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