DR. CRAFT VOLUME II PAGE 374 THE FOLLOWING PORTION OF THE DEPOSITION OF DR. CHRISTOPHER B. CRAFT WAS TAKEN ON THE 8TH DAY OF DECEMBER, 1992, BEGINNING AT OR AROUND 10:26 A.M. IN THE HILTON HOTEL, DURHAM, NORTH CAROLINA, AND WAS REPORTED BY CAROL ANN S. YOUNG, A NOTARY PUBLIC. - - - - - - - - - - WHEREUPON, DR. CHRISTOPHER B. CRAFT, HAVING PREVIOUSLY BEEN DULY SWORN, WAS EXAMINED AND TESTIFIED AS AS FOLLOWS: EXAMINATION BY MS. PONZOLI CONTINUES: Q. DR. CRAFT, I HAVE A FEW CLEAN-UP QUESTIONS AND THEN I HAVE A FEW MORE QUESTIONS ON A COUPLE OF AREAS THAT WE DIDN'T TALK ABOUT YESTERDAY. ONE CLEAN-UP QUESTION I HAVE IS IN REGARD TO CRAFT NUMBER SIXTEEN, YOUR PEAT ACCRETION AND NUTRIENT ACCUMULATION ALONG THE EUTROPHICATION GRADIENT IN THE NORTHERN EVERGLADES. I WOULD JUST LIKE YOU TO TURN TO THE DRAFT GRAPH AT THE END. ARE YOU WITH ME? A. UH-HUH (YES). (NODS AFFIRMATIVELY) Q. THAT LITTLE PHOSPHORUS ACCUMULATION POINT AT TEN DR. CRAFT VOLUME II PAGE 375 KILOMETERS FROM THE HILLSBORO CANAL, IS THAT AN OUTLIER? A. I REALLY DON'T KNOW. Q. DO YOU KNOW WHY THAT POINT IS SO FAR OFF THE CURVE? A. WELL, IT'S NOT OFF THE CURVE IN TERMS OF THE PEAT ACCUMULATION LINE, WHICH IS THE SLASH LINE. IT'S OFF THE CURVE FOR THE SURFACE WATER ACCUMULATION FLOW OR SURFACE WATER CONCENTRATION. Q. CAN YOU ACCOUNT FOR WHY EVERYTHING ELSE SEEMS TO MATCH SO WELL AND THAT ONE SEEMS TO BE DISTINCTLY DIFFERENT? A. NO, I REALLY DO NOT KNOW, AND I DON'T THINK IT IS ALL THAT DIFFERENT WHEN YOU COMPARE THAT ACCUMULATION NUMBER TO THE ONE LIKE, SAY, AT EIGHT KILOMETERS SOUTH. Q. WELL, THE ONE AT EIGHT WAS PRECEDING DOWNWARD FROM THE ONE AT SIX, AND THIS ONE JUMPS BACK UP AGAIN. A. BUT, AGAIN, I THINK YOU MIGHT -- IT MIGHT BE WORTHWHILE TO GO BACK TO THE ONE OF THE TABLES AND SEE HOW THE -- WHAT THE ERRORS ARE ASSOCIATED WITH THESE. Q. WHICH TABLE ARE YOU AT? DR. CRAFT VOLUME II PAGE 376 A. THIS IS TABLE 4. AND, AGAIN, I SEE IN THIS CASE, THE AVERAGE ACCUMULATION RATE AT THAT TEN POINT IS .13 GRAMS PER METER SQUARED PER YEAR. THE ERROR -- THE STANDARD ERROR IS GOING TO BE SOMEWHERE BETWEEN ZERO AND .01, THE ROUNDING ERROR, OF COURSE. AND IF YOU LOOK AT THE 8.3 SITE, IT'S .8 WITH A STANDARD ERROR OF .03, WHICH BRINGS IT UP TO POINT -- YOU KNOW, IT COULD GO UP TO -- GENERALLY SOME PEOPLE USE TWO STANDARD ERRORS AS A RANGE OF WHETHER THEY'RE SIGNIFICANTLY DIFFERENT ARE NOT. AND, AGAIN, I DON'T THINK THE .08 AND THE .13 REALLY DIFFER THAT MUCH. Q. SO, YOU'RE SAYING THEY'RE STATISTICALLY DIFFERENT? A. OH, I'M NOT SAYING THAT BECAUSE I DIDN'T DO THE TEST. Q. OKAY. I'D LIKE TO LOOK AT CRAFT NUMBER TWENTY-SIX, WHICH I THINK IS -- SHOULD BE IN FRONT OF YOU. (THEREUPON, WITNESS GETS DOCUMENT.) A. OKAY. I HAVE IT IN FRONT OF ME. Q. OKAY. HAS THIS -- IS THIS A DRAFT PUBLICATION THAT YOU'RE SUBMITTING? A. YES, IT'S IN DRAFT FORM. DR. CRAFT VOLUME II PAGE 377 Q. ALL RIGHT. AND ARE YOU INTENDING TO SUBMIT IT TO AQUATIC BOTANY? A. I'M LEANING IN THAT DIRECTION. AGAIN, I THINK I MAY TALK TO ONE OF THE EDITORS TO SEE WHETHER IT'S REALLY APPROPRIATE FOR THAT JOURNAL BEFORE I SEND IT THERE. Q. OKAY. SO, THAT ANSWERS MY NEXT QUESTION. YOU HAVEN'T SUBMITTED IT ANYWHERE? A. NO. NO, IT HAS NOT GONE OUT. Q. OKAY. HAVE YOU -- IS THIS THE MOST RECENT DRAFT OF IT? A. YES. Q. DO YOU INTEND TO MAKE ANY CHANGES BEFORE YOU DO SUBMIT IT? A. I'M DEFINITELY GOING TO HAVE DR. RICHARDSON REVIEW IT ONE MORE TIME BEFORE I SEND IT OUT. AND I, OF COURSE, WILL LOOK AT IT. SO, IT'S NOT READY, IT'S PROBABLY A MONTH AWAY, BUT IT'S CLOSE. Q. OKAY. WE DISCUSSED TWO PUBLICATIONS YESTERDAY AND WE'RE GOING TO TAKE JUST A SECOND AND LOOK AT THIS ONE. ARE THERE ANY OTHER PUBLICATIONS THAT YOU HAVE READY TO BE SUBMITTED THAT I HAVE NOT--- A. NO. THE TWO ARE THIS ONE AND THE ONE THAT WE JUST DR. CRAFT VOLUME II PAGE 378 ADDRESSED, THE PEAT ACCRETION AND NUTRIENT ACCUMULATION. Q. OKAY. I'D LIKE YOU TO LOOK IN THE ABSTRACT AT THE FINAL PARAGRAPH AND I WOULD JUST LIKE YOU TO TAKE A SECOND AND READ THAT FINAL PARAGRAPH OF THE ABSTRACT, AND ASK YOU IF YOU STILL CONCUR WITH WHAT'S WRITTEN THERE? (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. YES, I THINK, I CONCUR WITH THIS. Q. OKAY. AND YOU HAVE NO DATA THAT SHOWS DIFFERENT INFORMATION? A. NO, NOT AT THIS TIME. Q. OKAY. WOULD YOU TURN TO THE NEXT PAGE AND THE INTRODUCTION, PLEASE. AND FOUR LINES UP FROM THE BOTTOM IS A SENTENCE THAT STATES, "CONCURRENT WITH THIS INPUT HAS BEEN A SHIFT IN THE STRUCTURE AND COMPOSITION OF NATIVE EVERGLADES PLANT COMMUNITIES." DO YOU STILL CONCUR WITH THAT STATEMENT? (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. YES. BASED ON WHAT THE LITERATURE SHOWS TO THIS TIME, YEAH. Q. OKAY. AND THEN AT THE END, IN THE CONCLUSIONS, DR. CRAFT, YOU HAVE "CONCLUSIONS." ARE THESE DR. CRAFT VOLUME II PAGE 379 CONCLUSIONS STILL VALID? WOULD YOU -- IF YOU'LL JUST TAKE A SECOND AND READ THROUGH HERE AND TELL ME THAT YOU STILL BELIEVE THESE ARE VALID AND HAVE NO DATA THAT'S INDICATING THAT YOU WILL CHANGE THESE? (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. I CAN'T SAY WHETHER I'LL CHANGE THESE OR NOT. I MEAN, FOR THE MOST PART, THEY WILL NOT BE CHANGED. Q. FOR THE MOST PART? A. WELL, THE ONLY THING I MIGHT CHANGE -- WELL, I CAN'T, YOU KNOW--- Q. RIGHT. A. ---IS -- I FEEL LIKE AT THIS POINT WE DON'T HAVE ENOUGH DATA ON THE SHIFT -- THE POTENTIAL SHIFT THAT MIGHT OCCUR FROM SAWGRASS TO CATTAIL IN THAT LAST PARAGRAPH, NOR WAS THERE A NOTED INCREASE IN CATTAIL IN THE FERTILIZED PLOTS. I MAY NOT -- THAT MAY COME OUT OF THE CONCLUSIONS. I FEEL LIKE AT THIS POINT -- WE DIDN'T HAVE ANY PRE-TREATMENT INFORMATION WITHIN THE PLOTS ON WHAT THE CATTAIL DENSITY WAS. BUT AFTER ONE YEAR, WE HAVE CATTAIL DATA. AND AFTER TWO YEARS, WE HAVE MORE CATTAIL DATA. SO, I THINK, I WILL NOT DR. CRAFT VOLUME II PAGE 380 REALLY ADDRESS THAT UNTIL WE WRITE UP THE TWO YEARS WORTH OF DATA. Q. SO, YOU'RE GOING TO TAKE OUT THE PART FROM -- MORE TOWARD THE END--- A. I THINK I MAY TAKE THAT OUT--- Q. OKAY. A. ---THAT WILL BE THE ONE THING THAT I WOULD DEFINITELY REVIEW. Q. ALL RIGHT. AND THEN WAS THERE ANOTHER -- WAS THERE ANOTHER STATEMENT THAT YOU SAID YOU MIGHT ALTER? A. NO. I MEAN, I'M NOT GOING TO STATE EMPHATICALLY THAT IT WILL NOT CHANGE--- Q. I'M NOT ASKING FOR THAT -- I'M NOT ASKING FOR THAT. A. ---AGAIN, YOU KNOW, I THINK THAT'S SOMETHING I WANT TO LOOK AT HERE. BUT, REALLY, EVERYTHING ELSE WILL PROBABLY STAY IN THERE. Q. I'D LIKE TO TAKE JUST ONE TINY QUESTION ON CRAFT NUMBER TWENTY-THREE -- MAYBE TWO TINY QUESTIONS. A. OKAY. Q. THIS IS IN REGARD TO THE APPLICATION OF BROMIDES TO TRACE FERTILIZER AMMONIUM AND EVERGLADES MICROCOSM. DID YOU WRITE THIS? DR. CRAFT VOLUME II PAGE 381 A. YES. Q. OKAY. SO, WHEN YOU SAY, "I FAVOR SUGGESTION NUMBER ONE ON THE SECOND PAGE," YOU WERE IN FAVOR OF A SINGLE ANNUAL APPLICATION OF FERTILIZER? A. AT THE TIME I WROTE THIS, YES. Q. OKAY. WHY WAS THAT? A. MY MAIN INTEREST WHEN I STARTED THIS STUDY WAS THE EFFECT ON THE MACROPHYTES AND I FEEL LIKE -- WELL, I FELT LIKE, AND TO SOME EXTENT I STILL FEEL LIKE, FOR MACROPHYTES TO REALLY SEE THE RESPONSE, YOU SHOULD APPLY IT DOING THE DRIEST TIME OF YEAR WHEN MOST -- YOU HAVE THE GREATEST PROBABILITY OF RETAINING ALL THE FERTILIZER OR MOST OF IT IN THE PLOTS. AND AFTER I TALKED TO DR. VYMAZAL, WHO WAS INTERESTED IN DOING SOME WORK IN THE PLOTS, WE DECIDED TO LOOK AT THE EFFECTS OF PERIPHYTON, A SINGLE DRY SEASON APPLICATION PROBABLY WOULD NOT PROVIDE ANY INFORMATION ON LOOKING AT PERIPHYTON CHANGES. AND FOR THAT REASON WE STARTED GOING TO SPREADING IT MORE EVENLY THROUGHOUT THE YEAR. Q. OKAY. IS THAT SECOND SENTENCE, WE ARE INTERESTED IN DETERMINING IF AND AT WHAT LEVELS FERTILIZERS, NITROGEN AND PHOSPHORUS, CAUSE A SHIFT FROM A DR. CRAFT VOLUME II PAGE 382 SAWGRASS MARSH TO A WETLAND DOMINATED BY CATTAILS--- A. WHERE -- IS THIS ON THE FIRST PAGE? Q. SECOND PAGE. A. AND WHERE IS THIS? Q. RIGHT AFTER, "I FAVOR SUGGESTION NUMBER ONE." A. OKAY. Q. IS THAT PRETTY CLOSE TO A HYPOTHESIS? A. YES. AND AFTER THINKING ABOUT YESTERDAY'S QUESTIONS, I DO HAVE SOME -- THEY WEREN'T EXPLICIT HYPOTHESIS IN THIS STUDY, BUT WE HAD OBJECTIVES AND WITHIN THOSE ARE SOME IMPLICIT HYPOTHESES. Q. OKAY. AND ARE THOSE OBJECTIVES STATED IN YOUR CHAPTERS IN THE ANNUAL REPORTS? A. YES, YES. AND I DON'T KNOW IF YOU SHOULD UNDERSTAND, BUT I WOULD LIKE YOU ALL TO UNDERSTAND THAT BY LATE IN THE DAY YESTERDAY AND WITHOUT HAVING ANY OF THE DOCUMENTATION IN FRONT OF ME, THAT -- WELL, I REALLY JUST WASN'T THINKING. AND, YOU KNOW, I THINK I'VE PROBABLY WRITTEN CLOSE TO A MILLION WORDS IN THE PAST THREE OR FOUR YEARS AND IT'S HARD TO BE ABLE TO RECALL EVERYTHING FROM MEMORY. SO, IT'S NICE TO HAVE THE LITERATURE IN FRONT OF ME, SO. DR. CRAFT VOLUME II PAGE 383 Q. WELL, I WOULD HAVE HAD COPIES FOR YOU YESTERDAY, BUT WE HAD SOME SEVERE PROBLEMS BEING SO FAR AWAY FROM HOME. A. OKAY. Q. MY NEXT QUESTION IS IS THAT IF THERE WERE TO BE A SHIFT FROM A SAWGRASS MARSH TO A WETLAND DOMINATED BY CATTAILS, HOW DO YOU THINK THAT SHIFT WOULD TAKE PLACE? A. WELL, I DON'T REALLY KNOW, BUT I THINK THE STUDY -- THE FERTILIZER STUDY TRIES TO ADDRESS THAT BY EACH OF THE THREE SITES. AND AT THE SAWGRASS SITE, IT'S -- THE PLOTS ARE PURE SAWGRASS, THERE'S NO CATTAIL IN THEM. AND IF WE WERE TO SEE CATTAIL INVADE THOSE PLOTS, IT WOULD CERTAINLY SUGGEST THE SEEDS COMING IN AND THEN GERMINATING. AT THE MIXED SITE WHERE THERE IS CATTAIL IN ALL THE PLOTS, IF WE SAW A CATTAIL EXPANSION THERE, THAT WOULD CERTAINLY SUGGEST THAT IT'S VEGETATIVE REPRODUCTION. THEY ARE THERE TO BEGIN WITH AND THEY JUST OUT COMPETE OR COMPETE MORE SUCCESSFULLY FOR THE RESOURCES THAN SAWGRASS. AND AT THE SLOUGH SITE IS KIND OF -- WELL, A ROUNDABOUT WAY TO LOOK AT THE EFFECTS OF WATER LEVEL, THERE HAVE BEEN SOME DR. CRAFT VOLUME II PAGE 384 PEOPLE HYPOTHESIZE -- I THINK POPE -- AND AGAIN THIS IS FROM MEMORY -- THAT HE SUGGESTED THAT WHAT CATTAIL DOES IS IT TENDS TO COLONIZE THESE DEEPER AREAS SUCH AS SLOUGHS AND THEN MOVES INTO THE SAWGRASS AREAS. AND IF WE WERE TO SEE THAT AT THE SLOUGH, THAT WOULD SUGGEST THAT PERHAPS THAT IS THE MECHANISM THAT OCCURS. Q. WHAT PHYSICAL FACTORS, SPECIFICALLY WATER LEVELS, WOULD YOU EXPECT TO SEE IN A SHIFT? A. MAYBE REPHRASE THE QUESTION. I'M NOT QUITE SURE I'M--- Q. IF YOU'RE LOOKING TO SEE A SHIFT IN THE GENERAL EVERGLADES, WHAT WATER LEVELS DO YOU THINK YOU'RE GOING TO NEED TO SEE? A. TO A SHIFT FROM SAY SAWGRASS TO CATTAIL? Q. UH-HUH (YES). A. I THINK DEEPER WATER PROBABLY WOULD HAVE A ROLE IN THAT, AND MAYBE THE DURATION OF THE HYDROPERIOD, ALTHOUGH I DON'T REALLY KNOW ABOUT THAT. Q. AND HOW WOULD THEY PROPAGATE? IS THAT THE PROPER TERM? A. I DON'T KNOW. IT COULD BE VEGETATIVE OR IT COULD BE THE SEED GERMINATION. IN THAT CASE, PERHAPS, VEGETATIVE, I MEAN, THERE IS -- WE FOUND CATTAIL DR. CRAFT VOLUME II PAGE 385 IN CONSERVATION AREAS 3A AND 2A. THERE IS SOME CATTAIL EVERYWHERE, PERHAPS NOT IN THE KIND OF DENSITIES THAT YOU SEE IN 2A. AND IT'S POSSIBLE THAT THE COMBINATION OF DEEPER WATERS AND/OR NUTRIENT ENRICHMENT CAUSES THIS SHIFT. Q. CAN THEY GERMINATE IN DEEPER WATER? A. I DON'T THINK SO, BUT I DON'T KNOW. I THINK THEY DO REQUIRE A PERIOD WHERE YOU DON'T HAVE ANY SURFACE WATER OR SOMETHING. BUT, AGAIN, I DON'T KNOW ENOUGH ABOUT HOW CATTAIL -- THE GERMINATION REQUIREMENTS FOR CATTAIL SEEDS. Q. DO YOU HAVE ANY IDEA ABOUT THE NUTRIENT LEVELS THAT THEY NEED? A. NO, I DON'T KNOW. BUT I THINK THIS STUDY, IF WE CONTINUE TO FERTILIZE LONG ENOUGH, WE WILL BE ABLE TO DETERMINE WHETHER -- THE RELATIVE ROLE OF THESE ADDITIONS ON THE SHIFT. Q. I'D LIKE YOU TO LOOK AT CRAFT NUMBER THIRTY-TWO. I THINK I JUST REPRODUCED THE ONE DOCUMENT THAT I'M INTERESTED IN. SO, YOUR THIRTY-TWO IS A LOT BETTER THAN MY THIRTY-TWO. THIS IS A LETTER FROM ONE OF THE COUNSEL AT THIS TABLE TO ONE OF THE RESEARCHERS AT THIS TABLE, DR. RICHARDSON, REGARDING DRAFT EVERGLADES NUTRIENT THRESHOLD DR. CRAFT VOLUME II PAGE 386 STUDY PLAN. AND I WOULD LIKE TO KNOW HOW YOU GOT THIS? A. I BELIEVE -- ALTHOUGH I DON'T REMEMBER EXACTLY -- BUT DR. RICHARDSON PERIODICALLY PASSES INFORMATION ON TO ME THAT HE THINKS MIGHT BE OF INTEREST TO ME. Q. ARE YOU ASKED TO REVIEW THAT INFORMATION? A. NO. MORE JUST -- IT JUST GIVES ME A BETTER IDEA OF WHAT OTHER STUDIES ARE GOING ON AND--- Q. SO, YOU DON'T -- YOU DON'T, LIKE, REVIEW IT AND GO BACK TO DR. RICHARDSON AND TELL HIM WHAT YOU THINK OF IT? A. NO. Q. ALL RIGHT. THE NEXT DOCUMENT I'D LIKE TO ASK YOU ABOUT IS CRAFT NUMBER SIX. THIS IS IN A FILE LABELED "N AND P." I GUESS I'VE ONLY REPRODUCED FOR YOU CERTAIN PAGES FROM THIS FILE SO LET ME JUST ASK YOU ABOUT THOSE. IF I SHOW YOU THE FILE IT WAS FROM, CAN YOU TELL ME--- A. MAY I LOOK AT IT, PLEASE? Q. SURE. THAT'S THE WHOLE FILE AS YOU PRODUCED IT TO US. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. ALL RIGHT. DR. CRAFT VOLUME II PAGE 387 Q. WHAT IS THAT FILE, DR. CRAFT? A. THIS RELATES TO THE -- THIS IS THE FILE THAT HAS THE DATA ON THE PAPER THAT'S BEEN ACCEPTED BY ECOLOGICAL APPLICATIONS. Q. OKAY. THE PAGE THAT I BELIEVE THAT HAS BEEN REPRODUCED FOR YOU HAS "STRUCTURE, PHOSPHORUS LOAD, TREATMENT AREA, AND PHOSPHORUS STORAGE." RIGHT? A. RIGHT. Q. OKAY. I WOULD LIKE FOR YOU TO EXPLAIN TO ME WHAT THIS PAGE IS ABOUT, AND WHAT THE NUMBERS REPRESENT? A. I'M NOT SURE. I KNOW THAT THE LOAD IS -- I TOOK OUT OF THE SWIM PLAN. THIS IS, I THINK, WHAT GOES THROUGH THESE RESPECTIVE GATES IN METRIC TONS PER YEAR. I'M NOT SURE ABOUT THE TREATMENT AREA AND THE P STORAGE. I MEAN, I KNOW WHAT THEY MEAN, BUT I'M NOT SURE HOW I CALCULATED THESE NUMBERS OR WHETHER I TOOK THEM FROM SOMEWHERE. Q. DO THOSE NUMBERS LOOK REMOTELY FAMILIAR TO YOU? A. NOT REALLY. I DON'T THINK THEY'RE IN THE MANUSCRIPT. Q. WELL, LET'S ASSUME THAT THOSE ARE STA'S FOR EACH OF THOSE STRUCTURES. DR. CRAFT VOLUME II PAGE 388 A. IS THAT WHAT THEY ARE? I DON'T--- Q. WELL, I DON'T KNOW. YOU WROTE THIS--- A. ---REFRESH MY MEMORY. Q. ---I DIDN'T. BUT THEY LOOK PRETTY FAMILIAR TO ME. LET'S ASSUME THAT THEY ARE STA'S FOR S5A 6, 7, AND 8, AND THAT YOU TOOK THEM FROM THE SWIM PLAN OR SOMEWHERE ELSE. BUT YOU'VE GOT PHOSPHORUS STORAGE OVER TO THE RIGHT. I'D LIKE FOR YOU TO RECONSTRUCT FOR ME HOW YOU THINK YOU MIGHT HAVE DONE THAT. A. I'M WONDERING IF I DIVIDED THESE NUMBERS TO TREAT -- I'M NOT SURE WHERE THE TREATMENT AREA NUMBERS COME FROM THOUGH. THEY CERTAINLY DON'T SUM UP TO THAT NUMBER AT THE BOTTOM, THOUGH, THE 3260. Q. MAYBE YOU LEFT OFF A ZERO. A. WELL, THAT COULD BE. Q. WELL, ASSUMING YOU LEFT OFF A ZERO, DO YOU THINK YOU -- THAT THAT'S WHAT YOU ACTUALLY DID, WAS DIVIDE OUT? A. I THINK SO, BUT AGAIN I'M NOT A HUNDRED PERCENT SURE. Q. AND AREN'T THESE PHOSPHORUS STORAGE NUMBERS SIGNIFICANTLY LOWER THAN THOSE THAT YOUR RESEARCH DR. CRAFT VOLUME II PAGE 389 WOULD SHOW? A. THEY ARE. THEY'RE DEFINITELY LOWER THAN SOME OF THE NUMBERS THAT I'VE CALCULATED. Q. OKAY. DO YOU HAVE ANOTHER PAGE, OR DO YOU JUST HAVE THE SINGLE PAGE? A. THAT'S IT. Q. THAT'S FINE. I'D LIKE YOU TO LOOK AT CRAFT NUMBER TEN. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. OKAY. DO YOU HAVE THE WHOLE FILE, DR. CRAFT? A. I THINK I DO. Q. OKAY. WHAT FILE IS THIS? A. THIS IS -- IF I AM CORRECT, THIS IS THE VEGETATION -- THE DEPARTMENT OF VEGETATION PLOTS ON THE GRADIENT. Q. OKAY. IT SAYS SPECIAL COMPOSITION, 1992. A. SPECIES COMPOSITION. Q. OH. I'M SORRY, SPECIES. YOU'RE RIGHT. I READ IT WRONG. I'D LIKE YOU TO TURN TO THE FIRST PAGE IN THAT FILE AND IF YOU WOULD EXPLAIN TO ME WHAT THIS DATA REPRESENTS? A. WE WERE TRYING TO SET UP AN EXPERIMENT. WE WERE THINKING ABOUT SETTING UP AN EXPERIMENT LOOKING AT THE EFFECTS OF WATER LEVEL AND PHOSPHORUS ON -- DR. CRAFT VOLUME II PAGE 390 AND FIRE -- ON A CONTROL OF CATTAIL IN CONSERVATION AREA 2A. THESE ARE OUR PERMANENT EIGHTEEN PLOTS. THIS IS P CONCENTRATION AND PEAT DEPOSITED OVER THE PAST TWENTY-FIVE YEARS FROM MY PAPER. THIS IS SOME WATER LEVEL DATA FROM THOSE SAME PLOTS. I THINK THIS IS THE AVERAGE WATER LEVEL FOR A YEAR PERIOD THAT DR. QUALLS COLLECTED. AND THIS IS THE RELATIVE -- THE PERCENTS SAWGRASS AND PERCENT CATTAIL FROM DATA THAT I COLLECTED AT EACH OF THE PLOTS. AND WE WERE GOING TO USE THIS TO TRY TO DETERMINE WHERE TO SET UP THESE -- THESE PLOTS. Q. ALL RIGHT. HAS DR. QUALLS BEEN COLLECTING WATER LEVEL DATA FOR A YEAR? A. YES, AND PERHAPS LONGER. Q. HOW LONG DO YOU THINK HE'S BEEN COLLECTING IT? A. I DON'T KNOW. YOU WOULD HAVE TO TALK HIM ABOUT THAT. AND I'M SURE YOU'LL GET YOUR CHANCE TOMORROW, SO. Q. BUT THERE'S BEEN NO CORRELATION BETWEEN THOSE WATER LEVELS PRIOR TO NOW AND YOUR OTHER WORK ALONG THE GRADIENT? A. I TOOK THESE WATER LEVELS AND TRIED TO CORRELATE THEM TO THE PEAT ACCRETION RATES AND NUTRIENT DR. CRAFT VOLUME II PAGE 391 ACCUMULATION RATES ON THE GRADIENT, BUT THERE WAS NO CORRELATION ESSENTIALLY. Q. HAVE YOU DRAWN ANY CONCLUSIONS FROM LOOKING AT THIS DATA? A. IN TERMS OF -- REPHRASE THE QUESTION, PLEASE. Q. IN LOOKING AT THIS DATA, DO YOU DRAW ANY CONCLUSIONS REGARDING, LET'S SAY, EVEN THE WETNESS OR THE DRYNESS OF YOUR TRANSECT? A. WELL, IT BASICALLY APPEARS THAT THE "A" TRANSECT IS A LITTLE BIT WETTER, BUT THIS IS A YEAR'S WORTH OF DATA. AND ACTUALLY WHEN WE DID THE CORRELATION ANALYSIS, THERE WAS NO CORRELATION WITH DISTANCE OR ALONG THE TRANSECT. Q. DO YOU THINK THAT "A" IS ONLY A LITTLE BIT WETTER THAN "D"? A. WELL, WHAT I'M SAYING IS STATISTICALLY I RECALL, ALTHOUGH I'M NOT A HUNDRED PERCENT SURE, THAT THERE WAS A NOT A GOOD CORRELATION BETWEEN WATER LEVEL AND DISTANCE OR TRANSECT. BUT, AGAIN, I WOULD HAVE TO GO BACK AND LOOK AT THE CORRELATION MATRIX. Q. WHAT ABOUT CORRELATION BETWEEN THE WATER LEVEL AND THE CATTAIL PERCENTAGE OR THE VEGETATION? A. DOES NOT APPEAR TO BE A GOOD CORRELATION THERE. DR. CRAFT VOLUME II PAGE 392 Q. OKAY. HAVE YOU WRITTEN UP YOUR EXPERIMENT? A. NO. THIS IS -- HAS JUST SORT OF -- THIS IS, I THINK, THE EXTENT OF IT REALLY. THERE MAY BE A PARAGRAPH OR A PAGE IN HERE RELATING TO IT, BUT THERE MAY NOT EVEN BE THAT. Q. DO YOU KNOW IF THERE ARE ANY PLANS TO CONTINUE THIS DATA COLLECTION? A. AT THE GRADIENT? Q. RIGHT. A. YOU MEAN LIKE WATER LEVEL? Q. RIGHT. A. I THINK THERE HAS BEEN TALK OF CONTINUING IT, BUT, AGAIN, I HAVE NOT BEEN INVOLVED IN THAT, SO. Q. OKAY. IS THERE ANY TALK OF SETTING UP THE EXPERIMENT THAT YOU ASKED FOR? A. THAT, I THINK, WE MAY DO. IT'S CERTAINLY ON THE DRAWING BOARD AND HAS BEEN TALKED ABOUT. Q. DO YOU PLAN TO ADD ANY OF THE SECOND YEAR DATA TO PUT TOGETHER WITH THE WATER LEVELS? A. CERTAINLY. THE MORE WATER LEVEL DATA WE HAVE, THE BETTER, I FEEL LIKE. Q. OKAY. ARE THESE RESULTS REFLECTED IN YOUR DRAFT NUMBER SIXTEEN? A. THE P IS, BUT THE WATER LEVEL WE DID NOT INCLUDE DR. CRAFT VOLUME II PAGE 393 BECAUSE THERE WAS NO CORRELATION. WE COULDN'T -- WE HAD HOPED TO RELATE WATER LEVEL TO THE -- TO INCREASED PEAT ACCRETION. BUT AGAIN I FEEL LIKE A YEAR'S WORTH OF WATER LEVEL DATA IS JUST NOT SUFFICIENT. Q. WHAT DO THE ASTERISKS MEAN? A. I THINK THOSE ARE AREAS WHERE WE POTENTIALLY WOULD TRY TO SET UP OUR PLOTS. Q. YOU MEAN PERMANENT PLOTS FOR CORRELATING WATER LEVEL WITH--- A. NO. TO LOOK AT THE EFFECTS OF P WATER LEVEL AND FIRE ON SAWGRASS AND CATTAIL. Q. OKAY. WHY ARE YOU CHOOSING THESE SITES? A. WELL, I THINK THERE ARE -- THEY'RE CHARACTERIZED BY -- SOME OF THEM HAVE HIGH PE AND HIGH WATER LEVEL; SOME OF THEM HAVE LOW PE AND HIGH WATER LEVEL. AND, OF COURSE, WE WERE TRYING TO FIND THAT RIGHT MIX OF CATTAIL AND SAWGRASS, TOO, I THINK. Q. DO YOU HAVE ANY IDEA WHEN THIS EXPERIMENT MIGHT BE FIRMED UP AND PRESENTED IN THE FORM OF A PROPOSAL OR--- A. IT WOULD BE IN THE SPRING. I MEAN, I SEE -- IF THIS GOES THROUGH, WE WOULD PROBABLY TRY TO SET IT DR. CRAFT VOLUME II PAGE 394 UP NEXT SUMMER. Q. YOU WOULD START THE ACTUAL DATA COLLECTION NEXT SUMMER? A. NO. THE PREPARING THE SITES. AND PROBABLY THE DATA COLLECTION WOULD NOT START UNTIL LATE SUMMER OR EVEN EARLY FALL. AGAIN, WE HAVEN'T -- WE'VE TALKED ABOUT THIS, AND THIS IS THE EXTENT OF IT, BUT WE HAVEN'T REALLY--- Q. CAN YOU FIND ANY LOW P AND CATTAIL ON HERE FOR ME, DR. CRAFT? A. NO, YOU CANNOT FIND ANY IN THAT. Q. DOES THAT TELL YOU ANYTHING? A. IT DOES SUGGEST SOMETHING, YES. Q. WHAT? A. IT SUGGESTS THAT MAYBE NUTRIENT ENRICHMENT OR PHOSPHORUS ENRICHMENT PLAYS A ROLE IN THE CATTAIL EXPANSION. BUT, AGAIN, I DO THINK WATER LEVEL IS SOMETHING THAT NEEDS TO BE ADDRESSED. Q. ALL RIGHT. YOU HAVE -- FOLLOWING THAT PAGE, YOU HAVE A GRAPH AND THEN YOU HAVE -- I GUESS THERE -- YOU HAVE A SUMMARY OF SOME PERCENTAGES OF CATTAIL, SAWGRASS, OTHER, FROM JULY '89--- A. I SEE IT. Q. ---IS THIS YOUR--- DR. CRAFT VOLUME II PAGE 395 A. THAT'S MY WRITING, YES. Q. IT IS YOUR WRITING. BUT DID YOU COMPILE THESE NUMBERS OR NOT? A. NO, I COMPILED THEM. Q. YOU DID? A. YES. Q. YOU ACTUALLY WENT OUT AND LOOKED AT THE VEGETATION? A. RIGHT. THIS IS JUST A SUMMARY FROM SOME OF THIS OTHER STUFF. Q. OKAY. OKAY. AND THEN FOLLOWING THAT, YOU HAVE GRADIENT STUDY, VEGETATION SAMPLING. I GUESS THESE ARE LIKE FIELD NOTES. IS THAT WHAT THEY ARE? A. THIS IS THE ACTUAL DATA SHEETS WHERE WE DETERMINED, YOU KNOW, THE PERCENTAGE CATTAIL, SAWGRASS, AND OTHER VEGETATION AT EACH OF THE POINTS. Q. THIS IS YOUR CONTINUING STUDY, IS THAT RIGHT? A. IN TERMS OF THIS -- THESE CHANGES IN SPECIES COMPOSITION ON THE GRADIENT, YES. Q. JUST SO I'M CLEAR, IS THIS THE VEGETATION STUDY THAT CONTINUES THROUGH TIME OR NOT? A. RIGHT, RIGHT. DR. CRAFT VOLUME II PAGE 396 Q. OKAY. OKAY. I'D LIKE TO KNOW WHAT THE RELATIONSHIP -- IF YOU MOVE THROUGH THIS FILE, I THINK YOU SEE -- OH, NO -- WELL, IT'S NOT THIS FILE, I'M WRONG. IT'S THE NEXT ONE WE'RE GOING TO GET TO. I WANT TO WAIT TILL WE GET THERE. DO YOU HAVE ANY CONCLUSIONS FROM THIS, PRESENTLY, FROM THIS WORK? A. I DON'T REALLY HAVE ANY CONCLUSIONS, I HAVEN'T WRITTEN IT UP. MAYBE IN NEXT YEAR'S REPORT WE'LL -- WE'LL HAVE A SMALL -- SMALL CHAPTER. AGAIN, THE PROBLEM WITH THIS KIND OF DATA, I THINK IT'S USEFUL AND PROVIDES INFORMATION, BUT BY ITSELF, YOU REALLY CAN'T -- YOU CAN'T DO A WHOLE LOT WITH IT IN TERMS OF TRYING TO WRITE IT UP AS A SCIENTIFIC PAPER. IF I HAD SOME MORE INFORMATION ON PLANT COMMUNITIES OUT THERE, I COULD MAYBE DO SOMETHING WITH IT. Q. WHAT KIND OF INFORMATION WOULD YOU NEED? A. WELL, WE HAVE THE N AND P CONTENT OF THE SHOOTS AND THE ROOTS OF PLANTS ON THESE TRANSECTS AND THAT HELPS. BUT WHAT, I THINK, IS REALLY MISSING WOULD BE SOME ESTIMATE OF PRODUCTIVITY AT EACH OF THE POINTS OF EITHER STANDING CROP BIOMASS OR PHOTOSYNTHESIS RATE OR SOMETHING LIKE THAT. DR. CRAFT VOLUME II PAGE 397 Q. OKAY. AND WHY CAN'T YOU GET THAT KIND OF INFORMATION? A. BASICALLY, I JUST DON'T HAVE THE TIME TO GO OUT AND DO IT. THIS WOULD INVOLVE -- I MEAN, I'VE THOUGHT ABOUT HOW TO DO, CLIPPING FOUR PLOTS AT EACH OF THE POINTS WHICH QUICKLY GIVES ME SEVENTY-TWO CLIP PLOTS, WHICH REALLY THE COMBINATION OF THE ACCRETION WORK AND THE FERTILIZER STUDY TAKE UP JUST SO MUCH OF MY TIME. AGAIN, I THINK THIS IS SOMETHING THAT WOULD BE WORTH DOING. PERHAPS YOU CAN RECOMMEND A GRADUATE STUDENT WHO WOULD BE INTERESTED IN DOING A MASTER'S THESIS ON SOMETHING LIKE THIS. Q. I THINK I'M A GROWTH INDUSTRY ALREADY. MR. GREEN: THAT'S DEBATABLE. Q. I HAVE, I THINK, SOME MORE QUESTIONS ALONG THAT LINE, BUT LET ME GET TO THEM. I'D LIKE YOU TO LOOK AT CRAFT NUMBER FOURTEEN. (THEREUPON, DOCUMENT GIVEN TO WITNESS.) Q. THIS IS THE WHOLE FILE, DR. CRAFT, IF YOU WOULD LIKE TO TAKE A SECOND AND LOOK AT IT. A. OKAY. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. WHAT FILE IS THIS, DR. CRAFT? DR. CRAFT VOLUME II PAGE 398 A. WHAT IS THE TITLE ON THAT? Q. IT SAYS PAREN (TP) -- END OF PAREN -- VERSUS PHOSPHORUS ACCUMULATIONS. A. THAT'S JUST A FILE THAT CONTAINS INFORMATION ON TRYING TO DETERMINE THE RELATIONSHIP BETWEEN PHOSPHORUS AND SURFACE WATERS AND PHOSPHORUS ACCUMULATION IN THE SOIL. Q. ALL RIGHT. I'D LIKE YOU TO LOOK AT THE ONE SET OF DATA THAT I REPRODUCED FOR YOU. WOULD YOU EXPLAIN TO ME WHAT THESE DATA REFLECT? A. OKAY. THE P ACCUMULATION DATA IS FROM THE MANUSCRIPT ON PEAT ACCRETION AND NUTRIENT ACCUMULATION ALONG THE EUTROPHICATION GRADIENT AND SO ON AND SO FORTH. THE REGRESSION EQUATION AT THE TOP IS FROM THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT THAT PREDICTS SURFACE WATER TOTAL P WITH DISTANCE FROM THE HILLSBORO CANAL. AND WHAT I WAS TRYING TO DO WAS EXTRAPOLATE THEIR EQUATION TO GET AN ESTIMATE OF WHAT PHOSPHORUS CONCENTRATION IS AT OUR SAMPLING POINTS DOWN STREAM FROM THE CANAL AND TRY TO RELATE TP VERSUS P ACCUMULATION. Q. OKAY. ARE THOSE ACTUAL TOTAL PHOSPHORUS NUMBERS THAT ARE REFLECTED, THE .137 AND THE .083? A. THESE ARE CALCULATED FROM--- DR. CRAFT VOLUME II PAGE 399 Q. OKAY. A. ---THE EQUATION AT THE TOP. Q. OKAY. OKAY. I GUESS SO THEN MY NEXT QUESTION IS, HAVE YOU SEEN A .003 PARTS PER BILLION NUMBER AT TEN KILOMETERS? A. NO. IT'S JUST A CALCULATED NUMBER. Q. OKAY. OKAY. BUT THE PHOSPHORUS NUMBERS -- THE PHOSPHORUS ACCUMULATION NUMBERS ARE THE ACCRETION RATES AS REFLECTED IN THAT CRAFT NUMBER FIVE? A. RIGHT, YES--- Q. ALL RIGHT. A. ---OR SIXTEEN, WHICHEVER ONE IT IS. IT'S THE ONE IN CONSERVATION AREA 2A. Q. WHAT'S THE MAXIMUM ACCRETION RATE UNDER YOUR P ACCRETION? A. THE MAXIMUM IN TERMS OF WHAT WAS THE HIGHEST RATE THAT WE MEASURED? Q. WELL, YOU GAVE -- I KNOW IN SOME OF YOUR PAPERS YOU HAD THE MAXIMUM AND THEN YOU HAD -- YOU HAD THE MINIMUM. I GUESS I CAN FIND ONE AND SHOW YOU, BUT -- AND THEN YOU HAD AVERAGES -- YOU HAD AVERAGE AND MAXIMUM IN ONE OF YOUR PAPERS. A. OKAY. THE HIGHEST THAT WE MEASURED -- AND ACTUALLY THESE NUMBERS HERE THE THIRD COLUMN OF P DR. CRAFT VOLUME II PAGE 400 ACCUMULATION NUMBERS HAVE BEEN REVISED DOWNWARD BECAUSE WE USED THE INCORRECT BULK DENSITY NUMBERS TO CALCULATE THESE, AND SO -- I THINK THE HIGHEST RATE -- AND AGAIN I'D HAVE TO LOOK AT THE MOST RECENT COPY -- IT MAY BE THIS .85 GRAMS PER METER SQUARED PER YEAR AT -- IN THE MIDDLE ONE. BUT, AGAIN, I WOULD LIKE -- I'D HAVE TO LOOK TO MAKE SURE. IT'S SOMEWHERE AROUND .8 TO .85. Q. OKAY. I THINK YOU TOLD ME YESTERDAY ABOUT THE INCORRECT BULK DENSITIES BEING ONE OF THE ISSUES THAT YOU'RE GOING TO CORRECT IN WHAT IS THE FINAL ANNUAL REPORT FOR '92, AND I THINK I WAS BRAIN-DEAD LONG BEFORE THAT AND I DIDN'T ASK YOU VERY MUCH ABOUT IT. I DON'T THINK YOU EXPLAINED THAT TO ME YESTERDAY -- DID YOU -- WHAT WAS WRONG WITH YOUR BULK DENSITY NUMBERS? A. I JUST SAID THEY WERE CALCULATED INCORRECTLY. Q. OKAY. CAN WE TAKE THE ANNUAL REPORT -- THE '92 ANNUAL REPORT, AND ARE YOU ABLE TO EXPLAIN TO ME WHAT YOU DID WRONG AND HOW YOU'LL BE CHANGING THEM? A. OKAY. THEY HAVE BEEN CHANGED, AND I THINK--- Q. ARE THEY CORRECT IN HERE? A. ---THE CORRECT ONES -- NOT IN THE REPORT, BUT IN DR. CRAFT VOLUME II PAGE 401 THE DRAFT VERSION THAT YOU TOOK OUT OF ONE OF THE FOLDERS -- NUMBER FIVE OR NUMBER SIXTEEN. Q. ALL RIGHT. LET'S JUST IDENTIFY THEM AND MAKE SURE I UNDERSTAND--- A. WHICHEVER ONE--- Q. HERE'S NUMBER SIXTEEN--- A. OKAY. IT'S IN THIS ONE. Q. OKAY. IT'S IN SIXTEEN? A. WELL, LET ME MAKE SURE THAT THIS -- I THINK WE DID CORRECT FOR THESE BEFORE YOU ALL COPIED THIS, BUT I DO WANT TO MAKE SURE. Q. AND HERE'S NUMBER FIVE, IF YOU NEED NUMBER FIVE. A. OKAY. FIVE IS NOT IT--- Q. FIVE IS NOT IT? A. ---IT'S IN SIXTEEN. OKAY, THIS, YOU'LL SEE IT WAS ON THE "A" TRANSECT AND THE BULK DENSITIES WERE NOT CALCULATED RIGHT. BUT IN THIS DRAFT, THEY ARE CORRECT, AND WHAT YOU CAN DO IS COMPARE THESE NUMBERS WITH THE ANNUAL REPORT NUMBERS, IF YOU LOOK AT THE BULK DENSITIES. ON THAT "A" LINE, YOU'LL FIND THAT THEY'RE HIGHER IN THAT ONE THAN THEY ARE -- THEY'RE HIGHER IN THE ANNUAL REPORT THAN THEY ARE IN THIS NUMBER SIXTEEN. Q. AND HOW DID YOU CALCULATE THEM INCORRECTLY? DR. CRAFT VOLUME II PAGE 402 A. THERE IS A MOISTURE CORRECTION FACTOR THAT YOU USE. WE DO OUR ANALYSIS ON AN AIR-DRIED SAMPLES AND THE -- YOU USE A RATIO, AIR-DRIED WEIGHT TO OVEN-DRIED WEIGHT, AND WE GOT IT REVERSED, AND SO IT TENDED TO OVER ESTIMATE THE BULK DENSITY. AND SO WHEN THEY'RE CALCULATED CORRECTLY -- THIS WAS ONLY ON THE "A" TRANSECT -- THEY WERE REVISED DOWNWARD. Q. AND THAT WOULD INCREASE YOUR ACCRETION? A. NO, IT WOULD TEND TO DECREASE--- Q. DECREASE. A. ---THE RATES OF ACCUMULATION. IT OVERESTIMATED THEM IN THE ANNUAL REPORT, AND IN THE REVISED VERSION THEY HAVE COME -- THEY ARE SOMEWHAT LESS. Q. YOU HAVE, FOLLOWING THAT CHART -- AND I DON'T THINK I REPRODUCED ALL THIS. IT DIDN'T SEEM WORTHWHILE. MR. BURGESS: I'M SORRY, COUNSELOR, WHAT EXHIBIT? A. WHAT NUMBER, PLEASE? Q. I'M STILL ON CRAFT FOURTEEN. A. OKAY, I DON'T HAVE IT. Q. DR. CRAFT, YOU DON'T HAVE IT, BUT I CAN SHOW DR. CRAFT VOLUME II PAGE 403 YOU. YOU HAVE -- FOLLOWING THESE DATA, YOU HAVE SOME EXHIBITS THAT I DON'T BELIEVE ARE YOURS, IS THAT CORRECT--- A. THAT'S CORRECT. Q. ---LET ME JUST SHOW THEM TO YOU? A. THAT'S CORRECT. Q. DO YOU KNOW WHOSE THEY ARE? A. THEY ARE EITHER THE DISTRICTS, OR I THINK DR. WALKER'S WORK. Q. OKAY. ONE OF THEM APPEARS TO BE DR. WALKER'S, AND I DON'T KNOW IF THIS IS DR. KADLEC'S OR DR. WALKER'S. A. OKAY. Q. CAN YOU TELL ME WHY YOU HAVE THESE? A. AGAIN, DR. RICHARDSON PASSES INFORMATION ON TO ME THAT HE THINKS I MIGHT FIND OF USE OR HELPFUL OR INTERESTING. AND SO, AGAIN, I DID NOT -- HE DID NOT ASK ME TO REVIEW ANY OF THAT KIND OF INFORMATION, THOUGH. Q. OKAY. DID YOU ACTUALLY READ THROUGH THE STUFF? A. WELL, I LOOKED THROUGH IT. I'M NOT A MODELER, SO A LOT OF THAT I'M NOT SURE IF I REALLY UNDERSTOOD IT, SO -- I THINK CONCEPTIONALLY I UNDERSTAND IT, BUT I'M NOT A COMPUTER MODELER SO I'M THE WRONG DR. CRAFT VOLUME II PAGE 404 PERSON TO ASK ABOUT THAT--- Q. BELIEVE ME, I DON'T INTEND TO TRY. A. ---YOU'D GET NOTHING OUT OF ME, NOT BECAUSE I DON'T WANT TO, BUT BECAUSE I DON'T KNOW ANYTHING ABOUT IT. Q. I'D LIKE TO LOOK AT CRAFT NUMBER THIRTY. I THINK THIS WAS REPRINTED IN FULL FOR YOU, THE WHOLE EXHIBIT, IS IT NOT? YEAH. A. I BELIEVE SO, YES. Q. OKAY. WAS THIS PAPER PRESENTED AT A INTERNATIONAL SYMPOSIUM ON CONSTRUCTIVE WETLAND? A. I BELIEVE SO. THIS IS A PAPER THAT DR. RICHARDSON TOOK THE LEAD ON. Q. OKAY. SO, IN OTHER WORDS, SINCE HIS NAME IS FIRST, THEN HE TOOK THE LEAD, HE AUTHORED THIS? A. HE WAS CERTAINLY THE PRIMARY AUTHOR. I MEAN, I WOULD REVIEW IT FOR HIM, BUT--- Q. OKAY. WHEN YOU COME TO THE CONCLUSIONS ON PAGE 14 AND 15, YOU SEE AT THE BOTTOM RIGHT BEFORE IT SAYS "CONCLUSIONS" SORT OF AS A TITLE? A. YES. Q. AND IT TALKS ABOUT WETLANDS CONTAINING PEAT SOILS ARE NOT EFFICIENT SINKS FOR PHOSPHORUS ESPECIALLY UNDER HIGH LOADING RATES. CAN YOU DEFINE FOR ME DR. CRAFT VOLUME II PAGE 405 WHAT A HIGH LOADING RATE IS? A. I REALLY CAN'T DEFINE IT. THAT'S -- AGAIN, HE TOOK THE LEAD AND WAS, YOU KNOW, THE SENIOR AUTHOR ON THIS. Q. OKAY. WE'LL JUST HAVE TO WAIT UNTIL JANUARY. A. YEAH. I JUST DON'T KNOW. DR. RICHARDSON HAS HAD A LOT MORE EXPERIENCE WORKING WITH WETLANDS AND PHOSPHORUS THAN I HAVE. Q. OKAY. DO YOU THINK THAT -- DO YOU THINK THERE'S A BETTER WAY, DR. CRAFT, TO CONTROL THIS PHOSPHORUS COMING OUT OF THE EAA INTO THE WATER CONSERVATION AREAS THAN SOME TYPE OF A CONSTRUCTIVE WETLAND? A. I DON'T KNOW. I KNOW THERE HAVE BEEN SOME OTHER ALTERNATIVES THAT HAVE BEEN LOOKED AT, BUT, AGAIN, I DON'T KNOW HOW EFFECTIVE SOME OF THOSE WOULD BE EITHER. I THINK ONE WAS THAT AQUIFER STORAGE. AND RECOVERY WAS ONE MECHANISM. AND ADDING, I THINK, CALCIUM CARBONATE TO TRY TO PRECIPITATE PHOSPHORUS IS ANOTHER ONE. I THINK IT IS CERTAINLY WORTHWHILE TO LOOK AT A LOT OF DIFFERENT ALTERNATIVES. AND CERTAINLY CONSTRUCTIVE WETLANDS ARE A POTENTIALLY GOOD, YOU KNOW, ALTERNATIVE, TOO, SO. DR. CRAFT VOLUME II PAGE 406 Q. OKAY. ARE WETLANDS CONTAINING PEAT EFFICIENT SINKS FOR PHOSPHORUS UNDER THE LOADING RATES THAT WATER CONSERVATION AREA 2A RECEIVES? A. I THINK ACCORDING TO MY PAPERS, I SAY SOMETHING TO THAT EFFECT AT THE CURRENT LOADING RATES. Q. AND THAT'S THAT CONCERN I'M NEVER QUITE CLEAR ON, WHY YOU'RE SO CONCERNED ABOUT THEM INCREASING. DO YOU HAVE REASON TO BELIEVE THEY WILL INCREASE? A. NO. BUT I UNDERSTAND THAT RAINFALL IN FLORIDA, YOU KNOW, CAN VARY FROM THIRTY INCHES ONE YEAR TO SEVENTY OR EIGHTY IN ANOTHER YEAR, AND THAT JUST MEANS MORE WATER IN ONE OF THOSE HEAVY RAINFALL YEARS. AND, YOU KNOW, THERE'S -- IT'S DIFFICULT TO HOLD THAT WATER, IT'S GOING TO HAVE TO MOVE INTO -- THEY'RE GOING TO HAVE TO PUMP IT INTO THE WCA'S. WATER'S -- YOU KNOW, SOMETIMES THERE'S TOO MUCH DOWN THERE, AND SOMETIMES THERE DOESN'T JUST SEEM TO BE ENOUGH, SO. Q. ON PAGE 16 IN THE "ACKNOWLEDGEMENTS," WAS THIS WRITTEN BY DR. RICHARDSON? Q. ON--- A. YES. IS THERE A TABLE NUMBER? Q. PARDON? A. DO YOU HAVE A TABLE NUMBER? DR. CRAFT VOLUME II PAGE 407 Q. I'M -- I JUST SORT OF THINK -- I THINK I JUST WENT "UM." ON PAGES 24 AND 25--- A. OKAY. Q. ---YOU HAVE THE MAXIMUM PHOSPHORUS ACCUMULATION BEING .63, IS THAT RIGHT? A. YES, BASED ON -- AGAIN, THIS WAS PRELIMINARY DATA WHEN THIS WAS WRITTEN UP. Q. OKAY. HOW MANY CORES WAS THIS BASED ON -- THE NEXT PAGE, THE FORTY AVERAGE AND THE SIXTY-THREE MAXIMUM -- HOW MANY CORES ARE WE TALKING ABOUT TO COME UP WITH THESE NUMBERS? MR. GREEN: EXCUSE ME, COUNSEL, WE DON'T HAVE THAT MANY PAGES, IS THAT -- I DON'T HAVE--- MS. PONZOLI: IT WAS NOT A DELIBERATE OVERSIGHT. I DON'T KNOW. MR. GREEN: I'M NOT SUGGESTING IT WAS, I JUST DON'T HAVE IT. WHAT--- MS. PONZOLI: IT WAS TAGGED. SO, NORMALLY, WE WOULD HAVE MADE A COPY OF THAT LAST -- TABLE NUMBER 4, MR. GREEN. YOU DIDN'T GET IT? MR. GREEN: I DON'T THINK SO. I'LL LOOK ON. DR. CRAFT VOLUME II PAGE 408 MS. PONZOLI: WE GAVE THE DISTRICT A COPY, BUT NOT THE COOPERATIVE. MR. GREEN: THAT APPARENTLY IS THE CASE. MR. BURGESS: ON PURPOSE, NO DOUBT. MS. PONZOLI: BUT WE GAVE THE LEAD ONE. MR. GRIMSHAW: NO, I HAD IT COPIED MYSELF. MR. GREEN: WE DON'T ALWAYS HAVE THE SAME THINGS THAT THE LEAD HAS. MS. PONZOLI: NOR DO WE. Q. (BY MS. PONZOLI) SO, HOW MANY CORES DID YOU SAY? I'M SORRY, WE GOT DIVERTED. A. I HAVEN'T SAID YET. THE MAXIMUM IS JUST THE ONE CORE; THAT WAS THE CORE THAT HAD THE HIGHEST RATE. Q. OKAY. A. AND THE MEAN, IF I GO BACK TO LOOK AT THE METHODS HERE, IS BASED ON FIVE CORES. Q. SO, THE FORTY IS BASED ON FIVE? A. YES. Q. OKAY. AND WHAT TYPE -- ENRICHED OR UNENRICHED SITES? A. THEY ARE ALL FROM ENRICHED. AS YOU CAN SEE TO THE LEFT THERE, IT SAYS NUTRIENT ENRICHED. DR. CRAFT VOLUME II PAGE 409 Q. OKAY. WHERE AM I -- WHERE AM I MISSING IT -- TO THE LEFT, IT SAYS NUTRIENT ENRICHED? A. ON TABLE 3. OH, I'M BACK ON TABLE 3. IT'S THE SAME NUMBERS, I THINK. Q. RIGHT. A. ---AND IT SAYS, MEAN FOR 2A, (NUTRIENT ENRICHED) IN PARENTHESIS. Q. OKAY. OKAY. SO, THE FORTY IS BASED ON FIVE CORES IN AN ENRICHED SITE; AND THE SIXTY-THREE IS BASED ON ONE CORE IN A -- I CAN'T REMEMBER -- WAS IT UNENRICHED OR ENRICHED? A. NO. IT'S ENRICHED. THAT WAS THE HIGHEST CORE -- HIGHEST RATE OF ACCUMULATION IN THE ENRICHED ZONE OF THOSE FIVE. Q. OKAY. NOW, YOU SAY THIS WAS PRELIMINARY DATA. AND I GUESS WE HAVE MORE DATA NOW. A. RIGHT. Q. HAVE YOUR NUMBERS CHANGED BASED ON MORE DATA? A. THE AVERAGE NOW IS AROUND .45. Q. OKAY. A. AND, AGAIN, IT MIGHT BE .44; IT MIGHT BE .46. Q. RIGHT. A. SO, IT'S GONE UP A LITTLE BIT. AND THE HIGHEST ONE HAS GONE UP TO ABOUT .80 OF THE CORES THAT WE DR. CRAFT VOLUME II PAGE 410 HAVE COLLECTED. Q. OKAY. DOES THAT ALTER THE NUMBERS THAT YOU WOULD NEED IN SIZING IN HECTARES FOR A CLEAN-UP AREA TO DO THE JOB THAT WAS DESCRIBED? A. IN TERMS OF THE -- IT TENDS TO BRING THEM UP A LITTLE BIT. IT TENDS TO -- THE ACCUMULATION RATE TENDS TO COME UP A LITTLE BIT, A LITTLE BIT HIGHER, SO THE ACREAGE WOULD GO DOWN A LITTLE BIT. Q. DO YOU KNOW ABOUT WHAT PERCENTAGE? A. I WOULD JUST -- I WOULD HAVE TO LOOK AT THE INFORMATION TO SEE. BUT IF IT WENT FROM .40 TO .45, THAT'S ABOUT, YOU KNOW, TWELVE PERCENT (12%) OR SOMETHING LIKE THAT, TEN -- TEN TO TWELVE PERCENT (10% TO 12%). Q. OKAY. WE'RE GETTING CLOSER TOGETHER. A. I DON'T THINK WE WERE EVER THAT FAR APART, TO BEGIN WITH. Q. YOU WOULDN'T BELIEVE IT LOOKING AROUND THIS TABLE. A. I KNOW. Q. I'D LIKE TO ASK YOU ABOUT CRAFT NUMBER EIGHTEEN. (THEREUPON, DOCUMENT GIVEN TO DR. CRAFT.) Q. AND I THINK IN CRAFT EIGHTEEN, IT'S A LARGER FILE AGAIN, DR. CRAFT, DATA AND STATISTICS, AND I HAVE DR. CRAFT VOLUME II PAGE 411 PULLED JUST A SINGLE PAGE TO QUESTION YOU ON. AND IF YOU WANT TO -- IF YOU THINK THERE IS ANYTHING ELSE IN HERE YOU WANT TO TALK ABOUT, PLEASE FEEL FREE -- I'LL HAND YOU MY COPY -- BUT I ONLY HAD QUESTIONS ABOUT THIS ONE PAGE. A. OKAY. Q. WHAT DOES THIS REPRESENT, THIS DATA? A. I BELIEVE THIS IS THE WATER LEVEL DATA THAT WE TALKED ABOUT EARLIER THAT DR. QUALLS COLLECTED, THE SAME -- I'M PRETTY SURE IT'S THE SAME NUMBERS. AND, AGAIN, I WAS TRYING TO RELATE INCREASED PEAT ACCRETION TO WATER LEVEL. Q. DID YOU DRAW ANY CONCLUSIONS FROM THAT? A. THERE WAS NO CLEAR RELATIONSHIP. AND, AGAIN, I THINK, ONE YEAR OF WATER LEVEL DATA IS JUST NOT ENOUGH. Q. ARE YOU SURE THAT OTHER WATER LEVEL DATA WAS '91? I JUST CAN'T REMEMBER IF IT WAS '91 OR '92. A. I DIDN'T HAVE A DATE ON THAT, BUT I THINK IF YOU WENT BACK AND LOOKED, YOU'D SEE THE NUMBERS ARE THE SAME NUMBERS. Q. OKAY. DO YOU CONSIDER 3.7 AN ENHANCED HYDROPERIOD? IF YOU LOOK DOWN UNDER 10D1--- A. NO, NO. DR. CRAFT VOLUME II PAGE 412 Q. ---IT'S GOT 3.7. A. I MEAN, IT'S RELATIVE TO THE OTHER ONES. IT'S CERTAINLY DRIER THAN THE OTHER ONES. Q. OKAY. CRAFT NUMBER EIGHT IS THE NEXT ONE I WOULD LIKE TO ASK YOU ABOUT AND AGAIN I PROBABLY HAVE ONLY REPRODUCED A SINGLE PAGE THAT I'D LIKE TO -- WELL, NO, I THINK THE WHOLE FILE MAY HAVE BEEN DONE FOR YOU. A. I HAVE QUITE A BIT. Q. OKAY. THIS FILE IS ENTITLED "EVERGLADES COORDINATES." WHAT IS THIS FILE? A. THESE ARE THE LATITUDINAL AND LONGITUDINAL COORDINATES FOR OUR -- FOR THE VARIOUS SAMPLING POINTS. Q. THESE HAVE EXISTED THROUGH TIME FOR HOW LONG NOW? HOW LONG HAVE YOU HAD THESE ESTABLISHED? A. THE PLOTS? Q. RIGHT. A. THESE HERE WERE ESTABLISHED, I BELIEVE, IN JANUARY OF 1991. I THINK THAT'S RIGHT--- Q. DO YOU HAVE A--- A. ---NO, NO, WAIT A MINUTE LET ME BACKUP--- MS. PONZOLI: ARE YOU LOOKING FOR THE EXHIBIT, MR. BURGESS? DR. CRAFT VOLUME II PAGE 413 MR. BURGESS: YEAH. MS. PONZOLI: DO YOU WANT US TO WAIT FOR YOU? MR. BURGESS: THANK YOU. A. ---I THINK THEY WERE ESTABLISHED IN JANUARY OF '90 OR SO. Q. IT'S NUMBER EIGHT. ALL RIGHT, IT STARTS WITH -- ARE THESE -- THESE ARE LORAN READINGS OR GPS, I DON'T EVEN KNOW. A. THE MOST RECENT ONES HERE, THE FIRST PAGE, ARE GPS. Q. DID YOU -- YOU STARTED WITH LORAN AND THEN SWITCHED? A. YES. Q. DO YOU BELIEVE THAT YOUR SITES ARE PRETTY ACCURATE? A. I BELIEVE THAT MAY 25, 1992, ARE PRETTY ACCURATE. Q. THESE ARE GPS? A. YES. Q. I GUESS WHAT I WAS ASKING WAS WHEN YOU SWITCHED OVER, DO YOU THINK YOU'RE REALLY LOCATING THE SAME SITES, IS WHAT I'M TRYING TO SAY? A. WELL, WE HAVE -- WE HAD PERMANENT PLOTS SET UP WITH PVC PIPE AND THOSE SORTS OF THINGS, SO, WE DR. CRAFT VOLUME II PAGE 414 KNEW WHEN WE FOUND IT. BUT THE LORAN IS REALLY NOT -- IT WAS NOT VERY GOOD, SO. Q. OKAY. I WANT TO GO FIVE PAGES IN, AND THERE'S SORT OF A BLURRY DRAWING OF THE ENRICHED AREA, I BELIEVE OF WATER CONSERVATION AREA 2A. WHOSE DRAWING IS THIS? A. THIS IS MINE. Q. OKAY. AND WHAT IS IT REFLECTING? A. THIS IS -- I THINK, WE TOOK THE VEGETATION DATA THAT WAS MAPPED BY PAUL LARSON, OR IT WAS FROM THE DISTRICT -- THE CATTAIL SAWGRASS DISTRIBUTION -- AND JUST TRIED TO OVERLAY OUR PLOTS ON IT TO GET A RELATIVE IDEA OF WHERE WE WERE. Q. OKAY. I THINK THERE IS SOME LARSON INFORMATION AS WE GO FURTHER BACK. I GUESS IT'S IN THIS FILE. LET'S GO TO THE LETTER FROM MR. LARSON BACK TO MR. EARL. A. OKAY. Q. DR. CRAFT, YOU ARE CC'D ON THIS LETTER ALONG WITH DR. DAVIS, DR. PATRICK, AND DR. RICHARDSON. HAVE YOU COORDINATED WITH THESE THREE OTHER GENTLEMEN IN RELATION TO YOUR WORK IN WATER CONSERVATION AREA 2A? A. NO. THIS WAS THE FIRST DAY ON THE JOB, IN FACT, DR. CRAFT VOLUME II PAGE 415 OR THE SECOND DAY, AND I WENT OUT IN THE FIELD TO COLLECT THE CORES, AND ALL THESE FELLOWS WERE THERE, TOO. Q. THEY JUST HAPPENED TO BE THERE THE SAME DAY YOU WERE? A. NO. I MEAN, I DON'T KNOW WHAT, YOU KNOW, THE RELATIONSHIP WAS. I WAS HIRED TO LOOK AT PEAT ACCRETION AND NUTRIENT ACCUMULATION, AND, OF COURSE, I WAS OUT THERE DOING THE CORE TAKING. AND I RECALL ONE OF THOSE GUYS -- I THINK JOHN DAVIS -- WAS OUT THERE AND HAD A MOBILE PHONE AND WAS STANDING IN THE MIDDLE OF THE EVERGLADES TALKING ON THE PHONE, WHICH I THOUGHT WAS KIND OF--- Q. BUT, THIS WAS AT THE TOP OF WATER CONSERVATION AREA 2A? A. I RECALL THAT WAS ACTUALLY OUT IN THE SOUTHWEST PART IN ONE OF -- IN A DRIED UP SLOUGH. THIS WAS IN, I THINK, THAT 1989 DROUGHT. IT WAS VERY DRY OUT THERE, YOU COULD WORK IN YOUR TENNIS SHOES. Q. SO, YOU WEREN'T WITH THE SIXTEEN FOOT ALLIGATORS AND JOHN DAVIS? A. I DON'T KNOW WHERE THEY WERE. I DON'T KNOW IF A DR. CRAFT VOLUME II PAGE 416 SIXTEEN FOOT ALLIGATOR COULD EAT HIM. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER.) Q. (BY MS. PONZOLI) I TAKE IT, THEN, YOU DID NOT GO ON THE AERIAL TOUR WITH THEM? A. ON THAT DATE -- ON THOSE DATES, I DID, BECAUSE WE TOUCHED DOWN IN A LOT OF PLACES, OR IN SEVERAL PLACES, AND I TOOK SAMPLES. Q. OKAY. SO, YOU DON'T KNOW WHO SET UP ALL OF YOU TO GO OUT THERE TOGETHER, IS THAT ACCURATE? A. THAT'S CORRECT. Q. ALL RIGHT. BUT YOU WERE IN THE LONG RANGER? A. WE WERE IN ONE OF THOSE CRESCENT AIRWAY'S HELICOPTERS. I REMEMBER I WAS MOTION SICK, I THOUGHT I WAS GOING TO BARF ON SOMEBODY. CURT CAN ATTEST TO THAT. Q. I WON'T EVER GO IN A HELICOPTER WITH YOU. A. I TAKE THOSE PATCHES NOW, AND IT'S A LOT BETTER. Q. I CAN SEE WHY ACCESSIBILITY WAS IMPORTANT FOR THE FERTILIZER STUDY. A. IT'S JUST -- YOU DON'T -- IT'S HARD -- YOU DON'T WANT TO HAVE TO -- IF YOU WANT TO GET WORK DONE, DR. CRAFT VOLUME II PAGE 417 YOU DON'T WANT TO HAVE TO DEPEND ON SOMEBODY TO TAKE YOU IN AN AIR BOAT OR IN A HELICOPTER. Q. OKAY. SO, YOU DON'T KNOW WHO SET THIS UP, BUT THE PEOPLE WHO WERE ON THIS TRIP WERE MR. LARSON, YOURSELF, DR. DAVIS, DR. PATRICK, AND DR. RICHARDSON? A. YES. I DON'T -- I REMEMBER EVERYBODY, I THINK, BUT BILL EARL. THE OTHER THREE PEOPLE, I DEFINITELY, YOU KNOW, REMEMBER THEM. AND I'M SURE HE WAS THERE, BUT I CAN'T VISUALIZE HIS FACE. Q. YOU DON'T REMEMBER MR. EARL? A. NO. HE'S MAYBE ONE OF THOSE FORGETFUL KIND OF PEOPLE. Q. IT'S NOT MY IMPRESSION. ANYWAY, SO YOU -- TELL ME WHAT YOU DID. YOU SPENT A WHOLE DAY DOING WHATEVER YOU DID? A. WE TOUCHED DOWN IN, I THINK, THREE LOCATIONS IN CONSERVATION AREA 2A, AND I TOOK SOIL SAMPLES. I THINK WE ALSO TOOK SOME ABOVEGROUND PLANT SAMPLES OF SAWGRASS AND CATTAIL AND ALSO WE TOOK SOME ROOT SAMPLES. Q. WAS ANYONE TAKING SAMPLES OTHER THAN YOURSELF? A. I DON'T BELIEVE SO. I THINK I WAS -- WELL, DR. RICHARDSON AND I WERE TAKING THE SAMPLES. BUT DR. CRAFT VOLUME II PAGE 418 I THINK BEYOND US TWO, I DON'T THINK SO. Q. OKAY. YOU TOOK SOIL SAMPLES, YOU TOOK VEGETATION SAMPLES, AND YOU TOOK ROOT SAMPLES? A. AND WE MAY HAVE TAKEN SOME WATER SAMPLES WHERE WE COULD FIND WATER, BUT I -- AS I RECALL, IT WAS REALLY BONE DRY OUT THERE. Q. OKAY. THREE LOCATIONS, YOU BELIEVE? A. IN 2A, YES. Q. UH-HUH (YES). ARE THEY REFLECTED ON THE MAP THAT'S A COUPLE OF PAGES AHEAD OF THAT ESTABLISHED 9/30/89, SOMETHING ANOTHER -- IS IT RICHARDSON AND CRAFT? A. THEY ARE ON ONE OF THESE, AND I CAN PROBABLY FIND THAT FOR YOU. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. YEAH, I THINK THAT'S IT. IS THAT FURTHER ALONG--- Q. WELL, WHY--- A. ---TOWARD THE BACK? Q. ---DON'T YOU JUST LOOK THROUGH IT AND GET FAMILIAR -- THERE'S A PAGE FOLLOWING -- A COUPLE OF PAGES BEYOND--- A. THAT'S GOT TO BE--- Q. ---BEYOND THE LETTER. A. ---BECAUSE THIS WAS ALL ONE BIG HANDOUT. YOU CAN DR. CRAFT VOLUME II PAGE 419 SEE A LETTER FROM BILL EARL -- OR NOT BILL EARL, BILL EVANS. YES. THIS ONE HERE, YOU CAN SEE THESE CIRCLES; THEY ARE LIKE BULL'S-EYES HERE. THOSE WERE TWO OF THE LOCATIONS. Q. OKAY. A. AND THEN THE THIRD LOCATION WAS DOWN HERE WHERE IT SAYS -- IT'S NEAR THE WORDS "ALERT AREA," THERE'S KIND OF A BULL'S-EYE DOWN IN THE SOUTHWEST PART--- Q. OKAY. A. ---SOUTHWEST OF THE CANAL. Q. AND AT THESE SITES, YOU PULLED SOIL, VEGETATION, ROOT, AND WATER, YOU BELIEVE? A. DEFINITELY SOILS AND VEGETATION. THE WATER, I JUST DON'T -- WE MAY HAVE BEEN PREPARING TO TAKE WATER, BUT THERE JUST WASN'T ANY OUT THERE. Q. OKAY. SO, YOU WENT INTO 2A. WHERE ELSE DID YOU GO? A. I THINK OTHER THAN THAT -- I THINK WE MADE THAT BIG FLY-OVER -- WE FLEW DOWN ACROSS 3A ALONG THE TAMIAMI TRAIL, AND THEN WE FLEW UP ALONG THE BOARDER BETWEEN THE EVERGLADES AND THE BIG CYPRUS, AND THEN I THINK WE FLEW BACK TO THE WEST PALM BEACH AIRPORT. Q. OKAY. IS THAT WHERE YOU LEFT FROM WAS THE PALM DR. CRAFT VOLUME II PAGE 420 BEACH AIRPORT? A. I THINK SO. I THINK, BECAUSE -- I'M PRETTY SURE WE DID LEAVE FROM THERE. Q. DID ANYONE EXPLAIN THE SYSTEM TO YOU THAT DAY? A. WHAT DO YOU MEAN THE SYSTEM? Q. WELL, DID SOMEONE NARRATE THE HELICOPTER TRIP, AND SAY, NOW YOU'RE LOOKING AT 2A AND THIS IS WHAT YOU'RE SEEING; AND NOW YOU'RE LOOKING AT 3A AND--- A. I THINK -- I THINK PAUL LARSON MAY HAVE DONE THAT, BUT, AGAIN, I'M NOT A HUNDRED PERCENT SURE. Q. OKAY. DO YOU RECALL THE TYPE OF THINGS HE WAS TELLING YOU? A. JUST OTHER THAN THE PARK IS OVER HERE, AND THIS IS CONSERVATION AREA 3A. AND I DO BELIEVE WE FLEW ALONG THE EDGE OF THE EVERGLADES AGRICULTURAL AREA BECAUSE I THINK WE SAW SOME CATTLE AND SOME SUGARCANE FIELDS. Q. YOU SAW CATTLE? A. YEAH, I DO REMEMBER THAT. AND MY HEAD WAS HANGING OUT THE WINDOW, BELIEVE ME. THAT WAS A BAD EXPERIENCE. I WAS SO THANKFUL WHEN THEY LANDED. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION DR. CRAFT VOLUME II PAGE 421 WHICH WAS NOT REPORTED BY THE COURT REPORTER.) Q. (BY MS. PONZOLI) DID YOU UNDERSTAND WHAT ROLE THESE OTHER GENTLEMEN HAD ON THIS HELICOPTER TRIP? A. NO. I MEAN, I REALLY -- THIS WAS THE FIRST TIME, WITH THE EXCEPTION OF BILL PATRICK, WHO I'VE MET AT MEETINGS, THAT I HAD EVER MEET THESE GENTLEMEN, SO--- Q. OKAY. DO YOU NOW UNDERSTAND WHAT ROLE, LET'S SAY, FOR EXAMPLE, DR. PATRICK HAS IN THE EVERGLADES? A. NOT REALLY. I THINK HE'S MAYBE A CONSULTANT TO ONE OF THE INTERESTED PARTIES. Q. DO YOU KNOW WHAT TYPE OF WORK HE'S DOING? A. THAT I DON'T KNOW. I MEAN, IN TERMS OF HIS SCIENTIFIC RESEARCH, GENERALLY, I KNOW WHAT TYPE OF WORK HE'S DOING. Q. WHAT DOES DR. PATRICK DO GENERALLY? A. HE'S A -- WELL, HE MANAGES A WETLAND SOILS LAB AT LOUISIANA STATE UNIVERSITY, HE'S THE DIRECTOR, AND HE'S JUST A VERY WELL-KNOWN, VERY WELL-RESPECTED WETLAND SOIL SCIENTIST -- HAS, YOU KNOW, PUBLISHED PROBABLY HUNDREDS OF PAPERS, SO I KNOW HIM DR. CRAFT VOLUME II PAGE 422 PROFESSIONALLY. HIS CONSULTING WORK, I REALLY DON'T KNOW ABOUT. Q. OKAY. SO, YOU KNOW NOTHING ABOUT THE CONSULTING WORK THAT HE'S DOING FOR ONE OF THE INTERESTED PARTIES? A. NO. I'M NOT--- Q. DO YOU EVEN KNOW WHICH INTERESTED PARTY HE'S DOING IT FOR? A. WELL, I SUSPECT IT HAS TO DO WITH THE AGRICUL -- SOMEBODY WITH AGRICULTURE. BUT BEYOND THAT, I DON'T KNOW. Q. OKAY. HOW ABOUT MR. DAVIS? A. I'M AWARE THAT HE'S A CONSULTANT, I THINK TO SOME OF THE AGRICULTURAL INTERESTS, ALSO. Q. DO YOU KNOW WHAT KIND OF WORK HE'S DOING? A. THAT I DON'T KNOW. I KNOW THAT HE'S THE HEAD OF THE -- OR HE'S ENVIRONMENTAL SERVICES AND PERMITTING, I'M AWARE OF THE NAME OF THE COMPANY HE'S WITH, OR THAT HE'S THE HEAD OF. Q. UH-HUH (YES). ARE YOU EVER GIVEN ANY OF DR. PATRICK'S OR DR. DAVIS' WORK TO LOOK AT IN THE SAME WAY YOU WERE GIVEN DR. KADLEC'S AND DR. WALKER'S? A. I HAVEN'T SEEN ANY OF THAT, EXCEPT I THINK MAYBE DR. CRAFT VOLUME II PAGE 423 I HAD ONE PAGE THAT WAS GIVEN TO ME FROM DR. PATRICK, OR NOT DIRECTLY FROM HIM, BUT THAT WAS PASSED ON TO ME SEVERAL YEARS AGO. AND, AGAIN, I THINK IT'S IN ONE OF THOSE FILES THAT YOU ALL XEROXED. Q. WHAT WAS IT ON? A. I THINK IT HAD TO DO WITH THE IDEA OF SALT AND THE ROLE OF SODIUM CHLORIDE MAYBE IN CATTAIL ENCROACHMENT. Q. DID HE THINK THERE WAS A RELATIONSHIP? A. I THINK HE THOUGHT THAT IT WOULD BE WORTH TAKING A LOOK AT. I'M NOT SURE IF HE THOUGHT THERE WAS A RELATIONSHIP, BUT IT WAS SOMETHING THAT SHOULD BE PERHAPS LOOKED INTO. Q. OKAY. SO, YOU WENT TO 2A. DID YOU UNDERSTAND THE ROLES OF ANYONE ELSE THAT DAY, OF WHAT THEY WERE DOING? A. NO. I MEAN, ALL I KNEW WAS THAT I WAS DOING MOST OF THE WORK. BUT THAT'S TO BE EXPECTED WHEN, YOU KNOW, WHEN YOU'RE FIRST BROUGHT ON. Q. WAS THAT A CLUE? A. WELL, YOU FIGURED THEY WERE BIG SHOTS. BUT OTHER THAN THAT, I DON'T KNOW. Q. ALL RIGHT. HAVE YOU COME SUBSEQUENTLY TO DR. CRAFT VOLUME II PAGE 424 UNDERSTAND THE ROLES THAT ANY OF THESE OTHER PEOPLE HAVE? A. OTHER THAN WHAT I'VE TOLD YOU, AND I KNOW BILL EARL, HE'S A -- I GUESS A LAWYER, OR I THINK RICK WORKS WITH HIS PARTY, I THINK. BUT OTHER THAN THAT, I DON'T KNOW. Q. HAVE YOU SEEN ANY DOCUMENTS -- HAVE YOU SEEN ANY OTHER LARSON DOCUMENTS FOLLOWING THESE? A. I DON'T KNOW. I MAY HAVE SEEN SOMETHING AGAIN. I KNOW HE WAS INVOLVED IN THE VEGETATION MAPPING AND THE CATTAIL DISTRIBUTION. AND I DON'T THINK CURT PASSED ANYTHING ON TO ME, BUT HE MAY HAVE SHOWN ME SOMETHING AT ONE TIME, BUT--- Q. OKAY. WHEN YOU PULLED YOUR SOIL SAMPLES, WERE THESE CORES? A. YES. Q. OKAY. YOU PULLED THE TRADITIONAL RICHARDSON CORE? A. RIGHT -- CORRECT, YES. Q. AND YOU DID -- DID YOU DO THE FULL RANGE OF TEST ON IT THAT WE'VE DISCUSSED IN REGARD TO OTHER CORES? A. YES. WE MEASURED THE CESIUM, THE BULK DENSITY, PHOSPHORUS, THE OTHER ELEMENTS THAT WE WERE LOOKING AT. DR. CRAFT VOLUME II PAGE 425 Q. DO YOU KNOW -- DO YOU KNOW WHAT DR. RICHARDSON DOES IN RELATION TO ALL OF THIS? A. I'M JUST AWARE OF HIS ROLE AS DIRECTOR OF THE WETLAND CENTER AND OVERSEEING THE, YOU KNOW, OUR RESEARCH RELATING TO THE EVERGLADES -- TO THE WHATEVER, THE EVERGLADES PROTECTION DISTRICT. Q. OKAY. ARE YOU AWARE THAT HE'S AN EXPERT WITNESS, ALSO? A. YES, I AM AWARE THAT HE IS AN EXPERT WITNESS AND I'M AWARE DR. RADER, I THINK, IS AN EXPERT WITNESS, TOO. Q. OKAY. AND YOU'RE AWARE THAT -- AT LEAST, I KNOW DR. RADER'S IS COMPENSATED. AND I ASSUME DR. RICHARDSON IS COMPENSATED FOR THAT SEPARATELY. ARE YOU AWARE OF THAT? A. I FIGURED AS MUCH, BUT I DON'T -- YOU KNOW, IT'S NONE OF MY BUSINESS. Q. OKAY. I HAVE TO ASK YOU, ARE YOU BEING COMPENSATED? A. I'M JUST BEING COMPENSATED AS A EMPLOYEE OF DUKE UNIVERSITY. I MEAN, I WORK FOR DUKE UNIVERSITY AND THAT'S THE ONLY SOURCE OF INCOME RELATING, YOU KNOW, TO WORK THAT I GET. Q. YOU GET NO OTHER FEES FOR CONSULTATION--- DR. CRAFT VOLUME II PAGE 426 A. NO, NO. Q. ---OR PULLING CORES--- A. I'M NOT SURE WHETHER I'D WANT TO EITHER; I HAVE MIXED FEELINGS ABOUT THAT. Q. OKAY. HAVE YOU EVER HAD CONVERSATIONS WITH MR. LARSON FOLLOWING THIS, REGARDING YOUR VEGETATION WORK OR HIS VEGETATION WORK? A. YES. THERE WAS ONE TIME HE CALLED. AND, IN FACT, I HAVE SOME INFORMATION IN THIS DOCUMENT. HE INFORMED US -- HE WAS THE ONE THAT INFORMED US THAT OUR COORDINATES, HE THOUGHT, WERE NOT RIGHT USING LORAN-C, BECAUSE HE WENT OUT AND FOUND THAT THE GPS GAVE DIFFERENT COORDINATES. AND THAT WAS ONE REASON WE DECIDED WE SHOULD GO OUT AND REASSESS THE LOCATION OF OUR PLOTS. Q. WHEN WAS THIS? A. I THINK IT WAS ABOUT A YEAR AGO. I MEAN, IT HAS BEEN WITHIN THE PAST, I WOULD SAY, TWELVE TO EIGHTEEN MONTHS. IT'S -- YOU KNOW, IT'S BEEN A YEAR, BUT I CAN'T SAY FOR CERTAIN WHEN IT WAS. Q. ANY OTHER CONVERSATIONS WITH MR. LARSON? A. I DON'T THINK SO. Q. WHY DID HE FORWARD THESE -- HOW DID YOU GET THESE DR. CRAFT VOLUME II PAGE 427 DOCUMENTS -- OH, YOU GOT THESE DIRECTLY FROM MR. LARSON--- A. I THINK I WAS A -- RIGHT. Q. ---YOU WERE CC'D? A. YEAH. Q. WHY DID HE SEND THESE TO YOU? A. WELL, WE WANTED TO KNOW THE LOCATION OF WHERE WE TOOK THE CORES. THAT WAS THE WHOLE POINT. Q. OKAY. A. THIS ALL CAME AS ONE BIG LUMP, I BELIEVE, OR MOST OF THIS -- THESE THREE CERTAINLY. AND I DON'T KNOW ABOUT THIS ONE HERE, BUT THIS MAY HAVE COME WITH HIS, ALSO. Q. OKAY. AND WHAT YOU ARE TALKING ABOUT IS FIGURE TEN, SUMMARY OF RESULTS--- A. RIGHT. A. ---7/12/89 VEGETATION SURVEYS? A. RIGHT. THAT PROBABLY CAME -- SINCE IT HAS HIS NAME ON IT, IT PROBABLY CAME WITH ALL THIS. Q. OKAY. IS THIS MR. LARSON'S VEGETATION SURVEY? A. THAT, I'M NOT -- I DON'T KNOW. I THINK -- I ALWAYS HAVE TROUBLE TELLING WHOSE -- WHETHER IT'S THE DISTRICT'S WORK, OR HAS BEEN SOME OF HIS WORK. I'M ASSUMING IT'S HIS, SINCE IT'S ON LARSON AND DR. CRAFT VOLUME II PAGE 428 ASSOCIATES PAPER. Q. I'VE WAITED YEARS TO SEE THIS. A. SERIOUSLY? Q. SERIOUSLY. A. YOU SHOULD HAVE CALLED ME UP. Q. IF I'D ONLY KNOWN. THE HOLY LAND--- A. YES. Q. ---IS THE LAST, 9/27/89. I TAKE IT YOU DID NOT DO THIS THAT DAY? A. NO. AND ACTUALLY THE PREVIOUS PAGE, WE TOOK SOME MORE CORES IN SEPTEMBER OF '89. AND AGAIN, I GUESS PAUL LARSON WAS INVOLVED IN THIS, ALTHOUGH I DON'T REMEMBER THAT TRIP LIKE THE FIRST ONE. Q. YOU HAD THE PATCHES ON? A. UH-HUH (YES). Q. OKAY. LOOKING AT THE HOLY LAND, WHEN WAS THIS -- THIS WAS 9/27/89? A. IT WAS SEPTEMBER '89, YES. Q. OKAY. WHAT WAS THE PURPOSE OF THIS TRIP? A. AGAIN, WE WERE JUST TRYING TO GET A HANDLE ON JUST WHAT THE AREAS THAT WE WERE ABLE TO SAMPLE -- WHAT THE RATES OF PEAT ACCRETION AND NUTRIENT ACCUMULATION WERE. AND, ALSO, I THINK WE PROBABLY TOOK SOME PLANT SAMPLES AND SOME WATER SAMPLES DR. CRAFT VOLUME II PAGE 429 HERE--- Q. OKAY. A. ---WE TOOK TWO CORES, AS YOU CAN SEE MARKED. Q. RIGHT. RIGHT. DID YOU DO ANYTHING WITH THIS DATA? A. WE ANALYZED IT, AND THE CESIUM PROFILES WERE NOT -- THEY DIDN'T COME OUT. AND THEN I FOUND OUT THAT THEY USE TO USE THE HOLY LAND AS A BOMBING RANGE, SO I COULD SEE WHERE CESIUM MIGHT NOT WORK SO WELL. Q. I DON'T MEAN TO BE STUPID, BUT WOULD IT HAVE JUST BEEN MESSED UP; I MEAN, THOSE WOULDN'T HAVE BEEN RADIOACTIVE TEST OUT THERE? A. NO. BIG CRATERS--- Q. OH, BIG CRATERS WOULD JUST--- A. ---WOULD DISTURB THE PEAT. Q. ---JUST DISTURB THE WHOLE BENCHMARK? A. YEAH. Q. OKAY. WHO WENT ON THIS HELICOPTER TRIP TO THE HOLY LAND? A. I DON'T REMEMBER, BUT I'M SURE IT WAS DR. RICHARDSON AND MYSELF AND THE PILOT. AND I REALLY DON'T REMEMBER WHO ELSE, IF ANYBODY. Q. HAVE YOU DONE -- OTHER THAN THIS 9/27/89 TRIP TO DR. CRAFT VOLUME II PAGE 430 THE HOLY LAND, HAVE YOU DONE OTHER TRIPS TO THE HOLY LAND? A. THIS WAS THE ONE -- ONE TIME -- ONE SHOT DEAL, I GUESS. Q. OKAY. I'D LIKE TO LOOK BACK AT ONE OTHER OF THESE MAPS AND JUST ASK YOU SOME QUESTIONS. (MS. PONZOLI LOOKS THROUGH DOCUMENTS.) Q. OKAY. GOING BACK TO, I GUESS, THE ONE I HAD ASKED YOU BEFORE, ESTABLISHED 9/30/89, AND IT SAYS RICHARDSON AND CRAFT. ARE YOU WITH ME? A. NO, BUT I'M WORKING ON IT. (THEREUPON, WITNESS LOOKS FOR DOCUMENT.) A. HOW FAR IN IS THAT -- IS IT BACK QUITE A FEW PAGES? Q. IT MAY BE PRETTY MUCH IN THE MIDDLE. A. OKAY. YEAH, I THINK I'M THERE -- RIGHT HERE? Q. OKAY. IS THAT BENCHMARK -- IS THAT YOURS OR WHOSE? A. THIS IS -- I'M PRETTY SURE THIS IS WHAT THE HELICOPTER PILOT WAS DOING WHILE WE -- HE HAD THE LORAN WITH THE HELICOPTER. AND WHEN WE WERE COLLECTING SAMPLES, HE WAS, YOU KNOW, TRYING TO SET UP OR DETERMINE WHERE WE WERE -- THE COORDINATES. DR. CRAFT VOLUME II PAGE 431 Q. SO, THESE ARE JUST YOUR COORDINATES, IS THAT RIGHT? A. RIGHT. Q. THERE ARE SOME MORE LARSON DOCUMENTS IN ANOTHER FILE THAT I'D LIKE TO ASK YOU ABOUT. IT'S CRAFT NUMBER ELEVEN. I DON'T KNOW IF WE -- DID WE REPRODUCE THAT ONE PRETTY MUCH IN ITS ENTIRETY FOR YOU? A. I HAVE A LOT OF INFORMATION, YES. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. OKAY. WHAT IS THIS PARTICULAR FILE? A. THIS LOOKS LIKE THIS WAS THE -- WHEN WE WENT OUT AND MEASURED, WE FIRST SET UP OUR PERMANENT VEGETATION PLOTS AND MEASURED THE SPECIES COMPOSITION IN 1990. Q. WHAT -- IF YOU'D TURN TOWARD THE BACK, YOU HAVE -- WE HAVE -- I GUESS IT'S A FAX FROM LARSON AND ASSOCIATES IN 2/11/91 TO DR. QUALLS. HOW DID YOU COME TO HAVE THIS DOCUMENT, DR. CRAFT? A. I THINK JERRY OR DR. QUALLS PROBABLY PASSED IT ON TO ME SINCE I WAS DOING THE VEGETATION WORK. Q. OKAY. A. AND I'M NOT QUITE SURE WHY HE ENDED UP GETTING IT, YOU'LL GET TO ASK HIM THAT. DR. CRAFT VOLUME II PAGE 432 Q. SO, THE NOTE, "PLEASE REVIEW RELATIVE TO CHANGES OBSERVED ON YOUR TRANSECTS," REALLY IS A NOTE PROBABLY TO YOURSELF? A. WELL, THAT'S HIS WRITING, BUT I'M ASSUMING WHAT HE'S TALKING ABOUT IS MAYBE, SINCE HE HAD SOME GOOD VEGETATION DATA, MAYBE TRYING TO COMPARE OUR DATA TO WHAT HE FOUND ON HIS LINES. Q. OKAY. SO, YOU DID CONSULT AT THIS TIME WITH -- DID YOU TALK WITH MR. LARSON? A. NO. AGAIN, I THINK THIS WAS MORE FOR JUST MY BENEFIT. AND, SEE, HIS LINES ARE NOT THE SAME AS OUR TRANSECT, SO IT'S--- Q. RIGHT. A. ---YOU CAN'T REALLY DIRECTLY COMPARE THEM, YOU CAN JUST KIND OF GET AN EYEBALL, YOU KNOW, JUST SORT OF ESTIMATE. Q. OKAY. A. AND I DON'T SEE -- WELL, YOU CAN SEE SOME OF OUR POINTS ON THE NEXT TO THE LAST PAGE. IT LOOKS LIKE SOMEBODY -- MAYBE JERRY -- DRAWN IN D1, D2, D3, AND D4, AND YOU CAN SEE HIS TRANSECTS TEND TO RUN IN-BETWEEN OURS. Q. I'M NOT WITH YOU EXACTLY. SHOW ME WHAT YOU'RE--- (THEREUPON, WITNESS POINTS TO DOCUMENT.) DR. CRAFT VOLUME II PAGE 433 A. NEXT TO THE LAST PAGE. Q. IS THIS IT? A. SEE WHERE IT LOOKS LIKE SOMEBODY'S WRITTEN D1 -- WELL, D2, D3, D4 -- JUST SORT OF KIND OF SO WE CAN SEE WHAT HE FOUND AND SEE IF OUR NUMBERS SORT OF JIVE WITH THAT OR ARE SIMILAR. Q. OKAY. OKAY. SO, THIS IS NOT -- THIS VEGETATION WORK REFLECTED HERE, LIKE CATTAIL, PIGWEED, SAWGRASS, ETCETERA--- A. RIGHT. Q. ---THIS IS NOT YOUR VEGETATION WORK--- A. NO. THIS IS SOME WORK HE APPARENTLY DID. Q. ---THIS IS MR. LARSON'S? A. YEAH. Q. OKAY. AND THEN THE LAST PAGE, IS THAT THE SAME? A. I BELIEVE THAT'S THAT FIGURE WE SAW IN THE PREVIOUS EXHIBIT. Q. AND YOU BELIEVE THIS IS LARSON'S WORK? A. WELL, JUST -- I THOUGHT IT SAID AT THE TOP ON THE OTHER PAGE IT WAS FROM LARSON AND ASSOCIATES, SO, YEAH, I THINK THIS IS HIS WORK. Q. OKAY. DID YOU COMPARE YOUR WORK WITH THIS? A. I THINK I JUST LOOKED AT IT TO -- JUST TO GET A RELATIVE IDEA. THE ONE THING IS -- YOU KNOW, WITH DR. CRAFT VOLUME II PAGE 434 A MAP LIKE THIS, IT'S HARD TO REALLY PIN -- WE CAN PUT OUR PLOTS ON THERE, BUT YOU SEE HIS DETAIL IS NOT THAT GREAT -- FIFTY PERCENT (50%) OR MORE SAWGRASS, FIFTY PERCENT (50%) OR MORE CATTAIL, OTHER, YOU KNOW, WHEREAS WE ACTUALLY TRIED TO, YOU KNOW, GO INTO MORE DETAIL WITH THE INDIVIDUAL SPECIES. Q. WERE YOU ON THE JULY 12, 1989, SURVEY? I CAN'T REMEMBER THE DATES THAT YOU WERE WITH DUKE. A. NO, NO. I WAS NOT INVOLVED IN THAT. Q. OKAY. A. I WENT OUT IN JUNE OF '89, SEPTEMBER OF '89, IN A HELICOPTER, AND JANUARY OF '90. Q. DO YOU HAVE ANY IDEA, IF YOU LOOK AT THIS MAP FROM LARSON--- (THEREUPON, MS. PONZOLI SHOWS WITNESS DOCUMENT.) A. OKAY. I WILL FIND IT. I HAVE IT. Q. DO YOU HAVE ANY IDEA IF THIS SURVEY LIMITS LINE IS AS FAR AS THEY WENT? A. I DON'T KNOW. SOMETHING LIKE THAT WOULD SOUND TO ME LIKE THAT IS AS FAR AS THEY WENT, BECAUSE THEY SHOW THEIR TRANSECTS NOT GOING ANY FARTHER THAN THAT. Q. YOU HAVE NO IDEA OF HOW THE SURVEY LIMIT LINE WAS DR. CRAFT VOLUME II PAGE 435 DETERMINED EXCEPT THAT THAT WOULD APPEAR JUST RATIONALLY FROM THE WAY IT'S DRAWN? A. RIGHT. Q. OKAY. ALL RIGHT. THE MECHANISMS FOR CATTAIL MAINTENANCE FOR SAWGRASS COMMUNITIES--- A. IS THIS IN THE SAME EXHIBIT? (THEREUPON, MS. PONZOLI SHOWS WITNESS DOCUMENT.) A. OKAY. I HAVE IT. Q. OKAY. DID YOU WRITE THIS? A. YES. Q. YOU EXTRAPOLATED LARSON'S DATA TO YOUR LOCATIONS, RIGHT? A. RIGHT. Q. BUT YOU JUST ACCEPTED HIS FIGURES AS BEING ACCURATE BECAUSE YOU HAD NO WAY OF CONFIRMING THEM YOURSELF? A. OH, RIGHT, CERTAINLY--- Q. OKAY. A. ---I MEAN, THIS IS A SORT OF EXTRAPOLEE. Q. SURE, SURE. AND YOU ASSIGNED THE FIFTY PERCENT TO THE 10D2 SITE AND THE THIRTY PERCENT TO THE 10D3, IS THAT RIGHT? A. I SAY THAT, YES. Q. RIGHT. OKAY. YOU'RE TALKING THROUGH HERE ABOUT DR. CRAFT VOLUME II PAGE 436 THE BURN AND THE FREEZE AND ITS EFFECT ON THE CATTAIL. AND THEN, I THINK, YOU'VE GRAPHED SOME OF THAT ON THE FOLLOWING PAGE. IS THAT ACCURATE? A. YES. Q. OKAY. YOU SHOW IN FEBRUARY OF '91 THAT THE CATTAIL IS RECOLONIZING. IS THAT ACCURATE? A. WHICH ONE ARE WE TALKING ABOUT HERE? Q. BOTH. ACTUALLY BOTH. A. BOTH. OKAY, I SEE--- Q. D2 AND D3. A. ---THERE IS AN INCREASE IN CATTAIL OVER AUGUST OF 1990. Q. RIGHT. WHAT -- YOU DON'T THINK IT'S RECOLONIZING THOSE PLOTS? A. NO, NO. I'M SAYING THERE IS AN INCREASE COMPARED TO AUGUST OF 1990. Q. OH, OKAY. SINCE WE'RE IN '92 MOVING ON INTO '93, HAVE YOU BEEN BACK TO THESE SITES, AND CAN YOU TELL ME HOW THESE BARS WOULD LOOK TODAY? WOULD THEY HAVE MORE CATTAIL REFLECTED ON THEM? A. WE'VE BEEN BACK. I WOULD HAVE TO LOOK AT THE DATA TO SEE, BUT WE WERE BACK THIS PAST MAY TO THESE PLOTS. Q. BUT YOU DON'T RECALL WHETHER THEY'VE -- THERE'S DR. CRAFT VOLUME II PAGE 437 BEEN MORE COLONIZATION OF THE CATTAIL SINCE THE TIME IN FEBRUARY '91? A. NO. I MEAN, BUT THE INFORMATION IS THERE, YOU KNOW, AND IT COULD BE LOOKED AT. Q. WHERE WOULD THAT BE IN YOUR DATA? JUST TELL ME, I DON'T WANT TO LOOK FOR IT. A. IN THAT -- IN ALL THAT VEGETATION STUFF WE'VE BEEN TALKING ABOUT, YEAH. Q. OH, IS IT JUST AHEAD OF IT; IS THAT JUST AHEAD OF IT? A. IT'S PROBABLY ALL -- YEAH, ALL -- IT MAY ALL BE IN THIS--- Q. IS THIS ALL IN THIS SAME FILE? A. I THINK SO. LOOK AT THE DATE. WELL, NOW THIS IS 1990. DO YOU HAVE THE '92 STUFF IN HERE? Q. I HAVE SOME '92. I THINK SOMEONE'S WHISPERING TO ME THAT IT MAY BE IN NUMBER TEN. A. NO TALKING OVER THERE. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. THAT'S FINE, I CAN LOOK AT IT. A. OKAY. Q. HAVE YOU FORMED ANY CONCLUSIONS, DR. CRAFT, REGARDING THE USE OF FIRE AS A MECHANISM FOR CONTROLLING CATTAIL? DR. CRAFT VOLUME II PAGE 438 A. I HAVEN'T FORMULATED ANY CONCLUSIONS, BUT I THINK IT'S CERTAINLY WORTH LOOKING AT TO SEE IF PERIODIC FIRE CAN BE USED TO MANAGE -- TO MAINTAIN SAWGRASS. I MEAN, I THINK THAT'S SOMETHING THAT SHOULD BE INVESTIGATED. Q. AND YOU WOULD CONSIDER PERIODIC HOW OFTEN? A. THAT'S WHAT I DON'T KNOW ENOUGH ABOUT -- PERHAPS, MAYBE EVERY TWO OR THREE YEARS, I DON'T KNOW. THAT'S WHERE I THINK THESE PERMANENT PLOTS BY GOING BACK AND LOOKING EVERY COUPLE OF YEARS AND SEEING HOW THE PLANTS CHANGE. Q. AND HOW WOULD YOU -- I MEAN, I DON'T MEAN TO BE FACETIOUS -- I REALLY DON'T -- BUT HOW WOULD YOU CONTROL THESE FIRES? A. THEY'D HAVE TO BE PRESCRIBED BURNS, AND I'M NOT, YOU KNOW, SOMEBODY WHO DOES THAT, SO YOU'D CERTAINLY HAVE TO TALK TO SOMEBODY WHO IS -- WHO DOES THAT FOR A LIVING AND SEE. I MEAN, CERTAINLY YOU WOULDN'T WANT TO TRY TO GO OUT THERE AND BURN IN SEPTEMBER WHEN THERE'S THREE FEET OF WATER. THE TIME OF YEAR WOULD BE IMPORTANT TO -- YOU KNOW, I WOULD THINK YOU WOULD WANT TO HAVE WATER MAYBE JUST AT THE SURFACE. I THINK YOU'D NEED A COMBINATION OF BURNING AND THEN MAYBE A CHANGE IN DR. CRAFT VOLUME II PAGE 439 THE WATER LEVEL, TOO, BUT I DON'T KNOW ENOUGH ABOUT IT. I THINK IT'S SOMETHING THAT SHOULD BE LOOKED THOUGH. Q. SO, YOU'D NEED ENOUGH WATER THAT THE PEAT WOULDN'T BURN--- A. RIGHT. Q. ---YOU DON'T WANT IT SO DRY THAT THE PEAT'S BURNING, BUT--- A. YOU WANT IT DRY ENOUGH TO WHERE IT BURNS DOWN TO THE BASE OR PRETTY CLOSE TO IT. YOU MAYBE WOULDN'T HAVE TO HAVE SURFACE WATER. BUT IF YOU HAD IT RIGHT BELOW THE SURFACE, THE PEAT WOULD STILL STAY MOIST. Q. IS THE THEORY OF THIS THAT A SCORCHED EVERGLADES IS BETTER THAN ONE FILLED WITH CATTAILS? MR. GREEN: OBJECT TO THE FORM. A. WELL, NO. I'M NOT SURE IF THE -- IT'S NOT A THEORY. BUT, YOU KNOW, I THINK FROM WHAT YOU READ IN THE LITERATURE, FIRE WAS AN IMPORTANT COMPONENT OF THE HISTORICAL EVERGLADES AND THAT MAY HAVE HELPED MAINTAIN SAWGRASS AGAINST OTHER SPECIES IN THE PAST. Q. DO YOU THINK THAT CONTROLLING CATTAIL IS IMPORTANT FOR MANAGING THE EVERGLADES? DR. CRAFT VOLUME II PAGE 440 A. I THINK IT'S IMPORTANT IF PEOPLE DON'T WANT CATTAIL. THAT'S -- I DON'T KNOW IF THAT'S MY DECISION TO MAKE. IF THEY WANT TO MAINTAIN SAWGRASS, THEN MAYBE THEY NEED TO THINK ABOUT, YOU KNOW, CONTROLLING CATTAIL. Q. IS THERE LITERATURE THAT INDICATES THAT FIRE CONTROLS CATTAIL? A. I DON'T KNOW. I'M NOT AWARE OF IT. BUT, AGAIN, THIS IS NOT SOMETHING I'M REALLY KNOWLEDGEABLE ABOUT. Q. IS DR. RICHARDSON MORE AN EXPERT ON FIRE IN THE EVERGLADES? A. I DON'T KNOW. I'M NOT SURE. HE MAY KNOW MORE THAN ME, BUT, YOU KNOW, I'M NOT SURE IF HE'S AN EXPERT ON FIRE IN THE EVERGLADES. Q. OKAY. I'D LIKE TO MOVE ON TO CRAFT NUMBER SEVENTEEN, AND I DON'T KNOW IF I DID THE WHOLE FILE FOR YOU. THIS IS THE FILE FROM WHICH IT CAME. A. I HAVE SOME PAGES HERE. Q. YEAH. IT LOOKS LIKE YOU HAVE THE WHOLE FILE. THIS IS THE AREA OF ENHANCED PHOSPHORUS ACCUMULATION. IS THAT RIGHT? A. UH-HUH (YES). DR. CRAFT VOLUME II PAGE 441 Q. I WOULD LIKE TO GO TO THE FIRST PAGE OF DATA AND ASK YOU TO EXPLAIN WHAT THIS DATA REFLECTS. A. WE TOOK OUR DATA ON PHOSPHORUS ACCUMULATION IN 2A AND TRIED TO DETERMINE WHAT THE SIZE OF THIS AREA OF ENHANCED PEAT ACCUMULATION IS, AND THIS WAS OUR ATTEMPT TO DO THAT. Q. OKAY. I ASSUME THAT THE AREAS OF ENRICHMENT INCLUDE HIGH ENRICHMENT, MODERATE ENRICHMENT, AND LOW ENRICHMENT. IS THAT ACCURATE? A. RIGHT, WHICH I JUST BROKE OUT ARBITRARILY. Q. OKAY. AND THAT THAT IS DISTINGUISHED FROM THE UNENRICHED AREA? A. CORRECT. Q. OKAY. WHAT IS THIS TOTAL AREA OF FOURTEEN THOUSAND FIVE HUNDRED HECTARES? A. THAT AREA IS THE ELEVEN THOUSAND FIVE HUNDRED ENRICHED AREA PLUS THE ADDITIONAL THREE THOUSAND HECTARES THAT OUR TRANSECTS EXTENDED FURTHER SOUTH OUT OF THE ENRICHED ZONES. SO IT'S JUST THAT YOU ADD THOSE UP. Q. IS THIS THE TOTAL WATER CONSERVATION AREA 2A? A. NO. NO. NO. THIS IS THE ENRICHED AREA PLUS THE UNENRICHED AREA THAT WE SAMPLED. Q. OKAY. AND THEN THE NEXT PAGE REFLECTS WHAT? DR. CRAFT VOLUME II PAGE 442 A. THESE ARE THE PLANIMETER WORK THAT LORI SUTTER CALCULATED TO DETERMINE THE AREA. Q. AND IS SHE COMPARING -- IS THIS YOUR WRITING, OR HERS? A. NO. THIS IS HERS. Q. OKAY. AND WAS SHE COMPARING DR. REDDY'S WORK WITH YOURS? A. WELL, WE WERE JUST TRYING TO DETERMINE -- DR. REDDY'S DONE A LOT OF WORK IN CONSERVATION AREA 2A, AND WE WERE JUST LOOKING AT HIS DATA TO SEE HOW FAR HIS ZONE OF ENRICHMENT EXTENDED VERSUS OUR ZONE OF ENRICHMENT. Q. OKAY. ALL OF THESE ARE STAMPED WITH "DRAFT." IS THAT CUSTOMARY THAT YOU WOULD STAMP YOUR DATA SHEETS DRAFT? A. NOT CUSTOMARY. BUT SINCE THIS NUMBER SEEMS TO BE OF INTEREST TO A LOT OF PEOPLE, WE WOULD LIKE TO MAKE SURE WE HAVE IT RIGHT, OR WE THINK WE HAVE THE BEST ESTIMATE BEFORE, YOU KNOW, WE RELEASE IT, OR, YOU KNOW, LET IT OUT FOR THE PUBLIC TO SEE. Q. OKAY. SO, WHEN YOUR DOCUMENTS WERE PULLED TOGETHER, WERE THEY STAMPED "DRAFT" AT THAT TIME? DR. CRAFT VOLUME II PAGE 443 A. I DIDN'T STAMP THEM DRAFT, SO, I'M NOT SURE. I THINK DR. RICHARDSON MAY HAVE LOOKED AT THESE AND STAMPED THEM, BECAUSE THIS IS SUCH KIND OF A CONTENTIOUS ISSUE. Q. OKAY. DID DR. RICHARDSON REVIEW YOUR DOCUMENTS BEFORE THEY WERE TURNED OVER TO THE UNITED STATES? A. HE DIDN'T REVIEW THEM, BUT I THINK HE LOOKED AT SOME OF THEM. Q. DO YOU KNOW WHO DID CHOOSE TO MARK YOUR DOCUMENTS DRAFT? A. NO, I'M NOT SURE WHO STAMPED THEM -- THIS PARTICULAR ONE. I KNOW THAT IT WASN'T ME, SO. Q. DID YOU MAKE THE DECISION TO STAMP THIS "DRAFT," OR DID DR. RICHARDSON? A. I DID NOT MAKE THE DECISION, SO. Q. YOU DON'T KNOW WHO MADE IT? A. RIGHT. Q. OKAY. HOW DID YOU DISTINGUISH IN THIS ONE BETWEEN THE HIGH, THE MEDIUM, AND THE LOW ENRICHMENT? A. FIRST, WE DEFINED UNENRICHED VERSUS ENRICHED AS AN ACCUMULATION RATE OF .15 GRAMS PER METER SQUARED PER YEAR OR GREATER. WELL -- SO, THAT'S DR. CRAFT VOLUME II PAGE 444 THE OVERALL ENRICHED ZONE. SO, THE LOW AREA GOES FROM .15 TO .40 GRAMS PER METER SQUARED PER YEAR--- Q. OKAY. A. ---THE MEDIUM GOES FROM .40 TO .65. AND THE HIGH GOES FROM .65 TO .90. Q. AND THE LOW WAS THE .15 TO .40--- A. YES. Q. ---WAS THAT THE -- OKAY. ALL RIGHT. I'M SORRY, I THOUGHT THAT WAS UNENRICHED, AND I GOT IT WRONG. A. SO, THE UNENRICHED IS LESS THAN .15. Q. OKAY. THANK YOU. ALL RIGHT. I'D LIKE TO LOOK AT CRAFT NUMBER EIGHTY-EIGHT--- A. I DON'T KNOW WHERE THAT IS. (THEREUPON, WITNESS LOOKS FOR DOCUMENT.) A. OH, OKAY. Q. ---AND I PROBABLY REPRODUCED THE WHOLE DOCUMENT, BUT THERE'S REALLY A PAGE -- A FEW PAGES FROM THE END -- FOUR PAGES FROM THE END THAT I WOULD LIKE TO ASK YOU ABOUT--- A. OKAY. Q. ---THIS PAGE RIGHT HERE. (THEREUPON, MS. PONZOLI SHOWS WITNESS DOCUMENT.) DR. CRAFT VOLUME II PAGE 445 A. OKAY. I HAVE IT. Q. I WOULD LIKE FOR YOU TO TELL ME WHAT THESE DATA ARE. A. THESE ARE THE SOIL TOTAL P AT THE PRETREATMENT COURSE THAT WERE COLLECTED BETWEEN THE PLOTS BEFORE WE STARTED THE STUDY. Q. OKAY. AND THE ASTERISKS ON THIS DATA MEAN WHAT? A. I'M NOT SURE WHAT THEY MEAN -- OH, THEY'RE REVERSED. YOU CAN SEE THE TUBE NUMBERS REVERSE, SEE HOW THEY'RE IN SEQUENTIAL ORDER IN THE BLOCK NUMBER? Q. YES. WELL, NO, I'M SORRY, IT SAYS SEVEN, EIGHT, NINE. A. OKAY. I SEE THESE TWO ASTERISKS WAY DOWN HERE--- Q. YES, SIR. A. ---IF YOU GO TO THE SECOND COLUMN BLOCK NUMBER--- Q. YES, OH, I SEE. A. ---SEE HOW IT STARTS AT ONE. Q. SURE. OH, I SEE, SURE. A. SO, WHAT HAPPENED WAS THOSE TWO JUST GOT REVERSED IN THE BLOCK, AND WE JUST WANTED TO BE AWARE OF THAT AND MAKE SURE WE HAD THE RIGHT NUMBERS. Q. OKAY. ON THE NEXT PAGE, IT HAS SOMETHING ABOUT AN ASTERISK AND IT SAYS "THROWN OUT." WHAT DOES THAT DR. CRAFT VOLUME II PAGE 446 MEAN -- WHAT DOES THAT ASTERISK REFER TO? A. WELL, I'M NOT EXACTLY SURE, BUT IT MEANS THAT WE PROBABLY DIDN'T INCLUDE THE SAMPLING, REDIGESTED IT BECAUSE WE HAD PROBLEMS WITH IT. BUT I DON'T REALLY SEE WHAT--- Q. WAS THAT FROM SAMPLE 1D, PERHAPS, AT THE TOP? A. THAT'S SAMPLE ID--- Q. I'M SORRY, ID. A. ---AND THEN THE ASTERISK IS BELOW THAT, AND I DON'T SEE ANY IDENTIFICATION WITH IT. THAT'S THE THING -- THAT'S NINE, TEN, ELEVEN -- UNLESS IT'S THESE TWO ON THE PREVIOUS PAGE THAT HAVE THE ASTERISKS WITH THEM. MAYBE WE THREW THEM OUT BECAUSE WE DIDN'T KNOW WHICH ONES THEY EXACTLY WERE, ALTHOUGH -- IF WE'D GOTTEN THEM REVERSED. Q. SHOULD THEY HAVE BEEN CLOSER TOGETHER IN THEIR TOTAL PHOSPHORUS? YOU SEE THERE, ONE IS ALMOST DOUBLE THE OTHER. A. WELL, I DON'T KNOW. THAT MAY BE -- I DON'T KNOW WHETHER WE RERAN THOSE SAMPLES OR WHAT. BUT THERE'S A LOT OF VARIABILITY IN THE SOILS OUT THERE. THESE WERE ZERO TO THIRTY CENTIMETER DEEP CORES THAT WERE DRIED AND GROUND UP. DR. CRAFT VOLUME II PAGE 447 Q. DO YOU HAVE EXHIBITS LEFT THAT I HAVEN'T QUESTIONED YOU ON, BECAUSE I HAVE RUN THROUGH MINE? A. WELL, I WASN'T SEQUENTIALLY MOVING THEM OVER UNTIL LATER ON SO. Q. DO YOU HAVE A TWENTY-ONE AND A TWENTY-NINE? A. UH-HUH (YES). MAYBE THESE ARE THE TWO THAT REMAIN. MR. BURGESS: TWENTY-ONE AND TWENTY-NINE? WITNESS: YES. TWENTY-ONE AND TWENTY-NINE. (THEREUPON, MS. PONZOLI AND MR. MAFFEI CONFER.) MS. PONZOLI: I JUST HAVE A FEW QUESTIONS FROM THE ANNUAL REPORTS. WITNESS: CAN WE BACK UP, ARE WE GOING TO DEAL WITH TWENTY-ONE AND TWENTY-NINE? MS. PONZOLI: NO. WITNESS: OKAY. MS. PONZOLI: DO YOU WANT TO? WITNESS: NO, I JUST SAW MARK HANDING THEM TO YOU, SO, I DIDN'T KNOW IF WE WERE DONE ON THIS. DR. CRAFT VOLUME II PAGE 448 MS. PONZOLI: NO, I DON'T THINK I HAVE ANYTHING ON EITHER. WITNESS: OKAY. Q. (BY MS. PONZOLI) I DO HAVE A QUESTION FROM THE ANNUAL REPORT 1992, FROM YOUR CHAPTER ONE. I DON'T HAVE COPIES OF THIS. IF YOU NEED TO SEE IT, I'LL SHOW IT TO YOU. IT'S CHAPTER ONE, THE FERTILIZER STUDY, "RESPONSE OF EVERGLADES PLANT COMMUNITIES TO NITROGEN AND PHOSPHORUS ADDITIONS," ON PAGE 13, UNDER "EXPERIMENTAL DESIGN," YOU TALK IN THE -- I BELIEVE THE SECOND FULL SENTENCE REGARDING "THE THREE COMMUNITIES ARE FOUND ALONG A HYDROPERIOD GRADIENT WITH SAWGRASS EXTENDING ON THE DRIER END OF THE GRADIENT AND SLOUGH COMMUNITY OCCUPYING THE WETTER END." MAYBE I'VE JUST FORGOTTEN, DR. CRAFT, DID WE DISCUSS HOW YOU SET UP A GRADIENT OF HYDROPERIOD? A. WE DIDN'T SET UP A GRADIENT. WE SET UP THE PLOTS AND THEN WE MONITORED WATER LEVELS. AND, BASICALLY, ALL IT SHOWS IS THE WATER LEVEL DATA -- ON PAGE 15 -- SHOWS THAT THE SITES DO APPEAR TO EXIST ON A HYDROPERIOD GRADIENT. THAT WAS NOT AN INTENT. THAT WAS MORE JUST SOMETHING WE OBSERVED DURING, YOU KNOW, ONCE THE STUDY WAS SET UP. DR. CRAFT VOLUME II PAGE 449 Q. UH-HUH (YES). WHEN YOU LOOK AT PAGE 15, AT THE GRAPH, DO YOU BELIEVE THAT YOU ARE SEEING A DIFFERENCE EXCEPT WHEN THE GATES ARE OPENED? A. WELL, IF YOU COMPARE THE SAWGRASS AND THE SLOUGH SITE, THE DIFFERENCE SEEMS TO OCCUR YEAR ROUND. YOU CAN SEE THE SAWGRASS AND THE SLOUGH SITE REALLY SEEM TO MIMIC EACH OTHER IN TERMS OF GOING UP AND DOWN, BUT THE SAWGRASS SITE IS JUST DRIER. THE MIXED SITE SEEMS TO SHOW THAT WHEN THE GATES ARE OPEN, YOU SEE THESE BIG FLUCTUATIONS THERE IN THE MIDDLE OF THE SUMMER. Q. UH-HUH (YES). DO YOU HAVE A HYDROPERIOD STUDY ALSO LOCATED IN 2B? A. DR. RICHARDSON HAS THE LEAD IN A -- IN A NUTRIENT HYDROPERIOD DISTURBANCE STUDY IN 2B. Q. OKAY. NOW, BACK ON 13, YOU SAY, "THE MIXED SAWGRASS-CATTAIL COMMUNITY REPRESENTS AN INTERMEDIATE POSITION ALONG THE HYDROLOGIC GRADIENT." LOOKING AT THE GRAPH ON 15, OTHER THAN THE MIXED SITE RESPONDING SIGNIFICANTLY TO THE OPEN GATES, DOESN'T IT APPEAR THAT THE MIXED SITE IS PRETTY CLOSE TO THE SAWGRASS SITE IN ITS HYDROPERIOD? A. YEAH, I THINK YOU'RE RIGHT. I MEAN, I THINK THAT DR. CRAFT VOLUME II PAGE 450 MAY NOT BE A CORRECT STATEMENT. Q. OKAY. I HAVE PICTURES OF SOME OF YOUR SLIDES--- WITNESS: CAN WE TAKE A BREAK, OR ARE WE GETTING PRETTY CLOSE. MS. PONZOLI: NO. LET'S TAKE A BREAK, I'D LIKE A BREAK, AND I'LL GET A COKE. WITNESS: OKAY. MS. PONZOLI: WHAT -- TEN MINUTES, FIVE MINUTES? WITNESS: OKAY, WE'LL TAKE A BREAK NOW FOR TEN MINUTES? MS. PONZOLI: FIVE MINUTES IS FINE WITH ME. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER, AND A SHORT BREAK WAS TAKEN.) MS. PONZOLI: READY? WITNESS: YES. EXAMINATION BY MS. PONZOLI CONTINUES: Q. DR. CRAFT, MY FINAL QUESTIONS ARE REALLY TO HAVE YOU EXPLAIN SOME REPRODUCTIONS FROM YOUR SLIDES THAT WE WOULD JUST LIKE SOME -- TO UNDERSTAND WHAT DR. CRAFT VOLUME II PAGE 451 THEY MEAN. THIS IS DEPOSITION EXHIBIT NUMBER 112, WHICH WERE YOUR SLIDES -- NO, I'M WRONG -- OH, THEY WERE A DIFFERENT SET. I GUESS IT'S NUMBER 113. NO, IT'S NUMBER 117, DEPOSITION EXHIBIT NUMBER 117 CRAFT. AND SINCE THERE IS A SINGLE SET OF THESE, DR. CRAFT, MAYBE IF YOU WOULD JUST EXPLAIN TO EVERYONE SIMULTANEOUSLY WHAT IT REPRESENTS, I WOULD APPRECIATE IT. DO YOU WANT ME TO TURN IT AROUND FOR YOU, OR CAN YOU--- A. IF I WANT TO LOOK AT IT, I'LL JUST -- I CAN PICK IT UP AND JUST LOOK. Q. OKAY. AND WOULD YOU EXPLAIN THIS FIRST PHOSPHORUS ACCUMULATION GRAMS PER METER SQUARED PER YEAR? A. THIS IS A SLIDE THAT I'VE USED TO CONFUSE A LOT OF PEOPLE, INADVERTENTLY. BUT, BASICALLY, THIS IS DATA THAT COMES OUT OF THAT PAPER ON PEAT ACCRETION AND NUTRIENT ACCUMULATION ALONG THE EUTROPHICATION GRADIENT. AND IF YOU LOOK AT THIS, THE HILLSBORO CANAL IS HERE. AND SO AS YOU MOVE THIS WAY, YOU'RE GETTING FURTHER FROM THE HILLSBORO CANAL, AND IT JUST SHOWS THAT PHOSPHORUS ACCUMULATION IN GRAMS PER METER SQUARED PER YEAR DECREASES AS YOU MOVE AWAY AND IT SHOWS THIS IS THE "D" TRANSECT, THE "C" TRANSECT, AND THE "A" DR. CRAFT VOLUME II PAGE 452 TRANSECT. SO, THIS IS A THREE-DIMENSIONAL REPRESENTATION HERE, AND THIS IS JUST A TWO-DIMENSIONAL REPRESENTATION OF THE SAME THING. Q. AT THE BOTTOM? A. YES. IT'S A CONFUSING SLIDE, AND I'VE PRETTY MUCH GOTTEN RID OF IT. THIS IS THE SAME SORT OF SLIDE--- MR. BURGESS: I'M SORRY, IS THIS IN THE SAME 117? WITNESS: YES. A. ---THIS IS SODIUM ACCUMULATION, AGAIN, THE CANAL HERE, DISTANCE HERE, THE THREE-DIMENSIONAL REPRESENTATION HERE, THE TWO HERE. BUT IT SHOWS, AS I MENTIONED IN THE TEXT, THE SODIUM ENRICHMENT REALLY ONLY SEEMS TO OCCUR AT A COUPLE OF POINTS NEAR THE HILLSBORO CANAL. C1 IS ONE OF THEM. THE SAME TYPE OF GRAPH AS THE ONE WE JUST LOOKED AT THOUGH. (THEREUPON, MS. PONZOLI HANDS WITNESS SLIDE.) A. OKAY. THIS IS AGAIN THE SAME DATA GRAPH, BUT IT IS TWO-DIMENSIONAL. AND, AGAIN, DISTANCE DOWNSTREAM FROM THE HILLSBORO CANAL, YOU VIEW THE CANAL AS BEING RIGHT HERE, AND IT JUST SHOWS THAT PHOSPHORUS ACCUMULATION DECREASES WITH DISTANCE. DR. CRAFT VOLUME II PAGE 453 (THEREUPON, MS. PONZOLI HANDS WITNESS SLIDE.) A. THIS IS A TWO-DIMENSIONAL GRAPH SHOWING SODIUM ACCUMULATION WITH DISTANCE. AND, AGAIN, YOU SEE THIS HIGH ZONE OF ACCUMULATION IS NEAR C1. AND D1 ALSO SHOWS SOME EVIDENCE OF HIGHER ACCUMULATION. AND IT DECREASES AS YOU MOVE DOWNSTREAM. Q. THE NEXT SLIDES, DR. CRAFT, I BELIEVE ARE FROM COMPOSITE EXHIBIT NUMBER 120. (THEREUPON, MS. PONZOLI HANDS WITNESS SLIDE.) A. OKAY. THIS WAS A LITTLE MINI-STUDY WE DID LAST FEBRUARY WHERE WE PUT THE FERTILIZER INTO THE PLOTS AT THE FERTILIZER STUDY AND WE TOOK SAMPLES AT CERTAIN TIME INTERVALS AFTER WE APPLIED THE FERTILIZER TO GET AN IDEA OF HOW LONG THE MATERIAL WAS RETAINED IN THE PLOTS. AND IT SHOWS THAT THE HIGHEST PEAT TREATMENT, EVEN AFTER FORTY-EIGHT HOURS, THERE'S STILL QUITE A BIT IN THE PLOTS. IT JUST SHOWS A SORT OF A TIME SERIES STUDY TO SHOW HOW THE FERTILIZER CHANGES OVER TIME. THAT'S PHOSPHATE. THIS IS THE SAME GENERAL SLIDE, EXCEPT IT JUST SHOWS AMMONIUM, THE NITROGEN TREATMENTS, AND YOU CAN SEE THE CONCENTRATION IN THE WATER WITH TIME. THIS IS FOR THE HIGH END AND THEN THIS IS FOR THE MEDIUM AND P TREATMENT. DR. CRAFT VOLUME II PAGE 454 (THEREUPON, MS. PONZOLI HANDS WITNESS SLIDE.) A. AND THEN THIS IS NITRATE, AGAIN THE SAME GENERAL SERIES SHOWING. AND I THINK WHAT IS INTERESTING IS WE DON'T ADD NITRATE, BUT YOU SEE THAT OVER TIME, THE NITRATE ACTUALLY INCREASES IN THE PLOTS WITH TIME. AND THAT KIND OF SUGGESTS TO ME THAT THERE IS SOME NITRIFICATION GOING ON FROM THE AMMONIUM THAT WE APPLY. MS. PONZOLI: THOSE ARE ALL I HAVE QUESTIONS ON, DR. CRAFT. I THANK YOU VERY MUCH. YOU'VE BEEN VERY HELPFUL AND I THINK THAT CONCLUDES MY QUESTIONS, DR. CRAFT. THANK YOU VERY MUCH. (THEREUPON, A LUNCH BREAK WAS TAKEN.) EXAMINATION BY MR. NETTLETON: Q. DR. CRAFT, MY NAME IS PAUL NETTLETON. I REPRESENT THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT IN THIS LITIGATION. I'M GOING TO TRY TO BE AS NON-REPETITIVE AS POSSIBLE. I APOLOGIZE IF THERE IS SOME REPETITION. I WANT TO TRY AND FILL IN SOME GAPS IN MY UNDERSTANDING, AND I'LL PREFACE THAT BY ADVISING YOU THAT I'M PROBABLY THE NEWEST MEMBER TO THIS WHOLE SITUATION, SO I HAVEN'T LIVED DR. CRAFT VOLUME II PAGE 455 WITH IT AS LONG AS EVERYONE ELSE, EXCEPT MAYBE RALPH -- I DON'T KNOW. SO, I'M GOING TO TRY AND GO THROUGH THE SAME ORDER WE WENT YESTERDAY, THROUGH SOME OF THE DOCUMENTS. AND I WOULD FIRST LIKE TO TALK ABOUT THE CRAFT EXHIBIT NUMBER FIVE, AND THE DOCUMENT ENTITLED: PEAT ACCRETION IN NITROGEN, PHOSPHORUS, AND ORGANIC CARBON ACCUMULATION, ETCETERA, WHICH IS WETLAND CENTER PUBLICATION NUMBER 91-02. ON THE FIRST PAGE OF THAT -- ON THE FIRST PAGE OF THE ABSTRACT, THE -- ABOUT THIRD SENTENCE DOWN, IT READS "ACCRETION RATES WERE HIGHEST IN AREAS OF EXTENDED HYDROPERIOD" -- SKIPPING THE NUMBERS -- "AND/OR PHOSPHORUS ENRICHMENT." AM I CORRECT THAT -- THAT YOUR FINDING OF HIGHER RATES OF ACCRETION COULD NOT BE DIVIDED BETWEEN THE HYDROPERIOD INFLUENCE, AND THE PHOSPHORUS ENRICHMENT INFLUENCE, AND IS THAT WHY THE "AND/OR" APPEARS? A. NO. WHAT THAT MEANS IS THERE ARE SOME AREAS THAT ARE EXPOSED ONLY TO EXTENDED HYDROPERIOD THAT SHOW THIS HIGHER ACCRETION RATE, AND THEN THERE'S ANOTHER LOCATION THOUGH THAT HAS BOTH EXTENDED HYDROPERIOD AND PHOSPHORUS ENRICHMENT, AND ALSO SHOWS THIS HIGHER ACCRETION RATE. THE ONE SITE WE DR. CRAFT VOLUME II PAGE 456 DID NOT HAVE WAS AN AREA THAT HAS -- THAT WE WERE NOT -- DID NOT SAMPLE -- HAD A SHORT HYDROPERIOD AND PHOSPHORUS ENRICHMENT, SO. Q. OKAY. WHAT WAS THE SITE WITH THE EXTENDED HYDROPERIOD, WITHOUT PHOSPHORUS ENRICHMENT? A. THOSE WERE THE LOCATIONS DOWN IN THE SOUTHERN PART OF CONSERVATION AREA 3A, RIGHT ADJACENT TO THE TAMI -- I THINK IT'S THE TAMIAMI TRAIL. Q. WERE YOU ABLE, THROUGH THIS STUDY, AND THE DATA YOU COLLECTED, TO DETERMINE WHICH FACTOR IS A MORE SUBSTANTIAL FACTOR IN THE ACCRETION RATES OF THE PEATS? A. NO. YOU KNOW, THERE AGAIN, I THINK WE TALKED ABOUT THIS YESTERDAY, AND I THINK AT THIS POINT, I DON'T HAVE THE INFORMATION TO BE ABLE TO SEPARATE OUT THE RELATIVE IMPORTANCE OF HYDROPERIOD VERSUS PHOSPHORUS ENRICHMENT. Q. AND CONTINUING WITH THAT SENTENCE, IT SAYS, "AND THE LOWEST IN AREAS OF REDUCED HYDROPERIOD," MEANING, I ASSUME, THE LOWEST PEAT ACCRETION RATES? A. RIGHT. Q. IS THAT CORRECT? A. RIGHT. DR. CRAFT VOLUME II PAGE 457 Q. DID -- YOU MAY HAVE JUST ANSWERED THIS A MINUTE AGO, BUT WAS -- DID YOU HAVE ANY FINDINGS WITH REGARD TO AN AREA WITH LOW NUTRIENTS? A. WELL, THE PROBLEM WAS THE AREAS THAT HAD REDUCED HYDROPERIOD, ALSO HAD LOW NUTRIENTS, HAD LOW PHOSPHORUS, AND SO--- Q. OKAY. SO, WHAT IS THE COMBINATION THAT IS MISSING? YOU SAID IT WAS THE LOW NUTRIENTS AND THE HIGH HYDROPERIOD? A. LET ME LOOK. A SHORT HYDROPERIOD WITH HIGH PHOSPHORUS IS WHAT IS MISSING--- Q. OKAY. A. ---REDUCED HYDROPERIOD AND PHOSPHORUS ENRICHMENT. Q. IN YOUR STUDIES SINCE THIS WAS ORIGINALLY PLOTTED, HAVE YOU LOCATED ANY SITES WHERE THAT SITUATION WOULD EXIST? A. I HAVEN'T REALLY LOOKED FOR ANY, AND I HAVEN'T COME ACROSS ANY JUST, YOU KNOW, LOOKING THROUGH THE LITERATURE, EITHER. Q. AT THE BOTTOM OF THAT PAGE, AND CONTINUING ON TO THE NEXT PAGE, STARTING WITH THE FULL SENTENCE ON THAT PAGE, IT SAYS THAT THE -- AND I'M GOING TO SKIP A FEW WORDS, BUT I'LL PARAPHRASE IT -- INPUTS OF PHOSPHORUS TO THE NUTRIENT ENRICHED AREA DR. CRAFT VOLUME II PAGE 458 OF WCA 2A WERE SIX TIMES HIGHER THAN INPUTS TO THE UNENRICHED PART OF WCTA. AS A RESULT, THE EFFICIENCY OF PHOSPHORUS REMOVAL WAS LOWER AT THE ENRICHED SITE, EIGHTY-SEVEN PERCENT, THAN AT THE UNENRICHED LOCATION, ONE HUNDRED PERCENT. HOW -- HOW DOES THE SECOND SENTENCE RESULT FROM THE FIRST SENTENCE? A. WHAT YOU DO IS YOU COMPARE. WE HAVE THE INPUTS HERE. FOR EXAMPLE, P IS .56 GRAMS PER METER SQUARED PER YEAR TO THE ENRICHED SITE, AND WE COMPARE THIS WITH THE RATE OF PHOSPHORUS ACCUMULATION FOR THIS SITE, AND I THINK WE'D HAVE TO GO UP. WELL, YOU CAN SEE .46 GRAMS PER METER SQUARED PER YEAR IN THE SENTENCE RIGHT ABOVE THAT. SO, BASICALLY, YOU JUST DIVIDE THAT .46 BY .56, AND SO YOU GET AN EFFICIENCY OF EIGHTY-SEVEN PERCENT. SO, EIGHTY-SEVEN PERCENT OF THAT .56 GRAMS PER METER SQUARED PER YEAR ENTERING IS ACCUMULATING--- Q. OKAY. A. ---AND THAT YIELDS THE .46. Q. WHAT IS THE SIGNIFICANCE OF THE REST OF THE SENTENCE, THEN, AS FAR AS SAYING THAT IT'S SIX TIMES HIGHER INPUT THAN THE UNENRICHED AREA? DR. CRAFT VOLUME II PAGE 459 A. IT JUST MEANS THAT IT'S RECEIVING A LOT MORE PHOSPHORUS THAN THE UNENRICHED SITE. Q. WAS THE FACTOR SIX TIMES HIGHER, CALCULATED INTO THE RESULTS AT ALL, ON THE EFFICIENCY? A. I DON'T REALLY UNDERSTAND THE QUESTION. Q. ALL RIGHT. WELL, I BELIEVE WHAT YOU TOLD ME IS ALL YOU DID WAS DIVIDE THE .46 BY THE .56 TO COME UP WITH THE EIGHTY-SEVEN PERCENT. IS THAT RIGHT? A. RIGHT. Q. AND SO THE FACT THAT THERE WERE SIX TIMES THE LEVEL OF PHOSPHORUS COMING INTO THE ENRICHED AREA AS OPPOSED TO THE UNENRICHED AREA DID NOT REALLY PLAY INTO THAT EQUATION? A. NO. THAT JUST STATES THAT THIS AREA RECEIVES A LOT MORE PHOSPHORUS THAN THE UNENRICHED AREA. I MEAN, IT PLAYS INTO IT IN THE FACT THAT THAT SIX TIMES HIGHER YIELDS THAT INPUT OF .56 GRAMS PER METER SQUARED PER YEAR. Q. ON THE -- ON THE EIGHTY-SEVEN PERCENT FIGURE, I NOTE ON THE CONCLUSION ON PAGE 24, THAT IT REFLECTS EIGHTY-FIVE PERCENT. IS THAT JUST A TYPOGRAPHICAL ERROR? A. THAT DEFINITELY IS SOMETHING THAT I NEED TO GO BACK AND LOOK AT, BECAUSE, YOU SEE, I'M NOT AWARE DR. CRAFT VOLUME II PAGE 460 OF THAT. WHAT PAGE IS THAT ON? Q. ON PAGE 24. IT'S THE SENTENCE CONTINUING ON PAGE 24. A. OKAY. YEAH. THAT'S SOMETHING I NEED TO ADDRESS. Q. DO YOU KNOW, IS IT THE EIGHTY-SEVEN OR THE EIGHTY-FIVE THAT'S THE CORRECT NUMBER? A. IF SOMEBODY HAD A CALCULATOR AND DID THE QUICK DIVISION. Q. IT'S -- BUT IT'S JUST A MATTER OF THOSE CALCULATIONS WE TALKED ABOUT? A. RIGHT. Q. OKAY. TURNING TO PAGE FIVE OF THE DOCUMENT, PARAGRAPH -- THE PARAGRAPH AT THE END OF THAT PAGE, THE FIRST SENTENCE READS THAT THE -- "THE PRIMARY OBJECTIVE OF THIS STUDY WAS TO CHARACTERIZE RECENT, 1964 THROUGH 1989 YEAR RATES OF PEAT ACCRETION, NUTRIENT---" MR. GREEN: WHAT PAGE? I'M SORRY. MR. NETTLETON: PAGE FIVE. Q. (BY MR. NETTLETON) "---NUTRIENTS, NITROGEN AND PHOSPHORUS ACCUMULATION IN ORGANIC CARBON STORAGE IN EVERGLADE SOILS, AND TO RELATE THESE RATES TO DIFFERENT HYDROPERIOD AND NUTRIENT REGIMES." HOW WAS THE PRIMARY OBJECTIVE OF RELATING THE RATES OF DR. CRAFT VOLUME II PAGE 461 PEAT ACCRETION TO HYDROPERIOD -- HOW WAS THE STUDY DESIGNED TO DO THAT? A. IT WASN'T REALLY DESIGNED TO DO THAT. AGAIN, AS I TALKED ABOUT YESTERDAY, THE REAL LIMITATION IS GOOD HYDROLOGY DATA, GOOD LONG-TERM HYDROLOGY DATA FOR THESE LOCATIONS. AND SO, AGAIN, I RELIED ON INFORMATION IN THE SWIM PLAN, WHICH IS, I THINK, THE BEST AVAILABLE INFORMATION I COULD FIND TO TRY TO RELATE THE PEAT ACCRETION TO HYDROPERIOD. Q. AND AS I RECALL YOUR TESTIMONY, WAS THAT WITH THE GROSS DATA THAT JUST REFLECTED, YOU KNOW, HEAVIER THAN NORMAL AND LESS THAN NORMAL IN AREAS? A. RIGHT. Q. WELL, IF THIS WAS A PRIMARY OBJECTIVE OF THE STUDY FROM THE OUTSET, WHY WASN'T MORE EFFORT PUT INTO TRYING TO SET SOMETHING UP WHICH COULD MORE ACCURATELY MEASURE THE HYDROPERIOD? A. AGAIN, AS I MENTIONED, IF I HAD BEEN -- WHEN I WAS, SAY, SEVEN YEARS OLD IN 1964 AND HAD THOUGHT ABOUT DOING THIS STUDY, I MAYBE COULD HAVE TRIED TO, YOU KNOW, SET SOMETHING UP TO MEASURE WATER LEVELS. BUT SOMETIMES YOU JUST HAVE TO TAKE THE BEST AVAILABLE INFORMATION THAT YOU CAN FIND AND TRY TO RELATE IT TO YOUR INFORMATION. DR. CRAFT VOLUME II PAGE 462 Q. WELL, I THINK WE TALKED ABOUT, YESTERDAY, THE FACT THAT THE 217 GAUGE, WHICH IS IN WCA 2A -- ARE YOU FAMILIAR WITH THAT? A. RIGHT. Q. AND THAT HAD SOME HISTORICAL DATA ON HYDROPERIOD LEVELS. IS THAT RIGHT? A. YES. WELL, THAT'S MY UNDERSTANDING, YEAH. Q. ARE YOU AWARE OF OTHER SUCH GAUGES OR MECHANISMS FOR MEASURING HYDROPERIOD THAT EXIST THROUGHOUT THE WCA'S? A. THAT'S THE ONE I'VE HEARD ABOUT. I WOULDN'T BE SURPRISED IF THERE'S MAYBE ONE SOMEWHERE IN CONSERVATION AREA 3A, SEVERAL OF THEM. BUT THEN, AGAIN, I FEEL LIKE THE INFORMATION TAKEN OUT OF THE SWIM PLAN IS NOT A BAD OVERALL ESTIMATE OF -- I MEAN, OBVIOUSLY, THE DISTRICT BELIEVES THAT THIS IS THE WAY THAT -- THE WAY THAT THE HYDROPERIOD HAS CHANGED COMPARED TO HISTORICAL TIMES. AND, SO, I'M RELYING ON THEIR INFORMATION FROM THAT FIGURE. Q. IF I RECALL YOUR TESTIMONY CORRECTLY FROM YESTERDAY, YOU HAD INDICATED WHEN YOU FIRST SET UP THIS STUDY THAT YOU WERE NOT AWARE OF THE 217 GAUGE. IS THAT--- DR. CRAFT VOLUME II PAGE 463 A. RIGHT. I MEAN, WHEN I WENT OUT TO SAMPLE -- TO COLLECT THESE SAMPLES WAS IN 1989, AND PRETTY MUCH MY FIRST OR SECOND DAY ON THE JOB, I WAS PUT INTO THE FIELD ALMOST IMMEDIATELY. Q. WELL, DO YOU THINK THAT IT WOULD BE A GOOD IDEA TO BE TAKING SAMPLES FROM THOSE AREAS WHERE THERE IS HISTORICAL DATA ON HYDROPERIOD? A. YEAH. I THINK THAT WOULD BE A GOOD IDEA. Q. HOW LONG HAVE YOU KNOWN ABOUT THE 217 GAUGE? A. MAYBE SEVERAL YEARS. I DON'T -- YOU KNOW, CERTAINLY FOR A COUPLE OF YEARS, I WOULD THINK. Q. HAS THERE BEEN ANY DISCUSSIONS CONCERNING TAKING SAMPLINGS FROM THAT AREA? A. NO, WE HAVEN'T REALLY TALKED ABOUT THAT. Q. AND YOU DON'T HAVE ANY PLANS TO DO THAT AT THIS POINT? A. NO. BUT WE MAY RETHINK THOSE PLANS TO -- TO TRY TO ADDRESS THAT QUESTION, ALTHOUGH I'M SURE THERE ARE OTHER RESEARCHERS WHO ALSO THINK IT MIGHT BE WORTHWHILE ADDRESSING THAT SAME QUESTION. Q. DO YOU KNOW IF DR. RICHARDSON MIGHT BE TAKING ANY SAMPLES FROM THAT AREA AT THIS TIME, OR IN THE RECENT FEW YEARS? A. I DON'T KNOW, BUT I DON'T THINK SO, BECAUSE I'M DR. CRAFT VOLUME II PAGE 464 USUALLY INVOLVED WITH HIM IN TAKING THESE AND DOING THIS TYPE OF WORK. Q. WHAT ABOUT DR. RADER? A. HE'S A -- HE'S MORE OF AN INVERTEBRATE PERSON, YOU KNOW, A COMMUNITY PERSON. HE, I DO NOT THINK, WOULD BE INVOLVED IN THIS SORT OF WORK EITHER. Q. AS FAR AS YOU KNOW, NO ONE FROM THE DUKE WETLAND CENTER IS TAKING SAMPLES AROUND OF THE -- ANY MECHANISMS SUCH AS THE 217 GAUGE? A. I DON'T THINK SO, BUT I'M NOT A HUNDRED PERCENT SURE, BUT I'M PRETTY SURE ABOUT IT. Q. GOING TO -- GOING BACK TO THE FIRST PAGE OF THE DOCUMENT, ON THE INPUTS OF PHOSPHORUS -- DO YOU HAVE THAT -- .56? A. YES. Q. IS THAT THE LOADING RATE THAT YOU'RE USING? A. THAT IS, AGAIN, SOME DATA THAT I GOT FROM THE -- I THINK FROM THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT, FROM THE SWIM PLAN. Q. OKAY. DO YOU KNOW WHAT AREA WAS USED TO CALCULATE THAT NUMBER? A. NO, I WOULD HAVE TO GO BACK AND LOOK THAT UP. Q. DO YOU BELIEVE THAT CAME FROM THE SWIM PLAN? A. I THINK SO. DR. CRAFT VOLUME II PAGE 465 Q. TURNING TO PAGE 13 IN THE DOCUMENT, THIS FIRST FULL PARAGRAPH REFERS TO THE LEAD 210 MEASUREMENTS THAT WERE DONE. IS THAT RIGHT? A. YES. Q. AND, AM I CORRECT, THAT WAS ONLY DONE ON ONE CORE? A. RIGHT, THAT'S ALL THAT IS AT THIS TIME. Q. WHY WAS ONLY ONE CORE USED FOR THAT MEASUREMENT? A. THE FOCUS OF THE STUDY WAS TO REALLY LOOK AT THESE RECENT CHANGES IN ACCRETION, WHICH CESIUM IS AMENABLE TO, SINCE IT'S A -- THE ACCRETION RATE OVER THE PAST 25 TO 30 YEARS, AND THE LEAD IS JUST VERY TIME CONSUMING. WE ARE -- WE'RE CONTINUING TO TRY TO DO THAT KIND OF WORK. BUT IN THE PAST, IT HAS NOT BEEN AS HIGH A PRIORITY. Q. ARE YOU CURRENTLY ENGAGED IN CONTINUING ANY OF THE LEAD 210 TESTING ON ANY EXISTING CORES? A. OH, YES. Q. OKAY. WHAT'S THE STATUS OF THAT AT THIS POINT? A. IN FACT, WE HOPEFULLY HAVE HAD ABOUT TEN MORE SAMPLES COUNTED IN THE PAST COUPLE OF WEEKS. I HAVE NO SHORTAGE OF SOIL SAMPLES TO WHICH TO DO THE ANALYSIS. AND THE PROBLEM IS IS JUST THE TIME CONSTRAINTS. IT'S SOMETHING THAT I WOULD REALLY LIKE TO DO, BUT I JUST DON'T HAVE THE TIME, SO DR. CRAFT VOLUME II PAGE 466 WE'RE KIND OF DOING IT WHEN WE CAN. Q. IS THIS BEING DONE ON THE CORES THAT WERE TAKEN FOR PURPOSES OF THIS REPORT? A. A COUPLE OF THESE CORES. BUT, ALSO, WE'VE COLLECTED SOME MORE RECENT CORES TO LOOK AT IT ALSO. Q. WHEN WERE THESE RECENT CORES COLLECTED? A. IN THE PAST YEAR, AND I'D HAVE TO GO BACK AND SEE WHEN -- WHEN THEY WERE COLLECTED. WE HAVEN'T DONE ANYTHING WITH THEM, EXCEPT GROUND THEM UP AND GOTTEN THEM READY. Q. WHO -- WHO TOOK THOSE CORES? WERE YOU INVOL--- A. I TOOK THEM--- Q. OKAY. A. ---AND THERE MAY HAVE BEEN SOMEBODY HELPING ME, BUT--- Q. WHERE WERE THE CORES TAKEN FROM? A. WE TOOK ONE FROM THE INTERIOR OF CONSERVATION AREA 3A, CLOSE TO THE LOCATION, THE INTERIOR LOCATION IN THIS PAPER. AND WE TOOK ANOTHER CORE FROM -- I THINK IT'S 10C6, A LOCATION IN THE -- IN PROBABLY ONE OF THESE PAPERS WE'RE GOING TO TALK ABOUT, NUMBER SIXTEEN, CLOSE TO THAT POINT. Q. WHAT WAS THE PURPOSE OF THESE CORE SAMPLINGS? DR. CRAFT VOLUME II PAGE 467 A. I WOULD LIKE TO TRY TO GET A BETTER HANDLE ON THE HISTORICAL RATES, OR GET A HANDLE ON THE HISTORICAL RATES OF PEAT ACCRETION, AND I THINK THE LEAD MAY ALLOW US TO DO THAT. Q. WERE THE LOCATIONS -- WELL, HOW WERE THE LOCATIONS CHOSEN? A. THEY ARE LOCATIONS THAT WE HAD SAMPLED PREVIOUSLY FOR THE CESIUM WORK, SO WE WENT BACK TO TWO OF THESE LOCATIONS. Q. AND THOSE WERE THE LOCATIONS THAT WERE SAMPLED FOR PURPOSES OF THIS REPORT THAT WE'RE TALKING ABOUT? A. FROM ONE LOCATION IN THIS REPORT AND THEN ONE LOCATION IN THIS NUMBER SIXTEEN, THE PEAT ACCRETION. Q. EXHIBIT SIXTEEN? A. RIGHT. Q. OKAY. DO YOU KNOW OF ANYONE, OTHER THAN YOURSELF, WHO IS CURRENTLY INVOLVED IN DOING ANY LEAD 210 MEASUREMENTS ON CORES? A. I BELIEVE THERE IS SOMEBODY AT THE UNIVERSITY OF FLORIDA WHO IS DOING SOME LEAD 210 WORK. I'M NOT SURE TO WHAT EXTENT IN RELATION TO WHAT THEY'RE DOING IT FOR. BUT I GAVE A PRESENTATION THERE DR. CRAFT VOLUME II PAGE 468 ABOUT NINE MONTHS AGO, AND ONE OF THE PEOPLE WHO CAME TO SEE THE TALK, TALKED ABOUT THAT THEY WERE DOING THAT KIND OR WORK, OR THEY WERE GEARING UP TO DO IT. Q. WITH REGARD TO CORES FROM THE EVERGLADES AREA? A. I THINK THEY -- THEY WERE TALKING ABOUT DOING THE ENTIRE AREA, FROM CONSERVATION AREA 1 ALL THE WAY DOWN TO THE PARK, IS WHAT -- WHAT THEY WERE HOPING TO DO. Q. AND WHO IS THIS YOU WERE TALKING WITH? A. I CAN'T THINK OF HIS NAME. HE'S A GRADUATE STUDENT, AND I THINK HE WORKS FOR JOE -- AND FOR JOE DELFINO, WHO I THINK IS IN ENVIRONMENTAL ENGINEERING, OR HE'S CHAIRMAN OF THE ENVIRONMENTAL ENGINEERING DEPARTMENT THERE. IF I SAW HIS NAME, I'D PROBABLY RECOGNIZE IT, BUT--- Q. ANYBODY ELSE AT THE DUKE WETLAND CENTER, TO YOUR KNOWLEDGE--- A. HUH-UH (NO). Q. ---DOING ANY LEAD 210 TESTING? A. NO. THAT'S MY -- MY DOMAIN AT THIS POINT. Q. DO YOU ACTUALLY DO WHATEVER WORK NEEDS TO BE DONE TO DO THAT YOURSELF? A. WE DO THE DIGESTION AND THE PLATING, AND WE HAVE, DR. CRAFT VOLUME II PAGE 469 UP 'TIL NOW, HAVING SOMEBODY WHO HAS THE CAPABILITY TO DO THE COUNTING FOR US. WE HOPE TO GET THAT SET UP. WE HAVE THE INSTRUMENTATION. WE JUST DON'T HAVE IT SET UP YET. Q. I MEAN, DO YOU SEND SOME OF THIS OUT TO OUTSIDE LABS, OR--- A. I SEND IT TO SOMEBODY I COLLABORATE WITH AT NORTH CAROLINA STATE UNIVERSITY. Q. WHO'S THAT? A. HIS NAME IS DAVE DeMASTER. Q. WHAT'S YOUR -- WHAT'S YOUR PERSONAL INVOLVEMENT IN OVERSEEING THESE MEASUREMENTS? A. IN TERMS OF THE COUNTING? Q. UH-HUH (YES). A. HE DOES THE COUNTING, AND HE'S BEEN DOING LEAD 210 FOR FIFTEEN YEARS. HE'S A TENURED PROFESSOR THERE AND DOES WORK WITH LEAD 210 ON THE AMAZON SHELF, OUT IN THE ATLANTIC OCEAN. HE DOES WORK IN THE ANTARCTIC RELATING TO LEAD 210, SO I HAVE NO PROBLEMS WITH THAT--- Q. OKAY. A. ---I'M NINETY PERCENT -- NINETY-NINE PERCENT CONFIDENT THAT HE'S DOING VERY GOOD WORK. Q. ALL RIGHT. I THINK THAT YOU MISUNDERSTOOD MY DR. CRAFT VOLUME II PAGE 470 QUESTION. MY QUESTION WAS, WHAT WAS YOUR PERSONAL INVOLVEMENT? A. MY PERSONAL INVOLVEMENT IS EVERYTHING BUT THE COUNTING, PRETTY MUCH. I TAKE THE SAMPLES. I DO SOME OF THE GRINDING, ALTHOUGH WE HAVE GRADUATE STUDENTS WHO DO THAT NOW. I'M INVOLVED IN THE DIGESTIONS. I PRETTY MUCH AM IN CHARGE OF THAT, ALTHOUGH I HAVE STUDENTS HELP ME WITH IT SOMETIMES. AND I'M INVOLVED IN THE PLATING, ALTHOUGH I HAVE STUDENTS HELP ME WITH THAT SOMETIMES. Q. NOW, IF I RECALL CORRECTLY, YOUR TESTIMONY YESTERDAY WAS THAT THE ONE CORE THAT HAS -- THAT'S REFLECTED AS TESTED UNDER THE LEAD 210 MEASUREMENTS IN THIS REPORT, WAS FROM AN ENRICHED AREA. IS THAT CORRECT? A. THAT'S CORRECT. Q. OKAY. AND THEN THE END OF THAT PARAGRAPH COMPARES THAT TO AN UNENRICHED AREA OF THE EVERGLADES. IS THAT RIGHT? A. TO A BUNCH OF UNENRICHED AREAS. Q. THE -- THE FIGURE 2.33--- A. YES. Q. ---PLUS OR MINUS .24, WHERE DOES THAT FIGURE COME DR. CRAFT VOLUME II PAGE 471 FROM? A. THAT IS THE MEAN OF ALL THE UNENRICHED CORES THAT WE'VE COLLECTED, A TOTAL OF THIRTEEN. Q. UNDER THE -- AND THAT'S THE MEASUREMENT UNDER THE CESIUM ANALYSIS? A. RIGHT. Q. DID I SAY THAT RIGHT -- CESIUM? A. YES, THAT'S CORRECT. Q. CAN THE CORE SAMPLE PREPARATION AFFECT THE LEAD 210 RESULTS YOU GET? A. IF YOU DON'T WEIGH OUT THE SAMPLE CORRECTLY, YOU CAN HAVE PROBLEMS. THE GRINDING AND THAT SORT OF PROCEDURE, I DON'T THINK THAT THERE ARE PROBLEMS WITH, UNLESS YOU WERE TO GRIND IT IN A LEAD CONTAINER, WHICH OF COURSE WE DON'T DO ANYTHING LIKE THAT. WE ALSO USE A TRACER. THE TECHNIQUE USES A TRACER THAT ALLOWS A LOT BETTER RESOLUTION OF DEALING WITH THE LEAD. Q. IS THERE ANY PROBLEM USING A LEAD 210 ANALYSIS WITH COMPACTION? CAN THAT HAVE AN EFFECT ON IT? A. WELL, ANY ACCRETION -- ANY WAY YOU MEASURE ACCRETION COULD BE AFFECTED BY COMPACTION. Q. ON PAGE 16, ON EXHIBIT NUMBER FIVE, THE PARAGRAPH AT THE END OF THAT PAGE, THE SECOND SENTENCE DR. CRAFT VOLUME II PAGE 472 READS, "THE MEAN SURFACE SOIL PHOSPHORUS CONCENTRATIONS WERE MUCH HIGHER IN THE NUTRIENT ENRICHED PART OF WCA 2A, COMPARED TO ALL THEIR SITES." WHAT DOES THAT MEAN EXACTLY? A. IT JUST MEANS THAT THE SURFACE SOIL CONCENTRATIONS ARE HIGHER IN THE ENRICHED SITE AS COMPARED TO THE OTHER SITES. Q. I GUESS MY -- MAYBE I SHOULD REPHRASE MY QUESTION. I MEAN, WHAT DOES THAT -- WHAT DOES THAT LEAD YOU TO CONCLUDE? I MEAN, AS A RESULT OF THIS FINDING, WHAT -- DO YOU REACH ANY CONCLUSIONS AS A RESULT OF THAT? A. THAT PHOSPHORUS ENRICHMENT OF THE SOIL IS OCCURRING AT THAT LOCATION, IS MY CONCLUSION. Q. ALL RIGHT, ON THE NEXT PAGE, PAGE 17, THE FIRST SENTENCE, "SOIL PHOSPHORUS EXHIBITED A MARKED DECREASE WITH DEPTH AT ALL LOCATIONS." WHAT DO YOU CONCLUDE FROM THAT FINDING? A. THAT SUGGESTS TO ME THAT PHOSPHORUS IS LIMITING IN THESE SYSTEMS, AND IT'S HIGHER IN THE SURFACE, BECAUSE I THINK RECYCLING BY THE VEGETATION AND THE ORGANISMS THERE, NEAR AND AT THE SOIL SURFACE. Q. IS THAT PRETTY MUCH WHAT YOU STATE IN THE DR. CRAFT VOLUME II PAGE 473 SENTENCES FOLLOWING THAT -- THE LAST SENTENCE OF THE PARAGRAPH TALKS ABOUT THE EFFICIENT RECYCLING? A. YES, I THINK THAT KIND OF SUMMARIZES IT. Q. ON PAGE 18 OF THE REPORT, THE PARAGRAPH BEGINNING ON LINE 21, YOU SAY, "IN CONTRAST TO NITROGEN, PHOSPHORUS ACCUMULATION WAS MORE A FUNCTION OF THE PHOSPHORUS CONTENT OF THE SOIL THAN THE RATE OF PEAT ACCRETION." FIRST OF ALL, HOW DO YOU CONCLUDE THAT? A. WHAT I'M SAYING HERE IS THAT IN -- FOR EXAMPLE, WITH NITROGEN, YOU NEED SEVERAL NUMBERS TO CALCULATE ACCUMULATION RATE OF NITROGEN. YOU NEED THE NITROGEN CONTENT OF THE SOIL. YOU NEED THE BULK DENSITY, AND YOU NEED THE ACCRETION RATE. AND WITH NITROGEN, YOU SEE HIGHER RATES OF ACCUMULATION, BUT IT'S ONLY BECAUSE THE RATE OF PEAT ACCRETION AT THE SITE IS HIGHER. THE NITROGEN CONTENT IN THE SOILS IS PRETTY MUCH SIMILAR FROM ONE LOCATION TO THE NEXT. SO, IF YOU SEE -- WHEN YOU SEE AN INCREASE IN NITROGEN ACCUMULATION, IT'S REALLY JUST DUE TO THE FACT THAT PEAT ACCRETION IS HIGHER. BUT, WITH PHOSPHORUS, WHEN YOU SEE A HIGHER RATE OF DR. CRAFT VOLUME II PAGE 474 PHOSPHORUS ACCUMULATION AT A SITE, OR AT THAT ENRICHED SITE, FOR EXAMPLE, IT'S BECAUSE OF TWO THINGS. ONE, SOIL P IS HIGHER THERE, BUT ALSO THE RATE OF ACCRETION IS HIGHER THERE, TOO. Q. I GUESS I'M -- AGAIN, EXCUSE MY IGNORANCE, BUT I'M -- I'M TRYING TO UNDERSTAND THIS. AND ARE YOU SAYING THAT THE -- THAT THE RATE OF PHOSPHORUS ACCUMULATION IS -- IS A FACTOR OF THE PHOSPHORUS CONTENT IN THE SOIL? A. YES, BECAUSE THAT'S ONE OF THE NUMBERS THAT YOU HAVE TO MEASURE TO CALCULATE THE ACCUMULATION RATE. Q. WHY IS THE SOIL PHOSPHORUS HIGHER IN THE ENRICHED SITE? A. AGAIN, I WOULD THINK THAT AGRICULTURAL -- THE PUMPED AGRICULTURAL DRAINAGE FLOWING INTO THE NORTHERN PART OF CONSERVATION AREA 2A HAS A LOT TO DO WITH THE ACCUMULATION OF PHOSPHORUS IN THE SOIL. Q. THE NEXT SENTENCE READS THAT "THE NUTRIENT ENRICHED AREA OF WCA 2A HAD BY FAR THE HIGHEST RATE OF PHOSPHORUS ACCUMULATION." IS THAT -- IS THAT CONCLUSION ALTERED AT ALL BY YOUR FINDINGS THAT ARE INCLUDED IN EXHIBIT NUMBER DR. CRAFT VOLUME II PAGE 475 SIXTEEN? A. NO. THEY JUST SUPPORT THE -- BASICALLY, NUMBER SIXTEEN -- LET'S BACK UP. NUMBER FIVE LOOKED AT A LOT OF DIFFERENT AREAS, IN 2A, 2B AND 3A. AND WE SAW THIS ENRICHED AREA IN 2A BELOW THE HILLSBORO CANAL. SO, NUMBER SIXTEEN SAYS, LET'S GO TO THAT LOCATION AND DO MORE IN-DEPTH WORK THERE. SO -- SO, REALLY, IN SIXTEEN IS JUST A MORE IN-DEPTH TREATMENT OF THIS -- THIS AREA THAT HAD THE .46 GRAMS PER METER SQUARED PER YEAR. Q. GOING BACK TO THAT FIRST SENTENCE AGAIN, IS -- WERE YOU ABLE TO DIVIDE -- FOR LACK OF A BETTER TERM -- THE FACTOR OF PHOSPHORUS CONTENT OF SOIL, VERSUS THE RATE OF PEAT ACCRETION, AND HOW EACH ONE OF THOSE INFLUENCE THE PHOSPHORUS ACCUMULATION RATE? A. WELL, WE DIDN'T REALLY DO IT IN A TRUE -- IN A QUANTITATIVE WAY. BUT I THINK YOU CAN LOOK AT THE NUMBERS HERE AT THE BOTTOM OF THE PAGE, AND SEE, FOR EXAMPLE -- OKAY, WE SEE THAT .46 NUMBER IN THE NORTHERN PART OF 2A. YOU GO TO LINE 27, AND YOU SEE NUMBERS .18 TO .23, AND THESE ARE LOWER NUMBERS, BUT THEY'RE -- THESE -- THIS AREA HAS EXTENDED HYDROPERIOD, BUT NO PHOSPHORUS DR. CRAFT VOLUME II PAGE 476 ENRICHMENT. AND, AGAIN, I THINK THAT, AS I SAY HERE, PHOSPHORUS ACCUMULATION WAS MORE A FUNCTION OF P CONTENT THAN PEAT ACCRETION, AND THAT'S WHY YOU GET THIS -- I WOULD SAY -- I MEAN, I CAN'T GIVE YOU A PERCENTAGE IMPORTANCE -- BUT THAT THE PHOSPHORUS CONCENTRATION IN THE SOIL AT THAT SITE IS MORE OF A CONTROLLING FACTOR YIELDING THE HIGHER ACCUMULATION RATE, THAN IS THE ENHANCED RATE OF PEAT ACCRETION. Q. MAYBE I'M JUST HAVING A -- I JUST MISUNDERSTAND THE SCIENCE THAT'S INVOLVED HERE -- BUT HOW DOES PHOSPHORUS CONTENT IN SOIL AFFECT PHOSPHORUS ACCUMULATION? A. AGAIN, I NEED A BLACKBOARD, ALMOST, BECAUSE THIS NUMBER, P ACCUMULATION, GRAMS PER METER SQUARED PER YEAR, IS CALCULATED BY MULTIPLYING PHOSPHORUS CONCENTRATION, TIMES ACCRETION RATE, TIMES BULK DENSITY. SO, IF YOU DON'T HAVE ONE OF THOSE THREE NUMBERS, YOU CAN'T CALCULATE THE ACCUMULATION RATE. SO, I DON'T KNOW IF I'M ANSWERING THE QUESTION, BUT YOU NEED THOSE -- YOU NEED SOIL P CONCENTRATION, AND YOU NEED ACCRETION RATE TO CALCULATE ACCUMULATION RATE. (THEREUPON, MR. NETTLETON DR. CRAFT VOLUME II PAGE 477 AND MR. GRIMSHAW CONFER.) (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER.) Q. (BY MR. NETTLETON) WE WERE DISCUSSING YESTERDAY POLLEN ANALYSIS--- A. YES. Q. ---AND YOU INDICATED THAT THERE WAS A GRAD STUDENT THAT WOULD BE DOING SOME WORK ON POLLEN ANALYSIS FROM THE PEAT ACCRETION CORES? A. UH-HUH (YES). WE HOPE TO DO THAT, YES. Q. OKAY. IS THERE A GRAD STUDENT ASSIGNED TO THAT PROJECT AT THIS POINT? A. UH-HUH (YES). WE DO HAVE ONE. Q. WHAT IS HIS OR HER NAME? A. HER NAME IS SUE BARTOW. Q. B-A-R-T-O-W? A. RIGHT. Q. WHAT IS THE STATUS OF THAT RIGHT NOW? A. I THINK THIS WEEK I SHOWED HER WHERE THE SAMPLES WERE, BUT WE HAVEN'T EVEN STARTED THE EXTRACTION YET. I THINK WE HOPE TO START THE END OF NEXT WEEK. BUT, AGAIN, POLLEN IS LIKE LEAD, AND IT DR. CRAFT VOLUME II PAGE 478 WILL BE A VERY LONG, TEDIOUS, SLOW PROCESS. Q. DO YOU HAVE ANY COMPLETION DATE IN MIND? A. NO. AGAIN, I FIND IT INTERESTING WORK, BUT IN TERMS OF THE OVERALL RESEARCH, IT'S NOT CONSIDERED A HIGH -- AS HIGH A PRIORITY. Q. WHAT'S THE OBJECTIVE OF THE RESEARCH IN THIS PARTICULAR INSTANCE? A. AGAIN, I THINK POLLEN AND LEAD ARE WAYS TO TRY TO LOOK AT HISTORICAL RATES OF PEAT ACCRETION, THAT IS, OVER THE PAST ONE HUNDRED YEARS, AS COMPARED TO CESIUM, WHICH IS JUST FOR THE PAST TWENTY-FIVE YEARS. Q. WHO'S FUNDING THIS RESEARCH? A. THIS IS FUNDED THROUGH THE WETLAND CENTER, UNDER THE SAME--- Q. EPD? A. YEAH, THE SAME GRANT THAT FUNDS ME. Q. WHEN DID THIS PROJECT FIRST HIT THE BLACKBOARD, SO TO SPEAK? A. I'VE HAD IT IN MIND FOR A YEAR OR TWO. IT'S JUST, AGAIN, A TIME CONSTRAINT. Q. WHAT IS SUE BARTOW'S GRADUATE STUDENT STATUS? A. SHE'S BEEN THERE ONE SEMESTER. SHE STARTED THIS FALL, SO. DR. CRAFT VOLUME II PAGE 479 Q. SO, HOW MUCH LONGER DOES SHE HAVE? A. A YEAR AND A HALF. BUT THEN, AGAIN, IF SHE WORKS WITH ME, IT MIGHT TAKE TWO AND A HALF YEARS, SO, YOU CAN ASK MY PREVIOUS STUDENTS ABOUT THAT. THAT'S A SORE POINT. Q. DID -- DO YOU HAVE -- IF YOU DON'T HAVE A COMPLETION DATE IN MIND AT THIS POINT, DO YOU HAVE A START DATE IN MIND? A. WELL, I HOPE SHE -- WE HOPE TO DO -- START TO PROCESS TWENTY SAMPLES BEFORE CHRISTMAS. THAT'S OUR GOAL--- Q. BUT THAT--- A. ---WHEN SHE'S THROUGH WITH EXAMS. Q. ---BUT THAT HAS NOT STARTED YET? A. NO. Q. LOOKING BACK AT THE THREE AND A HALF YEARS, WITH THE TWENTY/TWENTY HINDSIGHT THAT WE HAVE NOW, IF YOU HAD IT TO DO OVER AGAIN, WOULD YOU REDESIGN THIS PARTICULAR PROJECT TO TAKE SAMPLES AROUND THE 217 GAUGE? A. I THINK I WOULD CERTAINLY CONSIDER IT MORE THAN I HAVE IN THE PAST. I THINK, YOU KNOW, THAT PROVIDES SOME GOOD INFORMATION, AND WE MIGHT DO IT. THE PROBLEM WITH DOING SOMETHING LIKE THAT, DR. CRAFT VOLUME II PAGE 480 IS -- THAT I SEE -- IS I COULD GO OUT AND COLLECT ONE OR TWO CORES AND PROVIDE SOME INFORMATION, BUT I PROBABLY COULD NOT GET IT PUBLISHED, BECAUSE IT WOULDN'T BE ENOUGH SAMPLES IN THE CONTEXT OF A PAPER. BUT THEN, AGAIN, YOU KNOW, IT'S EASY TO COLLECT THE CORES, AND JUST PUT THEM IN STORAGE UNTIL YOU HAVE TIME TO DO SOMETHING WITH THEM. Q. YESTERDAY, MS. PONZOLI ASKED YOU A QUESTION, AND IF MY NOTES ARE CORRECT, THAT IT WAS, THAT IF WE HELD PHOSPHORUS CONSTANT, AND INCREASED THE WATER LEVELS OR THE HYDROPERIOD, COULD THAT INCREASE PEAT ACCRETION? AND I BELIEVE YOUR TESTIMONY WAS THAT IT COULD INCREASE PEAT ACCRETION. A. RIGHT. Q. IS THAT CORRECT? A. I THINK SO, YES. Q. DO YOU THINK IT IS MORE LIKELY THAN NOT, THAT IF -- THAT THAT WOULD OCCUR? A. COULD YOU REPEAT THE QUESTION? I THOUGHT I UNDERSTOOD IT, BUT I'M NOT SO SURE. Q. WELL, DO YOU THINK IN -- BASED UPON YOUR QUALIFICATIONS AND YOUR RESEARCH IN THIS AREA, DO YOU THINK IT'S MORE LIKELY THAN NOT, THAT IF YOU DR. CRAFT VOLUME II PAGE 481 HELD PHOSPHORUS CONSTANT, THAT IF YOU INCREASED WATER, WATER LEVELS OR HYDROPERIOD, THAT THIS WOULD INCREASE PEAT ACCRETION? A. YES, I THINK YOU COULD -- YOU WOULD LIKELY -- YOU PROBABLY WOULD SEE AN INCREASE IN PEAT ACCRETION BY INCREASING THE HYDROPERIOD. Q. OKAY. NOW, LET ME ASK YOU THE FLIP SIDE, BASED UPON THE SAME THING, YOUR EXPERIENCE IN THIS AREA, IF YOU HELD THE HYDROPERIOD CONSTANT, WOULD YOU THINK IT MORE LIKELY THAN NOT THAT IF YOU INCREASED PHOSPHORUS, YOU WOULD INCREASE PEAT ACCRETION? A. YEAH, I THINK YOU WOULD INCREASE -- YOU COULD LIKELY INCREASE PEAT ACCRETION, TOO, BY -- BY PHOSPHORUS -- BY ADDING PHOSPHORUS. Q. BASED UPON YOUR WORK IN THE EVERGLADES, WHAT HAVE YOU LEARNED ABOUT THE CESIUM 137 METHOD? A. IT SEEMS TO WORK PRETTY DANG WELL IN THE EVERGLADES. AND I THINK THAT'S GOOD. Q. WOULD YOU AGREE THAT THE -- THAT IF -- FIRST OF ALL, LET ME ASK YOU THIS. WERE REPLICATES TAKEN OF THE CORE SAMPLES FOR THIS, THAT WERE USED IN THIS REPORT? A. FOR THIS PAPER, THERE WERE REPLICATES, YES. DR. CRAFT VOLUME II PAGE 482 Q. WERE THE CESIUM 137 RESULTS RUN ON EACH OF THE REPLICATES? A. OH, YES. AND THEY'RE IN THE PAPER. Q. AND THOSE ARE ALL REFLECTED IN THE TABLES? A. UH-HUH (YES). Q. ON PAGE 19 OF THE REPORT, BEGINNING ON LINE 12, THE SENTENCE THAT -- AGAIN, I'LL PARAPHRASE IT A LITTLE BIT -- "AS A RESULT, THE EFFICIENCY OF PHOSPHORUS REMOVAL AT THE ENRICHED LOCATION, EIGHTY-SEVEN PERCENT, WAS LESS AS COMPARED TO THE UNENRICHED SITE, ONE HUNDRED TO ONE HUNDRED AND THIRTY-THREE PERCENT, SUGGESTING THAT THE ENRICHED AREA MAY BE APPROACHING SATURATION WITH RESPECT TO PHOSPHORUS ACCUMULATION." WHAT DO YOU MEAN BY SATURATION? A. I DON'T KNOW. I'M GOING TO HAVE TO RETHINK THAT WORD SINCE IT'S GOTTEN SO MUCH ATTENTION FOR THE PAST TWO DAYS. WHAT I MEAN IS THAT SINCE THE EFFICIENCY IS LESS, HAS GONE -- IS LESS THAN A HUNDRED PERCENT, THAT MAYBE IT'S NOT ABLE TO HOLD ALL THE -- WELL, THE DATA SUGGESTS THAT IT'S NOT HOLDING ALL THE PHOSPHORUS THAT COMES INTO THE SYSTEM. Q. DO YOU STILL, IN LIGHT OF THE DATA THAT YOU'VE DR. CRAFT VOLUME II PAGE 483 USED, THAT IS INCORPORATED INTO EXHIBIT NUMBER SIXTEEN, DO YOU STILL HOLD THE OPINION THAT THERE MAY BE A SATURATION PROBLEM? A. WELL, I THINK -- AND I STATED THIS BEFORE -- THAT THERE MAY BE A PROBLEM. I MEAN, THE DATA SUGGESTS THAT THE AREA CAN STORE APPROXIMATELY FIFTY METRIC TONS OF P PER YEAR, AND I THINK THAT THERE IS A POSSIBLE CONCERN THAT LOADINGS GREATER THAN THAT, YOU KNOW, SUBSTANTIALLY GREATER THAN THAT, WILL NOT -- THE EXCESS WILL NOT BE STORED AND IT WILL POTENTIALLY MOVE DOWNSTREAM. Q. I THINK WHEN YOU WERE DISCUSSING THIS WITH REGARD TO SOME OF YOUR FINDINGS IN -- IN EXHIBIT NUMBER SIXTEEN YESTERDAY -- WELL, LET ME STRIKE THAT. IF WE HAD A HUNDRED PERCENT ACCUMULATION, WOULD THAT INDICATE EITHER EQUILIBRIUM, OR WE AREN'T AT A SATURATION LEVEL? A. I THINK IT WOULD -- YEAH, I THINK IT WOULD INDICATE THAT, THAT PERHAPS IT'S UNDERSATURATED, IF IT CAN STORE ONE HUNDRED PERCENT. Q. AND IF WE HAVE A HUNDRED PERCENT ACCUMULATION, THEN AM I CORRECT THAT THERE WOULD BE NO ADVANCING FRONT, AS THAT TERM'S BEEN USED? A. I THINK THAT THAT WOULD BE POSSIBLE. I MEAN, I'M DR. CRAFT VOLUME II PAGE 484 NOT GOING TO EMPHATICALLY STATE THAT A HUNDRED PERCENT MEANS THAT THERE WILL NEVER BE A FRONT ADVANCING, BUT IT SUGGESTS THAT WHAT -- WHAT IS BEING ADDED TO THE SYSTEM, ALL OF IT IS BEING STORED. Q. I BELIEVE YESTERDAY, AGAIN, WHEN WE WERE DISCUSSING EXHIBIT NUMBER SIXTEEN, AND THIS SAME CONCEPT OF THE POTENTIAL SATURATION THAT'S REFLECTED IN EXHIBIT NUMBER FIVE, THAT YOU HAD INDICATED THAT PERHAPS THE EIGHTY-SEVEN PERCENT, AND ITS RELATIONSHIP TO BEING A HUNDRED PERCENT, WAS CLOSE ENOUGH THAT THAT MIGHT FALL WITHIN THE RANGE OF POSSIBLE ERROR IN YOUR CALCULATIONS? A. IT COULD, ESPECIALLY BASED ON THE LIMITED NUMBER OF SAMPLES THAT WERE TAKEN FOR THIS STUDY. Q. ALL RIGHT. SO, IF -- IF, IN FACT, THE EIGHTY-SEVEN PERCENT WERE A HUNDRED PERCENT, THEN WE WOULD NOT HAVE A SATURATION SITUATION? A. I WOULD FEEL MORE COMFORTABLE, CERTAINLY, IF IT WAS A HUNDRED PERCENT. Q. AND THERE WAS SOME DISCUSSION YESTERDAY ABOUT LOOKING INTO SODIUM ENRICHMENT, AND WHETHER THAT WAS AFFECTING CATTAIL PROLIFERATION. IS THAT RIGHT? DR. CRAFT VOLUME II PAGE 485 A. YES. Q. OKAY. AND I BELIEVE YOU INDICATED THAT, AS A RESULT OF YOUR FINDINGS, THAT YOU DID NOT SEE ANY CORRELATION BETWEEN THE SODIUM ENRICHMENT AND THE CATTAIL PROLIFERATION? A. I DON'T SEE ANY, YES. Q. AND YOU MENTIONED, I BELIEVE THERE WAS A GRAD STUDENT INVOLVED IN DOING THAT RESEARCH, AS WELL. DO--- A. YES. Q. WHAT WAS HER NAME? A. JANE RAIKES. Q. AND HOW DO YOU SPELL HER LAST NAME? A. R-A-I-K-E-S. Q. AND WHAT IS HER STATUS AT THE UNIVERSITY RIGHT NOW? A. SHE IS ON -- ON TARGET TO GRADUATE THIS MONTH--- Q. THIS MONTH? A. ---WHICH WILL BE GREAT, I THINK. Q. OKAY. YOU INDICATED, I BELIEVE, THAT THIS -- THIS RESEARCH WAS DONE OR IT WAS LOOKED INTO BECAUSE OF SOME PRELIMINARY DATA WHICH INDICATED THAT SODIUM MIGHT HAVE AN EFFECT ON CATTAIL DR. CRAFT VOLUME II PAGE 486 PROLIFERATION. IS THAT RIGHT? A. NO. IT WAS MORE BASED ON THE IDEA THAT THERE WAS SODIUM ACCUMULATING IN SOME OF THESE AREAS, THAT THERE SEEMED TO BE SOME -- THERE'S EVIDENCE OF SODIUM ENRICHMENT IN PARTS OF -- OF NORTHERN WCA 2A. Q. WHAT DATA ARE YOU REFERRING TO WHEN YOU SAY THERE WAS EVIDENCE OF THIS SODIUM? A. SOME DATA ON -- NOT IN THIS PAPER, BUT IN ONE OF THE ANNUAL REPORTS, WHERE WE TOOK SOME PRELIMINARY CORES AND MEASURED PEAT ACCRETION AND SODIUM CONCENTRATIONS, AND WE FOUND THAT THERE WERE SOME AREAS NEAR THE "C" AND THE "D" GATES THAT SHOWED EVIDENCE OF THIS SODIUM ENRICHMENT. Q. OKAY. WERE YOU SPECIFICALLY LOOKING FOR SODIUM ENRICHMENT AT THAT TIME, OR HOW DID YOU GO ABOUT--- A. WE WERE MEASURING SEVEN OR EIGHT DIFFERENT ELEMENTS, NITROGEN, PHOSPHORUS, CARBON, BASE CATIONS, AND SODIUM WAS ONE OF THEM, AND IT JUST TURNED UP TO BE ONE THAT SEEMED TO BE ACCUMULATING. Q. HAVE YOU LOOKED AT ANY OTHER FACTORS THAT MIGHT EXPLAIN THE CATTAIL EXPANSION? DR. CRAFT VOLUME II PAGE 487 A. NO, I HAVEN'T ADDRESSED THAT, REALLY, IN-DEPTH. Q. PAGE 22 OF EXHIBIT NUMBER FIVE, THE SECTION THAT'S ENTITLED "ECOLOGICAL APPLICATIONS" OR "ECOLOGICAL APPLICATION," WHO WROTE THAT SECTION? A. OH, I WROTE THAT SECTION. Q. OKAY. DID YOU CONSIDER ANY OTHER APPLICATIONS, OTHER THAN WHAT'S REFLECTED IN THAT SECTION? A. WELL, THAT'S THE MAJOR APPLICATION THERE, IS THE WORK IN -- YOU KNOW, WE'RE DOING WORK IN THE EVERGLADES, THE DISTRICT'S THINKING ABOUT CREATING THESE LARGE WETLAND BUFFER AREAS, AND I THINK OUR INFORMATION IS AMENABLE TO TRYING TO DETERMINE HOW WELL THESE THINGS WILL WORK. Q. IS THERE ANY APPLICATION FOR THIS RESEARCH OUTSIDE OF WHAT'S STATED THERE? A. POTENTIALLY, ANYBODY WHO'S INTERESTED IN, I THINK, CREATING PEAT BASED WETLANDS TO REMOVE PHOSPHORUS, YOU KNOW, THIS WOULD HAVE A POTENTIAL APPLICATION, I THINK. I MEAN, AGAIN, IT WOULD HAVE TO BE IN THE CONTEXT OF -- I MEAN, YOU KNOW, YOU HAVE TO TAKE INTO ACCOUNT IF SOMEBODY IN IOWA WANTS TO CREATE A PEAT BASE -- A PEAT BASED WETLAND, IT MIGHT NOT BE AS APPLICABLE AS HERE IN SOUTH FLORIDA, BUT--- DR. CRAFT VOLUME II PAGE 488 Q. OKAY. AM I CORRECT THAT, AS A RESULT OF THIS STUDY, THAT YOU CONCLUDED -- AND I WILL TRY TO PARAPHRASE WHAT I BELIEVE YOU TESTIFIED TO YESTERDAY -- THAT YOU CONCLUDED THAT IF THE GOAL WAS TO REMOVE TEN METRIC TONS OF PHOSPHORUS IN A CONSTRUCTED WETLAND OR A NATURAL WETLAND, YOU WOULD NEED MORE LAND TO ACCOMPLISH THAT IF THE INFLOW WERE TEN PARTS PER BILLION, AS OPPOSED TO FIFTY PARTS PER BILLION? A. I THINK THAT SOUNDS PRETTY MUCH WHAT I SAID, OR--- Q. WHAT DO YOU BASE THAT ON? A. SOME OF THE INFORMATION IN EXHIBIT SIXTEEN, THAT THE DATA SUGGESTS THAT AS SURFACE WATER PHOSPHORUS CONCENTRATION DECREASES, PHOSPHORUS ACCUMULATION IN THE PEAT DECREASES. Q. OKAY. CAN YOU REPEAT THAT BACK TO ME? I MEAN YOU CAN EITHER -- CAN YOU PLAY IT BACK, PLEASE. I'M SORRY. A. I CAN -- I CAN REPEAT IT. Q. CAN YOU REPEAT? A. YEAH. Q. JUST TELL ME AGAIN. A. IF WE -- IF WE WANT TO GO TO EXHIBIT SIXTEEN, BASICALLY, WHAT IT SHOWS IS THAT -- THIS GRAPH DR. CRAFT VOLUME II PAGE 489 HERE, IS THAT WITH HIGH SURFACE WATER PHOSPHORUS CONCENTRATION, TOTAL P -- WHICH IS A SOLID LINE -- WHEN IT'S HIGH, YOU GET A HIGH RATE OF ACCUMULATION; BUT AS IT DECREASES, CONSEQUENTLY YOU GET A DECREASE IN THE AMOUNT OF PHOSPHORUS STORED. Q. AND WHAT DATA IS THAT BASED ON? A. THE ACCUMULATION RATE DATA IS -- IS OUR DATA. AND THE SURFACE WATER CHEMISTRY, THE SURFACE WATER TOTAL P IS TAKEN FROM SOUTH FLORIDA WATER MANAGEMENT DISTRICT. Q. WHO TOLD YOU THAT THE STA'S WOULD HAVE TO STORE A HUNDRED AND SEVENTY-NINE METRIC TONS PER YEAR? A. I TOOK THAT OUT OF A SWIM PLAN. Q. THE '92 VERSION? A. AS CITED, YES, ALTHOUGH I UNDERSTAND THAT NUMBER HAS CHANGED SINCE THEN, BUT--- Q. WHAT'S YOUR UNDERSTANDING IN THAT REGARD? A. I HAVE JUST HEARD -- DR. RICHARDSON HAS JUST MENTIONED THAT THE NUMBER IS -- IS LESS NOW, THAT IT'S DECREASED SOME. SO, PERHAPS THE BMP'S MAY REMOVE MORE THAN -- THAN ORIGINALLY STATED IN HERE. THE DISTRICT'S WORK IS MUCH LIKE OURS. IT'S KIND OF AN ITERATION OVER TIME. THINGS DR. CRAFT VOLUME II PAGE 490 CHANGE SOME. Q. NOW, I BELIEVE THE -- THE FOLLOW UP TO WHAT I JUST ASKED YOU, ABOUT THE NEEDING MORE LAND, YESTERDAY, YOU INDICATED THAT YOU WERE NOT PREPARED TO ADDRESS THE QUESTION OF WHETHER THE CON -- DEALING WITH CONCENTRATIONS, WHETHER YOU WOULD NEED MORE LAND TO REDUCE FROM FIFTY PARTS PER BILLION TO TEN PARTS PER BILLION, AS OPPOSED TO A HUNDRED AND FIFTY DOWN TO FIFTY PARTS PER BILLION. IS THAT RIGHT? A. I DIDN'T FEEL CONFIDENT TALKING ABOUT THAT. YES. Q. HAVE YOU EVER BEEN ASKED BY ANYONE TO DO THAT TYPE OF ANALYSIS? A. NO. AND IF I HAD, I PROBABLY WOULD BE ABLE TO ANSWER THE QUESTION, BUT--- Q. DO YOU KNOW IF ANYONE ELSE FROM THE DUKE WETLAND CENTER HAS BEEN DOING SUCH AN ANALYSIS? A. NOT THAT I'M AWARE OF, NO. Q. HOW ABOUT ANYBODY OUTSIDE OF THE DUKE WETLAND CENTER; ARE YOU AWARE OF ANYONE DOING THAT TYPE OF ANALYSIS? A. NO. Q. JUST GOING BACK A SECOND TO THE CONCEPT OF SATURATION, I BELIEVE YESTERDAY THAT YOU TESTIFIED DR. CRAFT VOLUME II PAGE 491 THAT MAYBE SATURATION IS NOT THE CORRECT WAY TO LOOK AT THE PROBLEM, WHEN YOU'RE TALKING ABOUT A PEAT ACCUMULATION TYPE OF SYSTEM. IS THAT CORRECT? A. YES. Q. OKAY. IN LIGHT OF THAT, DO YOU HAVE ANY PLANS TO CHANGE OR AMEND YOUR ARTICLE THAT'S CURRENTLY OUT FOR PUBLICATION? A. I MAY SEE IF THERE'S ANOTHER WORD THAT SAYS WHAT I WANT IT, YOU KNOW, WHAT I WANT IT TO MEAN, THAT'S NOT SATURATION, BECAUSE I'M NOT SURE THAT THAT IS -- IS THE APPROPRIATE WORD FOR THESE PEAT BASED WETLANDS. SATURATION MORE IMPLIES ADSORPTION OR ABSORPTION PROCESSES OF PHOSPHORUS ONTO EXCHANGE SITES. WHEREAS PEAT, AS PEAT BUILDS UP EVERY YEAR, YOU'RE GOING TO GET AN INCREMENTAL INCREASE. AND, SO, I HAVE TO RETHINK THE TERM SATURATION. I'M NOT SURE IF THAT'S THE MOST APPROPRIATE TERM. Q. WHAT -- WELL, UNFORTUNATELY, I, AS A LAYPERSON UNDERSTAND THE TERM SATURATION, AND I GUESS I'D LIKE TO KNOW WHAT -- WHAT IS YOUR CONCEPT THAT YOU WANT TO MOVE TO -- THAT YOU THINK MORE ACCURATELY DESCRIBES WHAT YOU'RE THINKING? DR. CRAFT VOLUME II PAGE 492 A. WELL, AS I MENTIONED, SATURATION ALMOST IMPLIES THAT -- LET'S SAY YOU HAVE A CLAY SURFACE, AND PHOSPHORUS SORBS ONTO IT. LET'S SAY THERE'S X-NUMBER OF EXCHANGE SITES. AT SOME POINT, PHOSPHORUS WILL SATU -- WILL SORB ONTO ALL THOSE EXCHANGE SITES, AND IT IS SATURATED. AND YOU CANNOT ADD ANY MORE PHOSPHORUS TO IT. AND I THINK THE PROBLEM WITH PEAT IS, IS THAT YOU DON'T REALLY SATURATE IT, BECAUSE ONE YEAR, YOU GET AN INCREMENT OF PEAT, BUT THEN THE NEXT YEAR YOU GET ANOTHER. IT'S A CONTINUOUSLY BUILDING PROCESS. SO -- SO, IN SOME WAYS, I'M -- YOU CAN -- I THINK YOU CAN -- SATURATE'S NOT THE RIGHT WORD. YOU CAN -- YOU CAN -- I DON'T KNOW. I WOULD HAVE TO HAVE A DICTIONARY TO THINK ABOUT WHAT THE WORD IS. Q. WELL, CAN YOU -- I THINK I UNDERSTAND THE CONCEPT YOU'RE SAYING, BUT IT'S NOT A SATURATION CONCEPT, BUT CAN YOU EVER GET SATURATED IN A PEAT ACCUMULATION SYSTEM? A. WELL, I THINK YOU CAN LOAD -- I THINK MAYBE SATURATION HERE MIGHT APPLY MORE TO THE PLANT, THE ABILITY OF THE PLANT TO TAKE UP PHOSPHORUS, BECAUSE THAT'S HOW THE PEAT IS BUILT UP. SO, DR. CRAFT VOLUME II PAGE 493 PLANTS CAN ONLY TAKE UP IN A GROWING SEASON A CERTAIN AMOUNT OF PHOSPHORUS, THAT NO MATTER HOW MUCH -- YOU KNOW, IF YOU ADD ABOVE A CERTAIN AMOUNT, THE PLANTS WILL NOT BE ABLE TO TAKE IT UP, AND THAT MATERIAL, OR THAT PHOSPHORUS WILL MOVE ON DOWNSTREAM. MAYBE SOMEBODY AT THE TABLE CAN OFFER ANOTHER DEFINIT -- ANOTHER WORD THAT WILL WORK WELL, THAT IS MORE DESCRIPTIVE OR MORE ACCURATE. MR. BURGESS: I'D KIND OF LIKE TO BE LISTED AS A CO-AUTHOR ON THAT PAPER. LET ME THINK ABOUT THAT. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER, AND MR. McCAUGHAN LEAVES.) Q. (BY MR. NETTLETON) PAGE 24, THE LAST PARAGRAPH, IN EXHIBIT NUMBER FIVE, THE SENTENCE THAT SAYS, "HOWEVER, THE INCREASE IN PHOSPHORUS STORAGE OCCURS AT A COST THROUGH DECREASED EFFICIENCY OF PHOSPHORUS REMOVAL." WHAT COST ARE YOU REFERRING TO? A. THE COST IS THAT THE EFFICIENCY GOES DOWN SOME. DR. CRAFT VOLUME II PAGE 494 SO, INSTEAD OF--- Q. AND THAT -- I'M SORRY. GO AHEAD. A. ---SO, LET'S SAY -- LET'S SAY IN ONE AREA YOU HAVE A HUNDRED PERCENT OF THE PHOSPHORUS REMOVED, BUT YOU CAN GO TO ANOTHER AREA THAT REMOVES MORE PHOSPHORUS, PRESUMABLY BECAUSE THERE'S MORE PHOSPHORUS INPUT, BUT IT DOESN'T -- WHILE IT REMOVES MORE, THE EFFICIENCY, IN TERMS OF COMPARED TO THE TOTAL INPUT, GOES DOWN. Q. AND, AGAIN, WHEN WE'RE TALKING ABOUT PHOSPHORUS STORAGE HERE, YOU'RE TALKING IN TERMS OF PHOSPHORUS LOADING, AS OPPOSED TO PHOSPHORUS CONCENTRATIONS? A. WE'RE TALKING GRAMS PER METER SQUARED PER YEAR, SO LOADING IS THE OPERATIVE TERM. Q. AND THE EFFICIENCY THAT WE'RE TALKING ABOUT IS THE EIGHTY-SEVEN PERCENT VERSUS THE HUNDRED PERCENT? A. RIGHT, RIGHT. Q. I'D LIKE TO MOVE TO EXHIBIT NUMBER SIXTEEN. BUT, BEFORE I DO THAT, JUST WITH REGARD IN GENERAL TO THE REPORT WE WERE JUST DISCUSSING--- A. YES. Q. ---IS THERE A COMPARABLE CHAPTER IN THE 1992 ANNUAL REPORT? DR. CRAFT VOLUME II PAGE 495 A. NO. Q. OKAY. IS THERE A CHAPTER IN ANY OF THE EARLIER REPORTS? A. SOME OF THE DATA IS IN THE 1990 REPORT -- IN THE 1990 -- IN THAT REPORT. Q. IS THERE SOME REASON THERE WAS NOT A CHAPTER INCLUDED IN THE 1992 REPORT WITH REGARD TO THIS STUDY? A. WELL, IT WAS JUST IN THE -- I FELT LIKE IT WOULD BE DUPLICATION OF INFORMATION THAT HAD ALREADY BEEN IN AN ANNUAL REPORT. Q. EXHIBIT NUMBER SIXTEEN, AM I CORRECT THAT THIS REPORT EFFECTIVELY PARALLELS CHAPTER SEVEN IN THE 1992 ANNUAL REPORT? A. YES. BUT IS THIS -- NUMBER SIXTEEN, IS THIS THE DRAFT OUT OF A FOLDER, AS OPPOSED TO -- OKAY, THIS IS THE -- THE MOST RECENT VERSION OF WHAT'S IN CHAPTER SEVEN. THIS HAS THE CORRECTED BULK DENSITIES IN IT. Q. ALL RIGHT. AND FOR PURPOSES OF THIS PARTICULAR REPORT, THERE WERE EIGHTEEN CORES THAT WERE TAKEN. IS THAT CORRECT? A. RIGHT. AND THEN I THINK WE WENT BACK A YEAR LATER AND TOOK FOUR ADDITIONAL CORES JUST FOR CESIUM DR. CRAFT VOLUME II PAGE 496 ANALYSIS. Q. NOW, YOU -- AND THERE WERE NO REPLICATES TAKEN OF THESE EIGHTEEN CORES, WERE THERE? A. NO. Q. OKAY. I BELIEVE YOU TESTIFIED YESTERDAY IN GENERAL SCIENCE PARLANCE, THAT THE MORE REPLICATES THE BETTER. IS THAT RIGHT? A. YES. Q. BUT WHY -- WHY WERE NOT ANY REPLICATES TAKEN OF THESE CORES? A. WELL, AGAIN, WHAT I VIEW ARE THE TIME CONSTRAINTS. EIGHTEEN CORES TAKE A VERY LONG TIME TO WORK UP, AND IN SOME WAYS, YOU CAN VIEW THE THREE TRANSECTS, THEY AREN'T TRUE REPLICATES, BUT SINCE THEY ARE AT -- LIKE, FOR EXAMPLE, THE NUMBER ONE POINTS ARE THE SAME DISTANCE BELOW THE HILLSBORO CANAL, THEY PROVIDE INFORMATION ACROSS THE SPATIAL. THEY'RE NOT TRUE REPLICATES, BUT THEY PROVIDE SOME COMPARABLE INFORMATION TO SEE HOW SIMILAR THE ACCUMULATION RATES ARE. AND WE'LL FIND OUT FROM THE REVIEWERS WHETHER I SHOULD HAVE HAD REPLICATES OR NOT, I GUESS. Q. NOW, IS THIS ARTICLE CURRENTLY -- OR IS THIS REPORT CURRENTLY OUT FOR PUBLICATION? DR. CRAFT VOLUME II PAGE 497 A. NO. IT'S -- I HOPE TO GET IT OUT IN THE NEXT MONTH, TO SEND IT OUT. Q. IS THAT THE ONE -- IS THERE ANOTHER EXHIBIT, I BELIEVE THAT WAS MARKED EARLIER -- OR NOT MARKED TODAY -- BUT DISCUSSED BY MS. PONZOLI THIS MORNING? A. WELL, THAT WE TALKED ABOUT THIS AS GOING TO -- SHE ASKED, AS GOING TO BIO -- TO THE -- WE'LL PROBABLY SEND IT TO BIOGEOCHEMISTRY. Q. JUST SPEAKING IN GENERAL CONCERNING THE 1992 REPORT, I UNDERSTAND THAT THAT IS NOW CONSIDERED A DRAFT, THE VERSION THAT WE HAVE. IS THAT RIGHT? A. YES. Q. WHEN WERE YOU FIRST ADVISED THAT THAT NEEDED TO BE REVISED UNTIL FINAL VERSION? A. WHEN WE BECAME AWARE OF ALL THE TYPOS AND THE CALCULATING ERRORS ON THE BULK DENSITY HERE, AND SOME OTHER, YOU KNOW, SMALL ERRORS THROUGHOUT. IT'S PROBABLY BEEN A MONTH OR MORE. IT WASN'T LONG AFTER IT CAME OUT. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED DR. CRAFT VOLUME II PAGE 498 BY THE COURT REPORTER.) Q. (BY MR. NETTLETON) WHO IS COORDINATING PUTTING THE FINAL VERSION TOGETHER? A. LISA PHELPS IS DOING THE COORDINATING. Q. AND WHO IS LISA PHELPS? A. SHE IS DR. RICHARDSON'S ADMINISTRATIVE ASSISTANT. Q. THERE HAS ALSO BEEN SOME DISCUSSION OF THE APPENDICES THAT WILL GO ALONG WITH THAT REPORT. HAVE THOSE APPENDICES BEEN PUT INTO DRAFT FORM AT THIS POINT? A. AGAIN, I THINK SHE'S ASSEMBLING THEM. I DON'T THINK WE HAVE A DRAFT VERSION AT THIS TIME, BUT MY UNDERSTANDING FROM YESTERDAY'S CONVERSATION IS THAT THOSE TWO THINGS WILL COME OUT AT THE SAME TIME IN JANUARY. Q. OKAY. WITH REGARD TO THE APPENDICES, ARE THERE ANY CHANGES BEING MADE, TO ANY OF THE DATA REFLECTED THERE? A. WELL, OTHER THAN THOSE BULK DENSITIES, WHICH HAVE BEEN CORRECTED, AND HAVE BEEN PASSED ON TO HER AT THIS POINT. I MEAN, THERE MAY BE A FEW OTHER SMALL ERRORS THAT OTHER PEOPLE ARE INVOLVED IN, BUT I'M NOT. Q. ON THE FIRST PAGE OF THE ABSTRACT OF EXHIBIT DR. CRAFT VOLUME II PAGE 499 NUMBER SIXTEEN, SECOND PARAGRAPH, THE FIRST SENTENCE, "RATES OF PEAT ACCRETION WERE HIGHEST WITHIN 1.5 KILOMETERS OF THE HILLSBORO CANAL, AND DECREASED TO 2.01, PLUS OR MINUS .31 AT DISTANCES OF 6.6 TO 10 KILOMETERS DOWNSTREAM." YOUR CHAPTER SEVEN HAD DIFFERENT NUMBERS FOR THAT SECOND ONE, IT WAS 2.08, PLUS OR MINUS .28. WAS THAT CHANGE ONE OF THE ONES WHICH WOULD BE AFFECTED BY THE BULK DENSITY? A. NO. THAT MAY HAVE BEEN A TYPO, BECAUSE THE ACCRETION RATES DIDN'T CHANGE, THEY'RE NOT AFFECTED BY THE BULK DENSITY. BUT, AGAIN, 2.01, WITH AN ERROR OF THAT, AND 2.08 WITH AN ERROR, NO, THEY'RE ESSENTIALLY THE SAME, AS I VIEW THEM. BUT I THINK WHAT MAY HAVE BEEN, IS THAT ONE MAY HAVE BEEN TYPED IN INCORRECTLY, COMPARED TO WHAT'S IN THE TEXT LATER ON. Q. OKAY. WHAT DO YOU THINK IS THE CORRECT NUMBER THEN, 2.08 OR 2.01? A. WELL, I THINK THIS IS, BEING THE MOST RECENT DRAFT, I THINK THIS IS THE CORRECT -- THE CORRECT ONE. BUT I CAN GO TO -- TO FURTHER IN THE TEXT, AND I'VE GOT THAT 2.01 PLUS OR MINUS .31 AGAIN, SO--- DR. CRAFT VOLUME II PAGE 500 Q. BUT AS FAR AS YOU'RE CONCERNED, THEY'RE CLOSE ENOUGH THAT IT DOESN'T MAKE ANY DIFFERENCE WHICH NUMBER YOU'RE USING? A. WELL, NO, IT MAKES A DIFFERENCE TO HAVE THE CORRECT NUMBER. BUT IN TERMS OF WHAT THE STORY TELLS, IT DOESN'T MAKE ANY DIFFERENCE. YOU ALWAYS WANT TO HAVE THE CORRECT NUMBER IN THERE, AND THAT'S WHY THIS IS A DRAFT. YOU KNOW, WE WILL -- WE'LL DOUBLE CHECK THESE AND MAKE SURE THAT THEY'RE CORRECT BEFORE WE SEND THEM OUT. Q. IN THE FIRST SENTENCE OF THE ABSTRACT, YOU REFER TO THE EUTROPHICATION GRADIENT. WHAT DO YOU MEAN BY EUTROPHICATION GRADIENT? A. I USE THAT AND NUTRIENT ENRICHMENT SYNONYMOUSLY. AND, IN FACT, MY TITLE ORIGINALLY HAD ALONG A NUTRIENT ENRICHMENT GRADIENT. BUT I HAD THE WORD NUTRIENT TWICE IN THE TITLE, AND I JUST DIDN'T LIKE THE WAY THAT SOUNDED, SO I CHANGED IT TO EUTROPHICATION. Q. OKAY. IN YOUR MIND, DOES EUTROPHICATION IMPLY SOME TYPE OF PROBLEM THROUGH NUTRIENT ENRICHMENT? A. I THINK WHAT IT MEANS, THE DEFINITION, OR AT LEAST ONE DEFINITION, MEANS ACCELERATED ENRICHMENT OF ECOSYSTEMS. DR. CRAFT VOLUME II PAGE 501 Q. DOES IT CONTAIN -- DOES IT ALSO CONTAIN THE CONCEPT OF -- OF AFFECTING, ADVERSELY AFFECTING THE ECOSYSTEM? A. POTENTIALLY. IT GENERALLY CONNOTES A LOT HIGHER PRODUCTIVITY, BECAUSE YOU'RE ADDING THESE LIMITING NUTRIENTS, AND OBVIOUSLY IT DEPENDS ON WHETHER YOU WANT TO ENHANCE PRODUCTIVITY. MAYBE THAT'S WHAT YOU'RE GOING FOR. BUT, IN MANY CASES, IT'S USED -- IT'S A DETRIMENTAL TERM. IT'S USED BY A LOT OF PEOPLE TO MEAN AN UNDESIRABLE EFFECT. Q. WAS THAT YOUR INTENT IN USING THE TERM? A. WELL, I WOULD HAVE TO GO LOOK AT THE DEFINITION AND SEE. IT JUST REPRESENTS NUTRIENT ENRICHMENT. Q. WELL, REGARDLESS OF WHAT WEBSTER'S OR WHATEVER DEFINITION WE WOULD LOOK AT, I MEAN, WHAT WAS YOUR INTENT BY USING THE TERM? A. I DON'T THINK I TRIED TO ASSESS IT IN EITHER A POSITIVE OR A NEGATIVE WAY. Q. DOES NUTRIENT ENRICHMENT IN THE EVERGLADES INCLUDE THE CONCEPT OF CULTURAL EUTROPHICATION? A. I'M NOT SURE. SOMEBODY WOULD HAVE TO DEFINE THAT FOR ME. IS THAT LIKE A CESSPOOL OF HUMANITY OR SOMETHING? (THEREUPON, THERE WAS AN DR. CRAFT VOLUME II PAGE 502 OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER.) Q. (BY MR. NETTLETON) WELL, WE'LL MOVE ALONG. BASED UPON YOUR EXPERIENCE IN THE AREA, WHAT -- WHAT EFFECT WOULD YOU EXPECT TO SEE FROM THE ADDITION OF NUTRIENTS TO AN OLIGOTROPHIC SYSTEM? A. CERTAINLY ENHANCED PRODUCTIVITY, BY, YOU KNOW, A LOT OF COMPONENTS; A SHIFT IN THE COMMUNITIES, POTENTIALLY, AND CHANGE IN SPECIES COMPOSITION. Q. WHAT WOULD YOU DO AS A SCIENTIST TO DOCUMENT OR TO DETERMINE THE EFFECT OF NUTRIENT ENRICHMENT ON A SYSTEM? A. I THINK SOME OF THE THINGS WE'RE DOING NOW -- AND I THINK OTHER RESEARCHERS -- ONE IS, I THINK THE FERTILIZER EXPERIMENT TRIES TO ADDRESS THAT BY STARTING AT TIME ZERO IN AN UNENRICHED AREA AND ADDING FERTILIZER ADDITIONS, AND SEEING HOW THE -- SEEING WHAT THESE CHANGES OCCUR, SEE HOW THESE CHANGES OCCUR, AND AT WHAT TIME INTERVAL. AND ANOTHER THING WOULD BE, IN CONSERVATION AREA 2A, TO SET UP -- IF THE AREA IS TRULY EXPANDING, THIS ENRICHED ZONE IS EXPANDING -- SET UP PLOTS DOWNSTREAM FROM THE ENRICHED AREA, AND SEE WHAT DR. CRAFT VOLUME II PAGE 503 CHANGES OCCUR OVER TIME. Q. WHEN YOU TALK ABOUT CHANGES, WHAT SPECIFICALLY WOULD YOU BE LOOKING FOR, WHAT TROPHIC LEVEL ARE YOU TALKING ABOUT? A. WELL, THAT'S MORE IN -- MY INTEREST WOULD BE RELATING -- BECAUSE I DO WORK WITH THINGS LIKE CHANGES IN MACROPHYTES -- DOES CATTAIL EXPAND INTO THESE AREAS IN RESPONSE TO ENRICHMENT. I'M INTERESTED IN THINGS LIKE PEAT BUILDUP AND PEAT ACCRETION. THOSE WOULD BE THINGS THAT I WOULD LOOK AT. DR. RADER, OBVIOUSLY, HAS DIFFERENT INTERESTS AND HE WOULD -- HE LOOKS AT SOME OF THE FOOD WEB COMPONENTS. Q. WOULD YOU EXPECT TO GET INCREASED PRODUCTIVITY BY ENHANCED HYDROPERIOD? A. YES. WELL, NO, NO -- LET ME BACK UP. I'M NOT SURE ABOUT THAT. I THINK YOU WOULD GET ENHANCED PEAT ACCRETION, BUT I'M NOT SURE TO WHAT EXTENT ENHANCED HYDROPERIOD WOULD ENHANCE PRODUCTIVITY. SO I DON'T REALLY KNOW ABOUT THAT. Q. YOU JUST DON'T KNOW ONE WAY OR THE OTHER? A. NO, I DON'T. Q. NO OPINION? A. WELL, I JUST DON'T KNOW. DR. CRAFT VOLUME II PAGE 504 Q. OKAY. THE FIRST PAGE OF THE ABSTRACT, THE FIGURES ON -- DO YOU SEE THE FIGURES, .66, PLUS OR MINUS .06? A. YES. Q. AND THEN THE NEXT FIGURE IS .10, PLUS OR MINUS .02? A. UH-HUH (YES). Q. I NOTED THAT THOSE ARE ALSO DIFFERENT FROM THE NUMBERS THAT ARE INCLUDED IN CHAPTER SEVEN OF THE ANNUAL REPORT. WOULD THOSE HAVE BEEN CHANGED AS A RESULT OF THE BULK DENSITY ERROR? A. RIGHT. THE PROBLEM WITH BULK, AGAIN, AS I MENTIONED EARLIER, TO CALCULATE ANY KIND OF ACCUMULATION RATE, PHOSPHORUS OR CARBON OR NITROGEN, YOU NEED BULK DENSITY, YOU NEED ACCRETION, AND YOU NEED THE CONCENTRATION OF THE ELEMENT. SO, WHEN THE BULK DENSITY CHANGED, IT WOULD CHANGE -- IT WOULD NECESSARILY RESULT IN A CHANGE IN THESE ACCUMULATION RATE NUMBERS ON THAT "A" TRANSECT. Q. SO, THAT'S THE REASON THOSE NUMBERS HAVE CHANGED AT THIS POINT? A. YES. AND I THINK THAT THEY'VE -- BECAUSE THE BULK DENSITY WENT DOWN, THESE NUMBERS ARE SOMEWHAT DR. CRAFT VOLUME II PAGE 505 LOWER THAN THEY WERE IN THE CHAPTER SEVEN. Q. WHO DISCOVERED THE ERROR IN THE BULK DENSITY? A. I DID. Q. WHEN DID YOU DISCOVER THAT? A. THIS WAS IN LATE OCTOBER, WHEN -- RIGHT AFTER THE REPORT HAD GONE OUT, AND I WAS STARTING TO REVISE THIS, TO TRY TO SEND IT OUT, AND I WANTED TO MAKE SURE THAT THE NUMBERS WERE RIGHT. SO, WE WENT BACK THROUGH THE DATA SETS, AND DISCOVERED THE ERROR. Q. NOW, ON THE SECOND PAGE OF THE ABSTRACT, EXHIBIT NUMBER SIXTEEN, THE PARAGRAPH THAT CONTINUES ACTUALLY ONTO THE NEXT PAGE, ABOUT HALFWAY THROUGH THERE, THE SENTENCE STARTS "HOWEVER." DO YOU SEE THAT? THOSE TWO SENTENCES READ, "HOWEVER, PHOSPHORUS ACCUMULATION ALONG THE GRADIENT IS A FUNCTION OF SURFACE WATER PHOSPHORUS CONCENTRATION, DECREASING AS SURFACE WATER PHOSPHORUS DECREASES. THESE FINDINGS SUGGEST THAT AS INFLOW PHOSPHORUS CONCENTRATIONS DECREASE, PROGRESSIVELY LARGER WETLAND AREAS WILL BE NEEDED TO REMOVE THE SAME AMOUNT OF PHOSPHORUS THAT IS SEQUESTERED IN A SMALLER WETLAND EXPOSED TO HIGHER INPUT PHOSPHORUS CONCENTRATIONS." THOSE TWO DR. CRAFT VOLUME II PAGE 506 SENTENCES DO NOT APPEAR IN CHAPTER SEVEN OF THE ANNUAL REPORT. WHO ADDED THOSE TO THIS DOCUMENT? A. IS THERE -- I WOULD LIKE TO LOOK AT CHAPTER SEVEN, BECAUSE THERE SHOULD BE SOMETHING IN THERE THAT -- THAT SAYS SOMETHING ALONG THOSE LINES, IF NOT THERE, BUT LATER IN THE TEXT. THIS MAY HAVE BEEN SOMETHING -- WELL, LET ME LOOK AND SEE WHAT -- WHAT IT SAYS IN HERE. I DON'T KNOW WHERE CHAPTER SEVEN IS. IS THIS -- IS THIS LAST YEAR? Q. 286. A. OKAY. OKAY. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. OKAY. I DO SEE THAT THEY ARE NOT IN THERE. BUT WE -- WE TALK ABOUT THIS. DR. RICHARDSON -- I DON'T REALLY REMEMBER -- BUT HE'S BEEN REVIEWING THE DOCUMENT, AND HE PROBABLY SUGGESTED THAT WE INCLUDE THAT. BUT LATER IN THE TEXT IN CHAPTER SEVEN WE DO ADDRESS THIS, TALKING ABOUT THIS PROBLEM, AND WE MAY EVEN -- LET'S SEE IF I CAN FIND IT. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. IN FACT, IF YOU LOOK IN THE -- I BELIEVE MAYBE THERE'S -- IF YOU LOOK ON PAGE 317, WHICH IS AT THE VERY END OF CHAPTER SEVEN, WE ESSENTIALLY SAY DR. CRAFT VOLUME II PAGE 507 THE SAME THING, WE -- "THESE FINDINGS" -- ABOUT HALFWAY DOWN. "THESE FINDINGS SUGGEST THAT, AS INFLOW CONCENTRATIONS DECREASE, PROGRESSIVELY LARGER WETLAND AREAS WILL BE NEEDED," AND SO ON AND SO FORTH. BUT, APPARENTLY, HE THOUGHT THAT THAT WAS IMPORTANT ENOUGH TO INCLUDE IN THE ABSTRACT. Q. SO, THAT WAS DR. RICHARDSON'S DETERMINATION TO INCLUDE THAT IN THE ABSTRACT? A. WELL, I THINK SO. AGAIN, THIS IS A DRAFT AND WE'RE -- AND, YOU KNOW, WE'RE TRYING TO GET IT IMPROVED ENOUGH TO SEND OUT. Q. I'D JUST LIKE TO CLARIFY, THERE'S NO PAGE NUMBERS ON THIS, BUT THERE'S A REFERENCE IN HERE TO CRAFT AND RICHARDSON, 1993. DO YOU KNOW WHAT THAT WOULD REFER TO? A. THAT WOULD REFER TO NUMBER FIVE--- Q. NUMBER FIVE? A. ---WHAT WE TALKED ABOUT PREVIOUSLY. Q. THERE'S A SECTION IN EXHIBIT NUMBER SIXTEEN THAT'S ENTITLED: ACCUMULATION RATES OF PHOSPHORUS, SODIUM, ETCETERA. I DON'T HAVE A PAGE NUMBER, SO I CAN'T PUT YOU ANY CLOSER--- A. I CAN FIND IT. OKAY. DR. CRAFT VOLUME II PAGE 508 Q. ---DO YOU SEE THAT? A. UH-HUH (YES). Q. TURN TO THE PAGE AFTER THAT--- A. OKAY. Q. ---ABOUT SIX OR SO LINES DOWN, THE LINE STARTS HILLSBORO CANAL? A. YES. Q. IT TALKS ABOUT EXTRAPOLATING THE EQUATION TO LOCATIONS, ADJACENT TO THE HILLSBORO CANAL, YIELDED A MAXIMUM ACCUMULATION RATE OF .92? A. RIGHT. Q. AGAIN, I NOTED THAT IN CHAPTER SEVEN, THE REFERENCE IS TO--- A. .9. Q. ---1.05. A. OKAY. AGAIN, THE SHIFT IN THE BULK DENSITIES ON THAT "A" LINE RESULTED IN THESE CHANGES. THAT'S WHY IT'S IMPORTANT TO MAKE SURE YOU HAVE YOUR BULK DENSITIES RIGHT. IT TENDS TO CHANGE A LOT OF OTHER NUMBERS. Q. THREE PAGES PAST THERE, UNDER THE HEADING PHOSPHORUS STORAGE EFFICIENCY OF WCA 2A, THE PAGE -- THE SECOND PAGE OF THAT, TWO LINES FROM THE BOTTOM REFERS TO 51 METRIC TONS OF PHOSPHORUS DR. CRAFT VOLUME II PAGE 509 PER YEAR. IN CHAPTER SEVEN, I NOTED THAT THAT PREVIOUSLY REFLECTED 52.4 METRIC TONS. IS THERE A REASON THAT WAS CHANGED? A. AGAIN, THE -- YOU UNDERSTAND WHEN THE BULK DENSITIES CHANGE, THAT CHANGES THE ACCUMULATION RATE, WHICH CHANGES A LOT OF THESE. BUT, AGAIN, THIS IS THE CORRECT NUMBER, BUT I DON'T THINK THE STORY CHANGES. FROM 51 METRIC TONS TO 52.4 IS A CHANGE OF MAYBE SLIGHTLY MORE THAN TWO PERCENT, SO. Q. I'M NOT TRYING TO SUGGEST OTHERWISE, BUT I'M JUST--- A. NO, I'M JUST TRYING--- Q. ---AS YOU MIGHT KNOW, I DON'T COMPLETELY UNDERSTAND EVERYTHING THAT'S BEEN SAID HERE, SO I JUST WANT TO MAKE SURE THAT THAT IS RELATED TO THE SAME--- A. HEY, I DON'T UNDERSTAND SOME OF THIS STUFF EITHER, SO. WITNESS: CAN WE -- ARE WE DONE WITH -- WELL, WHEN WE GET TO THIS, I'D LIKE TO MAYBE TAKE A BREAK. MR. NETTLETON: OKAY, I'VE JUST GOT A FEW MORE QUESTIONS ON THAT. DR. CRAFT VOLUME II PAGE 510 WITNESS: OKAY. Q. (BY MR. NETTLETON) WHEN WE WERE TALKING ABOUT THE POLLEN ANALYSIS EARLIER, ARE YOU COLLECTING ANY ADDITIONAL CORES FOR PURPOSES OF DOING THAT? A. NO. MY HOPE IS TO TAKE EXISTING CORES, AND TRY TO DO THE ANALYSIS ON THEM. THAT'S WHAT WE'RE GOING TO TRY FIRST. BUT I'LL SAY, WE'VE -- WE'VE NOT TRIED POLLEN ANALYSIS ON THESE, SO, WE DON'T REALLY KNOW HOW WELL THEY'LL -- HOW WELL THEY'LL WORK, OR HOW POORLY THEY'LL WORK. SO, WE MAY DECIDE TO GO BACK AND TAKE SOME CORES. Q. DO YOU KNOW OF ANYONE ELSE THAT'S CURRENTLY PULLING CORES FOR PURPOSES OF DOING A POLLEN ANALYSIS? A. NO, I DON'T KNOW OF ANYBODY. Q. WHAT WAS THE STATISTICAL PRECISION OF YOUR CESIUM 137 DATA? A. YOU CAN SEE THE COUNTING ERROR ON SOME OF THE FIGURES THAT I GIVE YOU -- I BELIEVE FIGURE TWO. IT IS NOT A STANDARD ERROR, BUT IT IS SIMILAR TO ONE. I MEAN, IT'S NOT CALCULATED LIKE A STANDARD ERROR, BUT YOU CAN SEE THE LITTLE -- THE BAR THERE ON THE PEAK, LIKE THE UPPER LEFT-HAND GRAPH, THE UPPER LEFT-HAND PROFILE. DR. CRAFT VOLUME II PAGE 511 Q. WHICH PAGE IS THIS? A. THIS IS IN THE DRAFT, AND IT'S ALMOST -- IT'S ABOUT FIVE PAGES FROM THE BACK. IT'S EASIER FOR ME TO SHOW YOU THAN TO TELL YOU--- Q. OKAY. I'VE GOT IT. A. ---YOU SEE THE UPPER LEFT-HAND PROFILE HAS A VERY NICE, WELL-DEFINED PEAK. CAN YOU SEE THAT LITTLE BAR STICKING OUT ON THE CESIUM? Q. UH-HUH (YES). A. THAT IS THE COUNTING ERROR FOR THAT DEPTH INCREMENT. AND WE GENERALLY FOUND THAT THE COUNTING ERRORS WERE FIVE TO TEN PERCENT, ON AVERAGE, OF THE SIZ -- OF THE ACTIVITY. Q. IS THERE A WAY TO ABSOLUTELY DETERMINE THE ACCURACY OF THE CESIUM 137 ANALYSIS? A. WELL, IT'S LIKE ANY SCIENTIFIC TECHNIQUE. THERE IS ALWAYS SOME UNCERTAINTY INVOLVED. AND, REALLY, CESIUM, I THINK, IS NOT AS COMPLICATED AS EVERYBODY -- AS SOME OF Y'ALL THINK IT IS. I MEAN, I REALLY THINK A LAYMAN CAN DO THIS KIND OF WORK. YOU BASICALLY -- SINCE IT'S CALLED AN IMPULSE MARKER -- SO, YOU LOOK AT THE PEAK AT DEPTH. AND IF YOU HAVE A NICE, WELL-DEFINED PEAK, AS IN THE CASE OF THAT FIGURE, THAT SUGGESTS TO DR. CRAFT VOLUME II PAGE 512 ME, AND TO OTHER SCIENTISTS WHO WORK WITH CESIUM, THAT IT'S A VERY GOOD MARKER IN A CORE LIKE THAT. WITH REGARDS TO THE INSTRUMENTATION, CESIUM, WHEN YOU COUNT CESIUM, THE INSTRUMENT EITHER WORKS OR IT DOESN'T. I MEAN, IT'S EITHER ON -- IT'S EITHER WORKING AND COUNTING, OR IT'S NOT COUNTING AT ALL. SO, THERE'S NO UNCERTAINTY IN THE WAY THE MACHINE COUNTS. IT'S MORE IN TERMS OF LOOKING AT THE COUNTS IN DIFFERENT CHANNELS. Q. DOES THE TERM STATISTICAL PRECISION HAVE A SPECIFIC SCIENTIFIC MEANING? A. PRECISION, I THINK, IMPLIES HOW CLOSE TO THE TRUE VALUE YOU ARE. AND THE COUNTING ERROR GIVES YOU SOME IDEA OF THAT, LOOKING AT THIS. AND I THINK WITH A SMALL COUNTING ERROR ON A FIGURE LIKE THAT, COMPARED TO THE SIZE OF THE PEAK, INDICATES THAT THERE'S A GREAT DEAL -- THERE'S A HIGH DEGREE OF CERTAINTY THAT THAT IS INDEED WHERE THE CESIUM MAXIMUM IS. Q. AND IF WE GET -- IF WE GET FURTHER AWAY FROM SAY THE TOP LEFT-HAND CORNER, AND GO DOWN TWO COLUMNS, WHERE THE BARS SEEM TO BE CLOSER TOGETHER, DOES THAT INDICATE THAT THE ERROR COULD HAVE SOME EFFECT ON--- DR. CRAFT VOLUME II PAGE 513 A. OH, YEAH, THE UNCERTAINTY IS CERTAINLY GREATER ON THOSE. Q. AT SOME POINT IN NUMBER SIXTEEN -- AND I DON'T HAVE A PAGE NUMBER -- UNDER THE HEADING "ACCRETION RATES." A. UH-HUH (YES). OKAY. I HAVE -- WELL, I WILL FIND IT HERE SHORTLY. I SEE IT. Q. OKAY. THE SECOND SENTENCE REFERS TO "PEAT ACCRETION WAS HIGHEST NEAREST THE HILLSBORO CANAL." A. YES. Q. AND IT GOES ON TO SAY THAT THE SOURCE OF -- "THE SOURCE OF THE NUTRIENT ENRICHED WATER DECREASED IN THE DOWNSTREAM DIRECTION." DO YOU CONSIDER -- DO YOU CONSIDER IN HERE THAT THE HILLSBORO CANAL IS THE SOURCE OF THE NUTRIENT? A. YEAH, I MEAN, I THINK SO. THAT'S WHERE THE WATER'S RELEASED INTO CONSERVATION AREA 2A. Q. WHERE ARE THE NUTRIENTS CONTAINED IN HILLSBORO CANAL ORIGINATING FROM? A. OKAY, THE TRUE SOURCE IS PROBABLY THE EAA AND LAKE OKEECHOBEE. IT'S COMING FROM UPSTREAM, SO. I MEAN, FOR THIS, I'M MORE TALKING ABOUT MAYBE THE OR -- WELL, ORIGIN MIGHT NOT BE THE CORRECT DR. CRAFT VOLUME II PAGE 514 WORD EITHER, BUT -- BUT THE -- IT FLOWS THROUGH THE GATES TO GET INTO CONSERVATION AREA 2A. INPUT MIGHT BE A BETTER WORD. Q. OKAY. DO YOU CONSIDER INCREASED RATES OF PEAT ACCRETION AND NUTRIENT ACCUMULATION IN THE EVERGLADES SOIL TO BE A CHANGE IN THE EVERGLADES ECOSYSTEM? A. WELL, IT'S A CHANGE RELATIVE TO THESE AREAS FURTHER SOUTH THAT DON'T SEEM TO SHOW THESE HIGHER RATES OF ACCRETION, YES. Q. DO YOU CONSIDER THIS TO BE A FUNCTIONALLY SIGNIFICANT CHANGE? A. YEAH, I THINK IT IS SIGNIFICANT. Q. WHAT WERE THE TOTAL NUMBER OF CORES THAT THE CESIUM 137 WAS BASED ON, THE ANALYSIS? A. I THINK TWENTY-TWO. IT WAS EIGHTEEN, AND THEN WE TOOK FOUR ADDITIONAL CORES A FOLLOWING YEAR, JUST TO COMPARE AND SEE IF THE CESIUM PEAKS WERE SIMILAR AT THOSE FOUR SITES; IF THERE WAS, YOU KNOW, REPEATABILITY. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. AGAIN, I'M WITHOUT A PAGE NUMBER FOR THAT. A. WELL, I AN FIND IT. WELL, WHAT'S THE LAST HEADING? DR. CRAFT VOLUME II PAGE 515 Q. "PHOSPHORUS STORAGE EFFICIENCY IN THE WCA 2A." A. OKAY. I'M THERE. Q. THERE'S A PARAGRAPH, A COUPLE PAGES IN, IT STARTS "MOST OF THE PHOSPHORUS THAT ACCUMULATES." A. I'M NOT EVEN SURE IF I HAVE THAT. IT STARTS AS A PARAGRAPH--- Q. RIGHT. A. ---UNDER PHOSPHORUS STORAGE EFFICIENCY. Q. RIGHT. A. PERHAPS THAT'S BEEN REVISED SOME. WHAT'S THE--- Q. TAKE A LOOK AT THE NEXT HEADING. ACTUALLY, I THINK THERE'S A PIECE MISSING OUT OF CHAPTER SEVEN, WHICH MAY BE THE--- A. OKAY. I DON'T SEE IT. MAYBE GO TO THE PROCEEDING. GO TO THE -- WELL, YOU DON'T HAVE A CONCLUSION SECTION, I DON'T THINK. Q. YEAH--- A. OH, OKAY. Q. ---IT'S THE SECTION RIGHT BEFORE THE CONCLUSION--- A. OKAY. Q. ---PAGE 316 ON THE ANNUAL REPORT. A. I THINK IT'S MAYBE -- MAYBE IT'S HERE. WHAT -- WHAT IS THE -- OKAY, SURE, I'LL LOOK AT THE DR. CRAFT VOLUME II PAGE 516 REPORT. OKAY, I SEE IT. Q. OKAY. THE LAST SENTENCE IN THAT PARAGRAPH READS THAT, "MOST OF THE PHOSPHORUS ACCUMULATING IN THE ENRICHED AREA IS PERMANENTLY SEQUESTERED IN THE PEAT MATRIX AND, UNDER CURRENT CONDITIONS, IS UNLIKELY TO BE RELEASED BACK INTO THE WATER COLUMN AND EXPORTED DOWNSTREAM." WHAT CURRENT CONDITIONS ARE YOU REFERRING TO? A. WELL, SINCE THIS MATERIAL HAS ACCUMULATED OVER A TWENTY-FIVE YEAR PERIOD, I GUESS WHAT I'M REFERRING TO IS IF THERE'S NO DRAMATIC CHANGE IN THE HYDROLOGY, LIKE, THEY LET IT DRY OUT COMPLETELY FOR TEN YEARS AND THEN REFLOOD IT, OR SOMETHING LIKE THAT. JUST NO DRAMATIC CHANGE IN THE WAY THAT THE CONSERVATION AREA 2A IS REGULATED NOW. Q. ANY OTHER TYPE OF CONDITIONS, OTHER THAN TEN YEAR DROUGHT TYPE OF--- A. WELL, I DON'T KNOW. THERE COULD BE OTHER THINGS. BUT ALL I'M REFERRING TO IS THAT I THINK IF IT IS -- IF IT'S MANAGED THE WAY IT HAS BEEN IN RECENT YEARS, THIS MATERIAL WILL PROBABLY STAY -- WILL STAY SEQUESTERED, PROBABLY. Q. WELL, OTHER THAN THE SCENARIO YOU SUGGESTED, ARE DR. CRAFT VOLUME II PAGE 517 THERE ANY OTHER CONDITIONS THAT COULD RESULT IN THIS RE-RELEASE BACK? A. I DON'T KNOW, IT'S SOMETHING THAT I'D HAVE TO REALLY THINK ABOUT. MR. NETTLETON: OKAY. THAT'S ALL THE OTHER QUESTIONS I HAD ON THAT DOCUMENT. WITNESS: TIME OUT, PLEASE. (THEREUPON, A SHORT BREAK WAS TAKEN.) EXAMINATION BY MR. NETTLETON CONTINUES: Q. IT MIGHT BE HELPFUL IF YOU HAD THE ANNUAL REPORT IN FRONT OF YOU, SO I CAN REFER TO THE PAGES. AND IN CHAPTER ONE, I THINK REFLECTS THAT--- A. OKAY. CAN WE SHARE THERE? OKAY, SURE. Q. PAGE 14 REFLECTS A DRAWING OF WCA 2B WHERE THE SAMPLING SITES WERE, I BELIEVE--- A. YES. Q. ---BUT BEFORE I GET INTO THIS, YOU HAD MENTIONED EARLIER THAT DR. CURTIS RICHARDSON IS CURRENTLY ENGAGED IN A HYDROLOGY STUDY IN THIS SAME AREA. IS THAT RIGHT? A. (NODS AFFIRMATIVELY.) Q. OKAY. DO YOU RECALL WHERE IN THE WCA 2B HIS STUDY DR. CRAFT VOLUME II PAGE 518 IS LOCATED? A. IT'S RIGHT ADJACENT TO OUR SAWGRASS SITE. ON THE DIAGRAM, IT WOULD BE BETWEEN THE SAWGRASS AND THE MIXED SITE, BUT IT'S METERS, TENS OF METERS AWAY FROM THE SAWGRASS SITE. Q. OKAY. WHAT'S THE PURPOSE OF THAT STUDY? A. I'M NOT REALLY INVOLVED IN IT, BUT MY UNDERSTANDING IS, IS IT'S TO LOOK AT THE EFFECTS OF DIFFERENT WATER LEVELS, AND HE HAS A PHOSPHORUS TREATMENT, AND HE HAS A DISTURBANCE TREATMENT ON RECOLONIZATION OF THESE PLOTS, ON WHAT COMES INTO THEM. Q. DOES IT -- IS IT -- DOES IT HAVE ANY RELATIONSHIP TO YOUR FERTILIZER STUDY? A. NO, NOT REALLY. IT'S MORE TRYING TO ADDRESS THIS QUESTION OF HYDROLOGY. Q. WAS THERE ANY SIGNIFICANCE TO THE FACT THAT IT'S ONLY METERS AWAY FROM YOUR -- ONE OF YOUR SITES HERE? A. NO, I THINK IT WAS JUST A MINIMAL -- WELL, IT WAS MAINLY PUT THERE FOR ACCESS, SO THAT BOTH SITES -- YOU KNOW, YOU COULD DRIVE A VEHICLE TO ONE LOCATION, AND ONE PERSON COULD GO WORK IN THE HYDROLOGY PLOTS, AND ANOTHER PERSON COULD WORK IN DR. CRAFT VOLUME II PAGE 519 THE SAWGRASS PLOTS. Q. I BELIEVE YOU TESTIFIED YESTERDAY THAT THE PEAT IN AREA 2B HAS HIGH MINERAL CONTENT. IS THAT RIGHT? A. IT IS HIGHER IN MINERAL CONTENT THAN IN 2A. Q. OKAY. ARE THERE ANY OTHER DIFFERENCES IN THE PEAT? A. THE PEAT'S NOT AS DEEP, I DON'T THINK, FROM SOME OF THE MEASUREMENTS WE MADE. Q. AS A RESULT OF THOSE DIFFERENCES, DO YOU THINK THAT IN ANY WAY SKEWS THE APPLICATION OF ANY OF YOUR FINDINGS OR CONCLUSIONS FROM 2B AS THEY MIGHT APPLY TO 2A? A. I DON'T THINK SO, BECAUSE THE DEPTH OF THE PEAT IS STILL SUCH, THAT IT'S MUCH DEEPER THAN THE ROOTING DEPTH OF THE PLANT ROOTS. AND, ALSO, 2B IS VERY SIMILAR TO CONSERVATION AREA 3A, WHICH ALSO IS DOMINATED BY SAWGRASS AND A SHALLOWER PEAT, AND HAS A LITTLE BIT MORE MINERAL MATERIAL IN IT. Q. WHAT ABOUT THE EVERGLADES PROTECTION AREA IN GENERAL, THE ENTIRE, INCLUDING THE PARK AND ALL THE WCA'S? A. WELL, FROM MY UNDERSTANDING OF THE LOXAHATCHEE, DR. CRAFT VOLUME II PAGE 520 THAT AREA IS THE ONE THAT REALLY DIFFERS IN TERMS OF THE SOILS, AND FROM THE REST OF THE CONSERVATION AREAS IN THE PARK. AND I THINK 2B IS CERTAINLY MORE LIKE 2A AND 3A IN THE PARK THAN IT IS -- YOU KNOW, IT HAS THAT CIRCUMNEUTRAL pH AS OPPOSED TO THE MORE ACIDIC pH THAT CONSERVATION AREA 1 HAS. Q. AM I CORRECT THAT THIS FERTILIZER STUDY WAS NOT DESIGNED, AND, IN FACT, THERE ARE NO CONCLUSIONS IN THIS CHAPTER, I BELIEVE, THAT REFLECT THE EFFECT OF HYDROPERIOD ON--- A. NO, IT DOES NOT REALLY ADDRESS HYDROPERIOD. Q. CAN YOU TELL ME WHAT THE REASON OF INCLUDING FIGURE 1-2 IS, THEN? A. WELL, WATER LEVEL -- CERTAINLY IN ANY WETLAND, HYDROPERIOD IS IMPORTANT, AND IT'S EASY TO MEASURE. SO, WE THOUGHT IT WOULD BE GOOD JUST TO KEEP A RUNNING RECORD OF WHAT THE WATER LEVELS ARE IN THE PLOTS, AND IT WILL PROVIDE SOME INFORMATION ON HYDROPERIOD IN THESE THREE KINDS OF COMMUNITIES. BUT, IT IS SECONDARY TO THE FERTILIZER ADDITIONS. Q. OKAY. IS THE INFORMATION THAT'S CONTAINED IN FIGURE 1-2 USED ANYWHERE IN THIS REPORT TO REACH DR. CRAFT VOLUME II PAGE 521 ANY CONCLUSIONS? A. NO. ALL I'M DOING IS PRESENTING IT TO SHOW THAT THE THREE SITES DO HAVE SOMEWHAT DIFFERENT HYDROPERIODS. Q. DO YOU ANTICIPATE USING THIS INFORMATION TO REACH CONCLUSIONS IN SOME FUTURE REPORT? A. TO BE HONEST WITH YOU, I DON'T THINK -- WE CAN MAYBE DRAW SOME CIRCUMSTANTIAL CONCLUSIONS FROM IT, BUT I DON'T THINK THAT YOU CAN DRAW SOME REALLY -- YOU'RE NOT GOING TO BE ABLE TO DRAW HARD AND FAST CONCLUSIONS FROM THE WATER LEVEL DATA. AGAIN, I THINK WHAT YOU NEED IS -- YOU WOULD NEED TO MANIPULATE THE WATER LEVELS IN SOME WAY, LIKE DR. RICHARDSON'S DOING IN THE HYDROLOGY STUDY. Q. OKAY. HOW IS HE MANIPULATING THE WATERS IN THAT STUDY? A. HE HAS RAISED AND LOWERED THE SOIL SURFACE, BY SHOVELING PEAT, BASICALLY. Q. DO YOU KNOW WHAT THE LEVELS ARE? A. NO, NOT OFF -- I DON'T -- NOT OFF THE TOP OF MY HEAD. AGAIN, THAT'S SOMETHING -- IT'S PROBABLY IN A CHAPTER IN HERE. BUT I'M NOT INVOLVED IN THAT, SO. DR. CRAFT VOLUME II PAGE 522 Q. ON PAGE 16, THE PARAGRAPH JUST BEFORE THE BIOMASS SAMPLING SECTION, IT INDICATES THE FERTILIZER HAS BEEN APPLIED BY HAND. A. UH-HUH (YES). Q. CAN YOU DESCRIBE TO ME, HOW -- WHAT YOU MEAN BY HAND APPLICATION? A. WELL, I HAD MY LITTLE BAG WITH FERTILIZER AND SAND IN IT, AND I'D STICK MY HAND IN IT, AND AFTER IT SITS -- IT'S MIXED IN THE LAB AND EVERYTHING, FIRST, SO WE GET IT NICE AND HOMOGENEOUS, AND WE STAND ON ONE SIDE OF THE PLOT, AND WE GO LIKE THAT (WITNESS DEMONSTRATING) AND THEN WE MOVE TO ANOTHER SIDE OF THE PLOT AND WE GO LIKE THAT, AND THEN WE GO AROUND THE THIRD SIDE AND DO THE SAME THING, AND THEN THE FOURTH SIDE. SO, THAT'S A HAND AND A BAG OF FERTILIZER, BASICALLY. Q. OKAY. SO AS FAR AS DISTRIBUTION AMONG THE PLOTS, IT'S PRETTY MUCH EYEBALLED? A. WELL, YOU KNOW THAT THE TOTAL AMOUNT GOES INTO THE PLOT, AND YOU DO THE BEST YOU CAN TO GET IT EVENLY DISTRIBUTED. Q. AND THE LAST SENTENCE IN THAT PARAGRAPH SAYS -- IT SAYS THAT, "TWO CONTROL TREATMENTS, ONE WITH FIBERGLASS SIDING AND ONE WITHOUT SIDING, WERE DR. CRAFT VOLUME II PAGE 523 ESTABLISHED FOR COMPARISON WITH THE FERTILIZER APPLICATIONS, AND TO INVESTIGATE THE EFFECTS OF THE FIBERGLASS SIDING ON BIOMASS PRODUCTION." WHAT WERE THE EFFECTS OF THE FIBERGLASS ON BIOMASS PRODUCTION? A. I'D HAVE TO GO LOOK IN THE RESULTS AND DISCUSSION. AT THE SAWGRASS SITE, WE SEEMED TO SEE AN EFFECT. AT THE MIXED SITE, WE DIDN'T SEEM TO SEE AN EFFECT. AND AT THE SLOUGH SITE, WE DIDN'T SEEM TO SEE AN EFFECT. BUT, IF WE GO, I BELIEVE, TO PAGE 19 UNDER "STANDING CROP BIOMASS," WE SAY THAT IN -- IT'S THE SECOND SENTENCE, "IN THE SAWGRASS PLOTS, ORGANIC CARBON IN ABOVEGROUND VEGETATION WERE SIGNIFICANTLY HIGHER IN THE UNENCLOSED CONTROL PLOTS AS COMPARED TO THE CONTROL PLOTS WITH SIDES, SUGGESTING THAT THE FIBERGLASS SIDING CAUSES A REDUCTION IN STANDING CROP BIOMASS AT THIS SITE." Q. SO, YOU CONCLUDED FROM THAT FINDING THAT THE FIBERGLASS CAN CAUSE A REDUCTION IN STANDING CROP BIOMASS? A. WELL, LET ME CONTINUE, BECAUSE I SAY IT SUGGESTS, AND THE REASON I'M NOT SURE THAT IT DOES, IS BECAUSE IF YOU GO TO THE BOTTOM OF PAGE 19 TO A DR. CRAFT VOLUME II PAGE 524 SENTENCE, IT SAYS, "IN CONTRAST TO THE SAWGRASS COMMUNITY, THE BIOMASS WAS HIGHER IN THE CONTROL PLOTS WITH SIDES, THAN WITHOUT SIDES." AND SO WHAT I REALLY THINK, IS THAT WHAT WE SEE AT THE SAWGRASS SITE IS MORE AN ARTIFACT OF THE DATA. IF THERE WAS A TRUE EFFECT OF SITING, I WOULD HAVE THOUGHT WE'D HAVE SEEN IT AT BOTH THE SAWGRASS AND THE MIXED SITES. BUT, EVEN IF THERE IS AN EFFECT, BECAUSE WE HAD TWO TYPES OF CONTROL PLOTS, WE CAN STILL COMPARE OUR FERTILIZER TREATMENTS WITH THE APPROPRIATE CONTROL. Q. OKAY. SO, NOTWITHSTANDING THE FINDINGS IN THE SAWGRASS PLOTS, YOU'RE OF THE OPINION THAT THE FIBERGLASS DOES NOT REALLY HAVE AN EFFECT? A. WELL, I THINK BECAUSE IT'S CONFLICTING AT THE TWO SITES, THAT -- I'M NOT SURE. I DON'T -- I REALLY DON'T THINK THERE IS AN EFFECT. BUT, AGAIN, SINCE WE SAMPLED THIS YEAR IN THESE SAME PLOTS, IT WILL BE INTERESTING TO SEE WHETHER THAT EFFECT SHOWS UP AGAIN. AND YOU HAVE TO REMEMBER, THE SAWGRASS SITE IS ALMOST PURE -- WELL, IT IS PURE SAWGRASS. THERE'S A FEW LITTLE THINGS IN THERE, BUT THE MIXED SITE IS STILL ABOUT EIGHTY PERCENT SAWGRASS, SO YOU WOULD THINK THAT YOU DR. CRAFT VOLUME II PAGE 525 WOULD SEE A REDUCTION THERE, TOO, AND WE SAW THE REVERSE THERE. SO IT WAS HIGHER IN THE PLOTS THAT HAD THE SIDES, SO. Q. WELL, YOU MENTIONED YOUR CONTROL PLOTS, THE FIGURE 1-3 REFLECTS, IN THE TOP FIGURE THERE--- A. RIGHT. Q. ---THAT'S THE SAWGRASS PLOTS. IS THAT RIGHT? A. YES. Q. OKAY. THE CONTROLS 1 AND 2 SEEM TO HAVE A SIGNIFICANT DIFFERENCE, AND I THINK YOU'VE ASTERISKED IT IN THE -- DOWN BELOW, WHICH SAYS IT "DENOTES THAT C2 (UNENCLOSED) HAS SIGNIFICANTLY MORE STANDING CROP BIOMASS THAT C1 (WITH SIDES)." A. RIGHT. AND I SAY THAT IN THE TEXT. Q. OKAY. DO YOU KNOW WHY THAT OCCURRED? A. WELL, IF IT IS -- LET'S ASSUME THAT IT IS A REAL EFFECT -- WHICH I'M NOT CONVINCED THAT IT IS, BECAUSE WE DON'T SEE THAT AT THE MIXED SITE -- I THINK WHAT WOULD CAUSE THAT IS, IS TO PUT THE SIDING INTO THE GROUND, TO PUT AT TWENTY CENTIMETERS INTO THE PEAT, WE HAD TO TAKE A SPADE AND KIND OF SHOVEL A LITTLE TRENCH SO IT WOULD PUSH DOWN, AND IT'S POSSIBLE THAT WE CUT ENOUGH DR. CRAFT VOLUME II PAGE 526 ROOTS THAT IT REDUCED THE BIOMASS OF THOSE PLOTS. Q. HAVE YOU TAKEN ANY -- TAKEN ANY ACTION TO TAKE INTO ACCOUNT THIS VARIANCE IN THE CONTROLS IN YOUR CALCULATION? A. WELL, AT THIS POINT, NO. THE ONLY THING I THINK I COULD DO WOULD BE TO SAY, OKAY, THERE IS AN EFFECT. IF I DO BELIEVE THAT THERE IS ONE -- AND, AGAIN, I'M NOT CONVINCED THAT THERE IS -- TO SAY WELL -- WELL, WE'LL JUST COMPARE THE CONTROL PLOT WITH SIDES WITH THE OTHER TREATMENTS, AND WE HAVEN'T DONE THAT YET. Q. THE CONTROL SITE WITH SIDES WITH THE TREATMENTS? A. RIGHT, WHICH ALSO HAVE SIDES. Q. ALL RIGHT. BUT IF -- IF THE FIBERGLASS SIDES ARE ACTUALLY HAVING AN EFFECT, WON'T THAT SKEW THE RESULTS OF WHATEVER YOU'RE TRYING TO ESTABLISH IS OCCURRING IN THE EVERGLADES? A. WELL, NO, I THINK IT WOULD STILL TELL US THAT WE WERE STILL LOOKING AT NUTRIENT ADDITIONS, BUT WE JUST HAVE TO COMPARE IT WITH THE APPROPRIATE CONTROL PLOT. I THINK THE INFORMATION WOULD STILL BE APPLICABLE. AGAIN, AND SINCE NOW WE'RE WORKING UP THE SECOND YEAR OF DATA, I THINK IT WOULD BE INTERESTING TO SEE WHETHER WE SEE THIS DIFFERENCE DR. CRAFT VOLUME II PAGE 527 AGAIN THIS YEAR. Q. PAGE 19, UNDER "STANDING CROP BIOMASS," HERE, THE FIRST SENTENCE THERE REFLECTS THAT "NITROGEN AND PHOSPHORUS APPLICATIONS HAD NO SIGNIFICANT EFFECT ON ABOVEGROUND STANDING CROP BIOMASS IN THE SAWGRASS OR MIXED SAWGRASS CATTAIL COMMUNITIES AFTER ONE YEAR OF FERTILIZER APPLICATIONS." NOW, I BELIEVE -- AM I CORRECT, YOU TESTIFIED YESTERDAY THAT -- THAT THE DATA FROM THE SECOND YEAR THAT'S COMING IN AT THIS POINT, WHICH YOU HAVE NOT YET ANALYZED, SEEMS TO SUGGEST THAT THERE MAY BE AN INCREASE IN BIOMASS? A. I THINK THAT THERE PROBABLY WILL BE AN INCREASE, A SIGNIFICANT INCREASE IN BIOMASS PRODUCTION, JUST LOOKING AT THE PLOTS, WHERE PHOSPHORUS IS ADDED, THE GROWTH IS LUXURIANT, VERY DENSE, VERY TALL, VERY GREEN. BUT, AGAIN, I'M NOT GOING TO STICK MY NECK OUT AND EMPHATICALLY STATE IT UNTIL I GET THE NUMBERS CRUNCHED AND LOOK STATISTICALLY AT THE DIFFERENCES. Q. HAVE YOU NOTED ANY -- WELL, AGAIN, I UNDERSTAND, I DON'T WANT TO TRY TO COMMIT YOU TO SOMETHING BEFORE YOU'VE ANALYZED THE NUMBERS, BUT YOU HAVE INDICATED THAT, JUST LOOKING AT IT, IT LOOKS LIKE DR. CRAFT VOLUME II PAGE 528 THAT'S GOING TO OCCUR. IS THAT WITH REGARD TO SAWGRASS AND THE MIXED COMMUNITIES? A. I FEEL MORE CONFIDENT AT THE SAWGRASS SITE. THE MIXED SITE, IF THERE IS A DIFFERENCE, IT'S REALLY NOT APPARENT, LOOKING AT IT VISUALLY. Q. OKAY. WHAT ABOUT THE SLOUGH COMMUNITIES? A. AGAIN, IT, TOO, AT LEAST IN TERMS OF THE MACROPHYTES, I DON'T THINK I CAN REALLY SAY ANYTHING ABOUT THAT. I DON'T FEEL CONFIDENT ABOUT IT. Q. ON THE NEXT PAGE, MIDDLE OF THE PARAGRAPH, SENTENCE READS, "NO EXPANSION OF CATTAIL WAS DETECTED AT THE SAWGRASS OR MIXED SITES AFTER THE FIRST YEAR OF FERTILIZATION." WHAT KIND OF DETECTION METHODS WERE YOU USING TO DETERMINE WHETHER THERE'S AN EXPANSION? A. ALL WE DID WAS BASICALLY JUST LOOK AT THE STANDING CROP BIOMASS OF CATTAIL IN THE CONTROL PLOTS VERSUS THE FERTILIZED PLOTS, AND THERE WAS NO SIGNIFICANT DIFFERENCE IN IT. Q. SO, YOU'D BE WEIGHING THE BIOMASS, AS OPPOSED TO A COUNTING OF INDIVIDUAL PLANTS? A. RIGHT. THAT'S TRUE. THAT'S HOW WE MEASURE. THAT'S OUR ESTIMATE OF PRODUCTIVITY. DR. CRAFT VOLUME II PAGE 529 Q. ARE YOU STILL KEEPING TRACK OF THAT? I MEAN, IS THAT SOMETHING THAT'S ONGOING? A. OH, YES. I MEAN, WE'RE -- WE'RE INTERESTED IN THIS CATTAIL ENCROACHMENT INTO THESE PLOTS, TO SEE WHETHER IT OCCURS, AND IN WHAT FERTILIZER TREATMENTS. BUT MY FEELING IS, IS A SHIFT IN PLANT SPECIES COMPOSITION IS NOT GOING TO HAPPEN IN A YEAR OR TWO. I THINK IT MAY BE IN THE THREE TO FIVE YEAR RANGE AND, WHO KNOWS, IT MAY TAKE LONGER THAN THAT. Q. THE NEXT PAGE -- EXCUSE MY PRONUNCIATION IF IT'S WRONG -- BUT WE HAD THE -- THE FIRST SENTENCE IN THAT PARAGRAPH, AFTER THE FIRST PHRASE, READS THAT, "THE ORGANIC CARBON STANDING CROP OF FLOATING UTRICULARIA-PERIPHYTON" -- IS THAT RIGHT WAY? A. UH-HUH (YES). Q. "---MAT WAS SIGNIFICANTLY AFFECTED BY THE HIGHEST PHOSPHORUS APPLICATIONS." IS THAT RELATED TO THE SLOUGH COMMUNITY? A. YES. THAT'S THE ONLY COMMUNITY THAT WE WORKED IN THAT HAD THIS -- HAD A SIGNIFICANT PERIPHYTON MAT. Q. RIGHT AFTER THAT, TWO SENTENCES DOWN, YOU TALK DR. CRAFT VOLUME II PAGE 530 ABOUT THE CONTROL PLOTS GOING FROM 92 -- WAS 92 TO 98, COMPARED TO 20 TO 21 GRAMS PER METER SQUARED IN THE HIGH PHOSPHORUS. WHAT DID YOU CONCLUDE FROM THOSE DIFFERENCES? A. THE CONCLUSION IS THAT THE HIGHEST PHOSPHORUS APPLICATIONS REDUCE THE STANDING CROP BIOMASS OF THIS UTRICULARIA-PERIPHYTON COMPLEX. Q. OKAY. DO YOU CONSIDER THE LOSS OF THE UTRICULARIA-PERIPHYTON -- I CAN'T GET THAT ALL OUT IN ONE WORD -- STANDING CROP AT THE HIGH PHOSPHORUS TREATMENTS AS A SIGNIFICANT EFFECT OF PHOSPHORUS LOADING TO THE EVERGLADES' ECOSYSTEM? A. YEAH, I THINK SO. IN FACT, IN THE SUMMARY, I THINK I SAY SOMETHING TO THAT EFFECT. IF YOU GO TO PAGE 31, I SAY THAT -- IT'S THE LAST, NEXT TO LAST SENTENCE -- "THE DECLINE IN STANDING CROP BIOMASS OF UTRICULARIA-PERIPHYTON IN THE HIGH P TREATMENT, SUGGEST THAT THIS COMPONENT OF THE SLOUGH MAY BE AN EARLY INDICATOR OF P ENRICHMENT IN THE EVERGLADES." Q. DO YOU STILL HOLD THAT CONCLUSION? A. YEAH, I THINK--- Q. WHAT DO YOU MEAN BY PHOSPHORUS ENRICHMENT IN THAT DR. CRAFT VOLUME II PAGE 531 SENTENCE? A. I MEAN, ADDITIONS OF PHOSPHORUS TO THE -- TO THE EVERGLADES. Q. AND THAT CONCLUSION'S BASED UPON THE RESULTS OF THIS STUDY? A. YES. AND THERE HAVE BEEN PREVIOUS RESEARCHERS WHO HAVE FOUND THIS SIMILAR RESPONSE, AND I THINK I'VE CITED THEM IN HERE. Q. DO YOU CONSIDER THE LOSS OF THE UTRI -- BOY, I CAN'T GET THAT WORD -- UTRICULARIA STANDING CROP BIOMASS TO BE AN ECOLOGICALLY SIGNIFICANT CHANGE IN THE MACROPHYTE SPECIES COMPOSITION? A. WELL, MY UNDERSTANDING IS -- I GUESS UTRICULARIA IS A SUBMERGED AQUATIC, AND IT IS -- IS -- I THINK IT'S A MACROPHYTE. I DON'T KNOW. IF SOMEBODY COULD TELL ME IT IS, I MIGHT BE ABLE TO ADDRESS IT MORE. CAN YOU NOD YOUR HEAD--- Q. ASSUMING--- A. ---IS IT A MACROPHYTE? Q. LET ME REPHRASE THE QUESTION THEN. ASSUMING IT'S A MACROPHYTE, WOULD YOU CONSIDER THAT SIGNIFICANT? A. YEAH, I THINK THAT IS -- THAT IS IMPORTANT. Q. DURING YOUR STUDY AND COLLECTION OF DATA, DID YOU NOTICE A LARGE INITIAL INCREASE IN THE PERIPHYTON DR. CRAFT VOLUME II PAGE 532 ON THE UTRICULARIA? A. I DID NOT NOTICE THAT, BUT DR. VYMAZAL, WHO DID WORK WITH THE PERIPHYTON, IF I RECALL -- AGAIN, HE'S THE PERIPHYTON PERSON --FOUND THAT -- HE PUT OUT ARTIFICIAL SUBSTRATES. HE PUT OUT SLIDES IN THE SLOUGH PLOTS AND FOUND THAT THE PERIPHYTON GREW -- THERE WAS A SIGNIFICANT INCREASE IN GROWTH OF PERIPHYTON ON THE SLIDES RECEIVING THE HIGHEST PHOSPHORUS APPLICATIONS. BUT, AGAIN, THAT'S ANOTHER CHAPTER IN HERE, AND HE'S THE PRIMARY AUTHOR ON IT. Q. WELL, MOVING DOWN TO THE END OF THE PAGE THERE, IT TALKS ABOUT -- IT SAYS, "THE DISAPPEARANCE OF THE UTRICULARIA-PERIPHYTON MAT DOES NOT NECESSARILY INDICATE A DECLINE IN PERIPHYTON PRODUCTIFITY -- PRODUCTIVITY." WHAT'S THE DISTINCTION THAT'S BEING MADE THERE? CAN YOU EXPLAIN THAT TO ME? A. MAYBE REPHRASE THE QUESTION. I'M NOT QUITE SURE I UNDERSTAND. Q. OKAY. WELL, IF YOU CAN EXPLAIN TO ME WHAT DISTINCTION IS BEING MADE BETWEEN THE DISAPPEARANCE OF THE MAT, AND THE DECLINE IN THE PERIPHYTON PRODUCTIVITY. DR. CRAFT VOLUME II PAGE 533 A. OKAY. AS I MENTIONED, IF YOU GO TO THE NEXT SENTENCE AFTER THAT, DR. VYMAZAL -- "IN FACT, VYMAZAL OBSERVED A SIGNIFICANT INCREASE IN BIOMASS, PERIPHYTON BIOMASS, IN THE HIGH P TREATMENT." AND IF YOU READ THE NEXT COUPLE OF SENTENCES, HE POSTULATES -- AND THIS IS SOMETHING THAT STEWARD AND ORNES POSTULATED, I THINK YEARS AGO -- THAT IT'S LIKELY THAT THE INCREASED PERIPHYTON PRODUCTIVITY, THAT HE SAW, REDUCES THE LIGHT INTENSITY, SHADING OUT FLOATING AQUATIC VEGETATION, SUCH AS UTRICULARIA. AND AS UTRICULARIA DIES BACK, THE AMOUNT OF SUBSTRATE AVAILABLE FOR PERIPHYTON TO ATTACH TO, DECREASES AND RESULTING IN A DECLINE IN THE STANDING CROP BIOMASS OF THE COMBINED COMPONENT. Q. ARE THOSE CONCLUSIONS YOU HAVE REACHED, OR THOSE ARE CONCLUSIONS OF VYMAZAL THAT YOU'RE JUST REPEATING IN HERE? A. WELL, THESE ARE CONCLUSIONS THAT REALLY, I THINK STEWARD AND ORNES FIRST POSTULATED. IF YOU GO BACK TO PAGE 22, AT THE BOTTOM, I CITE THEM 1975a, AND WE OBSERVED THIS SAME SORT OF PHENOMENA, AND IT SOUNDS LIKE A PLAUSIBLE EXPLANATION TO ME. IT MAKES SENSE. DR. CRAFT VOLUME II PAGE 534 Q. SO, YOU HAVEN'T MADE AN INDEPENDENT DETERMINATION THAT -- THAT, AS A RESULT OF YOUR FERTILIZING STUDY, THAT THIS HAS OCCURRED, SO AS TO SHADE OUT THE--- A. WELL, WE SEE THE SAME PHENOMENA, AND I FALL BACK ON THEIR THEORY AS TO WHY IT OCCURS. I THINK THAT MAKES SENSE. THAT MAY NOT BE THE TRUE WAY THAT IT HAPPENS, BUT I THINK THAT'S THE BEST EXPLANATION AT THIS TIME. Q. WERE DR. VYMAZAL'S -- OR DR. VYMAZAL'S STUDY, WHICH IS IN CHAPTER TWO OF THIS REPORT, WAS THAT BASED UPON THE DATA COLLECTED FROM THIS SAME SLOUGH? A. YEAH. HE PUT HIS SUBSTRATES IN MY -- IN THESE SLOUGH PLOTS, YES. I MEAN, THIS IS THE SAME -- THAT'S THE NICE THING ABOUT THIS STUDY, YOU CAN ACTUALLY DO SEVERAL DIFFERENT THINGS IN IT, AND GET SOME USEFUL INFORMATION OUT OF IT. (THEREUPON, MR. NETTLETON AND MR. GRIMSHAW CONFER.) Q. (BY MR. NETTLETON) DID YOU OR DR. VYMAZAL TAKE ANY LIGHT OR LIGHT LEVEL READINGS? A. NO, HUH-UH (NO). THAT WOULDN'T -- THAT WOULD PROBABLY BE A GOOD IDEA, IF YOU COULD PUT IT UNDER DR. CRAFT VOLUME II PAGE 535 THE WATER AND MEASURE SOMETHING LIKE THAT. Q. BUT THAT WAS NOT DONE AS PART OF THIS STUDY? A. NO, NO. MR. NETTLETON: I'M GOING TO TRY TO MOVE LONG. WITNESS: OKAY. WELL, YOU CAN ALWAYS COME BACK TO IT. Q. (BY MR. NETTLETON) AND YOU CONCLUDE ON PAGE 24 THAT, "PHOSPHORUS ADDITIONS RESULTED IN INCREASED PHOSPHORUS UPTAKE BY THE EMERGENT MACROPHYTES." IS THAT RIGHT? A. YES. Q. THAT'S ONE OF THE TWO CONCLUSIONS THAT WE WERE DISCUSSING YESTERDAY, THAT RESULTED FROM THIS STUDY? A. UH-HUH (YES), ONE OF THE TWO MAJOR CONCLUSIONS. Q. AND THAT WAS WITH REGARD TO BOTH SAWGRASS AND CATTAILS? A. YES. Q. AND YOU ALSO FOUND OUT WITH REGARD TO THE UTRICULARIA -- BOY, I DIDN'T SAY THAT RIGHT --- PERIPHYTON. DR. RICHARDSON: UTRICULARIA. MR. NETTLETON: I'LL NEVER GET IT DR. CRAFT VOLUME II PAGE 536 RIGHT. MR. GREEN: UTRICULARIA. DR. RICHARDSON: AND THE OTHER ONE IS VYMAZAL. MR. NETTLETON: VYMAZAL? DR. RICHARDSON: VYMAZAL. MR. NETTLETON: I'M SORRY. WITNESS: YOU CAN CALL HIM JAN. Q. (BY MR. NETTLETON) YOU MADE THE SAME CONCLUSION WITH REGARD TO THE PERIPHYTON, RIGHT? A. EXCUSE ME? Q. THE PHOSPHORUS UPTAKE? A. WELL, YEAH, BUT I DIDN'T REALLY SEPARATE OUT THE PERIPHYTON FROM THE UTRICULARIA. I TREATED THEM AS SORT OF A COMPONENT, BECAUSE IT'S SO DIFFICULT TO SEPARATE THEM. BUT THAT COMPONENT, THERE WAS AN INCREASE IN PHOSPHORUS UPTAKE BY THAT UTRICULARIA-PERIPHYTON COMPLEX, YES. Q. ALL RIGHT. SO, THOSE WERE ANALYZED TOGETHER--- A. RIGHT. Q. ---TO DETERMINE TOTAL PHOSPHORUS? A. YES. Q. DO YOU BELIEVE THAT THE ADDING OF FERTILIZER AND INCREASED BIOMASS OF MACROPHYTES REDUCES THE DR. CRAFT VOLUME II PAGE 537 AMOUNT OF LIGHT REACHING THE SOIL SURFACE? A. OKAY. LET ME MAKE SURE I UNDERSTAND THAT. YOU'RE ASKING ME IF INCREASED -- BY ADDING PHOSPHORUS, DO WE INCREASE BIOMASS, THEREBY REDUCING LIGHT REACHING THE SURFACE? Q. RIGHT. A. YEAH, I THINK IF YOU GET A BIG ENOUGH INCREASE IN BIOMASS, THAT CERTAINLY HAPPENS. Q. OKAY. NOW, YOU DID NOT FIND THE SAME EFFECT WITH REGARD TO PHOSPHORUS UPTAKE -- AND I'M GOING TO MESS UP ANOTHER PRONUNCIATION HERE, BUT THE--- A. ELEOCHARIS. Q. ---THAT'S THE ONE--- A. OKAY. Q. ---IN THE SLOUGH COMMUNITY, IS THAT RIGHT? A. THAT'S RIGHT. Q. OKAY. NOW, THAT PARTICULAR, IS THAT A SPECIES? AM I USING THE RIGHT TERM? A. IT'S A GENUS. Q. A GENUS? A. YEAH. Q. THAT'S INDICATED AS THE DOMINANT MACROPHYTE IN THE SLOUGH COMMUNITY? DR. CRAFT VOLUME II PAGE 538 A. RIGHT. Q. NOW, IF MY MEMORY IS CORRECT, I SAW SOMEWHERE IN THIS REPORT THAT -- THAT IT WAS FIVE PERCENT OF THE COMMUNITY. DOES THAT--- A. NO, IT HAD TO HAVE BEEN MORE THAN THAT. Q. IT WAS MORE THAN THAT? A. YEAH, IT HAD TO HAVE BEEN. LET'S BACK UP. WELL, ANYWAY -- I DON'T REALLY ADDRESS HOW MUCH IT WAS. AT LEAST, I DON'T SEE IT RIGHT OFF THE BAT. BUT RIGHT, IF YOU LOOK AT FIGURE 1-4 ON PAGE 23, YOU SEE ELEOCHARIS STANDING CROP BIOMASS VERSUS ALL THE OTHER MACROPHYTES COMBINED, AND YOU CAN SEE THAT IT'S -- IN ALMOST ALL PLOTS, IT'S HIGHER. AND THAT "OTHER" INCLUDES ABOUT FIVE OR SIX DIFFERENT SPECIES. Q. OKAY. DID YOU MEASURE THE PHOSPHORUS IN ANY OF THE OTHER SPECIES OR GENUS? A. YEAH, WE MEASURED IT IN PANICUM, BECAUSE IT WAS PRETTY ABUNDANT, BUT THE PROBLEM WITH THE OTHER SPECIES WAS, THEY WERE NOT FOUND IN ALL PLOTS, AND SO WE COULDN'T DO A STATISTICAL COMPARISON. THEY WERE SCATTERED. YOU WOULD FIND NYMPHAEA IN SOME, BUT NOT IN ALL. Q. SO, WHEN YOU WERE DOING THIS -- THE TESTING FOR DR. CRAFT VOLUME II PAGE 539 THE PURPOSES OF THIS STUDY, YOU WERE ATTEMPTING TO JUST COMPARE THE DIFFERENT SPECIES THAT APPEARED IN EACH COMMUNITY--- A. RIGHT. Q. ---AS OPPOSED TO THE TOTAL? A. RIGHT. I MEAN, WE LOOKED AT THE TOTAL, BUT IT SEEMED TO MAKE MORE SENSE TO BREAK IT OUT BY SPECIES, AND THEN GROUP THESE ONES AS OTHER. Q. DID YOU REACH ANY CONCLUSION AS TO WHY THE PHOSPHORUS UPTAKE DID NOT OCCUR IN THE SLOUGH COMMUNITY MACROPHYTE THAT WAS ANALYZED? A. I DIDN'T EXPLICITLY STATE IT IN HERE, BUT WHAT I THINK IS HAPPENING IS, AT THE SLOUGH -- THERE'S ALWAYS SURFACE WATER PRESENT, AND I THINK REALLY, MOST OF THE PHOSPHORUS IS TAKEN UP IN THE WATER COLUMN BY THE PERIPHYTON AND THE FLOATING AQUATICS. YOU HAVE TO REMEMBER, THESE MACROPHYTES, LIKE ELEOCHARIS, ARE ROOTED DOWN IN THE SOIL, AND I THINK VERY LITTLE PHOSPHORUS MADE IT DOWN INTO THE SUBSTRATE, AT LEAST IN THE FIRST YEAR. Q. IS THAT PRETTY MUCH WHAT YOU SAY ON PAGE 27, RIGHT AFTER THE--- A. THAT MAY BE. YEAH, THAT'S EXACTLY WHAT I SAY. DR. CRAFT VOLUME II PAGE 540 Q. WHAT IS THAT BASED ON, THOUGH? HOW DO YOU REACH THAT CONCLUSION, THAT IT'S BEING ABSORBED BY THE--- A. IT'S JUST -- JUST BY SEEING THE HIGHER CONCENTRATIONS IN THE UTRICULARIA-PERIPHYTON MAT. I MEAN, IT'S MORE SPECULATION, REALLY, THAN ANYTHING ELSE. Q. ON PAGE 29, THE END OF THAT PARAGRAPH, BEFORE "NITROGEN" STARTS, THE LAST TWO SENTENCES READ, "APPARENTLY, CATTAIL IS AN OPPORTUNISTIC SPECIES THAT TAKES ADVANTAGE OF INCREASED NUTRIENT SUPPLY BY ASSIMILATING LARGE RESERVES OF CARBON AND NUTRIENTS, ESPECIALLY PHOSPHORUS," CITING TO DAVIS, '89. THE NEXT SENTENCE IS "IN CONTRAST, SAWGRASS, WHICH IS SLOWER TO RESPOND TO INCREASED NUTRIENT SUPPLY THAN CATTAIL, IS BETTER ADAPTED TO A LOW NUTRIENT ENVIRONMENT," CITING DAVIS '89 AND '91. DO YOU AGREE WITH THOSE STATEMENTS? A. YEAH, I THINK SO. THAT'S WHY -- AND WE SEE IN OUR DATA THAT THE PHOSPHORUS CONTENT IN CATTAIL IS -- IS CONSISTENTLY HIGHER THAN THE PHOSPHORUS CONTENT IN SAWGRASS, REGARDLESS OF THE TREATMENT. IF YOU LOOK ON PAGE 26, TABLE 1-3, YOU SEE SAWGRASS IN THE CONTROL PLOTS THAT RECEIVE NO PHOSPHORUS, DR. CRAFT VOLUME II PAGE 541 ABOUT 250 MICROGRAMS PER GRAM, AND CATTAIL IN THE CONTROL PLOTS, THAT ALSO DON'T RECEIVE PHOSPHORUS, ARE 450 TO 700 MICROGRAMS PER GRAM. AND, AGAIN, YOU SEE THAT SAME TREND WHEN YOU ADD PHOSPHORUS FERTILIZER. AGAIN, CATTAIL SEEMS TO HAVE HIGHER CONCENTRATIONS. Q. ARE YOU AWARE OF ANY DATA THAT EXISTS THAT MIGHT BE CONTRARY TO THAT CONCLUSION? A. I'M NOT AWARE OF ANY. Q. ON -- I'M FINISHED WITH THAT NOW. ON CRAFT EXHIBIT NUMBER TWENTY-ONE--- MR. BURGESS: WERE THESE ALREADY REFERRED TO, OR NOT? MR. NETTLETON: THESE WERE PASSED OUT WITH SUZAN'S COPIES THIS MORNING, I BELIEVE. WITNESS: ALL RIGHT. Q. ---MY QUESTION IS REALLY FAIRLY SIMPLE, AND IT DOESN'T SPECIFICALLY DEAL WITH THE EXHIBIT, PER SE. IT'S JUST -- IT'S THE ONLY PLACE I'VE SEEN THIS FIGURE, WHICH REFLECTS KIND OF A LAYOUT OF THE PLOT, AND THAT'S FROM THE FERTILIZER STUDY? A. RIGHT. Q. AND I'M REFERRING SPECIFICALLY TO FIGURE TWO, DR. CRAFT VOLUME II PAGE 542 HERE. A. WE ARE TALKING ABOUT EXHIBIT TWENTY-ONE? Q. RIGHT. A. OKAY. Q. LET ME JUST ASK YOU THE QUESTION -- AND YOU MAY NOT EVEN NEED TO REFER IT -- AND THAT IS, DID YOU COLLECT ANY PORE WATER AND STAGED DATA IN THE FIBERGLASS ENCLOSURES? A. OH, YES. WE HAVE BEEN COLLECTING THAT. Q. HAS THAT DATA BEEN PUT TOGETHER AT THIS POINT? A. I THINK WE -- WE SHOWED SOME OF IT IN LAST YEAR'S ANNUAL REPORT. WHAT I HAVE NOW IS TWO YEARS OF THAT DATA, AND I'M TRYING TO GET IT ALL ON THE COMPUTER AND CRUNCH IT AS ONE BIG DATA SET. IN NEXT YEAR'S ANNUAL REPORT, YOU WILL SEE A PRETTY IN-DEPTH CHAPTER ON THE TWO YEARS OF DATA FROM THE FERTILIZER STUDY, INCLUDING PORE WATER AND SURFACE WATER CHEMISTRY AND WATER LEVELS. Q. OKAY. WHAT ARE YOU PLANNING TO USE THE DATA FROM THE PORE WATER TO ESTABLISH? A. JUST TO DETERMINE WHETHER WE ARE SEEING AN ENRICHMENT OF PORE WATERS IN RESPONSE TO FERTILIZER ADDITIONS. Q. DO YOU KNOW WHO ELSE IS INVOLVED, BESIDES DR. DR. CRAFT VOLUME II PAGE 543 RICHARDSON, IN THE HYDROPERIOD -- HYDROLOGICAL STUDY THAT'S GOING ON IN 2B? A. HE'S DEFINITELY THE LEAD PERSON. I BELIEVE JOHN ZAHINA IS INVOLVED WITH HIM, IN TERMS OF THE DATA COLLECTION; AND BOB JOHNSON PROBABLY IS INVOLVED ALSO, TO SOME EXTENT, IN THE DATA COLLECTION. Q. I APOLOGIZE, BUT I NEED TO GO BACK TO ONE THING IN YOUR FERTILIZER STUDY. IT WAS ON PAGE 17 OF CHAPTER ONE, AND IT'S IN YOUR TABLE -- TABLE 1-1, REFERRING TO THE LEVEL OF MEDIUM PHOSPHORUS LOADING. IT INDICATES 2.4, AND I BELIEVE YOU TOLD US YESTERDAY IT WAS 1.2. A. I'LL HAVE TO GO CHECK AND SEE. I THINK -- FOR SOME REASON, I THINK IT'S 1.2, BUT I WOULD HAVE TO GO BACK AND LOOK AT THAT. LET'S SEE IF I -- IF IN THE METHODS I LIST WHAT THE -- THE RATES ARE. I WOULD HAVE TO GO BACK AND SEE. BUT, FOR SOME REASON, I DON'T THINK THAT 2.4 IS RIGHT. I THINK IT'S 1.2. Q. I MEAN, COULD THAT HAVE AN EFFECT ON THE STATISTICAL ANALYSIS THAT YOU PERFORMED TO--- A. NO, IT WOULDN'T AFFECT THE OUTCOME, BUT IT WOULD AFFECT -- WELL, FOR ONE THING, WE DIDN'T -- DR. CRAFT VOLUME II PAGE 544 GENERALLY, WE DIDN'T SEE ANY RESPONSE TO MEDIUM P APPLICATIONS, ALTHOUGH IT MAY BE IN ONE OF THE PHOSPHORUS UPTAKES. NO, REALLY, IF YOU LOOK AT THE DATA, AT THIS POINT, ONLY THE HIGHEST RATE SHOWED ANY KIND OF SIGNIFICANT DIFFERENCE. BUT IT IS -- IT'S IMPORTANT TO GO BACK. NONE OF THE MEDIUM MP IN UTRICULARIA-PERIPHYTON MAT SHOWED HIGHER PHOSPHORUS CONTENT. BUT, AGAIN, I NEED TO CHECK THAT. I RECALL THAT -- I THINK IT'S 1.2. Q. AS A SCIENTIST, IN GENERAL, ARE YOU CONCERNED ABOUT PRESERVING THE ENVIRONMENT IN THE EVERGLADES? A. YEAH, I THINK I CONSIDER MYSELF AN ENVIRONMENTALLY CONSCIOUS PERSON, I THINK. Q. AND DO YOU CONSIDER THE NUTRIENT ENRICHMENT THAT'S PRESENTLY OCCURRING TO BE CAUSING HARM TO THE EVERGLADES? MR. BURGESS: OBJECTION TO THE FORM OF THE QUESTION. MR. NETTLETON: YOU CAN ANSWER. WITNESS: WELL, WHAT WAS THE QUESTION, AGAIN? MR. McCAUGHAN: REPEAT THE QUESTION, DR. CRAFT VOLUME II PAGE 545 PLEASE. Q. (BY MR. NETTLETON) DO YOU CONSIDER THE NUTRIENT ENRICHMENT THAT'S OCCURRING PRESENTLY IN THE EVERGLADES PROTECTION AREA TO BE HARMFUL TO THE SYSTEM? A. I'M NOT SURE IF I -- IF HARMFUL, IF I WOULD AGREE THAT IT'S HARMFUL. I WOULD AGREE THAT PARTS OF THE EVERGLADES ARE CHANGING IN RESPONSE TO NUTRIENT ADDITIONS. Q. AS A SCIENTIST, DO YOU CONSIDER SUCH CHANGES TO BE ADVERSE? A. I DON'T WANT TO STEP OUT ON A LIMB AND ANSWER THAT QUESTION. IT DEPENDS ON WHAT PEOPLE WANT THE EVERGLADES TO BE, I THINK. IF YOU WANT A SAWGRASS MARSH, I THINK IT PROBABLY -- THERE ARE AREAS THAT ENRICHMENT IS ADVERSE. Q. YOU -- WHEN MS. PONZOLI THIS MORNING WAS ASKING ABOUT WHETHER YOU WERE RECEIVING ANY COMPENSATION, YOU INDICATED YOU HAD SOME MIXED FEELINGS ABOUT THAT. COULD YOU TELL ME WHAT YOUR MIXED FEELINGS ABOUT THAT ARE? A. WELL, I JUST MEANT THAT IF I'M GOING TO THROUGH THIS DEPOSITION, IT MIGHT BE NICE TO BE COMPENSATED; BUT ON THE FLIP SIDE OF THE COIN, IT DR. CRAFT VOLUME II PAGE 546 MIGHT BE BETTER JUST TO NOT BE COMPENSATED AND GET AS FAR AWAY FROM THIS TYPE ENVIRONMENT AS IS POSSIBLE. SO, THAT'S WHAT I MEAN BY MIXED FEELINGS. Q. WELL, DO YOU FEEL THAT ANY OF THE RESEARCH THAT YOU HAVE BEEN DOING HAS AT ALL BEEN COMPROMISED OR INFLUENCED BY THE FACT THAT A PARTICULAR INDUSTRY MAY BE FUNDING IT? A. NOT AT ALL. I DON'T HAVE THAT -- THAT CONCERN WITH IT. AND I'LL SAY NOW, WE HAVE NOT -- I HAVE NOT BEEN COERCED INTO TRYING TO GENERATE ANY KIND OF RESULTS OR ANYTHING LIKE THAT. I MEAN, YOU LOOK AT THE DATA. WE FIND THINGS THAT I THINK MOST PEOPLE WOULD AGREE THAT THE AGRICULTURAL INTERESTS WOULD PROBABLY NOT BE HAPPY WITH SOME OF OUR FINDINGS. Q. MY FINAL QUESTION CONCERNS EXHIBIT NUMBER THIRTY-FIVE, WHICH IS -- I'M NOT SURE THAT THIS HAS BEEN DISCUSSED IN THE TESTIMONY, OTHER THAN BY REFERENCE BEFORE. IT'S A REPORT ENTITLED "MERCURY CONTAMINATION IN THE EVERGLADES ECOSYSTEM." IT'S A -- IT INDICATES IT'S A DRAFT PREPARED FOR U.S. EPA REGION FOUR. ON PAGE TEN OF THIS EXHIBIT, THE FOLLOWING -- I'LL JUST QUOTE IT -- STATES THAT THE DR. CRAFT VOLUME II PAGE 547 "ABOVE BRIEF EXPLANATION" -- REFERRING TO WHAT IS ABOVE, OBVIOUSLY -- "LEADS TO THE FOLLOWING HYPOTHESIS. THE EUTROPHICATION OF THE EVERGLADES IS RESULTING IN THE CONDITIONS FOR THE METHYLATION OF MERCURY." DO YOU AGREE THAT THAT'S A POSSIBILITY? A. CAN I -- CAN I LOOK AT THE DOCUMENT? Q. SURE. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. OKAY. AND THE QUESTION IS AGAIN? Q. DO YOU AGREE THAT THAT'S A POSSIBILITY, THAT HYPOTHESIS? A. JUST READ THAT LAST SENTENCE BACK TO ME, JUST THE BOTTOM. I WANTED TO READ THE PRECEDING PARAGRAPH. Q. OKAY. "THE EUTROPHICATION OF THE EVERGLADES IS RESULTING IN THE CONDITIONS FOR METHYLATION OF MERCURY." A. AGAIN, I DON'T KNOW A LOT ABOUT MERCURY, BUT I DON'T -- I DON'T THINK I AGREE WITH THAT RIGHT NOW, BASED ON MY LIMITED KNOWLEDGE, AND IT'S BASED MORE ON THE PRECEDING PARAGRAPH. Q. WHAT DO YOU MEAN, BASED UPON, YOUR--- A. WELL, THE HYPOTHESIS SUGGESTS THAT PHOSPHORUS DR. CRAFT VOLUME II PAGE 548 ADDITIONS ARE INCREASING, CAUSING MORE REDUCED ANAEROBIC CONDITIONS. AND AS YOU WILL GET A CRACK AT -- I THINK TOMORROW AND THE NEXT DAY -- DR. QUALLS HAS SOME REDOX POTENTIAL DATA, THAT INDICATES THAT -- THAT SUGGESTS THAT THERE IS REALLY NO DIFFERENCE IN REDOX POTENTIAL BETWEEN ENRICHED AND UNENRICHED AREAS OF 2A. AND I THINK BASED ON THAT DATA, I'M NOT -- I DON'T THINK I AGREE WITH THAT. I WOULD LIKE TO SEE DATA ON REDOX POTENTIALS, GOOD REDOX DATA, IN ENRICHED AND UNENRICHED AREAS, AND THEN TRY TO DETERMINE WHETHER THE HYPOTHESIS IS PLAUSIBLE. Q. OKAY. I BELIEVE YOU TESTIFIED YESTERDAY THAT YOU HAD RECEIVED A COPY OF THIS REPORT FROM DR. RICHARDSON AT SOME POINT? A. RIGHT. I THINK HE PASSED ON A COPY TO ME, IN FACT--- Q. OKAY. A. ---BECAUSE IT HAD MY NAME ON IT, OR SOMETHING LIKE THAT. Q. DO YOU KNOW WHY YOU WERE GIVEN THIS REPORT? A. AGAIN, HE JUST PASSES INFORMATION ON TO ME THAT I THINK MIGHT BE OF SOME INTEREST. THERE'S A LOT OF RESEARCH GOING ON IN THE EVERGLADES NOW, AND IT'S DR. CRAFT VOLUME II PAGE 549 WORTHWHILE FOR ME TO SEE WHAT EVERYBODY ELSE IS DOING, AND JUST TO SEE WHAT KIND OF RESEARCH IS BEING PERFORMED. Q. HAVE YOU BEEN ASKED TO GET INVOLVED IN ANY--- A. NO, NO--- Q. LET ME FINISH MY QUESTION. A. SORRY. Q. ---ANY RESEARCH CONCERNING MERCURY? A. NO. Q. WERE YOU ASKED FOR ANY COMMENTS CONCERNING THIS REPORT? A. NO. Q. HAVE YOU GIVEN ANY COMMENTS? A. I THINK WE MAY HAVE TALKED ABOUT THE HYPOTHESIS, JUST, YOU KNOW, IN PASSING. Q. WHEN DID THAT OCCUR? A. THIS WAS PROBABLY LAST SUMMER. I MEAN, IT'S BEEN THREE OR FOUR MONTHS OR MORE. I THINK I PROBABLY HAD THAT THING FOR, I DON'T KNOW, SINCE SUMMERTIME. Q. WHAT -- WHAT WAS THE NATURE OF YOUR DISCUSSIONS, CONCERNING THE HYPOTHESIS? A. JUST BASED ON DR. QUALLS' DATA. YOU KNOW, THE DATA TO THIS POINT DOESN'T SHOW ANY DIFFERENCES DR. CRAFT VOLUME II PAGE 550 IN REDOX POTENTIAL BETWEEN ENRICHED AND UNENRICHED AREAS. AND THAT HYPOTHESIS IS BASED ON THE IDEA THAT REDOX IS LOWER IN THESE ENRICHED AREAS. Q. IS ANYONE AT THE DUKE WETLAND CENTER, TO YOUR KNOWLEDGE, DOING RESEARCH IN THIS AREA? A. NO, NOT AT THIS TIME. Q. DO YOU KNOW IF DR. PATRICK MIGHT BE DOING SOME RESEARCH IN THIS AREA? A. I DON'T KNOW. I HAVEN'T HEARD. Q. OTHER THAN THIS PARTICULAR REPORT HERE, ARE YOU AWARE OF ANYONE ELSE THAT'S CURRENTLY DOING RESEARCH ON MERCURY IN THE EVERGLADES? A. NO. IN FACT, I'M NOT AWARE OF ANYBODY DOING RESEARCH YET, ALTHOUGH, YOU KNOW, IT SOUNDS LIKE THAT'S THE NEXT BIG ENVIRONMENTAL ISSUE, SO--- MR. NETTLETON: NO MORE QUESTIONS. EXAMINATION BY MR. BURGESS: Q. DR. CRAFT, THIS MORNING YOU SAID THAT WITH RESPECT TO, I BELIEVE IT WAS THE FERTILIZER -- WITH RESPECT TO THE FERTILIZER STUDY, THAT ALTHOUGH YOU MAY NOT HAVE HAD ANY SPECIFIC HYPOTHESIS, YOU HAD STUDY OBJECTIVES. COULD YOU TELL US WHAT THOSE OBJECTIVES WERE? DR. CRAFT VOLUME II PAGE 551 A. YES. I'D LIKE TO MAYBE BORROW RALPH'S ANNUAL REPORT, SINCE, AGAIN, I CAN'T REMEMBER EVERYTHING THAT I WRITE. AFTER A WHILE IT GOES IN ONE EAR AND COMES OUT THE OTHER. AND WE DIDN'T HAVE ANY EXPLICIT HYPOTHESES, BUT WITHIN THE OBJECTIVES, I THINK WE HAD SEVERAL IMPLICIT HYPOTHESES, AND I JUST WANT TO GO OVER SOME OF THEM. MS. PONZOLI: ARE WE ON THE '91 ANNUAL REPORT? WITNESS: I'LL LOOK AND SEE WHICH IS THE RIGHT -- THE RIGHT ONE. THIS IS THE '92 ANNUAL REPORT. BUT IF YOU LOOK ON PAGE 12, YOU CAN SEE -- ACTUALLY, LET ME FIND THE ONE. I THINK MAYBE IT IS THE '91. DOES ANYBODY HAVE A COPY OF THE '91 THAT I COULD LOOK AT? I DON'T THINK THIS WILL TAKE LONG, BUT IT WOULD BE BETTER FOR ME TO SAY IT OUT OF HERE THAN TO TRY TO REMEMBER IT, SINCE I DIDN'T DO A GOOD JOB OF THAT BEFORE. MS. PONZOLI: JUST DON'T READ MY NOTES. WITNESS: I WON'T LIKE WHAT I SEE, PROBABLY. MR. McCAUGHAN: DID YOU FIND DR. CRAFT VOLUME II PAGE 552 SATURATION? WITNESS: I'M GOING TO LOOK THAT UP IN THE DICTIONARY. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER.) (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. IN THE '91 ANNUAL REPORT, ON PAGE 182, I DO LIST AN OBJECTIVE SECTION, TALKS ABOUT EVIDENCE TO SUGGEST PHOSPHORUS LOADING AND INCREASED HYDROPERIOD CAUSE CHANGES IN PLANT COMMUNITIES, AND SO ON AND SO FORTH. AND THEN DOWN HERE AFTER SEVERAL SENTENCES, I SAY, "HOWEVER, THE EFFECTS OF N ON NATIVE EVERGLADES VEGETATION IS UNCLEAR." AND I TALK ABOUT THE REASONS FOR THAT, SINCE ALL THE PREVIOUS STUDIES HAVE USED NITRATE, AND NOBODY'S REALLY LOOKED AT AMMONIUM, WHICH IS USUALLY THE DOMINANT FORM OF NITROGEN IN WETLAND SYSTEMS. AND IF YOU GO TO THE PAGE -- TOP OF PAGE 183, OUR OBJECTIVES WERE TO DETERMINE IF, AND AT WHAT LEVELS N AND P, AND THE COMBINATION OF N AND P ARE RESPONSIBLE FOR INVASION OF CATTAIL INTO SAWGRASS AND SLOUGH COMMUNITIES. SO, I MEAN, WE DR. CRAFT VOLUME II PAGE 553 HAVE OBJECTIVES, AND I THINK IMPLICIT IN THEM ARE THE NULL HYPOTHESIS, THAT FERTILIZER ADDITIONS HAVE NO EFFECT, AND THE ALTERNATIVE HYPOTHESIS THAT FERTILIZER ADDITIONS HAVE AN EFFECT. AND, SPECIFICALLY, WE'RE INTERESTED IN PHOSPHORUS BECAUSE OF THE -- WELL, THERE'S JUST A LOT OF INTEREST IN PHOSPHORUS. WE'RE ALSO INTERESTED IN NITROGEN, AND WE'RE INTERESTED IN THE RESPONSE OF THEM IN COMBINATION. AND SOME PEOPLE HAVE SUGGESTED THAT PERHAPS IF YOU ADD ENOUGH P TO THE SYSTEM, NITROGEN WILL BE BECOME LIMITING, BUT -- SO I THINK OUR OBJECTIVES ARE TO LOOK AT THE EFFECTS OF N BY ITSELF, P BY ITSELF, AND N AND P TOGETHER ON A -- SOME OF THESE COMMUNITY ATTRIBUTES, INCLUDING PRODUCTIVITY, NUTRIENT UPTAKE, AND CHANGES IN PLANT SPECIES COMPOSITION, SPECIFICALLY THE ENCOURAGEMENT OF CATTAIL INTO NATIVE EVERGLADE PLANT COMMUNITIES. Q. OKAY. AND, DR. CRAFT, WITH RESPECT TO ALL THE WORK THAT YOU HAVE DONE IN THE EVERGLADES AND THE WORK THAT YOU HAVE TESTIFIED ABOUT FOR THE LAST TWO DAYS, HAS ALL OF THAT WORK BEEN DONE BY YOURSELF AS AN EMPLOYEE OF THE DUKE WETLAND CENTER? DR. CRAFT VOLUME II PAGE 554 A. ONE HUNDRED PERCENT OF IT HAS BEEN DONE. Q. OKAY. AND HAS IT BEEN DONE UNDER THE DIRECTION OF DR. CURTIS RICHARDSON? A. YES. Q. OKAY. IN THE NORMAL COURSE OF YOUR WORK, DO YOU INTERACT WITH DR. RICHARDSON ON THE PROGRESS OF YOUR STUDIES? A. WELL, CERTAINLY, HE'S MY -- HE'S MY BOSS, SO. Q. OKAY. AND HE REVIEWS DRAFTS OF YOUR PAPERS? A. OH, YES. Q. HE REVIEWS YOUR DATA? A. YES. MR. BURGESS: OKAY, I DON'T HAVE ANYTHING ELSE. THANK YOU. MR. NETTLETON: I'D LIKE TO ASK A QUESTION, IF I COULD, JUST TO FOLLOW UP. FURTHER EXAMINATION BY MR. NETTLETON: Q. DID YOU DISCUSS YOUR TESTIMONY YOU JUST GAVE CONCERNING YOUR -- THE HYPOTHESIS OF THE FERTILIZER STUDY WITH MR. BURGESS WITHIN THE LAST DAY? A. YEAH. BUT I THOUGHT ABOUT IT AFTER I LEFT YESTERDAY, AND REALIZED THAT I DIDN'T DO A GOOD JOB OF ADDRESSING THE QUESTION, AND SO I TALKED DR. CRAFT VOLUME II PAGE 555 TO CURTIS. I WANTED TO BE ABLE TO COME BACK TODAY, AND MAKE IT CLEAR THAT THERE WERE HYPOTHESES. I REMEMBER YESTERDAY, I WAS KIND OF ON THE EDGE THERE AT 4:30 IN THE AFTERNOON. Q. DID YOU DISCUSS ANY OTHER AREAS OF YOUR TESTIMONY? A. NO, I DON'T THINK SO. MR. NETTLETON: NO FURTHER QUESTIONS. FURTHER EXAMINATION BY MR. BURGESS: Q. I WOULD LIKE TO CLEAR UP THE RECORD, WITH RESPECT TO YOUR TESTIMONY REGARDING THE HYPOTHESIS, WHEN WAS THE FIRST TIME THAT YOU TALKED TO ME ABOUT THAT? A. I THINK IT WAS TODAY, I THOUGHT. Q. AND WAS IT PURSUANT TO YOU ASKING ME TO LEAVE THE ROOM THIS MORNING, BECAUSE YOU HAD SOMETHING--- A. YEAH, THAT WAS. Q. WHAT DID YOU ASK ME WHETHER YOU SHOULD DO? A. BASICALLY, I ASKED MR. BURGESS WHETHER I SHOULD GO AHEAD AND SAY FOR THE RECORD, AT NINE O'CLOCK THIS MORNING, THAT I WANTED TO SET THE RECORD STRAIGHT, OR WHETHER IT WOULD BE ADDRESSED LATER ON IN THE DAY. AND HE SAID THAT, WELL, YOU KNOW, WE CAN ADDRESS THAT AT THE END OF THE DAY AND CLARIFY IT. DR. CRAFT VOLUME II PAGE 556 MR. BURGESS: THANK YOU. A. I WANT -- WELL, LET ME FINISH UP, TO SAY, YESTERDAY, WHEN THE QUESTION ABOUT HYPOTHESIS CAME UP, I WAS THINKING IN TERMS OF AN EXPLICIT HYPOTHESIS, MUCH LIKE DR. RADER PUTS IN HIS PAPERS AT HYPOTHESIS ONE. AND I DON'T GENERALLY DO THAT. I SORT OF SET THE STAGE AND LAY OUT SOME OBJECTIVES IN MY HYPOTHESES. I'M MORE IMPLICIT IN THE OBJECTIVES SECTION. MR. BURGESS: THANK YOU. ------------------------------------------------------- (THEREUPON, THE DEPOSITION WAS CONCLUDED AT 4:20 P.M.) ------------------------------------------------------- DR. CRAFT VOLUME II PAGE 557 NORTH CAROLINA WAKE COUNTY I, CHRISTOPHER B. CRAFT, HAVE READ THE FOREGOING TRANSCRIPT OF MY DEPOSITION AND DO HEREBY CERTIFY THAT THE PRECEDING PAGES, 109-556, VOLUME II, CONSTITUTE A TRUE AND ACCURATE TRANSCRIPTION OF MY TESTIMONY. ______________________________ CHRISTOPHER B. CRAFT SWORN TO AND SUBSCRIBED BEFORE ME, A NOTARY PUBLIC, THIS THE ____ DAY OF ________________, 1992. _______________________________ NOTARY PUBLIC MY COMMISSION EXPIRES: _______________________________ DR. CRAFT VOLUME II PAGE 558 NORTH CAROLINA WAKE COUNTY C E R T I F I C A T E I, CAROL S. YOUNG, A NOTARY PUBLIC, DO HEREBY CERTIFY THAT DR. CHRISTOPHER BRUCE CRAFT WAS DULY SWORN PRIOR TO THE TAKING OF THE FOREGOING DEPOSITION, AND THAT SAID DEPOSITION WAS TAKEN AND TRANSCRIBED UNDER MY DIRECT SUPERVISION, AND THAT THE FOREGOING PAGES, 109-556, VOLUME II, CONSTITUTE A TRUE AND ACCURATE TRANSCRIPTION OF THE TESTIMONY OF THE SAID WITNESS. I DO FURTHER CERTIFY THAT THE PERSONS WERE PRESENT AS STATED IN THE CAPTION. I DO FURTHER CERTIFY THAT I AM NOT OF COUNSEL FOR, OR IN THE EMPLOYMENT OF EITHER OF THE PARTIES TO THIS ACTION, NOR AM I INTERESTED IN THE RESULTS OF THIS ACTION. IN WITNESS WHEREOF, I HAVE HEREUNTO SUBSCRIBED MY NAME, THIS THE 31ST DAY OF DECEMBER, 1992. _____________________________ CAROL S. YOUNG CAROLYN Y. HALL & ASSOCIATES 2551 ALBEMARLE AVENUE RALEIGH, NORTH CAROLINA 27610 MY COMMISSION EXPIRES DECEMBER 26, 1995