| I, DR. RONALD JONES, Ph.D., declare:
1. I am Dr. Ronald Jones, Ph.D., Associate Professor of
Biological Sciences at Florida International University. I
attended Illinois State University from 1974 to 1975 and then
attended the University of West Florida where I received my B.S.
(1977) and my M.S. (1980) in Biology. In 1984 I was awarded a
Ph.D. in Microbiology from Oregon State University. The research
in the field of microbiology for which I was awarded M.S. and
Ph.D. included work in nitrogen and phosphorus cycling and the
effects of pesticides on nitrogen cycling. Cycling refers to the
complex pathways and interactions that an element such as
phosphorus undergoes as a result of biological and nonbiological
processes. Currently my research areas are microbial ecology,
Everglades nutrient cycling and chemical oceanography. Microbial
ecology is the study of the interactions of bacteria, fungi and
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algae with the chemical, physical and biological components of
their ecosystems. I have been conducting research within the
Everglades system since 1985 n cooperation with the National Park
Service through Everglades National Park. I conducted the studies
I discuss in this declaration at the request of the United States
Attorney in preparation for trial in United States v. South Florida
Water Management District, Civil No. 88-1886-CIV (Hoeveler) (S.D.
Fla.). My curriculum vitae is Attachment 1.
2. Based on the work upon which I base this declaration
and my knowledge and understanding of the Everglades ecosystem, it
is my opinion that excess phosphorus in inflows to Everglades
National Park have caused and continue to cause significant long-
term damage to biological communities in the Park. The work upon
which I base this opinion included collection and laboratory
analysis of soil and water samples from in the Park, as well as field
observations of plant communities in the Park. The results of this
work show that the levels of phosphorus in the peat soils in an
area extending at least 6 km into the Park from Park water inflow
points are significantly higher than background levels in pristine
areas of the Park, and that these excessive peat phosphorus levels
are a precursor to abnormal plant growth, including invasion by
nuisance plant species. The results of similar analysis I
performed on soil and water samples I collected in the Loxahatchee
National Wildlife Refuge, Water Conservation Area 2A (WCA-2A) and
Water Conservation Area 3A (WCA-3A) (see Map, Attachment
2)
corroborate my conclusions.
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3. Unlike most wetlands in the United States, the
natural Everglades ecosystem is oligotrophic. An oligotrophic
ecosystem is one characterized by low biological growth rates
(productivity). In the aquatic portions of the natural Everglades
ecosystem, this means that the growth of plant and animal life is
limited by extremely low concentrations of phosphorus and/or
nitrogen. Both phosphorus and nitrogen are nutrients essential to
plant and animal life. The ambient phosphorus (phosphate) levels
in pristine, oligotrophic areas of Everglades National Park and
Loxahatchee Wildlife Refuge are so low that they are difficult to
detect with existing methodologies. These systems have adapted
over thousands of years to oligotrophic conditions, which have
allowed the development of specialized communities of mircobiota,
plants and animals that are unique to the Everglades.
4. Because naturally-occurring nutrient levels in the
Everglades marsh are so low, any additional nutrients dramatically
change the ecosystem. Although changes in macrophyte (large
plants, such as cattails and sawgrass) and algal communities are
often the first visually apparent ecosystem alterations resulting
from excess nutrients, the effects on the nutrient composition of
the soils and bacterial communities in both the water and soils
occur much earlier and can have an equal or greater adverse impact
on the natural productivity of the system.
5. All ecosystems have an intrinsic capacity to handle
fluctuations in phosphorus levels which depends on many factors,
such as water flow, sediment composition, historical phosphorus
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loads and, most important, microbial mineralization and
remineralization processes. Mineralization and remineralization
processes are biological processes by which microorganisms
particularly bacteria- recycle organic forms of phosphorus (which
are often unusable to many species plants and animals) to inorganic
phosphate, a biologically more usable form of phosphorus. Indeed
microbial processes such as mineralization and remineralization are
critical to the stability of the ecosystem because they are
involved in most, if not all, of the cycling of phosphorus (see
1). Because of their important role in phosphorus cycling,
bacteria are the first group of organisms to exhibit measurable
effects of perturbations in phosphorus concentrations in the water.
6. The effect of these perturbations on bacteria can be
monitored by measuring the activity in the water of the enzyme
alkaline phosphate (AP). All living organisms possess AP, which
enables organisms to utilize organic phosphorus by promoting the
remineralization of organic forms of phosphorus to a biologically
usable form of inorganic phosphate. Unlike other organisms,
bacteria and fungi on excrete AP outside their cells. Thus, the
reliance of bacteria and fungi on AP can be monitored by measuring
AP that they have excreted. Specifically, these microorganisms
excrete less AP as the concentration in the water of biologically
available phosphorus increases, because their need to convert
unavailable forms of phosphorus to biologically available forms
decreases.
7. Laboratory analyses I have conducted on Everglades
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water samples show that a correlation exists between the level of
total phosphorus (TP) and the level of AP activity in the water. I
have further determined on the basis of these experiments that
changes in the AP activity due to changes in total phosphorus
concentration occurs on the order of hours, as opposed to the long
time periods (days to weeks, or even years) required to observe
changes in periphyton, macrophytes or TP levels in the soil. Thus,
AP is extremely valuable as a sensitive and early indicator of
ecosystem changes caused by excess phosphorus in the Everglades
ecosystem. Specifically, a decrease in AP activity indicates that
excess phosphorus is adversely affecting the natural cycling of
phosphorus in the ecosystem.
8. My research on the ecosystems in the Everglades
National Park, Loxahatchee National Wildlife Refuge and Water
Conservation Areas 2A and 3A has included the following three
components: first, I measured whether phosphorus has accumulated in
the soils of the Park and Loxahatchee; second, I measured the areal
extent of phosphorus concentrations in the soils along transects (a
series of sampling points along a flow way, such as a river
channel) in the Park, the Refuge, WCA-2A and WCA-3A; third, I
measured the AP activity in the water at sampling points along a
transect in the Park and in the perimeter canal in Loxahatchee
National Wildlife Refuge.
9. There is a decreasing gradient of TP in the soils
extending south from the S-12 water delivery structures into the
Shark River Slough of Everglades National Park. See Map
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(Attachment 2). Thus, the highest soil phosphorus concentrations I
observed were in the soil samples taken nearest to the S-12C
structure, and the farther from the S-12C structure soil samples
were taken, the lower the soil phosphorus level. I determined this
by collecting samples of soil from sawgrass and spikerush marshes
at sampling points along a 16 km transect extending from water
delivery structure S-12C south into the Park. See Map (Attachment
2). I selected this transect in order to observe any changes
occurring along the direction of the water flow south of the inflow
points to the Shark River Slough portion of the Park. Soil samples
I collected along the transect revealed elevated levels of TP with
an increasing trend towards the northern border of the Park.
Levels of TP in the soil at a point 100 meters south of S-12C
averaged 1241 parts per million (ppm). These concentrations were 5
to 10 times higher than TP levels in the soil at a point at least 16 km
south of S-12C, which averaged 186 ppm. I found elevated TP levels
at least 6 km into the Park. As explained below, these elevated TP
levels in the soil are long-term changes representing damage to the
ecosystem.
10. I collected soil samples along a control transect in
Water Conservation Area 3A running north from S-12C to determine if
any of the TP effects abserved in the Park could have been caused
by either construction of or proximity to U.S. 41 (Tamiami Trail).
See Map (Attachment 2). This transect, which extended 8 km north
into WCA-3A from the S-12C structure, revealed elevated TP only in
soil samples collected within 10 meters of the canal near the S-12C
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structure. The TP levels in the soil at a point approximately 10
meters from the canal immediately adjacent to S-12C averaged 1214
ppm. At the next farthest point north of S-12C that I sampled, the
TP levels averaged 538 ppm, and at 8 km, the TP levels in the soil
also averaged 538 ppm. These data revealed a significantly
different gradient of TP levels in the soil that the gradient I
observed in the Park. This is very strong evidence that neither
construction nor proximity to U.S. 41 is the cause of the TP
gradient in the soils in the Park.
11. I also collected soil sample along a transect
in the Loxahatchee National Wildlife Refuge running from near pump
station S-6 due east across the Refuge. See Map (Attachment 2).
The soil samples I collected along this transect revealed that
elevated levels of TP exist in the soils in the Refuge. In
Loxahatchee, the soils naturally contain higher levels of TP
(around 600 ppm) than soils in the Park (150-250 ppm) because of
the conditions under which they were formed. Along the transect in
the Refuge, concentrations of TP were highest in the soil at the
western boundary near S-6 (2380 ppm), decreasing towards the center
(600 ppm) and increasing towards the eastern boundary (1462 ppm).
These data show that the concentrations of TP in the soils in the
Refuge increases as the distance decreases from the perimeter canal
that rings the Refuge inside the perimeter levee of the Refuge.
12. I collected soil samples along an additional
transect in Loxahatchee, north of the central transect, using the
same sampling methodology. The soil samples from this transect
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revealed the same general gradient that I observed along the
central transect.
13. I also collected soil samples along the transect in
WCA-2A (see Map, Attachment 2). TP levels in the soil were greater
than 2000 ppm near S-10 water delivery structures (see Map,
Attachment 2) and never dropped below 584 ppm. This compares with
backgrounds of 150 to 250 ppm in the Park, and WCA backgrounds of
300 to 550 ppm.
14. My field observations and laboratory measurements of
TP levels in Everglades soils indicate that once the peat becomes
saturated, it can no longer hold additional phosphorus, and thus
phosphorus added to the saturated peat is transported downstream
and taken up by unsaturated peat. Thus, as excess phosphorus
continues to be added to the marsh, the zone in which the peat soil
accumulates and becomes saturated with excess phosphorus expands.
15. The only ways in which TP effects can be eliminated
from the peat are by 1) the extremely slow accumulation of new peat
containing lower levels of phosphorus, which buries the phosphorus-
enriched peat; 2) destruction of the peat by fire, which removes
the phosphorus from the peat, but in such a way that the phosphorus
is transported downstream; or 3) slow release and transport
downstream of phosphorus that would occur if the soils were exposed
continuously and for extremely long periods of time to pristine
water flow. Based on my knowledge and understanding of phosphorus
cycling in Everglades peat soils, it is my opinion that the effects
of elevated TP in Everglades soils have the potential to remain for
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hundreds of years because of the limited ability of the system to
rid itself of phosphorus. For this reason it is imperative that
the spread of phosphorus in the Everglades be stopped as soon as
possible.
16. I have made hundreds of field visits to the marshes
in the Everglades National Park, the Water Conservation Areas and
Loxahatchee National Wildlife Refuge in the past five years.
Through these field visits and my scientific studies of Everglades
ecosystems, I have become familiar with the normal growth patterns
of native Everglades plant species. The macrophyte and algal
communities that I observe in Shark River Slough along the
portions of the transect in the Park ( See Map, Attachment 2) were
altered as compared to the macrophyte and algal communities in
pristine areas of the Park. Whereas sawgrass was two to four feet
high 12 km south of S-12C, the sawgrass stands in the first 0.5 km
south of S-12C were approximately five to seven feet high. Also,
whereas open water marshes in Shark River Slough are normally
dominated by the plant species Eleocharis sp., the open water
marshes in the first 0.5 km south of S-12C were dominated by the
plant species Panicum sp. Finally, it was visually apparent in the
same area near the S-12C structure that the plant species
Utricularia sp., which normally forms a major component of the
periphyton community in the Shark River Slough, was greatly suppressed.
The presence of the Panicum sp. that I observed is commonly
enhanced, and the presence of the Eleocharis sp. and the
Utricularia sp. that I observed is commonly suppressed, in
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nutrient-enriched marshes. Therefore, it is my opinion that the
growth patterns and community structures of the vegetation in the
area in Everglades National Park extending 0.5 km south of the S-12
water delivery structures are abnormal. It is my opinion that this
abnormality is caused by elevated levels of nutrients in the water
delivered to the Park through S-12 structures.
17. TP levels that I measured in the soils in Everglades
National Park, Loxahatchee and WCA-2A, coupled with field
observations and my overall understanding of the Everglades
ecosystem, indicate that an elevated level of TP in the soil causes
alteration of macrophyte communities in the marsh. An example of
such alteration, in addition to the abnormal vegetation patterns I
observed in Shark River Slough just south of the S-12C structure,
is the conversion of sawgrass-dominated stands to cattail-dominated
stands in the marsh.
18. In addition to measuring peat phosphorus levels and
making field observations, I also measured AP activity at points
along the transects in Everglades National Park and in the
perimeter canal in Loxahatchee National Wildlife Refuge. See Map
(Attachment 2). A decrease in AP activity indicates and excess of
phosphorus. Along the transect in Everglades National Park, AP
activity ranged at a point 12 km south of S-12C was four to five
times greater than at a point 100 meters south of S-12C. In the
perimeter canal around the Refuge, I detected virtually no AP.
19. It is my opinion that the AP activity I observed in
the Park shows that significant damage to the biological
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communities in the Park extends at least 8 km into the Park south
of S-12C. The extremely low AP activity I measured in the
Loxahatchee perimeter canal also shows significant damage. These
results corroborate my conclusions, based on my field observations
and peat phosphorus measurements, that excess phosphorus in Park
inflows is causing significant harm to biological communities in
the Park.
I declare under penalty of perjury that the foregoing is
true and correct to the best of my knowledge and belief.
Dated this 18th day of September, 1990.
______________________________
Dr. Ronald Jones
Associate Professor
Florida International University
Miami, Florida 33199
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