NUMBER TWENTY ARE THE FIGURES. AND, AGAIN, I
WOULD REQUEST THAT Y'ALL TAKE REAL GOOD CARE OF
THEM. AND THEY GO -- THEY'RE THE FIGURES THAT GO
WITH THE GRADIENT PAPER.
Q. OKAY. THE NEXT GREEN FOLDER IS "FIELD
FERTILIZATION." IT INCLUDES CRAFT COMPOSITE
EXHIBITS NUMBER TWENTY-ONE, TWENTY-TWO AND
TWENTY-THREE. I WOULD ASK YOU, PLEASE,
DR. CRAFT, TO IDENTIFY THOSE STARTING WITH NUMBER
TWENTY-ONE.
A. OKAY. THIS FALLS UNDER THE FERTILIZER STUDY.
NUMBER TWENTY-ONE IS THE PROPOSAL BEFORE THE WORK
WAS DONE, YOU KNOW, TO FIGURE OUT WHAT WE WERE
GOING TO DO.
NUMBER TWENTY-TWO IS AN ADDENDUM TO THE
PROPOSAL WRITTEN BY JAN VYMAZAL ON THE PERIPHYTON,
ON HOW HE WOULD MAYBE SAMPLE THE PERIPHYTON IN THE
FERTILIZER STUDY.
NUMBER TWENTY-THREE, BROMIDE TRACER DATA USED
DR. CRAFT PAGE 49
TO DETERMINE HOW LONG THE RETENTION TIME OF THE
FERTILIZER IN THE PLOTS. AND THAT'S IT.
Q. THE TRACER DATA, WAS THAT '90 THROUGH '92, OR JUST
'92, OR WHAT?
A. THAT WAS '90 AND '91.
Q. AND YOU DIDN'T DO THAT IN '92?
A. NO. THIS WAS DONE AT -- EARLY IN THE STUDY.
Q. OKAY. THE GREEN FOLDER NEXT IS THE FERTILIZER
DATA, THIS INCLUDES CRAFT COMPOSITE EXHIBIT
NUMBERS TWENTY-FOUR AND TWENTY-FIVE. I WOULD ASK
YOU, DR. CRAFT, TO PLEASE IDENTIFY THESE, STARTING
WITH NUMBER TWENTY-FOUR.
A. OKAY. THIS IS THE -- NUMBER TWENTY-FOUR IS THE
FERTILIZER BIOMASS DATA AND THE ASSOCIATED
STATISTICS. THIS IS MAINLY JUST THE STATISTICS.
Q. OKAY.
A. NUMBER TWENTY-FIVE IS THE FERTILIZER STUDY, AND
THIS IS LIKE TISSUE NUTRIENT CONCENTRATION DATA,
AND, AGAIN, A LOT OF COMPUTER OUTPUT.
Q. I DON'T UNDERSTAND WHAT YOU MEAN, "COMPUTER
OUTPUT"?
A. WELL, THE STATISTICAL -- THE RESULTS OF THE
STATISTICAL ANALYSES, LOOKING AT THE TISSUE
NUTRIENT DATA.
DR. CRAFT PAGE 50
Q. OKAY. AND THESE WOULD PROBABLY BE FOUND UNDER,
WHAT, YOUR SAS SET IN YOUR HARD DISK?
A. RIGHT.
Q. THE NEXT GREEN FOLDER IS ENTITLED "FERTILIZER MS."
I WOULD ASSUME THAT MEANS MANUSCRIPT FROM WHAT YOU
WERE EXPLAINING PREVIOUSLY. IT CONTAINS CRAFT
EXHIBITS NUMBERS TWENTY-SIX AND TWENTY-SEVEN, AND
ASK YOU TO IDENTIFY THOSE, PLEASE, DR. CRAFT.
A. OKAY. TWENTY-SIX IS THE DRAFT OF THE MANUSCRIPT
THAT'S STILL IN THE PROCESS OF REVISION. HOPE TO
SEND IT OUT IN THE NEXT MONTH, WHICH PROBABLY
WON'T HAPPEN, BUT.
TWENTY-SEVEN ARE THE ASSOCIATED FIGURES. AND
I'M REALLY CONCERNED HERE BECAUSE THIS IS A BLACK
AND WHITE PHOTOGRAPH HERE, AND I REMOVED ALL THESE
BECAUSE THEY'RE DUPLICATED---
Q. RIGHT.
A. ---IN OTHER FIGURES IN HERE. SO, I'D LIKE TO
TAKE -- TO KEEP THESE IN MY POSSESSION, BECAUSE,
AS YOU CAN SEE, ALL THIS IS---
Q. SURE.
A. ---IS THE SAME AS THIS.
Q. THAT'S FINE. I HAVE NO PROBLEM WITH THAT,
DR. CRAFT---
DR. CRAFT PAGE 51
A. OKAY. GOOD. FINE.
Q. ---I WOULD PREFER THAT YOU DO THAT.
A. YOU KNOW, THAT WAS AN OVERSIGHT BY ME.
Q. AS LONG AS WE HAVE A COPY OF SOMETHING, IT'S NOT
NECESSARY THAT WE HAVE---
MR. BURGESS: WHAT FILE FOLDER WERE
THE GRAPHS IN?
MR. KILLINGER: TWENTY-SEVEN.
WITNESS: TWENTY-SEVEN. WELL,
THEY'RE ACTUALLY BLACK AND WHITE PHOTOS.
THEY'RE FIGURES, TOO, BUT I DON'T -- YOU
KNOW, THEY'RE FINE FOR Y'ALL TO LOOK AT.
Q. OKAY. THE NEXT GREEN FOLDER IS ENTITLED
GREENHOUSE, AND IT CONTAINS CRAFT EXHIBITS NUMBERS
TWENTY-EIGHT AND TWENTY-NINE. I WOULD ASK YOU TO
IDENTIFY THOSE, PLEASE, DR. CRAFT.
A. NUMBER TWENTY-EIGHT, SAWGRASS AND PHOSPHOROUS
EXPERIMENT UNDERTAKEN BY LORI SUTTER, AND THIS IS
BASICALLY HER PROPOSAL TO DO THAT WORK, AND THEN
SOME -- AN ADDENDUM WRITTEN BY JAN VYMAZAL ON
MAYBE HOW TO SAMPLE THE PERIPHYTON IN THAT
STUDY.
Q. UH-HUH (YES).
A. AND TWENTY-NINE IS A SAWGRASS CATTAIL COMPETITION
DR. CRAFT PAGE 52
STUDY LOOKING AT THE EFFECTS OF SALINITY AND
HYDROPERIOD ON THE GROWTH OF THOSE TWO SPECIES.
Q. IS THAT THE HYDROLOGY EXPERIMENT THAT
DR. RICHARDSON IS DOING?
A. NO, THIS IS ANOTHER GREENHOUSE STUDY.
Q. OH, IS THIS THE OTHER GREENHOUSE STUDY THAT YOU
HAD PREVIOUSLY---
A. RIGHT. UNDERTAKEN, YEAH.
Q. YOU HAVE UNDERTAKEN IT?
A. NO, BY ANOTHER STUDENT.
Q. OKAY. WHO'S THE OTHER STUDENT?
A. JANE RAIKES.
Q. HOW DO YOU SPELL THAT LAST NAME?
A. R-A-I-K-E-S.
Q. OKAY. AND WHAT WAS THE DATE OF UNDERTAKING THIS
STUDY?
A. WELL, THE PROPOSAL HERE IS AUGUST OF '91, AND THE
STUDY WAS, I THINK, COMPLETED ABOUT TEN MONTHS
AGO, THE ACTUAL GREENHOUSE EXPERIMENT.
Q. OKAY. IS THAT GOING TO BE IN A FUTURE ANNUAL
REPORT, TO THE BEST OF YOUR KNOWLEDGE?
A. PROBABLY IN NEXT YEAR'S.
Q. OKAY. ARE THERE ANY OTHER DOCUMENTS ASSOCIATED
WITH THAT, OTHER THAN THE TWO YOU'VE POINTED
DR. CRAFT PAGE 53
OUT?
A. WITH THIS PARTICULAR FOLDER -- THE GREENHOUSE?
Q. THE SECOND GREENHOUSE, OTHER THAN MS. SUTTER'S.
A. OKAY. AND THEN THERE'S THE SALINITY STUFF WITH
JANE RAIKES IS THE OTHER.
Q. THAT'S WHAT I'M REALLY REFERRING TO. ARE THERE
ANY OTHER DOCUMENTS THAT REFER TO MS. RAIKES,
OTHER THAN THE PREVIOUS ONE YOU---
A. WELL, THERE'S TWO DOCUMENTS HERE. ONE, A
PROPOSAL---
Q. RIGHT.
A. ---TO DO THE GREENHOUSE EXPERIMENT.
Q. RIGHT.
A. AND, TWO, A -- I GUESS IT'S A CLASS PROJECT FOR A
COURSE SHE TOOK, AND SHE DID SOME WORK FOR ME,
AND SHE USED THE DATA FOR A CLASS PROJECT IN
WETLANDS ECOLOGY. BUT IT WAS SO GOOD THAT I KEPT
A COPY.
Q. OKAY. AND YOU BELIEVE THAT SOME VERSION OF THAT
MIGHT BE INCLUDED IN THE ANNUAL REPORT IN THE
FUTURE?
A. THE GREENHOUSE EXPERIMENT, BUT NOT THIS.
Q. RIGHT.
A. NOW, THIS IS SOME DATA THAT WE -- WILL APPEAR IN
DR. CRAFT PAGE 54
ONE OF OUR MANUSCRIPTS. THIS RELATES TO CATIONS
AND METALS, WHICH I HAVE SOME INFORMATION ON, BUT
I HAVEN'T DONE A WHOLE LOT WITH IT YET.
Q. OKAY. THE NEXT GREEN FOLDER IS ENTITLED
MANUSCRIPTS, AND IT CONTAINS CRAFT COMPOSITE
EXHIBITS NUMBERS THIRTY AND THIRTY-ONE, AND I'D
ASK YOU TO PLEASE IDENTIFY THESE, DR. CRAFT,
STARTING WITH NUMBER THIRTY-ONE.
A. NUMBER -- I'LL START WITH NUMBER THIRTY, SINCE
IT'S ON THE TOP.
Q. THIRTY, I'M SORRY.
A. THIS IS A MANUSCRIPT WRITTEN BY DR. RICHARDSON AND
MYSELF, SUBMITTED TO THIS PROCEEDINGS AT A MEETING
ON, I GUESS, CONSTRUCTED WETLANDS IN PENSACOLA,
FLORIDA.
Q. WHAT'S THE DATE OF THAT?
A. WELL, IT'S IN PRESS, 1992. AND IT SOUNDS LIKE
IT WILL BE IN PRESS IN 1993, PRETTY MUCH. UNLESS
BOB CAN GET HIS MEAT GRINDER TO GET TO WORK ON
THAT.
Q. ARE THERE ANY REVIEWS OF THAT PARTICULAR DRAFT,
DR. CRAFT?
A. I DON'T HAVE ANY. CURT -- DR. RICHARDSON IS
SENIOR AUTHOR ON THAT.
DR. CRAFT PAGE 55
Q. SO, IF THERE WERE ANY THERE, THAT DR. RICHARDSON
WOULD HAVE THOSE, YOU BELIEVE?
A. RIGHT, I -- YOU KNOW, I HAVEN'T SEEN. AND, TO BE
HONEST, I DON'T KNOW IF IT WAS EVEN PEER REVIEWED.
I REALLY DON'T KNOW.
Q. YOU HAVE NEVER READ A PEER REVIEW OF THAT
DOCUMENT?
A. NO.
Q. ALL RIGHT. CRAFT NUMBER THIRTY-ONE.
A. THIRTY-ONE ARE THE MONTHLY AND QUARTERLY REPORTS
FOR THE PROJECT. THERE'S ONE FOR SEPTEMBER OF
'92, JULY OF '92, APRIL OF '92, BASICALLY.
Q. HAVE YOU BEGUN TO PRODUCE MONTHLY REPORTS,
DR. CRAFT?
A. I THINK WE'VE PRODUCED ONE.
Q. ALL RIGHT. WAS IT A CUSTOM TO PRODUCE QUARTERLY
REPORTS PRIOR TO THAT?
A. YES.
Q. ARE YOU NOW MOVING TO MONTHLY REPORTS?
A. I DON'T GET INVOLVED IN THE DAY-TO-DAY GOINGS-ON
OF THIS KIND OF STUFF. BUT MY UNDERSTANDING IS,
IS WE HAVE TO WRITE MONTHLY, AND QUARTERLY, AND
ANNUAL REPORTS NOW. SO, WE'RE BECOMING LIKE THE
GOVERNMENT IN SOME RESPECTS.
DR. CRAFT PAGE 56
Q. WE WRITE THEM WEEKLY.
A. IT'S HARD TO GET WORK DONE.
Q. YEAH. A GREEN FOLDER ENTITLED -- WELL, IT SAYS
"SFWMD," WHICH I ASSUME TO BE THE SOUTH FLORIDA
WATER MANAGEMENT DISTRICT.
A. RIGHT.
Q. IT CONTAINS CRAFT COMPOSITE EXHIBITS THIRTY-TWO,
THIRTY-THREE, THIRTY-FOUR AND THIRTY-FIVE. I
WOULD ASK YOU TO IDENTIFY THOSE, PLEASE,
DR. CRAFT, BEGINNING WITH NUMBER THIRTY-TWO.
A. OKAY. NUMBER THIRTY-TWO SAYS "DISTRICT
EXPERIMENTS," AND THESE ARE, I GUESS, SOME DRAFTS
OF SOME OF THE IDEAS THE SOUTH FLORIDA WATER
MANAGEMENT DISTRICT'S BEEN KICKING AROUND TO DO
SOME CONTROL TYPE EXPERIMENTS.
Q. ARE THESE DOSING STUDY TYPE EXPERIMENTS, OR NOT?
A. I REALLY DON'T -- I'D HAVE TO READ THROUGH THESE
AGAIN---
Q. ALL RIGHT. THAT'S FINE.
A. ---TO SAY WHETHER THEY ARE OR NOT.
Q. OKAY.
A. DO I NEED TO SPECIFICALLY---
Q. NO. NO. YOU CAN JUST LEAVE THE FOLDER AS IT IS.
A. IT'S BASICALLY DISTRICT TYPE INFORMATION THAT'S
DR. CRAFT PAGE 57
PASSED ON TO ME TO SEE WHETHER I MIGHT, YOU KNOW,
HAVE SOME USE FOR IT OR NOT.
Q. OKAY.
A. OH, HERE'S A FOLDER I'M SURE EVERYBODY WOULD LIKE,
THE LITIGATION FOLDER.
Q. THAT'S CRAFT NUMBER THIRTY-THREE.
A. UH-HUH (YES).
Q. YOU HAVE THE UNIQUE DISTINCTION OF HAVING THE
SMALLEST LITIGATION FOLDER ON THIS CASE I HAVE
EVER SEEN.
A. AND I'D LIKE TO ADD THAT IT'S TOO BIG AS IT IS.
SO, APPARENTLY, HERE, I HAVE A COPY OF THE -- I
MEAN, I CAN'T EVEN READ MOST OF THIS STUFF, SO, IT
MAY BE A COPY OF THE -- I HAVE A COPY OF THE
SETTLE -- THE ORIGINAL SETTLEMENT. I'M NOT SURE
WHAT THIS IS. THIS MAY RELATE TO THE HEARING.
THIS IS A SETTLEMENT AGREEMENT, WHICH I GUESS HAS
NOT TRULY BEEN SETTLED YET, SO.
THIS FOLDER DOES NOT GET A LOT OF USE, AND
YOU COULD PROBABLY HAVE THIS ONE FOR MORE THAN
TWENTY-FOUR HOURS, SO.
NUMBER THIRTY-FOUR RELATES TO AGRICULTURAL
BEST MANAGEMENT PRACTICES, WHICH I THINK IT'S
IMPORTANT TO BE FAMILIAR WITH.
DR. CRAFT PAGE 58
Q. THE AG-BMP DOCUMENTS, FROM WHERE DID YOU OBTAIN
THOSE, DR. CRAFT?
A. I BELIEVE DR. RICHARDSON GAVE ME A COPY, AND I
THINK HE PROBABLY GOT THEM FROM THE DISTRICT, BUT
IT DOES HAVE SOME USEFUL KIND OF INFORMATION ON
ONE OR TWO PAGES -- AT LEAST, USEFUL FOR ME.
AND THEN I HAVE ANOTHER EVERGLADES FOLDER,
WHICH AT THIS POINT JUST HAS A PROPOSAL TO STUDY
MERCURY IN THE EVERGLADES FROM THE EPA.
Q. OKAY. DO YOU KNOW HOW YOU CAME TO HAVE THAT
DOCUMENT, DR. CRAFT?
A. I CAN'T SAY I'M A HUNDRED PERCENT SURE, BUT MORE
THAN LIKELY DR. RICHARDSON PASSED ON A COPY TO ME.
Q. OKAY.
A. SINCE I MAY -- YOU KNOW, WHO KNOWS, SOME OF MY
DATA MAY HAVE SOME USE IN IT. I DON'T KNOW.
Q. HAVE YOU STUDIED MERCURY IN THE EVERGLADES,
DR. CRAFT?
A. NO.
MS. PONZOLI: ALL RIGHT. LET'S GO
OFF THE RECORD.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
DR. CRAFT PAGE 59
BY THE COURT REPORTER, AND
A LUNCH BREAK WAS TAKEN.)
- - - - - - - - - - - - - - - - - - - -
MS. PONZOLI: WE'RE BACK ON THE
RECORD, AND DR. CRAFT IS GOING FIRST
THROUGH HIS NOTEBOOKS THEN THROUGH SOME
HARD COPY, AND SLIDES.
EXAMINATION BY MS. PONZOLI CONTINUES:
Q. THE FIRST NOTEBOOK IS ENTITLED "EVERGLADES,
CATIONS (TOTAL)," AND IT CONTAINS CRAFT EXHIBITS
NUMBERS SIXTY-NINE THROUGH SEVENTY-THREE.
DR. CRAFT, WOULD YOU PLEASE IDENTIFY THESE,
STARTING WITH NUMBER SIXTY-NINE.
A. OKAY. ALL SIXTY-NINE IS, IS HOW YOU CALIBRATE THE
ATOMIC ABSORPTION UNIT, AND WHAT PARAMETERS ARE
REQUIRED FOR MEASURING DIFFERENT ELEMENTS, THE WAY
YOU SET THE MACHINE UP.
NUMBER SEVENTY IS THE IRON AND THE MANGANESE
DATA, AND THIS IS FROM 1989, 1990 CORES WHEN WE
MEASURED CATIONS AND METALS IN CONSERVATION AREAS
2A, 2B AND 3A.
NUMBER SEVENTY---
Q. EXCUSE ME. WHAT YEAR DID YOU SAY THAT WAS?
A. IT'S '89, AND MAYBE SOME '90 DATA, BUT IT'S
DR. CRAFT PAGE 60
PREDOMINATELY '89.
SEVENTY-ONE, AGAIN, MAINLY '89 CORES, MAYBE
SOME '90 CORES, BUT THE DATA FOR BASE CATIONS AND
FOR ALUMINUM.
NUMBER SEVENTY-TWO IS THE CATION DATA FROM
THE PRELIMINARY CORES WE COLLECTED ALONG THE
GRADIENT IN 1989.
AND THEN SEVENTY-THREE IS CATION DATA, JUST
SODIUM AND CALCIUM ON THE GRADIENT IN CONSERVATION
AREA 2A.
Q. ALL RIGHT. THANK YOU. THE NEXT NOTEBOOK---
A. DO YOU WANT THIS---
Q. I THINK YOU SHOULD JUST PLACE THEM IN THE BOX---
A. OH, OKAY.
Q. ---TO BE COPIED AS WE FINISH THEM.
A. OKAY.
Q. WELL, MAYBE YOU SHOULD PUT THEM DOWN HERE IN CASE
SOMEONE WANTS TO LOOK THROUGH, THAT MIGHT BE
BETTER.
THE NEXT NOTEBOOK IS ENTITLED "EVERGLADES
C&N," AND IT CONTAINS CRAFT EXHIBITS NUMBERS
SEVENTY-FOUR AND GOES THROUGH CRAFT EXHIBIT NUMBER
SEVENTY-SIX. CAN YOU IDENTIFY THESE, PLEASE,
DR. CRAFT.
DR. CRAFT PAGE 61
A. NUMBER SEVENTY-FOUR ARE RUNS OF THE INTERNAL
STANDARDS WE USE TO CALIBRATE THE INSTRUMENT TO
MAKE SURE WE'RE -- WHAT WE GET IS WHAT'S CLOSE TO
WHAT THE TRUE VALUE IS.
Q. WHICH INSTRUMENT IS THIS?
A. THIS IS A CHN ANALYZER.
NUMBER SEVENTY-FIVE IS THE DATA, TOTAL CARBON
AND NITROGEN FROM ALL OUR DATA, ESSENTIALLY FROM
1989 UP TO THE PRESENT, AND THIS IS JUST SOILS
DATA, THOUGH. IT'S FROM THE GRADIENT -- FROM
CONSERVATION AREAS 2A, 2B, 3A, AND FROM THE
GRADIENT.
Q. WHERE HAVE YOU DONE WORK IN 3A, DR. CRAFT?
A. FOUR LOCATIONS. NEAR ALLIGATOR ALLEY; IN THE
VARIOUS -- CENTER OF CONSERVATION AREA 3A, AND AT
TWO LOCATIONS OFF THE TAMIAMI TRAIL, NEAR THE 12A
STRUCTURE AND THE 12C STRUCTURE.
Q. OKAY. ARE THESE -- YOU GAVE US A NUMBER OF
COORDINATES---
A. THEY'RE -- YEAH, THEY WILL BE -- WELL, SOME OF THE
COORDINATES WILL BE LISTED THERE.
Q. ARE THEY LISTED ANYWHERE AMONG THE DOCUMENTS THAT
YOU HAVE?
A. THEY'RE IN THAT FOLDER THAT WE TALKED ABOUT
DR. CRAFT PAGE 62
PREVIOUSLY.
Q. WHERE YOU HAD THE COORDINATES---
A. RIGHT.
Q. ---THE GPS.
A. THAT'S WHERE YOU WOULD DERIVE THESE. WITH THE
EXCEPTION OF ALLIGATOR ALLEY, 12A, AND 12C, WE --
I THINK, IN THE FIRST ANNUAL REPORT, WE TELL YOU
IN THE METHODS WHERE WE COLLECTED THOSE SAMPLES.
THAT WAS JUST---
Q. THE 3A CENTER WOULD BE FIND IN THAT GPS?
A. RIGHT. AND THEN NUMBER SEVENTY-SIX IS ORGANIC
"C," THEN SOME SAMPLES WHERE WE FOUND MEASURABLE
CARBONATES, SO WE REMOVED THEM AND THEN MEASURED
THE ORGANIC CARBON CONTENT.
Q. AND THE LOCATIONS AND DATES, ARE THEY REFLECTED
THERE?
A. THESE ARE THE SAME -- THESE ARE JUST SAMPLES WE
TALKED ABOUT PREVIOUSLY IN THE PREVIOUS SECTION.
SO, AGAIN, THE LOCATIONS FOR THESE ARE EITHER IN
THE '90 REPORT, OR IN THAT GPS FOLDER.
Q. ALL RIGHT. SO, THIS WOULD BE 2A, 2B AND 3A, OR
WAS THIS THE FOUR LOCATIONS NEAR ALLIGATOR ALLEY?
A. THIS IS EVERYTHING.
Q. EVERYTHING?
DR. CRAFT PAGE 63
A. 2A, 2B, 3A.
Q. OKAY. AND ALL DATA---
A. RIGHT.
Q. ---FOR ORGANIC "C"?
A. UH-HUH (YES).
Q. ALL RIGHT. THE NEXT NOTEBOOK IS ENTITLED
"EVERGLADES P," AND CONTAINS CRAFT EXHIBITS NUMBER
SEVENTY-SEVEN THROUGH EIGHTY-TWO. CAN YOU PLEASE
IDENTIFY THESE, DR. CRAFT.
A. OKAY. NUMBER SEVENTY-SEVEN -- SOMETHING THAT I
DON'T WANT Y'ALL TO LOSE BECAUSE THESE ARE A RACK
OF SAMPLES WE'RE IN THE PROCESS OF DIGESTING RIGHT
NOW -- AND THIS IS THE SHEET TELLING ME HOW MUCH
WE WEIGHED OUT FOR THEM.
Q. I'M SORRY, I DIDN'T CATCH THAT FIRST WORD, WHAT
SAMPLES?
A. THESE ARE SAMPLES THAT WE ARE ANALYZING RIGHT NOW,
SO THIS IS---
Q. OF WHAT?
A. ---FOR PHOSPHORUS---
Q. OF PHOSPHORUS. I'M SORRY.
A. ---FOR TOTAL PHOSPHORUS.
Q. DID YOU SAY A "RACK" OF SAMPLES?
A. A RACK, YES.
DR. CRAFT PAGE 64
Q. THAT IS WHAT I DIDN'T UNDERSTAND -- A RACK OF
SAMPLES. OKAY. ARE THESE REFLECTED ON YOUR
DISKS?
A. THESE, WE DON'T HAVE THE NUMBERS FOR SO THEY'RE
NOT ON THE DISKS. WE DON'T HAVE ANY DATA FOR IT.
THEY HAVE -- ALL THAT HAS BEEN DONE IS THESE -- A
TENTH OF A GRAM OF SOIL HAS BEEN WEIGHED OUT, AND
WE'RE IN THE PROCESS OF DIGESTING AND GETTING
AROUND TO MEASURING THE PHOSPHORUS.
Q. WHERE ARE THEY FROM?
A. THESE ARE FROM 10A, JUST SOUTH OF THE 10A
STRUCTURE.
Q. THESE ARE NOT PART OF YOUR ENTRY INTO THE PARK,
ARE THEY?
A. NO, I'VE NOT BEEN INTO THE PARK EXCEPT AS A
TOURIST, SO.
Q. I GUESS THE QUESTION GOES TO WHETHER YOU THOUGHT
YOU WERE IN THE PARK WHEN YOU WERE PULLING THESE
SAMPLES. AND YOU DID NOT, I TAKE?
A. NO, THESE ARE CONSERVATION AREA 2A.
Q. OH, OKAY.
A. THIS IS THE GRADIENT.
Q. OKAY. I'M SORRY. THESE ARE NOT THE 12'S, THESE
ARE -- I'M SORRY.
DR. CRAFT PAGE 65
A. RIGHT, RIGHT. 10.
Q. YEAH, OKAY. ALL RIGHT. MY MISTAKE.
A. NUMBER SEVENTY-EIGHT. THESE ARE RESULTS OF SOME
REPLICATE SAMPLES THAT WE'VE RUN, AND ALSO SOME
INTERNAL LAB STANDARDS.
Q. FOR WHAT?
A. FOR PHOSPHORUS. EVERYTHING IN THIS NOTEBOOK IS
PHOSPHORUS.
Q. OKAY. WHAT PARTICULAR WORK FOR PHOSPHORUS ARE
THESE INTERNAL LAB STANDARDS FOR? ARE THEY
SELF-EXPLANATORY, OR -- THEY APPEAR TO BE NOTES?
A. THESE ARE -- MAYBE REPEAT THE QUESTION, I'M NOT
SURE I UNDERSTAND YOU.
Q. ALL RIGHT. MAYBE I MISUNDERSTOOD, LIKE THE 10A.
I THOUGHT YOU SAID THEY WERE INTERNAL LAB
STANDARDS FOR PHOSPHORUS. IS THAT RIGHT?
A. THEY ARE SOME RUNS OF SOME DUPLICATE SAMPLES --
RUN THE SAME SAMPLE TWO TIMES TO SEE WHAT KIND OF
REPEATABILITY YOU GET.
Q. THAT'S WHAT YOU MEANT BY A STANDARD?
A. NO. THAT'S WHAT I MEANT BY DUPLICATES---
Q. OKAY.
A. ---OR REPLICATES IS WHAT IT SAYS HERE---
Q. RIGHT.
DR. CRAFT PAGE 66
A. ---USE REPLICATE.
Q. RIGHT.
A. AND THEN THERE ARE SOME STANDARDS THAT WE RUN IN
THE LAB THAT WE KNOW WHAT THE PHOSPHORUS
CONCENTRATION IS, AND SO WE RUN THEM WITH OUR SOIL
SAMPLES TO SEE THAT THE DIGEST IS WORK -- WE DON'T
HAVE ANY PROBLEMS WITH IT.
Q. OKAY. GOOD. NUMBER SEVENTY-NINE.
A. NUMBER SEVENTY-NINE. THESE ARE OVEN-DRIED
WEIGHTS. WE USE THESE AS A MOISTURE CORRECTION
FACTOR TO CORRECT EACH INDIVIDUAL SAMPLE FOR THE
SMALL AMOUNT OF WATER THAT'S IN IT. WE PERFORM
OUR ANALYSES ON AIR-DRIED SAMPLES, AND THEN
CORRECT FOR -- TAKE A SMALL SUB-SAMPLE AND OVEN
DRY IT, AND USE THAT TO CORRECT FOR IT.
Q. OKAY.
A. NUMBER EIGHTY IS THE TOTAL PE CONCENTRATION IN THE
SOILS, FROM CORES IN '89, '90 AND '91.
EIGHTY-ONE, I TRIED TO TAKE A STAB AT
MEASURING ORGANIC PHOSPHORUS IN THESE SAMPLES, AND
THESE WERE JUST DONE ON A FEW CORES IN '89.
AND EIGHTY-TWO, ANOTHER STAB AT TRYING TO
MEASURE THE CALCIUM PHOSPHATE FRACTION, AND,
AGAIN, I JUST RAN A FEW SAMPLES, AND THAT WAS NOT
DR. CRAFT PAGE 67
THE MAIN FOCUS OF MY WORK.
Q. THE NEXT NOTEBOOK IS "FERTILIZER-SOILS,
VEGETATION, WATER LEVELS." AND IT CONTAINS
CRAFT EXHIBITS NUMBER EIGHTY-THREE THROUGH
EIGHTY-NINE. AND I WOULD ASK YOU TO IDENTIFY
THOSE, PLEASE.
A. EIGHTY-THREE, THE DATES THAT WE'VE BEEN APPLYING
FERTILIZER IN THE FERTILIZER STUDY SO FAR.
Q. AND THEY'RE REFLECTED THERE ON THE SHEET?
A. RIGHT.
Q. OKAY.
A. IT TELLS YOU WHAT DATE AND HOW MUCH WE PUT DOWN.
ALSO, A LIST, AT LEAST UP TO A POINT, OF WHEN WE
TOOK OUR WATER SAMPLES.
Q. ALL RIGHT. DID YOU PRODUCE TRACER DATA FOR THAT
THIS MORNING ON---
A. YEAH, IN A FOLDER.
Q. IN A FOLDER?
A. YEAH.
Q. DID YOU DO TRACERS ONCE, OR MORE THAN ONCE,
DR. CRAFT?
A. I THINK WE DID IT ABOUT TWICE.
Q. DID YOU PRODUCE BOTH OF THOSE DATAS IN THAT
FOLDER?
DR. CRAFT PAGE 68
A. IT'S -- YEAH, IT'S ALL IN THERE.
Q. AND DOES IT INDICATE THE TIME FRAMES?
A. IT GIVES A DATE, YEAH---
Q. OKAY. OKAY.
A. ---FOR EACH OF THE TIMES WE WENT OUT.
Q. GOOD.
A. EIGHTY-FOUR IS A SUMMARY OF THE BIOMASS DATA
BEFORE WE STARTED APPLYING FERTILIZER. THIS IS,
LIKE, PRE-FERTILIZATION BY DRY WEIGHTS AND STEM
COUNTS.
Q. OKAY.
A. EIGHTY-FIVE IS -- IN FACT, MAYBE I SHOULD BACK UP
TO EIGHTY-FOUR, BECAUSE I THINK I'M MISSING MY
LITTLE DIVIDER THING. SPECIFICALLY EIGHTY-FOUR
IS THE PRE-TREATMENT DATA FOR THE SAWGRASS SITE
ONLY.
EIGHTY-FIVE IS THE PRETREATMENT BIOMASS DATA
FROM THE MIXED SITE.
AND EIGHTY-SIX IS THE PRETREATMENT BIOMASS
DATA FROM THE SLOUGH SITE.
MR. BURGESS: WHAT WAS EIGHTY-FIVE
AGAIN?
WITNESS: PRETREATMENT BIOMASS DATA
FROM THE MIXED SITE.
DR. CRAFT PAGE 69
MR. BURGESS: THANK YOU.
Q. (BY MS. PONZOLI) AND THEN EIGHTY-FOUR WAS THE
SAWGRASS, AND EIGHTY-SIX WAS THE SLOUGH---
A. RIGHT.
Q. ---IS THAT ACCURATE?
A. RIGHT.
Q. OKAY.
A. EIGHTY-SEVEN, ONCE AGAIN SOME PRETREATMENT DATA TO
TRY TO DEVELOP A NON-DESTRUCTIVE WAY TO SAMPLE
BIOMASS BY PREDICTING DRY WEIGHT FROM STEM
LENGTHS. AND INCLUDED IN THERE ARE SOME
PRETREATMENT DATA ON CARBON AND NITROGEN CONTENT
OF THESE PLANT SAMPLES THAT WE COLLECTED. AND
SOME PHOSPHORUS CONCENTRATION FROM THESE
PRETREATMENT PLOTS.
EIGHTY-EIGHT, SOILS IS WHAT IT SAYS. THERE'S
FIGURES SHOWING THE SPACIAL -- HOW THE PLOTS ARE
LAID OUT AT EACH SITE, AND ALSO SOIL DEPTHS TO
BEDROCK AT EACH OF THE THREE SITES, SAWGRASS,
MIXED, AND SLOUGH. THERE IS SOME CORE WEIGHT DATA
SO WE COULD ESTIMATE BULK DENSITY. THERE IS WET
WEIGHT/DRY WEIGHT CONVERSION DATA SO THAT WE CAN
USE THIS TO CORRECT FOR SOME ADDITIONAL DATA THAT
I AM GOING TO TALK ABOUT RIGHT NOW. THERE IS
DR. CRAFT PAGE 70
SOME -- WE MEASURED EXTRACTABLE NITROGEN AND
PHOSPHORUS ON WET SAMPLES, AND SO THE PRELIM --
THE WET/DRY WEIGHT INFORMATION IS TO CONVERT THIS
AND EXPRESS IT ON A DRY WEIGHT BASIS. AND, AGAIN,
THAT'S IT. THERE'S A LOT OF -- THERE'S DUPLICATE
PRESENTATION ON SOME OF THE INFORMATION IN HERE,
SUMMARIZED BY HAND USUALLY, SO. OKAY.
Q. OKAY. NUMBER EIGHTY-NINE.
A. EIGHTY-NINE IS WATER LEVEL DATA FROM ALL THREE
SITES FOR THE PAST OVER TWO YEARS NOW, FOR EACH
PLOT.
Q. OKAY. ARE THE DATES OF WHEN THOSE WERE MEASURED
REFLECTED?
A. UH-HUH (YES).
Q. OKAY.
A. AND THEY ARE IN CHRONOLOGICAL ORDER.
Q. OKAY. IS THAT BY HAND, THAT WATER LEVEL DATA WAS
TAKEN?
A. YES. WITH A MEASURING STICK, ESSENTIALLY.
Q. JUST LITERALLY DOWN THE CAP ROCK WITH THE
MEASURING STICK?
A. WELL, THIS IS JUST DEPTH OF WATER ABOVE THE SOIL
SURFACE, SO -- THIS LATEST INFORMATION.
Q. ALL RIGHT.
DR. CRAFT PAGE 71
MR. KILLINGER: CAN WE STOP AND GO
OFF THE RECORD FOR A SECOND?
MS. PONZOLI: YEAH, SURE.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
MS. PONZOLI: ALL RIGHT. BACK ON THE
RECORD.
Q. (BY MS. PONZOLI) THE NEXT NOTEBOOK IS FERTILIZER,
WATER CHEMISTRY, AND FIGURES. THIS NOTEBOOK
CONTAINS CRAFT EXHIBITS NUMBERS NINETY THROUGH
NINETY-ONE. RETURNING -- BEFORE WE DO NINETY AND
NINETY-ONE, DR. CRAFT, RETURNING TO THE WAY YOU
MEASURED THE WATER LEVEL DATA, WHAT TYPE OF A
MEASURING STICK DID YOU USE?
A. WE HAD A PIECE OF PVC PIPE WITH A FLAT BOTTOM
GLUED ON IT, THAT WE JUST SAT DOWN IN THE SAME
LOCATION IN THE PLOT EVERY TIME, AND IT WAS
GRADATED IN CENTIMETERS, SO WE JUST MEASURED IT
LIKE THAT.
Q. THANK YOU. WOULD YOU PLEASE IDENTIFY EXHIBITS
NUMBERS NINETY AND NINETY-ONE.
A. OKAY. THIS IS WATER CHEMISTRY DATA, PHOSPHATE,
DR. CRAFT PAGE 72
AMMONIUM, NITRATE, FROM THE THREE SITES IN THE
FERTILIZER STUDY. IT INCLUDES BOTH SURFACE AND
PORE WATER SAMPLES. AND THEY'RE BROKEN OUT, TOO,
SO THAT YOU CAN TELL.
NINETY-ONE ARE SOME FIGURES. PROBABLY FROM
A YEAR OR TWO AGO, PRETREATMENT STANDING CROP
BIOMASS, STEM COUNTS. SOME OF THE EARLY PORE
WATER AND SURFACE WATER CHEMISTRY DATA GRAPH, A
COUPLE WEEKS AFTER THE STUDY GOT STARTED, SIX
WEEKS. AND THAT'S IT.
Q. THE NEXT NOTEBOOK IS ENTITLED "FERTILIZER DRY
WEIGHT N,P." THIS CONTAINS CRAFT EXHIBITS NUMBERS
NINETY-TWO THROUGH NINETY-SIX. WOULD YOU PLEASE
IDENTIFY THESE, DR. CRAFT.
A. OKAY. NINETY-TWO IS A SUMMARY OF THE RESULTS OF
THE ANALYSIS OF VARIANTS FROM THE FIRST YEAR OF
BIOMASS DATA.
NINETY-THREE IS THE FIRST YEAR OF DRY WEIGHT
DATA, BROKEN OUT INTO INDIVIDUAL DATA, AS WELL AS
MEANS AND STANDARD ERRORS.
NINETY-FOUR IS JUST A CONTINUATION OF THAT
SAME DATA, THE FIRST YEAR DRY WEIGHT DATA. MEANS,
AND ALSO SOME OF THE RAW NUMBERS, TOO.
NINETY-FIVE IS THE PHOSPHORUS CONCENTRATION
DR. CRAFT PAGE 73
IN THE PLANT TISSUE FROM THE FIRST YEAR OF
HARVESTING. THERE'S PHOSPHORUS. THERE'S ALSO
CARBON AND NITROGEN DATA. WHAT'S THE NEXT NUMBER?
Q. NUMBER NINETY-SIX.
A. OKAY. NINETY-SIX IS A -- THESE ARE SOME OF THE
RAW DATA SETS AS UPDATED AS I'VE TRIED TO MAKE
THEM. THE FIRST ONE IS THE WATER LEVEL, STARTING
FROM THE BEGINNING OF THE STUDY IN 1990, AND IT
GOES UP THROUGH AUGUST OF THIS YEAR.
ANOTHER IS THE SURFACE AND PORE WATER
AMMONIUM NITRATE AND PHOSPHATE CONCENTRATIONS
FROM 1990, AND ONLY UP THROUGH, I THINK, JANUARY
OF '92.
Q. THAT'S WITHIN A LARGE CLIP?
A. RIGHT.
Q. OKAY.
A. AND THIS LAST IS SOME MORE FERTILIZER DATA WHERE
WE'VE COLLECTED WATER SAMPLES AT SET INTERVALS
AFTER WE APPLIED FERTILIZER TO LOOK AT PHOSPHORUS,
AMMONIUM AND NITRATE TO SEE HOW LONG IT STAYED IN
THE PLOTS.
AND THEN LAST, BUT NOT LEAST, IS A DATA SET
CONTAINING pH, OXYGEN AND CONDUCTIVITY IN
TEMPERATURE IN THE FERTILIZER PLOTS OVER ABOUT A
DR. CRAFT PAGE 74
YEAR AND A HALF PERIOD.
Q. WHAT YEAR AND A HALF WAS THAT?
A. THAT STARTS IN APRIL OF '91 AND GOES TO JULY OF
'92.
Q. THE NEXT NOTEBOOK IS ENTITLED "FERTILIZER STUDY
1992," AND CONTAINS CRAFT EXHIBITS NUMBERS
NINETY-SEVEN THROUGH A HUNDRED AND ONE. A HUNDRED
AND ONE IS IN THE FRONT POCKET, DR. CRAFT. YOU
MAY WANT TO DO THAT FIRST, IF YOU THINK IT'S
LOGICAL. I HAD MISSED IT WHEN I NUMBERED THE
EXHIBITS.
A. I'LL DO THAT. TO TELL YOU THE TRUTH, I'M NOT SURE
WHAT THIS IS, BUT I THINK IT'S A CHECK SHEET WE'VE
BEEN USING TO MAKE SURE THAT WE HAVE THE WEIGHTS
OF THE SAMPLES AFTER THEY'RE GROUND. WE'RE IN THE
PROCESS OF GRINDING THE PLANT TISSUES, SO THIS IS
USED AS CHECK TO MAKE SURE WE HAD A WEIGHT ON THEM
FOR US.
Q. THAT'S A HUNDRED AND ONE THAT YOU'RE TALKING
ABOUT?
A. RIGHT.
Q. OKAY. AND THE NEXT ONE WILL BE NUMBER
NINETY-SEVEN.
A. OKAY. NINETY-SEVEN IS -- AGAIN, THIS WAS A SECOND
DR. CRAFT PAGE 75
TIME WE DID THIS. WE TOOK WATER SAMPLES AFTER WE
APPLIED FERTILIZER AT SET INTERVALS TO SEE THE
RETENTION OF THE FERTILIZER, BUT THIS WAS DONE ON
A DIFFERENT DATE. THIS WAS DONE IN AUGUST OF THIS
YEAR.
Q. YOU'RE NOT TALKING ABOUT A TRACER, ARE YOU?
A. NO. WELL, WE'RE JUST TALKING ABOUT WE ADD
FERTILIZER AND SO WE WANTED TO SAMPLE THE
FERTILIZER CONCENTRATIONS IN THE WATER JUST TO
GIVE US AN IDEA OF THE RETENTION TIME.
NINETY-EIGHT IS THE SOILS DATA FROM 1992. WE
MEASURED EXTRACTABLE FORMS OF PHOSPHATE, AMMONIUM
AND NITRATE IN THE PLOTS TO GET A FEEL FOR HOW
MUCH FERTILIZER IS ENDING UP IN THE SOIL
COMPONENT. AND THEN THERE ARE SOME STATISTICAL
PROGRAMS AFTER THAT RUNNING SOME ANALYSIS ON THAT
DATA TO SEE WHAT KIND OF RESULTS WE GET.
NINETY-NINE IS THE 1992 BIOMASS DATA AND THE
DRY WEIGHT DATA THAT IS STILL -- IT'S IN ITS
INCOMPLETE STAGES, BECAUSE WE'RE IN THE PROCESS OF
GRINDING AND MAKING SURE THAT ALL THE NUMBERS --
THAT WE HADN'T MISSED ANY SAMPLES BASICALLY.
AND ONE HUNDRED IS SOME PRELIMINARY BELOW
GROUND BIOMASS DATA FROM 1992. AND, AGAIN, THIS
DR. CRAFT PAGE 76
IS THE KIND OF DATA THAT WE'RE SEPARATING ROOTS
FROM SOIL AT THIS -- PROBABLY NOT AT THIS VERY
MOMENT, BUT THIS IS THE KIND OF WORK WE'LL BE
DOING FOR THE NEXT SIX MONTHS TRYING TO GET THESE
SAMPLES WORKED UP.
AND THAT'S IT WITH THIS ONE.
Q. THE NEXT NOTEBOOK IS ENTITLED PLANT TISSUE, AND IT
CONTAINS CRAFT COMPOSITE EXHIBITS NUMBERS ONE OH
TWO AND ONE OH THREE.
MS. PONZOLI: I'D LIKE THE RECORD TO
REFLECT THAT WHEN I SAY COMPOSITE EXHIBIT,
NEARLY ALL OF THESE EXHIBITS, VIRTUALLY ALL
DAY LONG, HAVE BEEN COMPOSITE EXHIBITS. SO,
MY FAILURE NOT TO DESIGNATE THAT HAS NO
MEANING. THEY'VE ALMOST ALL TO A DOCUMENT
BEEN COMPOSITE EXHIBITS.
A. THIS IS A NITROGEN PHOSPHORUS CONTENT OF
VEGETATION, SAWGRASS AND CATTAIL, COLLECTED IN
CONSERVATION AREAS 2A, 2B, 3A AND ALSO ON THE
GRADIENT IN 2A.
Q. AND THE YEAR?
A. THAT'S WHAT NINETY -- OH, THAT'S WHAT ONE OH TWO
IS.
Q. AND THE YEAR?
DR. CRAFT PAGE 77
A. IT'S PRETTY MUCH, I THINK, '89 AND '90.
AND ONE OH THREE ARE FIGURES, PRETTY MUCH
GRAPHING THAT DATA THAT I TALKED ABOUT THAT'S IN
ONE OH TWO, THE VEGETA -- THE N AND P DATA IN
PLANT TISSUE.
Q. ONE OH TWO IS THE N AND P?
A. UH-HUH (YES). IN PLANTS. AND ONE OH THREE IS---
MR. BURGESS: DID YOU SAY IN PLANTS?
WITNESS: RIGHT. NITROGEN IN PLANTS.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
Q. (BY MS. PONZOLI) OKAY. IF I COULD ASK YOU TO
LOCATE NUMBER NINETY-SEVEN, DR. CRAFT---
A. OKAY.
Q. ---NINETY-SIX, NINETY-SEVEN, NINETY-EIGHT, IN
FRONT OF YOU. IT WOULD GO BACK PROBABLY ONE
NOTEBOOK.
A. THERE'S ONE OH ONE, WE'VE GOT TO GO WAY BACK.
MR. BURGESS: IT'S ACTUALLY IN THAT
ONE OH ONE NOTEBOOK.
MS. PONZOLI: I THINK IT MIGHT BE IN THE
ONE OH ONE NOTEBOOK.
DR. CRAFT PAGE 78
WITNESS: OH, OKAY.
A. NINETY-SIX?
Q. (BY MS. PONZOLI) NINETY-SIX, NINETY-SEVEN AND
NINETY-EIGHT. I THINK IT'S ON NINETY-SEVEN.
A. OKAY. NINETY-SIX IS IN THE PREVIOUS ONE.
MR. BURGESS: YEAH, IT'S THE
PREVIOUS NOTEBOOK.
A. NINETY-SEVEN STARTS HERE. OKAY. NINETY-SEVEN.
Q. ALL RIGHT. WELL, LET'S START WITH NINETY-SEVEN.
YOU TALK, I THINK, ABOUT THE TIME OF THE
DISAPPEARANCE OF THE FERTILIZER, WAS THAT RIGHT?
A. RIGHT.
Q. ALL RIGHT. AND YOU SAID YOU WERE MEASURING
PHOSPHORUS, AMMONIUM AND NITRATE?
A. PHOSPHATE, AMMONIUM, NITRATE.
Q. OKAY. PHOSPHATE. IS THAT ALL THAT YOU WILL BE
ANALYZING?
A. IN TERMS OF WATER SAMPLES, YEAH, THAT'S MY EXTENT
OF IT.
Q. OKAY. WILL YOU BE ANALYZING FOR SOMETHING ELSE IN
THE SOIL CORES?
A. WELL, LIKE, TOTAL NITROGEN, TOTAL PHOSPHORUS, AND
PERHAPS THESE EXCHANGE OR EXTRACTABLE FORMS OF
N AND P.
DR. CRAFT PAGE 79
Q. AND PORE WATER, WILL YOU MEASURE FOR ANYTHING
DIFFERENT THERE?
A. NO.
Q. ALL RIGHT. THANK YOU. I APPRECIATE THAT. ALL
RIGHT, THE NEXT NOTEBOOK IS "EVERGLADES CESIUM,"
AND THAT WILL BE CRAFT EXHIBITS NUMBERS A HUNDRED
AND FOUR AND A HUNDRED AND FIVE. WOULD YOU PLEASE
IDENTIFY THESE RATHER LARGE COMPOSITE EXHIBITS,
DR. CRAFT.
A. OKAY. THIS IS -- ONE OH FOUR IS THE RAW COUNT
DATA FOR CESIUM ACROSS DIFFERENT CHANNELS. THIS
IS THE VERY RAW, RAW, RAW, RAW CESIUM DATA.
Q. AT WHAT LOCATION?
A. OKAY. THIS IS -- I'LL HAVE TO GO BACK AND LOOK.
THIS IS PRETTY MUCH THE '89 DATA, CONSERVATION
AREA 2A, 2B, 3A. THAT'S THE RAWEST.
Q. UH-HUH (YES).
A. ONE OH FIVE IS KIND OF INTERMEDIATE DATA THAT'S
DERIVED FROM ONE OH FOUR, PULLING OUT THE -- WHERE
THE CESIUM PEAK IS AND WHAT THE COUNTS PER MINUTE
ARE PER INCREMENT. AND, AGAIN, THIS DATA IS
MAINLY '89, BUT IT ALSO HAS THE CESIUM DATA FROM
THE GRADIENT, TOO, THE '90 AND THE '91 DATA.
OKAY.
DR. CRAFT PAGE 80
Q. THE NEXT NOTEBOOK IS ENTITLED "CESIUM COUNTING,"
AND IT CONTAINS CRAFT EXHIBIT -- I THINK IT'S JUST
ALL JUST ONE OH SIX, IT'S ONE COMPOSITE EXHIBIT.
COULD YOU IDENTIFY THAT, PLEASE, DR. CRAFT.
A. OKAY. THIS GOES WITH THE PREVIOUS NOTEBOOK IN
THAT THIS HAS DATA ON WHAT THE INCREMENT WEIGHT
WAS, AND HOW MUCH WE WEIGHED OUT FOR THE CESIUM
ANALYSIS, AND ALSO HOW LONG WE COUNTED THE SAMPLES
FOR, SO THAT WE CAN EXPRESS THE CESIUM DATA ON A
PER WEIGHT, PER UNIT TIME BASIS.
Q. AGAIN, IS THIS '90 AND '91?
A. IT'S '89 THROUGH '91.
Q. AND INCLUDES THE GRADIENT?
A. RIGHT, IN 2A, 2B, 3A.
Q. AND ARE THEY PRETTY MUCH LABELED? I MEAN, IF YOU
LOOK AT THEM, YOU COULD TELL WHERE YOU WERE AND
WHAT YEAR?
A. YEAH. WELL, YOU CAN SEE 10A---
Q. RIGHT.
A. ---YOU KNOW WHERE THAT IS---
Q. RIGHT.
A. ---COLLECTED UNDER CATTAIL, DATE THE CORE WAS
COLLECTED. PRETTY STRAIGHTFORWARD.
Q. RIGHT.
DR. CRAFT PAGE 81
A. CONSERVATION AREA WCA-2B, SO, YEAH, IT'S---
Q. IT'S ALL LABELED---
A. RIGHT.
Q. ---SELF-EXPLANATORY, REALLY?
A. I THINK SO.
Q. OKAY. THANK YOU. THE NEXT NOTEBOOK HAS Pb AND
THEN A 210.
A. IT'S LEAD 210 ANALYSIS.
Q. OKAY. ALL RIGHT. AND THIS CONTAINS CRAFT
EXHIBITS ONE OH SEVEN THROUGH ONE ELEVEN. COULD
YOU IDENTIFY THESE, PLEASE.
A. OKAY. ONE OH SEVEN IS JUST A SUMMARY OF THE
PROTOCOLS FOR WORKING WITH RADIOACTIVITY IN THE
LAB.
ONE OH EIGHT IS THE LEAD 210 DATA, ALL THE
WAY FROM HOW YOU DIGEST IT DOWN TO COUNTING. SO,
IT CONTAINS ALL KINDS OF STUFF.
ONE OH NINE IS ANOTHER WAY TO TRY TO COUNT
LEAD 210 BY DIRECT GAMMA COUNTING.
ONE TEN ARE INVOICES FOR THINGS THAT WE
BOUGHT RELATING TO DOING LEAD 210 WORK.
AND ONE ELEVEN IS SOME INFORMATION ON HOW TO
DO POLLEN ANALYSIS.
Q. POLLEN?
DR. CRAFT PAGE 82
A. POLLEN, P-O-L-L-E-N. AND AT THE VERY END OF THAT
SECTION, THERE ARE SOME GRAPHS SHOWING SOME OF THE
GRAPHING OF THE LEAD 210 DATA, WHICH I MIGHT --
WELL, AFTER Y'ALL ARE DONE, I MIGHT MOVE IT INTO
ANOTHER SECTION BECAUSE I DON'T THINK IT GOES WITH
THE POLLEN. PUT THEM IN---
MR. BURGESS: OFF THE RECORD.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER.)
Q. (BY MS. PONZOLI) WHAT WAS THE POINT OF POLLEN
ANALYSIS?
A. WELL, BOB ALREADY KNOWS PROBABLY, IS IT'S ANOTHER
WAY TO DATE SEDIMENTS, SO.
Q. OKAY. ALL RIGHT. IS THERE A SUMMARY OF THE
POLLEN ANALYSIS SOMEWHERE?
A. ALL IT IS IS A METHOD HERE. WE DON'T HAVE ANY
DATA. WE HAVEN'T EVEN STARTED COLLECTING ANY DATA
FOR POLLEN, SO.
Q. BUT YOU DO INTEND TO?
A. YEAH, WE WOULD LIKE TO.
Q. DO YOU KNOW WHO WILL BE DOING THAT, DR. CRAFT?
A. IT'LL PROBABLY BE ME AND A GRADUATE STUDENT.
DR. CRAFT PAGE 83
Q. HENCE IT'S IN YOUR NOTEBOOK.
A. RIGHT.
Q. HOW MUCH LEAD 210 WORK HAVE YOU DONE?
A. NOT A WHOLE LOT. WE'VE PROBABLY ANALYZED ABOUT
FIFTY DEPTH -- WELL, FIFTY DEPTH INCREMENTS.
WE HAVE DONE ABOUT FIFTY INDIVIDUAL
DETERMINATIONS.
Q. AND I DON'T RECALL FROM MY NOTES. I THINK I'M---
A. NOT ENOUGH.
Q. RIGHT. COULD YOU TELL US WHERE YOU HAD DONE THAT?
A. IT'S BEEN DONE ON SOME OF THE SAME CORES THAT
WE'VE COLLECTED AND DID THE CESIUM ON. AND I
THINK YOU COULD PROBABLY GO THROUGH HERE. AND
AGAIN, I THINK IT'S PRETTY SELF-EXPLANATORY AS TO
WHERE WE DID SOME OF THESE. FOR EXAMPLE, HERE'S
A CORE FROM CONSERVATION AREA 2A OUT OF THE ZONE
OF ENRICHMENT. AND ANOTHER CORE FROM CONSERVATION
AREA 2A IN THE ZONE OF ENRICHMENT. AND THIS ONE
10D-1 IS IN THE ZONE OF ENRICHMENT ALSO. SO, IT'S
LOCATED JUST BELOW THAT 10D STRUCTURE. NOT SUCH A
PRETTY LINE THERE.
Q. OKAY. DO YOU HAVE ANY IDEA WHEN YOU'LL BEGIN
THAT?
A. THE POLLEN WORK?
DR. CRAFT PAGE 84
Q. UH-HUH (YES).
A. I HOPE BY THE END OF THE YEAR. I HOPE.
Q. END OF THIS YEAR, '92?
A. UH-HUH (YES). I HOPE SO.
Q. OKAY. NEXT, DR. CRAFT, WE HAVE YOUR FULL NOTEBOOK
OF SLIDES, AND WE HAVE PREVIOUSLY GONE THROUGH AND
SORT OF GROUPED THESE AND PUT EXHIBIT NUMBERS ON
THEM. I WOULD ASK YOU TO GO THROUGH, AND AS YOU
COME TO EACH EXHIBIT NUMBER, READ THE EXHIBIT
NUMBER INTO THE RECORD, AND TELL US WHAT THIS
GROUP OF SLIDES REPRESENTS. AND IF I HAVE -- IF
I NEED TO HAVE YOU IDENTIFY A SPECIFIC SLIDE, I
MIGHT DO IT THEN. I'M PROBABLY JUST GOING TO
LISTEN TO YOUR GENERAL EXPLANATIONS AND LOOK AT
THEM DOWNSTREAM, AND THEN IF I HAVE A SPECIFIC
QUESTION I WOULD ASK YOU WHEN I---
A. IT'S---
Q. ---DID YOUR DEPOSITION AGAIN.
A. ---IT'S REAL STRAIGHTFORWARD. I'VE GOT THEM
GROUPED BY THE TALK I GAVE. SO, ONE TWELVE---
Q. IS THIS THE SOCIETY OF WETLANDS SCIENTIST TALK?
A. I HAVE TO LOOK. THIS IS A PEAT ACCRETION NUTRIENT
ACCUMULATION TALK, THAT ACTUALLY IS DATA FROM 2A,
2B, 3A, AND IT WAS GIVEN AT SWS IN 1990.
DR. CRAFT PAGE 85
ONE THIRTEEN IS A TALK ON ORGANIC AND
INORGANIC CARBON ACCUMULATION IN THE EVERGLADES.
I THINK RON MIGHT HAVE BEEN AT THAT MEETING, THE
SOIL SCIENCE SOCIETY OF AMERICA. AND I THINK THAT
WAS -- I THINK THAT WAS IN '91, LAST FALL.
Q. OKAY.
A. I MEAN, I'M NOT A HUNDRED PERCENT SURE ON THAT,
BUT I THINK SO.
ONE FOURTEEN, EFFECTS OF AGRICULTURAL RUNOFF
ON NUTRIENT ACCUMULATION IN THE EVERGLADES. THIS
WAS SOME OF THE PRELIMINARY DATA COLLECTED FROM
THE GRADIENT STUDY, AND WAS PRESENTED AT A
SYMPOSIUM ON BIOGEOCHEMISTRY AT LSU.
Q. DO YOU REMEMBER THE DATE, ROUGHLY?
DR. KADLEC: MARDI GRAS.
WITNESS: YEAH, I REMEMBER THAT
PART.
A. IT WAS '91. IT WAS FEBRUARY '91.
THIS ONE PAGE HERE, ONE FIFTEEN, ON WATER
QUALITY IN THE EVERGLADES. THIS WAS GIVEN IN JUNE
OF '91 TO THE FLORIDA ASSOCIATION OF ENVIRONMENTAL
PROFESSIONALS, TO THEIR ANNUAL MEETING.
MR. BURGESS: WHAT WAS THE DATE?
I'M SORRY.
DR. CRAFT PAGE 86
WITNESS: IT WAS JUNE OF '91.
MR. BURGESS: THANK YOU.
A. I MIGHT HAVE TO BACK UP, BECAUSE I THINK I DIDN'T
CORRECTLY IDENTIFY ONE. LET ME IDENTIFY THIS.
THIS IS ONE SIXTEEN.
Q. UH-HUH (YES).
A. THIS WAS GIVEN AT THE '91 SOIL SCIENCE SOCIETY OF
AMERICA MEETINGS. IT'S HISTORICAL AND RECENT
RATES OF PEAT ACCRETION IN THE EVERGLADES.
LET ME BACK UP, BECAUSE I THINK I INCORRECTLY
IDENTIFIED ONE OF THESE.
Q. I THINK YOU THOUGHT ONE THIRTEEN WAS THAT.
A. RIGHT. AND I'M TRYING TO REMEMBER EXACTLY WHERE I
GAVE ONE THIRTEEN. OH, I KNOW. ONE THIRTEEN WAS
GIVEN AT THE 1990 SOIL SCIENCE SOCIETY OF AMERICA
MEETINGS IN NOVEMBER OF '90---
MR. BURGESS: I BELIEVE THAT'S WHAT
YOU SAID, THE FALL OF '90.
WITNESS: RIGHT.
A. ---AND THEN WHATEVER THIS LAST ONE WAS, WAS FALL
OF '91---
MR. BURGESS: ONE SIXTEEN.
A. ---ONE SIXTEEN WAS FALL OF '91.
ONE SEVENTEEN, EFFECTS OF DRAINAGE --
DR. CRAFT PAGE 87
AGRICULTURAL DRAINAGE ON PEAT ACCRETION NUTRIENT
ACCUMULATION. THIS WAS GIVEN AT THE INTECOL
MEETING IN COLUMBUS IN SEPTEMBER OF THIS YEAR.
OKAY. ONE EIGHTEEN IS JUST SOME -- A FEW
SLIDES ON SPECIES COMPOSITION ON THE GRADIENT, AND
ALSO ON THE TISSUE N AND P CONCENTRATIONS, IT'S
JUST A FEW SLIDES. THEY WERE NOT -- I DON'T THINK
I EVER REALLY GAVE THEM, I JUST GRAPHED IT TO SEE
WHAT IT LOOKED LIKE AND MAKE SLIDES.
NINETEEN IS THE EFFECTS OF NITROGEN AND
PHOSPHORUS ADDITIONS ON PLANT COMMUNITIES. THIS
WAS GIVEN AT THE '92 SWS MEETINGS.
WAIT A MINUTE, LET ME BACK UP. THIS WAS
ACTUALLY SOME PRELIMINARY DATA FROM THE FERTILIZER
STUDY, PRELIMINARY SLIDES, WITH MAINLY JUST THE
FIRST YEAR OF DATA, THE PRE -- NOT EVEN THE FIRST
YEAR AFTER FERTILIZATION, BUT THE PRETREATMENT
DATA.
MR. BURGESS: IS THAT ONE NINETEEN?
WITNESS: YEAH.
A. AND THIS WAS NEVER PRESENTED AT A TALK. NOW ONE
TWENTY IS THE SWS TALK.
Q. ALL RIGHT. HAS ONE NINETEEN BEEN SUPERSEDED BY
LATER DATA?
DR. CRAFT PAGE 88
A. WELL, IT'S BEEN SUPERSEDED BY LATER DATA, BUT
THEY'RE -- THEY'RE EXCLUSIVE. THIS DATA IS BEFORE
WE EVEN ADDED FERTILIZER, JUST TO GIVE US SORT OF
BASELINE MEASUREMENTS---
Q. OKAY.
A. ---AND WE HAVE GRAPHS TO SHOW THIS SAME STUFF.
Q. OKAY.
A. SO, ONE TWENTY IS SWS. AND THAT'S IT.
Q. ONE TWENTY WAS THE SOCIETY OF WETLANDS
SCIENTISTS---
A. '92 MEETING.
Q. ---'92. ON WHAT?
A. EFFECTS OF N AND P ON THE EVERGLADES PLANT
COMMUNITIES.
Q. OKAY.
MR. BURGESS: NOW, IS THAT THE SAME
AS ONE NINETEEN, WHICH IS---
WITNESS: I'LL HAVE TO GO BACK.
MR. BURGESS: NOW, ONE NINETEEN, I HAVE
WRITTEN DOWN, EFFECTS OF N AND P ADDITIONS ON
PLANT COMMUNITY.
WITNESS: THIS WAS -- ONE NINETEEN IS
PRIOR TO FERTILIZATION.
MR. BURGESS: OKAY.
DR. CRAFT PAGE 89
WITNESS: IT'S TO PROVIDE BASELINE
INFORMATION. ONE TWENTY IS AFTER THE FIRST
YEAR OF FERTILIZING.
MR. BURGESS: OKAY.
Q. (BY MS. PONZOLI) I'M GOING TO HAND YOU CRAFT
NUMBER ONE TWENTY-ONE, AND ASK YOU TO PLEASE
IDENTIFY IT.
A. THIS IS SAS OUTPUT ON WATER LEVELS IN THE
FERTILIZER PLOTS FOR A TWO-YEAR PERIOD 1990 TO
1992.
Q. OKAY. CRAFT EXHIBIT NUMBER ONE TWENTY-TWO.
A. THIS IS SOME SAS RESULTS ON pH OXYGEN AND
CONDUCTIVITY FROM THE FERTILIZER PLOTS.
Q. OKAY. CRAFT EXHIBIT NUMBER ONE TWENTY-THREE.
A. ONE TWENTY-THREE. THIS IS, AGAIN, COMPUTER OUTPUT
FOR THE NITROGEN AND PHOSPHORUS CONTENT OF PLANT
TISSUE IN THE FERTILIZER STUDY. THIS MAY JUST BE
PHOSPHORUS. NO, IT HAS NITROGEN AND PHOSPHORUS.
MR. BURGESS: OFF THE RECORD.
(THEREUPON, THERE WAS AN
OFF-THE-RECORD DISCUSSION
WHICH WAS NOT REPORTED
BY THE COURT REPORTER, AND
A SHORT BREAK WAS TAKEN.)
DR. CRAFT PAGE 90
MS. PONZOLI: LET'S GO BACK ON
THE RECORD.
EXAMINATION BY MS. PONZOLI CONTINUES:
Q. ALL RIGHT. I'M GOING TO HAND YOU CRAFT COMPOSITE
EXHIBIT NUMBER ONE TWENTY-FOUR, AND ASK YOU WHAT
THAT IS.
A. OKAY. THIS IS THE SURFACE AND PORE WATER,
AMMONIUM, NITRATE, PHOSPHATE DATA FROM THE
FERTILIZER STUDY. AND THERE'S TWO THINGS, THE
MEAN VALUES OF EACH OF THOSE BY SITE AND TREATMENT
AND DEPTH. AND ALSO WE PLOTTED THE RESIDUALS TO
LOOK FOR THINGS LIKE OUTLIERS AND INFLUENTIAL DATA
POINTS, AND THAT SORT OF THING.
Q. ALL RIGHT. THE FINAL REALLY MASSIVE COMPOSITE
EXHIBIT IS NUMBER TWENTY-FIVE [sic.] AND ASK YOU
TO IDENTIFY THAT, PLEASE.
A. OKAY.
MR. BURGESS: ONE TWENTY-FIVE.
MR. KILLINGER: ONE TWENTY-FIVE.
MS. PONZOLI: ONE TWENTY-FIVE, I
APOLOGIZE.
A. OKAY. THIS IS, AGAIN -- ALL THIS IS SAS OUTPUT.
THESE ARE THE STATISTICAL ANALYSES OF THE BIOMASS
DATA FROM THE FIRST YEAR OF THE STUDY. THE FIRST
DR. CRAFT PAGE 91
YEAR AFTER WE STARTED FERTILIZING.
Q. OKAY.
A. SO, THIS IS DRY WEIGHT DATA ESSENTIALLY, AND IT'S
EVERYTHING FROM MEANS TO ANALYSIS OF VARIANTS TO
OTHER THINGS.
Q. OKAY.
A. AND, TO BE HONEST, I'M NOT SURE WHAT THIS IS HERE.
SOMEHOW THIS THING GOT STUCK IN WITH IT. AND I'M
NOT -- IT LOOKS LIKE A PAPER OF JAN'S OR
SOMETHING. SO YOU MAY HAVE SEEN THIS.
Q. I DON'T KNOW.
A. BUT I'D RATHER PUT THIS IN ANOTHER GROUP---
Q. A SEPARATE -- OKAY.
A. ---I DON'T RECALL HAVING THAT. I DON'T KNOW HOW
THAT EVEN GOT IN HERE, SO.
MS. PONZOLI: OKAY. WE'LL JUST MARK
IT AS ONE TWENTY-SIX.
(THEREUPON, THE DOCUMENT REFERRED
TO BELOW WAS MARKED AS DEPOSITION
EXHIBIT 126 - CHRISTOPHER B. CRAFT
DEPOSITION - FOR IDENTIFICATION.)
Q. (BY MS. PONZOLI) IT HAS YOUR NAME ON IT, AND HIS,
AND DR. RICHARDSON'S.
A. YEAH. BUT I -- I MEAN, THE WAY IT LOOKS TO ME IS
DR. CRAFT PAGE 92
IT'S SOMEBODY ELSE'S COPY.
Q. OH, THAT'S NOT YOUR HANDWRITING THAT'S ON IT?
A. NO. AND I DON'T -- I WOULDN'T KEEP A COPY THAT
LOOKS LIKE THAT ANYWAY. I MEAN, IT JUST LOOKS
LIKE, YOU KNOW, THERE'S SMUDGES ON IT AND
EVERYTHING---
Q. I DON'T KNOW. ANYWAY.
A. ---BUT ANYWAY YOU CAN PUT THAT AS ANOTHER DOCUMENT
NUMBER. I NORMALLY KEEP MY STUFF PRETTY WELL
ORGANIZED.
Q. ALL RIGHT. YOU MENTIONED THERE WAS A MS. -- WAS
IT RAIKES, WHO DID A GREENHOUSE STUDY NUMBER
TWO---
A. CORRECT.
Q. ---IS THAT RIGHT?
A. CORRECT.
Q. IS THERE DATA -- THERE WAS WRITE-UP, BUT IS THERE
DATA THAT ACCOMPANIES THAT WRITE-UP?
A. SHE'S IN THE PROCESS OF WRITING THAT NOW TO TRY TO
GRADUATE IN DECEMBER.
Q. OKAY. AND YOU DO NOT HAVE THE DATA?
A. NO, I DON'T HAVE A COPY OF THE DATA. THAT IS --
THAT'S HER PROJECT, AND I JUST KIND OF HELP HER
OUT AND SUPERVISE IT.
DR. CRAFT PAGE 93
Q. COULD THAT DATA BE SUPPLIED TO US WITHOUT OUR
HAVING TO GO THROUGH THE FORMAL PROCESS OF GETTING
HER---
A. WELL, I WOULD BE HAPPY TO SUPPLY IT, BECAUSE I
WOULD LIKE TO SAY ON THE RECORD THAT I DON'T --
AFTER LORI SUTTER CALLED OVER TO DUKE CAMPUS ON
MONDAY AFTERNOON IN TEARS AND SUCH, I REALLY WOULD
HATE TO SEE YOU-ALL DO THE SAME THING TO JANE
RAIKES. AND I SAY IT AS A CITIZEN, THAT I FEEL
LIKE YOU-ALL, IN A LOT OF WAYS, OUGHT TO KIND OF
BE ASHAMED OF YOURSELF FOR THE WAY SHE GOT ALL
WORKED UP. AND I JUST SAY THIS AS CHRIS CRAFT,
AND I -- YOU KNOW, I FEEL LIKE -- I MEAN, MAYBE
IT'S YOUR JOB, BUT, YOU KNOW, WHEN YOU HAVE
SOMEBODY WHO'S A GRADUATE STUDENT CALLING UP
ALMOST IN TEARS, I BEGIN TO WONDER WHETHER THE
SYSTEM IS WORKING RIGHT. AND I DON'T KNOW WHO WAS
IN HERE THAT DAY, BUT IN SOME WAYS I THINK Y'ALL
OUGHT TO BE ASHAMED OF THAT. BUT THAT'S JUST THE
WAY I FEEL, AND I FELT LIKE I SHOULD SAY THAT.
AND I REALLY DON'T -- I'LL BE HAPPY TO SUPPLY IT
IF JANE DOES NOT HAVE TO COME AND GO THROUGH THE
SAME KIND OF -- I THINK -- INTIMIDATION THAT Y'ALL
PUT LORI THROUGH.
DR. CRAFT PAGE 94
Q. ARE YOU FINISHED, DR. CRAFT?
A. YES.
Q. WELL, DR. CRAFT, SINCE I THINK YOUR ALLEGATIONS
ARE UNFAIR AND UNWARRANTED, I FEEL I MUST RESPOND.
MY VIEW IS, IS THAT DUKE WETLANDS CENTER HAS PUT A
PUBLICATION OUT IN THE STATE OF FLORIDA CALLED THE
ANNUAL REPORT OF THE DUKE WETLANDS CENTER, WHICH
BEARS MS. SUTTER'S NAME. AND MS. SUTTER HAS IN
HER CHAPTER SAID A NUMBER OF THINGS THAT HAVE VERY
LARGE IMPLICATIONS FOR WHAT I BELIEVE YOU, FOR
THREE YEARS, HAVE BEEN AWARE IS A VERY HOTLY
DISPUTED ISSUE WITHIN OUR STATE ABOUT WHICH MY
CLIENTS FEEL ENORMOUSLY, STRONGLY. SHE CERTAINLY
MUST DEFEND HER SCIENCE. AND I THINK THAT DUKE
WETLANDS CENTER, BY PUBLISHING HER SCIENCE, IN ITS
ANNUAL REPORT, IS THE ONE THAT MADE HER SUBJECT TO
THAT DEPOSITION, NOT THE UNITED STATES. AND IT
CERTAINLY WAS NOT THE UNITED STATES THAT HAD ANY
DECISION IN SENDING MS. SUTTER TO A DEPOSITION IN
A HOTLY DISPUTED MATTER TO DEFEND -- AND I WON'T
CHARACTERIZE HER WORK AT THIS TIME -- BUT TO
DEFEND THAT WITHOUT AN ATTORNEY PRESENT WAS NOT --
IN MY VIEW AS AN ATTORNEY AND AS A PERSON, AND
AS A CITIZEN -- A VERY GOOD IDEA. I THINK SHE
DR. CRAFT PAGE 95
SHOULD HAVE COME IN THE FIRST INSTANCE WITH AN
ATTORNEY WHO ACTUALLY REPRESENTED HER. I THINK
SHE'S A---
MS. PONZOLI: I GET TO FINISH. I LET
HIM FINISH; I'M GOING TO FINISH.
Q. ---I THINK THAT SHE IS A VERY LOVELY PERSON, AND
I'M VERY SORRY THAT IT CAME TO THAT, AND THAT SHE
GOT THAT UPSET. I WANT YOU TO UNDERSTAND THAT---
A. OKAY.
Q. ---BECAUSE I THINK YOU ARE PROBABLY HER PERSONAL
FRIEND, AND I THINK YOU'RE PROBABLY VERY ANGRY
ABOUT WHAT HAPPENED. AND IF I WERE IN YOUR
POSITION, I WOULD FEEL EXACTLY THE SAME. SO, I DO
NOT FAULT YOU FOR THAT AT ALL. I THINK YOU NEED
TO LOOK A LITTLE INSIDE THE CENTER AND INSIDE THE
SYSTEM THAT SENDS HER OVER HERE ALONE. AND SO THE
FAULT CAN BE SPREAD IN A NUMBER OF DIRECTIONS IS
WHAT I THINK I'M TRYING TO SAY. AND THERE WAS
CERTAINLY NO INTENTION ON THE UNITED STATES' PART
THROUGH MYSELF TO INTIMIDATE HER.
MR. BURGESS: OKAY. I'M NOT GOING
TO MAKE ANY SPEECHES FOR THE RECORD, BUT
BEFORE YOU AGREE -- AND I'M NOT YOUR LAWYER
REPRESENTING YOU -- BUT BEFORE YOU AGREE TO
DR. CRAFT PAGE 96
PROVIDE DATA THAT HASN'T BEEN SUBPOENAED, I
THINK YOU NEED TO TALK TO YOUR LAWYER. AND
IF YOU WANT TO BE EXCUSED TO CALL RALPH, OR
CALL AND ASK ABOUT THAT TONIGHT, BECAUSE IT'S
EXACTLY WHAT MS. PONZOLI IS SAYING -- ACTIONS
THAT THE DEPONENT TOOK WITHOUT AN ATTORNEY,
AND YOU NEED TO BE COGNIZANT OF THE SAME
ADVICE THAT SHE WAS GIVING LORI.
WITNESS: OKAY. CAN WE DEAL WITH THIS
A LITTLE BIT LATER? CAN I TALK TO RALPH A
LITTLE BIT LATER?
MS. PONZOLI: OH, SURE. I'M JUST ASKING
YOU IF IT CAN BE DONE. I'M NOT GETTING --
YOU DON'T HAVE -- YOU CAN'T COMMIT SOMEONE
ELSE'S DATA. I'M ASKING IF WE CAN DO THIS AN
EASY WAY. AND IF WE CAN, LET'S DO IT AN EASY
WAY. IF WE CAN'T DO IT AN EASY WAY, THEN I
HAVE TO DECIDE IF IT'S WORTH IT TO THE UNITED
STATES TO DO IT THE HARD WAY, WHICH IS WHAT
MR. BURGESS IS SAYING, WITH A SUBPOENA.
WITNESS: OKAY. THAT'S FINE.
MS. PONZOLI: I WOULD PREFER IT -- I
WOULD PREFER TO DO IT THE EASY WAY, BECAUSE
I DON'T---
DR. CRAFT PAGE 97
WITNESS: WELL, ME TOO, BUT LET ME TALK
TO RALPH AND SEE IF HE---
MS. PONZOLI: OKAY. ALL RIGHT. I HAVE
A COUPLE OF OTHER QUESTIONS ON DATA.
Q. (BY MS. PONZOLI) HAVE YOU, DR. CRAFT, EVER WORKED
WITH DR. REDDY'S DATA FOR THE WATER MANAGEMENT
DISTRICT, THE DATA THAT DR. REDDY HAS GENERATED
FOR THE WATER MANAGEMENT DISTRICT?
A. I'VE WORKED WITH SOME OF HIS DATA, YES.
Q. OKAY. IS THAT AMONG YOUR DOCUMENTS?
A. YEAH, IT'S GOING TO BE IN ONE OF THOSE FOLDERS
THAT WE TALKED ABOUT EARLIER TODAY.
Q. OKAY. WILL IT INDICATE THAT IT WAS DR. REDDY'S
DATA?
A. I THINK WE GIVE HIM -- YEAH, WE SAY SOMETHING LIKE
"REDDY DATA," OR SOMETHING.
Q. OKAY. DO YOU KNOW HOW MUCH OR WHICH OF HIS DATA
YOU WORKED WITH THAT MIGHT HELP US IDENTIFY IT?
A. YEAH, IT WAS HIS PHOSPHORUS ACCUMULATION DATA ON
HIS TRANSECT IN THE GRADIENT.
Q. OKAY. AND THAT'S ALL THAT YOU RECALL?
A. YEAH, THAT'S---
Q. OKAY. AND HAS THERE BEEN ANY SURFACE WATER
CHEMISTRY DATA WORKED WITH, BY EITHER YOURSELF OR
DR. CRAFT PAGE 98
DR. QUALLS, TO THE BEST OF YOUR KNOWLEDGE---
A. DOCTOR---
Q. ---BY THE WATER MANAGEMENT DISTRICT?
A. I HAVE USED A LITTLE BIT OF THEIR DATA. AND IT
IS, AGAIN, IN ONE OF THESE FOLDERS, TO TRY TO
RELATE -- THEY HAVE THE BEST, YOU KNOW, WATER
CHEMISTRY DATA OF ANYBODY AROUND -- BUT TO TRY TO
RELATE THEIR DATA TO OUR SOILS DATA.
Q. OKAY. DO YOU KNOW WHERE THAT WAS AMONG THE
DOCUMENTS THAT WE GOT?
A. THAT, AGAIN, WAS IN ONE OF THOSE GREEN FOLDERS,
AND IT SAYS, PP VERSUS PEAT ACCUMULATION IS WHAT
IT'S IN.
Q. DOES IT -- WILL WE KNOW IT'S THE WATER MANAGEMENT
DISTRICT'S DATA?
A. YEAH, I THINK SO, BECAUSE IN ONE OF THE -- IN THE
GRADIENT MANUSCRIPT, I CITE THEM, AND THEIR
REGRESSION EQUATION AS TO HOW WE, YOU KNOW, USED
THEIR NUMBERS.
Q. OKAY. I GUESS MY FINAL QUESTION IS -- AND I NEED
TO PUT THIS ON THE RECORD -- YOU NEED TO
UNDERSTAND -- THE UNITED STATES FEELS VERY
STRONGLY ABOUT DEPOSING DR. RICHARDSON, THE SECOND
WEEK OF JANUARY, AND IT'S NECESSARY BEFORE WE
DR. CRAFT PAGE 99
DEPOSE DR. RICHARDSON THAT WE DEPOSE HIS PRINCIPAL
RESEARCHERS. WE'VE BEEN WORKING -- AND I
UNDERSTAND THE UNIVERSITY AND YOU TO BE WORKING
COOPERATIVELY WITH THE UNITED STATES TO SCHEDULE
THESE SUBSTANTIVE DEPOSITIONS WHERE WE WILL
QUESTION YOU ON ALL THE ACTUAL RESEARCH OF THE
DATA THAT YOU'VE PRODUCED.
MY UNDERSTANDING IS, IS THAT YOU TEACH
CLASSES OF YOUR OWN AND THAT YOU HAVE TO
SUBSTITUTE TEACH FOR DR. RICHARDSON -- OR YOU
CO-TEACH OR YOU TEAM TEACH A CLASS. IS THAT
RIGHT?
A. RIGHT. WE CO-TEACH.
Q. OKAY. ALL RIGHT. I WOULD JUST LIKE TO KNOW --
YOU TEACH ONE WATER QUALITY CLASS, IS THAT RIGHT?
A. IT'S CALLED APPLIED ECOLOGY IS THE NAME OF THE
CLASS.
Q. OKAY. YOU TEACH APPLIED ECOLOGY. THAT'S THE ONLY
CLASS YOU TEACH?
A. RIGHT.
Q. ALL RIGHT. AND YOU HAVE HOW MANY STUDENTS?
A. APPROXIMATELY SIXTY.
Q. OKAY. AND YOUR CLASSES END WHEN?
A. WE HAVE LECTURES MONDAY -- YOU MEAN, THE END OF
DR. CRAFT PAGE 100
THE SEMESTER?
Q. THE END OF THE SEMESTER, RIGHT.
A. THE LAST WEEK -- AGAIN, I'D HAVE TO CHECK ON THIS,
BUT I THINK THE LAST DAY OF CLASS IS FRIDAY,
DECEMBER 4TH, I THINK.
Q. AND THEN WHEN DO EXAMS BEGIN?
A. THEN THERE'S A WEEK WHERE THEY STUDY FOR EXAMS---
Q. RIGHT.
A. ---AND THEN EXAMS BEGIN THE FOLLOWING WEEK.
Q. OKAY. OKAY. SO, WHAT WE ARE TRYING TO DO IS TO
EITHER HIT THE FIRST WEEK BEFORE THE STUDY WEEK,
OR HIT THE STUDY WEEK---
A. RIGHT.
Q. ---IS THAT RIGHT?
A. THAT WOULD BE -- YEAH, THAT'S FINE WITH ME.
Q. OKAY. AND YOUR CONFLICT, PRESENTLY, THE FIRST
WEEK IS YOU CO-TEACH ON MONDAY AND TUESDAY WITH
DR. RICHARDSON?
A. WELL, HE WILL NOT BE -- I WILL BE TEACHING IN
PLACE OF HIM THOSE DAYS, SO THAT'S---
Q. WHAT---
MS. PONZOLI: I GUESS I OFFER FOR
CONSIDERATION, MR. BURGESS, IF HE WOULD
TAKE TIME OUT TO DO THAT CLASS AND THEN
DR. CRAFT PAGE 101
RETURN TO HIS DEPOSITION, IT MIGHT BE
POSSIBLE.
Q. (BY MS. PONZOLI) WHAT TIME IS THE CLASS?
A. ON MONDAY, IT'S 11:30 TO 12:30, BUT---
Q. RIGHT.
A. ---I HAVE TO LECTURE THAT DAY. AND I FEEL LIKE I
WOULD REALLY NEED THE MORNING TO PREPARE.
Q. OKAY.
A. THERE IS A POSSIBILITY TUESDAY.
Q. RIGHT.
A. THAT'S A LAB, AND THAT DOESN'T REQUIRE SO MUCH
PREP, AT LEAST FOR THAT -- NOT THAT WEEK. SO, I
COULD POTENTIALLY, YOU KNOW, GO -- LEAVE FOR AN
HOUR AND A HALF ON TUESDAY AFTERNOON, AND THEN
COME BACK, BUT THAT'S LIKE 1:30 TO 3:30. BUT I
PROBABLY WOULD NOT BE GONE -- I COULD PROBABLY BE
GONE MAYBE A LITTLE BIT LESS THAN THAT---
Q. OKAY.
A. ---OR IT'S 1:30 TO 3:00, OR SOMEWHERE AROUND
THERE.
Q. I JUST OFFER THAT BY WAY OF POSSIBILITY, THAT WE
COULD DO---
A. OKAY.
Q. ---YOU KNOW, WE DON'T HAVE TO DO A FULL DAY,
DR. CRAFT PAGE 102
ALTHOUGH IT'S THE MOST EFFICIENT FOR EVERYBODY,
IF IT RELIEVES THE SQUEEZE THAT WE'RE HAVING FOR
SCHEDULING.
A. THE LESS TIME THE BETTER---
Q. WELL, I WOULD---
A. ---FOR ME.
Q. ---I MIGHT STILL NEED YOU TWO FULL DAYS, BUT THAT
WOULD STILL LEAVE US -- WE WOULD HAVE MOST OF
TUESDAY, LET'S SAY ALL OF WEDNESDAY. WELL, WE
WOULD BE SHORT. WE'D HAVE TO -- I THINK WE COULD
FINISH THE TWO OF YOU IF WE COULD RUN YOU BACK TO
BACK -- WHENEVER WE FINISH ONE, BEGIN THE NEXT.
THAT MIGHT WORK.
A. OKAY.
Q. THE WEEK OF THE 7TH IS THE STUDY WEEK, SO THAT
LOOKS LIKE OUR BEST POSSIBILITY, DOESN'T IT?
A. (NODS AFFIRMATIVELY.)
MS. PONZOLI: OKAY. ALL RIGHT. LET
ME JUST TAKE ONE SECOND WITH MY PEOPLE AND
MAKE SURE I'VE ASKED YOU EVERYTHING REGARDING
YOUR DATA AND YOUR DOCUMENTS, AND THEN WE'LL
BE FINISHED.
(THEREUPON, A SHORT
BREAK WAS TAKEN.)
DR. CRAFT PAGE 103
MS. PONZOLI: THAT'S ALL, DR. CRAFT. I
THANK YOU. WE'LL SEE YOU IN DECEMBER.
WITNESS: THAT'S IT?
MS. PONZOLI: THAT'S IT FOR TODAY.
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(THEREUPON, THE DEPOSITION WAS CONCLUDED AT 2:34 P.M.)
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DR. CRAFT PAGE 104
NORTH CAROLINA
DURHAM COUNTY
I, CHRISTOPHER BRUCE CRAFT, HAVE
READ THE FOREGOING TRANSCRIPT OF
MY DEPOSITION AND DO HEREBY CERTIFY
THAT THE PRECEDING 103 PAGES
CONSTITUTE A TRUE AND ACCURATE
TRANSCRIPTION OF MY TESTIMONY.
______________________________
CHRISTOPHER BRUCE CRAFT
SWORN TO AND SUBSCRIBED
BEFORE ME, A NOTARY PUBLIC,
THIS THE ____ DAY OF ________________,
1992.
_______________________________
NOTARY PUBLIC
MY COMMISSION EXPIRES:
_______________________________