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