DR. CRAFT VOLUME II PAGE 374 THE FOLLOWING PORTION OF THE DEPOSITION OF DR. CHRISTOPHER B. CRAFT WAS TAKEN ON THE 8TH DAY OF DECEMBER, 1992, BEGINNING AT OR AROUND 10:26 A.M. IN THE HILTON HOTEL, DURHAM, NORTH CAROLINA, AND WAS REPORTED BY CAROL ANN S. YOUNG, A NOTARY PUBLIC. - - - - - - - - - - WHEREUPON, DR. CHRISTOPHER B. CRAFT, HAVING PREVIOUSLY BEEN DULY SWORN, WAS EXAMINED AND TESTIFIED AS AS FOLLOWS: EXAMINATION BY MS. PONZOLI CONTINUES: Q. DR. CRAFT, I HAVE A FEW CLEAN-UP QUESTIONS AND THEN I HAVE A FEW MORE QUESTIONS ON A COUPLE OF AREAS THAT WE DIDN'T TALK ABOUT YESTERDAY. ONE CLEAN-UP QUESTION I HAVE IS IN REGARD TO CRAFT NUMBER SIXTEEN, YOUR PEAT ACCRETION AND NUTRIENT ACCUMULATION ALONG THE EUTROPHICATION GRADIENT IN THE NORTHERN EVERGLADES. I WOULD JUST LIKE YOU TO TURN TO THE DRAFT GRAPH AT THE END. ARE YOU WITH ME? A. UH-HUH (YES). (NODS AFFIRMATIVELY) Q. THAT LITTLE PHOSPHORUS ACCUMULATION POINT AT TEN DR. CRAFT VOLUME II PAGE 375 KILOMETERS FROM THE HILLSBORO CANAL, IS THAT AN OUTLIER? A. I REALLY DON'T KNOW. Q. DO YOU KNOW WHY THAT POINT IS SO FAR OFF THE CURVE? A. WELL, IT'S NOT OFF THE CURVE IN TERMS OF THE PEAT ACCUMULATION LINE, WHICH IS THE SLASH LINE. IT'S OFF THE CURVE FOR THE SURFACE WATER ACCUMULATION FLOW OR SURFACE WATER CONCENTRATION. Q. CAN YOU ACCOUNT FOR WHY EVERYTHING ELSE SEEMS TO MATCH SO WELL AND THAT ONE SEEMS TO BE DISTINCTLY DIFFERENT? A. NO, I REALLY DO NOT KNOW, AND I DON'T THINK IT IS ALL THAT DIFFERENT WHEN YOU COMPARE THAT ACCUMULATION NUMBER TO THE ONE LIKE, SAY, AT EIGHT KILOMETERS SOUTH. Q. WELL, THE ONE AT EIGHT WAS PRECEDING DOWNWARD FROM THE ONE AT SIX, AND THIS ONE JUMPS BACK UP AGAIN. A. BUT, AGAIN, I THINK YOU MIGHT -- IT MIGHT BE WORTHWHILE TO GO BACK TO THE ONE OF THE TABLES AND SEE HOW THE -- WHAT THE ERRORS ARE ASSOCIATED WITH THESE. Q. WHICH TABLE ARE YOU AT? DR. CRAFT VOLUME II PAGE 376 A. THIS IS TABLE 4. AND, AGAIN, I SEE IN THIS CASE, THE AVERAGE ACCUMULATION RATE AT THAT TEN POINT IS .13 GRAMS PER METER SQUARED PER YEAR. THE ERROR -- THE STANDARD ERROR IS GOING TO BE SOMEWHERE BETWEEN ZERO AND .01, THE ROUNDING ERROR, OF COURSE. AND IF YOU LOOK AT THE 8.3 SITE, IT'S .8 WITH A STANDARD ERROR OF .03, WHICH BRINGS IT UP TO POINT -- YOU KNOW, IT COULD GO UP TO -- GENERALLY SOME PEOPLE USE TWO STANDARD ERRORS AS A RANGE OF WHETHER THEY'RE SIGNIFICANTLY DIFFERENT ARE NOT. AND, AGAIN, I DON'T THINK THE .08 AND THE .13 REALLY DIFFER THAT MUCH. Q. SO, YOU'RE SAYING THEY'RE STATISTICALLY DIFFERENT? A. OH, I'M NOT SAYING THAT BECAUSE I DIDN'T DO THE TEST. Q. OKAY. I'D LIKE TO LOOK AT CRAFT NUMBER TWENTY-SIX, WHICH I THINK IS -- SHOULD BE IN FRONT OF YOU. (THEREUPON, WITNESS GETS DOCUMENT.) A. OKAY. I HAVE IT IN FRONT OF ME. Q. OKAY. HAS THIS -- IS THIS A DRAFT PUBLICATION THAT YOU'RE SUBMITTING? A. YES, IT'S IN DRAFT FORM. DR. CRAFT VOLUME II PAGE 377 Q. ALL RIGHT. AND ARE YOU INTENDING TO SUBMIT IT TO AQUATIC BOTANY? A. I'M LEANING IN THAT DIRECTION. AGAIN, I THINK I MAY TALK TO ONE OF THE EDITORS TO SEE WHETHER IT'S REALLY APPROPRIATE FOR THAT JOURNAL BEFORE I SEND IT THERE. Q. OKAY. SO, THAT ANSWERS MY NEXT QUESTION. YOU HAVEN'T SUBMITTED IT ANYWHERE? A. NO. NO, IT HAS NOT GONE OUT. Q. OKAY. HAVE YOU -- IS THIS THE MOST RECENT DRAFT OF IT? A. YES. Q. DO YOU INTEND TO MAKE ANY CHANGES BEFORE YOU DO SUBMIT IT? A. I'M DEFINITELY GOING TO HAVE DR. RICHARDSON REVIEW IT ONE MORE TIME BEFORE I SEND IT OUT. AND I, OF COURSE, WILL LOOK AT IT. SO, IT'S NOT READY, IT'S PROBABLY A MONTH AWAY, BUT IT'S CLOSE. Q. OKAY. WE DISCUSSED TWO PUBLICATIONS YESTERDAY AND WE'RE GOING TO TAKE JUST A SECOND AND LOOK AT THIS ONE. ARE THERE ANY OTHER PUBLICATIONS THAT YOU HAVE READY TO BE SUBMITTED THAT I HAVE NOT--- A. NO. THE TWO ARE THIS ONE AND THE ONE THAT WE JUST DR. CRAFT VOLUME II PAGE 378 ADDRESSED, THE PEAT ACCRETION AND NUTRIENT ACCUMULATION. Q. OKAY. I'D LIKE YOU TO LOOK IN THE ABSTRACT AT THE FINAL PARAGRAPH AND I WOULD JUST LIKE YOU TO TAKE A SECOND AND READ THAT FINAL PARAGRAPH OF THE ABSTRACT, AND ASK YOU IF YOU STILL CONCUR WITH WHAT'S WRITTEN THERE? (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. YES, I THINK, I CONCUR WITH THIS. Q. OKAY. AND YOU HAVE NO DATA THAT SHOWS DIFFERENT INFORMATION? A. NO, NOT AT THIS TIME. Q. OKAY. WOULD YOU TURN TO THE NEXT PAGE AND THE INTRODUCTION, PLEASE. AND FOUR LINES UP FROM THE BOTTOM IS A SENTENCE THAT STATES, "CONCURRENT WITH THIS INPUT HAS BEEN A SHIFT IN THE STRUCTURE AND COMPOSITION OF NATIVE EVERGLADES PLANT COMMUNITIES." DO YOU STILL CONCUR WITH THAT STATEMENT? (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. YES. BASED ON WHAT THE LITERATURE SHOWS TO THIS TIME, YEAH. Q. OKAY. AND THEN AT THE END, IN THE CONCLUSIONS, DR. CRAFT, YOU HAVE "CONCLUSIONS." ARE THESE DR. CRAFT VOLUME II PAGE 379 CONCLUSIONS STILL VALID? WOULD YOU -- IF YOU'LL JUST TAKE A SECOND AND READ THROUGH HERE AND TELL ME THAT YOU STILL BELIEVE THESE ARE VALID AND HAVE NO DATA THAT'S INDICATING THAT YOU WILL CHANGE THESE? (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. I CAN'T SAY WHETHER I'LL CHANGE THESE OR NOT. I MEAN, FOR THE MOST PART, THEY WILL NOT BE CHANGED. Q. FOR THE MOST PART? A. WELL, THE ONLY THING I MIGHT CHANGE -- WELL, I CAN'T, YOU KNOW--- Q. RIGHT. A. ---IS -- I FEEL LIKE AT THIS POINT WE DON'T HAVE ENOUGH DATA ON THE SHIFT -- THE POTENTIAL SHIFT THAT MIGHT OCCUR FROM SAWGRASS TO CATTAIL IN THAT LAST PARAGRAPH, NOR WAS THERE A NOTED INCREASE IN CATTAIL IN THE FERTILIZED PLOTS. I MAY NOT -- THAT MAY COME OUT OF THE CONCLUSIONS. I FEEL LIKE AT THIS POINT -- WE DIDN'T HAVE ANY PRE-TREATMENT INFORMATION WITHIN THE PLOTS ON WHAT THE CATTAIL DENSITY WAS. BUT AFTER ONE YEAR, WE HAVE CATTAIL DATA. AND AFTER TWO YEARS, WE HAVE MORE CATTAIL DATA. SO, I THINK, I WILL NOT DR. CRAFT VOLUME II PAGE 380 REALLY ADDRESS THAT UNTIL WE WRITE UP THE TWO YEARS WORTH OF DATA. Q. SO, YOU'RE GOING TO TAKE OUT THE PART FROM -- MORE TOWARD THE END--- A. I THINK I MAY TAKE THAT OUT--- Q. OKAY. A. ---THAT WILL BE THE ONE THING THAT I WOULD DEFINITELY REVIEW. Q. ALL RIGHT. AND THEN WAS THERE ANOTHER -- WAS THERE ANOTHER STATEMENT THAT YOU SAID YOU MIGHT ALTER? A. NO. I MEAN, I'M NOT GOING TO STATE EMPHATICALLY THAT IT WILL NOT CHANGE--- Q. I'M NOT ASKING FOR THAT -- I'M NOT ASKING FOR THAT. A. ---AGAIN, YOU KNOW, I THINK THAT'S SOMETHING I WANT TO LOOK AT HERE. BUT, REALLY, EVERYTHING ELSE WILL PROBABLY STAY IN THERE. Q. I'D LIKE TO TAKE JUST ONE TINY QUESTION ON CRAFT NUMBER TWENTY-THREE -- MAYBE TWO TINY QUESTIONS. A. OKAY. Q. THIS IS IN REGARD TO THE APPLICATION OF BROMIDES TO TRACE FERTILIZER AMMONIUM AND EVERGLADES MICROCOSM. DID YOU WRITE THIS? DR. CRAFT VOLUME II PAGE 381 A. YES. Q. OKAY. SO, WHEN YOU SAY, "I FAVOR SUGGESTION NUMBER ONE ON THE SECOND PAGE," YOU WERE IN FAVOR OF A SINGLE ANNUAL APPLICATION OF FERTILIZER? A. AT THE TIME I WROTE THIS, YES. Q. OKAY. WHY WAS THAT? A. MY MAIN INTEREST WHEN I STARTED THIS STUDY WAS THE EFFECT ON THE MACROPHYTES AND I FEEL LIKE -- WELL, I FELT LIKE, AND TO SOME EXTENT I STILL FEEL LIKE, FOR MACROPHYTES TO REALLY SEE THE RESPONSE, YOU SHOULD APPLY IT DOING THE DRIEST TIME OF YEAR WHEN MOST -- YOU HAVE THE GREATEST PROBABILITY OF RETAINING ALL THE FERTILIZER OR MOST OF IT IN THE PLOTS. AND AFTER I TALKED TO DR. VYMAZAL, WHO WAS INTERESTED IN DOING SOME WORK IN THE PLOTS, WE DECIDED TO LOOK AT THE EFFECTS OF PERIPHYTON, A SINGLE DRY SEASON APPLICATION PROBABLY WOULD NOT PROVIDE ANY INFORMATION ON LOOKING AT PERIPHYTON CHANGES. AND FOR THAT REASON WE STARTED GOING TO SPREADING IT MORE EVENLY THROUGHOUT THE YEAR. Q. OKAY. IS THAT SECOND SENTENCE, WE ARE INTERESTED IN DETERMINING IF AND AT WHAT LEVELS FERTILIZERS, NITROGEN AND PHOSPHORUS, CAUSE A SHIFT FROM A DR. CRAFT VOLUME II PAGE 382 SAWGRASS MARSH TO A WETLAND DOMINATED BY CATTAILS--- A. WHERE -- IS THIS ON THE FIRST PAGE? Q. SECOND PAGE. A. AND WHERE IS THIS? Q. RIGHT AFTER, "I FAVOR SUGGESTION NUMBER ONE." A. OKAY. Q. IS THAT PRETTY CLOSE TO A HYPOTHESIS? A. YES. AND AFTER THINKING ABOUT YESTERDAY'S QUESTIONS, I DO HAVE SOME -- THEY WEREN'T EXPLICIT HYPOTHESIS IN THIS STUDY, BUT WE HAD OBJECTIVES AND WITHIN THOSE ARE SOME IMPLICIT HYPOTHESES. Q. OKAY. AND ARE THOSE OBJECTIVES STATED IN YOUR CHAPTERS IN THE ANNUAL REPORTS? A. YES, YES. AND I DON'T KNOW IF YOU SHOULD UNDERSTAND, BUT I WOULD LIKE YOU ALL TO UNDERSTAND THAT BY LATE IN THE DAY YESTERDAY AND WITHOUT HAVING ANY OF THE DOCUMENTATION IN FRONT OF ME, THAT -- WELL, I REALLY JUST WASN'T THINKING. AND, YOU KNOW, I THINK I'VE PROBABLY WRITTEN CLOSE TO A MILLION WORDS IN THE PAST THREE OR FOUR YEARS AND IT'S HARD TO BE ABLE TO RECALL EVERYTHING FROM MEMORY. SO, IT'S NICE TO HAVE THE LITERATURE IN FRONT OF ME, SO. DR. CRAFT VOLUME II PAGE 383 Q. WELL, I WOULD HAVE HAD COPIES FOR YOU YESTERDAY, BUT WE HAD SOME SEVERE PROBLEMS BEING SO FAR AWAY FROM HOME. A. OKAY. Q. MY NEXT QUESTION IS IS THAT IF THERE WERE TO BE A SHIFT FROM A SAWGRASS MARSH TO A WETLAND DOMINATED BY CATTAILS, HOW DO YOU THINK THAT SHIFT WOULD TAKE PLACE? A. WELL, I DON'T REALLY KNOW, BUT I THINK THE STUDY -- THE FERTILIZER STUDY TRIES TO ADDRESS THAT BY EACH OF THE THREE SITES. AND AT THE SAWGRASS SITE, IT'S -- THE PLOTS ARE PURE SAWGRASS, THERE'S NO CATTAIL IN THEM. AND IF WE WERE TO SEE CATTAIL INVADE THOSE PLOTS, IT WOULD CERTAINLY SUGGEST THE SEEDS COMING IN AND THEN GERMINATING. AT THE MIXED SITE WHERE THERE IS CATTAIL IN ALL THE PLOTS, IF WE SAW A CATTAIL EXPANSION THERE, THAT WOULD CERTAINLY SUGGEST THAT IT'S VEGETATIVE REPRODUCTION. THEY ARE THERE TO BEGIN WITH AND THEY JUST OUT COMPETE OR COMPETE MORE SUCCESSFULLY FOR THE RESOURCES THAN SAWGRASS. AND AT THE SLOUGH SITE IS KIND OF -- WELL, A ROUNDABOUT WAY TO LOOK AT THE EFFECTS OF WATER LEVEL, THERE HAVE BEEN SOME DR. CRAFT VOLUME II PAGE 384 PEOPLE HYPOTHESIZE -- I THINK POPE -- AND AGAIN THIS IS FROM MEMORY -- THAT HE SUGGESTED THAT WHAT CATTAIL DOES IS IT TENDS TO COLONIZE THESE DEEPER AREAS SUCH AS SLOUGHS AND THEN MOVES INTO THE SAWGRASS AREAS. AND IF WE WERE TO SEE THAT AT THE SLOUGH, THAT WOULD SUGGEST THAT PERHAPS THAT IS THE MECHANISM THAT OCCURS. Q. WHAT PHYSICAL FACTORS, SPECIFICALLY WATER LEVELS, WOULD YOU EXPECT TO SEE IN A SHIFT? A. MAYBE REPHRASE THE QUESTION. I'M NOT QUITE SURE I'M--- Q. IF YOU'RE LOOKING TO SEE A SHIFT IN THE GENERAL EVERGLADES, WHAT WATER LEVELS DO YOU THINK YOU'RE GOING TO NEED TO SEE? A. TO A SHIFT FROM SAY SAWGRASS TO CATTAIL? Q. UH-HUH (YES). A. I THINK DEEPER WATER PROBABLY WOULD HAVE A ROLE IN THAT, AND MAYBE THE DURATION OF THE HYDROPERIOD, ALTHOUGH I DON'T REALLY KNOW ABOUT THAT. Q. AND HOW WOULD THEY PROPAGATE? IS THAT THE PROPER TERM? A. I DON'T KNOW. IT COULD BE VEGETATIVE OR IT COULD BE THE SEED GERMINATION. IN THAT CASE, PERHAPS, VEGETATIVE, I MEAN, THERE IS -- WE FOUND CATTAIL DR. CRAFT VOLUME II PAGE 385 IN CONSERVATION AREAS 3A AND 2A. THERE IS SOME CATTAIL EVERYWHERE, PERHAPS NOT IN THE KIND OF DENSITIES THAT YOU SEE IN 2A. AND IT'S POSSIBLE THAT THE COMBINATION OF DEEPER WATERS AND/OR NUTRIENT ENRICHMENT CAUSES THIS SHIFT. Q. CAN THEY GERMINATE IN DEEPER WATER? A. I DON'T THINK SO, BUT I DON'T KNOW. I THINK THEY DO REQUIRE A PERIOD WHERE YOU DON'T HAVE ANY SURFACE WATER OR SOMETHING. BUT, AGAIN, I DON'T KNOW ENOUGH ABOUT HOW CATTAIL -- THE GERMINATION REQUIREMENTS FOR CATTAIL SEEDS. Q. DO YOU HAVE ANY IDEA ABOUT THE NUTRIENT LEVELS THAT THEY NEED? A. NO, I DON'T KNOW. BUT I THINK THIS STUDY, IF WE CONTINUE TO FERTILIZE LONG ENOUGH, WE WILL BE ABLE TO DETERMINE WHETHER -- THE RELATIVE ROLE OF THESE ADDITIONS ON THE SHIFT. Q. I'D LIKE YOU TO LOOK AT CRAFT NUMBER THIRTY-TWO. I THINK I JUST REPRODUCED THE ONE DOCUMENT THAT I'M INTERESTED IN. SO, YOUR THIRTY-TWO IS A LOT BETTER THAN MY THIRTY-TWO. THIS IS A LETTER FROM ONE OF THE COUNSEL AT THIS TABLE TO ONE OF THE RESEARCHERS AT THIS TABLE, DR. RICHARDSON, REGARDING DRAFT EVERGLADES NUTRIENT THRESHOLD DR. CRAFT VOLUME II PAGE 386 STUDY PLAN. AND I WOULD LIKE TO KNOW HOW YOU GOT THIS? A. I BELIEVE -- ALTHOUGH I DON'T REMEMBER EXACTLY -- BUT DR. RICHARDSON PERIODICALLY PASSES INFORMATION ON TO ME THAT HE THINKS MIGHT BE OF INTEREST TO ME. Q. ARE YOU ASKED TO REVIEW THAT INFORMATION? A. NO. MORE JUST -- IT JUST GIVES ME A BETTER IDEA OF WHAT OTHER STUDIES ARE GOING ON AND--- Q. SO, YOU DON'T -- YOU DON'T, LIKE, REVIEW IT AND GO BACK TO DR. RICHARDSON AND TELL HIM WHAT YOU THINK OF IT? A. NO. Q. ALL RIGHT. THE NEXT DOCUMENT I'D LIKE TO ASK YOU ABOUT IS CRAFT NUMBER SIX. THIS IS IN A FILE LABELED "N AND P." I GUESS I'VE ONLY REPRODUCED FOR YOU CERTAIN PAGES FROM THIS FILE SO LET ME JUST ASK YOU ABOUT THOSE. IF I SHOW YOU THE FILE IT WAS FROM, CAN YOU TELL ME--- A. MAY I LOOK AT IT, PLEASE? Q. SURE. THAT'S THE WHOLE FILE AS YOU PRODUCED IT TO US. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. ALL RIGHT. DR. CRAFT VOLUME II PAGE 387 Q. WHAT IS THAT FILE, DR. CRAFT? A. THIS RELATES TO THE -- THIS IS THE FILE THAT HAS THE DATA ON THE PAPER THAT'S BEEN ACCEPTED BY ECOLOGICAL APPLICATIONS. Q. OKAY. THE PAGE THAT I BELIEVE THAT HAS BEEN REPRODUCED FOR YOU HAS "STRUCTURE, PHOSPHORUS LOAD, TREATMENT AREA, AND PHOSPHORUS STORAGE." RIGHT? A. RIGHT. Q. OKAY. I WOULD LIKE FOR YOU TO EXPLAIN TO ME WHAT THIS PAGE IS ABOUT, AND WHAT THE NUMBERS REPRESENT? A. I'M NOT SURE. I KNOW THAT THE LOAD IS -- I TOOK OUT OF THE SWIM PLAN. THIS IS, I THINK, WHAT GOES THROUGH THESE RESPECTIVE GATES IN METRIC TONS PER YEAR. I'M NOT SURE ABOUT THE TREATMENT AREA AND THE P STORAGE. I MEAN, I KNOW WHAT THEY MEAN, BUT I'M NOT SURE HOW I CALCULATED THESE NUMBERS OR WHETHER I TOOK THEM FROM SOMEWHERE. Q. DO THOSE NUMBERS LOOK REMOTELY FAMILIAR TO YOU? A. NOT REALLY. I DON'T THINK THEY'RE IN THE MANUSCRIPT. Q. WELL, LET'S ASSUME THAT THOSE ARE STA'S FOR EACH OF THOSE STRUCTURES. DR. CRAFT VOLUME II PAGE 388 A. IS THAT WHAT THEY ARE? I DON'T--- Q. WELL, I DON'T KNOW. YOU WROTE THIS--- A. ---REFRESH MY MEMORY. Q. ---I DIDN'T. BUT THEY LOOK PRETTY FAMILIAR TO ME. LET'S ASSUME THAT THEY ARE STA'S FOR S5A 6, 7, AND 8, AND THAT YOU TOOK THEM FROM THE SWIM PLAN OR SOMEWHERE ELSE. BUT YOU'VE GOT PHOSPHORUS STORAGE OVER TO THE RIGHT. I'D LIKE FOR YOU TO RECONSTRUCT FOR ME HOW YOU THINK YOU MIGHT HAVE DONE THAT. A. I'M WONDERING IF I DIVIDED THESE NUMBERS TO TREAT -- I'M NOT SURE WHERE THE TREATMENT AREA NUMBERS COME FROM THOUGH. THEY CERTAINLY DON'T SUM UP TO THAT NUMBER AT THE BOTTOM, THOUGH, THE 3260. Q. MAYBE YOU LEFT OFF A ZERO. A. WELL, THAT COULD BE. Q. WELL, ASSUMING YOU LEFT OFF A ZERO, DO YOU THINK YOU -- THAT THAT'S WHAT YOU ACTUALLY DID, WAS DIVIDE OUT? A. I THINK SO, BUT AGAIN I'M NOT A HUNDRED PERCENT SURE. Q. AND AREN'T THESE PHOSPHORUS STORAGE NUMBERS SIGNIFICANTLY LOWER THAN THOSE THAT YOUR RESEARCH DR. CRAFT VOLUME II PAGE 389 WOULD SHOW? A. THEY ARE. THEY'RE DEFINITELY LOWER THAN SOME OF THE NUMBERS THAT I'VE CALCULATED. Q. OKAY. DO YOU HAVE ANOTHER PAGE, OR DO YOU JUST HAVE THE SINGLE PAGE? A. THAT'S IT. Q. THAT'S FINE. I'D LIKE YOU TO LOOK AT CRAFT NUMBER TEN. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. OKAY. DO YOU HAVE THE WHOLE FILE, DR. CRAFT? A. I THINK I DO. Q. OKAY. WHAT FILE IS THIS? A. THIS IS -- IF I AM CORRECT, THIS IS THE VEGETATION -- THE DEPARTMENT OF VEGETATION PLOTS ON THE GRADIENT. Q. OKAY. IT SAYS SPECIAL COMPOSITION, 1992. A. SPECIES COMPOSITION. Q. OH. I'M SORRY, SPECIES. YOU'RE RIGHT. I READ IT WRONG. I'D LIKE YOU TO TURN TO THE FIRST PAGE IN THAT FILE AND IF YOU WOULD EXPLAIN TO ME WHAT THIS DATA REPRESENTS? A. WE WERE TRYING TO SET UP AN EXPERIMENT. WE WERE THINKING ABOUT SETTING UP AN EXPERIMENT LOOKING AT THE EFFECTS OF WATER LEVEL AND PHOSPHORUS ON -- DR. CRAFT VOLUME II PAGE 390 AND FIRE -- ON A CONTROL OF CATTAIL IN CONSERVATION AREA 2A. THESE ARE OUR PERMANENT EIGHTEEN PLOTS. THIS IS P CONCENTRATION AND PEAT DEPOSITED OVER THE PAST TWENTY-FIVE YEARS FROM MY PAPER. THIS IS SOME WATER LEVEL DATA FROM THOSE SAME PLOTS. I THINK THIS IS THE AVERAGE WATER LEVEL FOR A YEAR PERIOD THAT DR. QUALLS COLLECTED. AND THIS IS THE RELATIVE -- THE PERCENTS SAWGRASS AND PERCENT CATTAIL FROM DATA THAT I COLLECTED AT EACH OF THE PLOTS. AND WE WERE GOING TO USE THIS TO TRY TO DETERMINE WHERE TO SET UP THESE -- THESE PLOTS. Q. ALL RIGHT. HAS DR. QUALLS BEEN COLLECTING WATER LEVEL DATA FOR A YEAR? A. YES, AND PERHAPS LONGER. Q. HOW LONG DO YOU THINK HE'S BEEN COLLECTING IT? A. I DON'T KNOW. YOU WOULD HAVE TO TALK HIM ABOUT THAT. AND I'M SURE YOU'LL GET YOUR CHANCE TOMORROW, SO. Q. BUT THERE'S BEEN NO CORRELATION BETWEEN THOSE WATER LEVELS PRIOR TO NOW AND YOUR OTHER WORK ALONG THE GRADIENT? A. I TOOK THESE WATER LEVELS AND TRIED TO CORRELATE THEM TO THE PEAT ACCRETION RATES AND NUTRIENT DR. CRAFT VOLUME II PAGE 391 ACCUMULATION RATES ON THE GRADIENT, BUT THERE WAS NO CORRELATION ESSENTIALLY. Q. HAVE YOU DRAWN ANY CONCLUSIONS FROM LOOKING AT THIS DATA? A. IN TERMS OF -- REPHRASE THE QUESTION, PLEASE. Q. IN LOOKING AT THIS DATA, DO YOU DRAW ANY CONCLUSIONS REGARDING, LET'S SAY, EVEN THE WETNESS OR THE DRYNESS OF YOUR TRANSECT? A. WELL, IT BASICALLY APPEARS THAT THE "A" TRANSECT IS A LITTLE BIT WETTER, BUT THIS IS A YEAR'S WORTH OF DATA. AND ACTUALLY WHEN WE DID THE CORRELATION ANALYSIS, THERE WAS NO CORRELATION WITH DISTANCE OR ALONG THE TRANSECT. Q. DO YOU THINK THAT "A" IS ONLY A LITTLE BIT WETTER THAN "D"? A. WELL, WHAT I'M SAYING IS STATISTICALLY I RECALL, ALTHOUGH I'M NOT A HUNDRED PERCENT SURE, THAT THERE WAS A NOT A GOOD CORRELATION BETWEEN WATER LEVEL AND DISTANCE OR TRANSECT. BUT, AGAIN, I WOULD HAVE TO GO BACK AND LOOK AT THE CORRELATION MATRIX. Q. WHAT ABOUT CORRELATION BETWEEN THE WATER LEVEL AND THE CATTAIL PERCENTAGE OR THE VEGETATION? A. DOES NOT APPEAR TO BE A GOOD CORRELATION THERE. DR. CRAFT VOLUME II PAGE 392 Q. OKAY. HAVE YOU WRITTEN UP YOUR EXPERIMENT? A. NO. THIS IS -- HAS JUST SORT OF -- THIS IS, I THINK, THE EXTENT OF IT REALLY. THERE MAY BE A PARAGRAPH OR A PAGE IN HERE RELATING TO IT, BUT THERE MAY NOT EVEN BE THAT. Q. DO YOU KNOW IF THERE ARE ANY PLANS TO CONTINUE THIS DATA COLLECTION? A. AT THE GRADIENT? Q. RIGHT. A. YOU MEAN LIKE WATER LEVEL? Q. RIGHT. A. I THINK THERE HAS BEEN TALK OF CONTINUING IT, BUT, AGAIN, I HAVE NOT BEEN INVOLVED IN THAT, SO. Q. OKAY. IS THERE ANY TALK OF SETTING UP THE EXPERIMENT THAT YOU ASKED FOR? A. THAT, I THINK, WE MAY DO. IT'S CERTAINLY ON THE DRAWING BOARD AND HAS BEEN TALKED ABOUT. Q. DO YOU PLAN TO ADD ANY OF THE SECOND YEAR DATA TO PUT TOGETHER WITH THE WATER LEVELS? A. CERTAINLY. THE MORE WATER LEVEL DATA WE HAVE, THE BETTER, I FEEL LIKE. Q. OKAY. ARE THESE RESULTS REFLECTED IN YOUR DRAFT NUMBER SIXTEEN? A. THE P IS, BUT THE WATER LEVEL WE DID NOT INCLUDE DR. CRAFT VOLUME II PAGE 393 BECAUSE THERE WAS NO CORRELATION. WE COULDN'T -- WE HAD HOPED TO RELATE WATER LEVEL TO THE -- TO INCREASED PEAT ACCRETION. BUT AGAIN I FEEL LIKE A YEAR'S WORTH OF WATER LEVEL DATA IS JUST NOT SUFFICIENT. Q. WHAT DO THE ASTERISKS MEAN? A. I THINK THOSE ARE AREAS WHERE WE POTENTIALLY WOULD TRY TO SET UP OUR PLOTS. Q. YOU MEAN PERMANENT PLOTS FOR CORRELATING WATER LEVEL WITH--- A. NO. TO LOOK AT THE EFFECTS OF P WATER LEVEL AND FIRE ON SAWGRASS AND CATTAIL. Q. OKAY. WHY ARE YOU CHOOSING THESE SITES? A. WELL, I THINK THERE ARE -- THEY'RE CHARACTERIZED BY -- SOME OF THEM HAVE HIGH PE AND HIGH WATER LEVEL; SOME OF THEM HAVE LOW PE AND HIGH WATER LEVEL. AND, OF COURSE, WE WERE TRYING TO FIND THAT RIGHT MIX OF CATTAIL AND SAWGRASS, TOO, I THINK. Q. DO YOU HAVE ANY IDEA WHEN THIS EXPERIMENT MIGHT BE FIRMED UP AND PRESENTED IN THE FORM OF A PROPOSAL OR--- A. IT WOULD BE IN THE SPRING. I MEAN, I SEE -- IF THIS GOES THROUGH, WE WOULD PROBABLY TRY TO SET IT DR. CRAFT VOLUME II PAGE 394 UP NEXT SUMMER. Q. YOU WOULD START THE ACTUAL DATA COLLECTION NEXT SUMMER? A. NO. THE PREPARING THE SITES. AND PROBABLY THE DATA COLLECTION WOULD NOT START UNTIL LATE SUMMER OR EVEN EARLY FALL. AGAIN, WE HAVEN'T -- WE'VE TALKED ABOUT THIS, AND THIS IS THE EXTENT OF IT, BUT WE HAVEN'T REALLY--- Q. CAN YOU FIND ANY LOW P AND CATTAIL ON HERE FOR ME, DR. CRAFT? A. NO, YOU CANNOT FIND ANY IN THAT. Q. DOES THAT TELL YOU ANYTHING? A. IT DOES SUGGEST SOMETHING, YES. Q. WHAT? A. IT SUGGESTS THAT MAYBE NUTRIENT ENRICHMENT OR PHOSPHORUS ENRICHMENT PLAYS A ROLE IN THE CATTAIL EXPANSION. BUT, AGAIN, I DO THINK WATER LEVEL IS SOMETHING THAT NEEDS TO BE ADDRESSED. Q. ALL RIGHT. YOU HAVE -- FOLLOWING THAT PAGE, YOU HAVE A GRAPH AND THEN YOU HAVE -- I GUESS THERE -- YOU HAVE A SUMMARY OF SOME PERCENTAGES OF CATTAIL, SAWGRASS, OTHER, FROM JULY '89--- A. I SEE IT. Q. ---IS THIS YOUR--- DR. CRAFT VOLUME II PAGE 395 A. THAT'S MY WRITING, YES. Q. IT IS YOUR WRITING. BUT DID YOU COMPILE THESE NUMBERS OR NOT? A. NO, I COMPILED THEM. Q. YOU DID? A. YES. Q. YOU ACTUALLY WENT OUT AND LOOKED AT THE VEGETATION? A. RIGHT. THIS IS JUST A SUMMARY FROM SOME OF THIS OTHER STUFF. Q. OKAY. OKAY. AND THEN FOLLOWING THAT, YOU HAVE GRADIENT STUDY, VEGETATION SAMPLING. I GUESS THESE ARE LIKE FIELD NOTES. IS THAT WHAT THEY ARE? A. THIS IS THE ACTUAL DATA SHEETS WHERE WE DETERMINED, YOU KNOW, THE PERCENTAGE CATTAIL, SAWGRASS, AND OTHER VEGETATION AT EACH OF THE POINTS. Q. THIS IS YOUR CONTINUING STUDY, IS THAT RIGHT? A. IN TERMS OF THIS -- THESE CHANGES IN SPECIES COMPOSITION ON THE GRADIENT, YES. Q. JUST SO I'M CLEAR, IS THIS THE VEGETATION STUDY THAT CONTINUES THROUGH TIME OR NOT? A. RIGHT, RIGHT. DR. CRAFT VOLUME II PAGE 396 Q. OKAY. OKAY. I'D LIKE TO KNOW WHAT THE RELATIONSHIP -- IF YOU MOVE THROUGH THIS FILE, I THINK YOU SEE -- OH, NO -- WELL, IT'S NOT THIS FILE, I'M WRONG. IT'S THE NEXT ONE WE'RE GOING TO GET TO. I WANT TO WAIT TILL WE GET THERE. DO YOU HAVE ANY CONCLUSIONS FROM THIS, PRESENTLY, FROM THIS WORK? A. I DON'T REALLY HAVE ANY CONCLUSIONS, I HAVEN'T WRITTEN IT UP. MAYBE IN NEXT YEAR'S REPORT WE'LL -- WE'LL HAVE A SMALL -- SMALL CHAPTER. AGAIN, THE PROBLEM WITH THIS KIND OF DATA, I THINK IT'S USEFUL AND PROVIDES INFORMATION, BUT BY ITSELF, YOU REALLY CAN'T -- YOU CAN'T DO A WHOLE LOT WITH IT IN TERMS OF TRYING TO WRITE IT UP AS A SCIENTIFIC PAPER. IF I HAD SOME MORE INFORMATION ON PLANT COMMUNITIES OUT THERE, I COULD MAYBE DO SOMETHING WITH IT. Q. WHAT KIND OF INFORMATION WOULD YOU NEED? A. WELL, WE HAVE THE N AND P CONTENT OF THE SHOOTS AND THE ROOTS OF PLANTS ON THESE TRANSECTS AND THAT HELPS. BUT WHAT, I THINK, IS REALLY MISSING WOULD BE SOME ESTIMATE OF PRODUCTIVITY AT EACH OF THE POINTS OF EITHER STANDING CROP BIOMASS OR PHOTOSYNTHESIS RATE OR SOMETHING LIKE THAT. DR. CRAFT VOLUME II PAGE 397 Q. OKAY. AND WHY CAN'T YOU GET THAT KIND OF INFORMATION? A. BASICALLY, I JUST DON'T HAVE THE TIME TO GO OUT AND DO IT. THIS WOULD INVOLVE -- I MEAN, I'VE THOUGHT ABOUT HOW TO DO, CLIPPING FOUR PLOTS AT EACH OF THE POINTS WHICH QUICKLY GIVES ME SEVENTY-TWO CLIP PLOTS, WHICH REALLY THE COMBINATION OF THE ACCRETION WORK AND THE FERTILIZER STUDY TAKE UP JUST SO MUCH OF MY TIME. AGAIN, I THINK THIS IS SOMETHING THAT WOULD BE WORTH DOING. PERHAPS YOU CAN RECOMMEND A GRADUATE STUDENT WHO WOULD BE INTERESTED IN DOING A MASTER'S THESIS ON SOMETHING LIKE THIS. Q. I THINK I'M A GROWTH INDUSTRY ALREADY. MR. GREEN: THAT'S DEBATABLE. Q. I HAVE, I THINK, SOME MORE QUESTIONS ALONG THAT LINE, BUT LET ME GET TO THEM. I'D LIKE YOU TO LOOK AT CRAFT NUMBER FOURTEEN. (THEREUPON, DOCUMENT GIVEN TO WITNESS.) Q. THIS IS THE WHOLE FILE, DR. CRAFT, IF YOU WOULD LIKE TO TAKE A SECOND AND LOOK AT IT. A. OKAY. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. WHAT FILE IS THIS, DR. CRAFT? DR. CRAFT VOLUME II PAGE 398 A. WHAT IS THE TITLE ON THAT? Q. IT SAYS PAREN (TP) -- END OF PAREN -- VERSUS PHOSPHORUS ACCUMULATIONS. A. THAT'S JUST A FILE THAT CONTAINS INFORMATION ON TRYING TO DETERMINE THE RELATIONSHIP BETWEEN PHOSPHORUS AND SURFACE WATERS AND PHOSPHORUS ACCUMULATION IN THE SOIL. Q. ALL RIGHT. I'D LIKE YOU TO LOOK AT THE ONE SET OF DATA THAT I REPRODUCED FOR YOU. WOULD YOU EXPLAIN TO ME WHAT THESE DATA REFLECT? A. OKAY. THE P ACCUMULATION DATA IS FROM THE MANUSCRIPT ON PEAT ACCRETION AND NUTRIENT ACCUMULATION ALONG THE EUTROPHICATION GRADIENT AND SO ON AND SO FORTH. THE REGRESSION EQUATION AT THE TOP IS FROM THE SOUTH FLORIDA WATER MANAGEMENT DISTRICT THAT PREDICTS SURFACE WATER TOTAL P WITH DISTANCE FROM THE HILLSBORO CANAL. AND WHAT I WAS TRYING TO DO WAS EXTRAPOLATE THEIR EQUATION TO GET AN ESTIMATE OF WHAT PHOSPHORUS CONCENTRATION IS AT OUR SAMPLING POINTS DOWN STREAM FROM THE CANAL AND TRY TO RELATE TP VERSUS P ACCUMULATION. Q. OKAY. ARE THOSE ACTUAL TOTAL PHOSPHORUS NUMBERS THAT ARE REFLECTED, THE .137 AND THE .083? A. THESE ARE CALCULATED FROM--- DR. CRAFT VOLUME II PAGE 399 Q. OKAY. A. ---THE EQUATION AT THE TOP. Q. OKAY. OKAY. I GUESS SO THEN MY NEXT QUESTION IS, HAVE YOU SEEN A .003 PARTS PER BILLION NUMBER AT TEN KILOMETERS? A. NO. IT'S JUST A CALCULATED NUMBER. Q. OKAY. OKAY. BUT THE PHOSPHORUS NUMBERS -- THE PHOSPHORUS ACCUMULATION NUMBERS ARE THE ACCRETION RATES AS REFLECTED IN THAT CRAFT NUMBER FIVE? A. RIGHT, YES--- Q. ALL RIGHT. A. ---OR SIXTEEN, WHICHEVER ONE IT IS. IT'S THE ONE IN CONSERVATION AREA 2A. Q. WHAT'S THE MAXIMUM ACCRETION RATE UNDER YOUR P ACCRETION? A. THE MAXIMUM IN TERMS OF WHAT WAS THE HIGHEST RATE THAT WE MEASURED? Q. WELL, YOU GAVE -- I KNOW IN SOME OF YOUR PAPERS YOU HAD THE MAXIMUM AND THEN YOU HAD -- YOU HAD THE MINIMUM. I GUESS I CAN FIND ONE AND SHOW YOU, BUT -- AND THEN YOU HAD AVERAGES -- YOU HAD AVERAGE AND MAXIMUM IN ONE OF YOUR PAPERS. A. OKAY. THE HIGHEST THAT WE MEASURED -- AND ACTUALLY THESE NUMBERS HERE THE THIRD COLUMN OF P DR. CRAFT VOLUME II PAGE 400 ACCUMULATION NUMBERS HAVE BEEN REVISED DOWNWARD BECAUSE WE USED THE INCORRECT BULK DENSITY NUMBERS TO CALCULATE THESE, AND SO -- I THINK THE HIGHEST RATE -- AND AGAIN I'D HAVE TO LOOK AT THE MOST RECENT COPY -- IT MAY BE THIS .85 GRAMS PER METER SQUARED PER YEAR AT -- IN THE MIDDLE ONE. BUT, AGAIN, I WOULD LIKE -- I'D HAVE TO LOOK TO MAKE SURE. IT'S SOMEWHERE AROUND .8 TO .85. Q. OKAY. I THINK YOU TOLD ME YESTERDAY ABOUT THE INCORRECT BULK DENSITIES BEING ONE OF THE ISSUES THAT YOU'RE GOING TO CORRECT IN WHAT IS THE FINAL ANNUAL REPORT FOR '92, AND I THINK I WAS BRAIN-DEAD LONG BEFORE THAT AND I DIDN'T ASK YOU VERY MUCH ABOUT IT. I DON'T THINK YOU EXPLAINED THAT TO ME YESTERDAY -- DID YOU -- WHAT WAS WRONG WITH YOUR BULK DENSITY NUMBERS? A. I JUST SAID THEY WERE CALCULATED INCORRECTLY. Q. OKAY. CAN WE TAKE THE ANNUAL REPORT -- THE '92 ANNUAL REPORT, AND ARE YOU ABLE TO EXPLAIN TO ME WHAT YOU DID WRONG AND HOW YOU'LL BE CHANGING THEM? A. OKAY. THEY HAVE BEEN CHANGED, AND I THINK--- Q. ARE THEY CORRECT IN HERE? A. ---THE CORRECT ONES -- NOT IN THE REPORT, BUT IN DR. CRAFT VOLUME II PAGE 401 THE DRAFT VERSION THAT YOU TOOK OUT OF ONE OF THE FOLDERS -- NUMBER FIVE OR NUMBER SIXTEEN. Q. ALL RIGHT. LET'S JUST IDENTIFY THEM AND MAKE SURE I UNDERSTAND--- A. WHICHEVER ONE--- Q. HERE'S NUMBER SIXTEEN--- A. OKAY. IT'S IN THIS ONE. Q. OKAY. IT'S IN SIXTEEN? A. WELL, LET ME MAKE SURE THAT THIS -- I THINK WE DID CORRECT FOR THESE BEFORE YOU ALL COPIED THIS, BUT I DO WANT TO MAKE SURE. Q. AND HERE'S NUMBER FIVE, IF YOU NEED NUMBER FIVE. A. OKAY. FIVE IS NOT IT--- Q. FIVE IS NOT IT? A. ---IT'S IN SIXTEEN. OKAY, THIS, YOU'LL SEE IT WAS ON THE "A" TRANSECT AND THE BULK DENSITIES WERE NOT CALCULATED RIGHT. BUT IN THIS DRAFT, THEY ARE CORRECT, AND WHAT YOU CAN DO IS COMPARE THESE NUMBERS WITH THE ANNUAL REPORT NUMBERS, IF YOU LOOK AT THE BULK DENSITIES. ON THAT "A" LINE, YOU'LL FIND THAT THEY'RE HIGHER IN THAT ONE THAN THEY ARE -- THEY'RE HIGHER IN THE ANNUAL REPORT THAN THEY ARE IN THIS NUMBER SIXTEEN. Q. AND HOW DID YOU CALCULATE THEM INCORRECTLY? DR. CRAFT VOLUME II PAGE 402 A. THERE IS A MOISTURE CORRECTION FACTOR THAT YOU USE. WE DO OUR ANALYSIS ON AN AIR-DRIED SAMPLES AND THE -- YOU USE A RATIO, AIR-DRIED WEIGHT TO OVEN-DRIED WEIGHT, AND WE GOT IT REVERSED, AND SO IT TENDED TO OVER ESTIMATE THE BULK DENSITY. AND SO WHEN THEY'RE CALCULATED CORRECTLY -- THIS WAS ONLY ON THE "A" TRANSECT -- THEY WERE REVISED DOWNWARD. Q. AND THAT WOULD INCREASE YOUR ACCRETION? A. NO, IT WOULD TEND TO DECREASE--- Q. DECREASE. A. ---THE RATES OF ACCUMULATION. IT OVERESTIMATED THEM IN THE ANNUAL REPORT, AND IN THE REVISED VERSION THEY HAVE COME -- THEY ARE SOMEWHAT LESS. Q. YOU HAVE, FOLLOWING THAT CHART -- AND I DON'T THINK I REPRODUCED ALL THIS. IT DIDN'T SEEM WORTHWHILE. MR. BURGESS: I'M SORRY, COUNSELOR, WHAT EXHIBIT? A. WHAT NUMBER, PLEASE? Q. I'M STILL ON CRAFT FOURTEEN. A. OKAY, I DON'T HAVE IT. Q. DR. CRAFT, YOU DON'T HAVE IT, BUT I CAN SHOW DR. CRAFT VOLUME II PAGE 403 YOU. YOU HAVE -- FOLLOWING THESE DATA, YOU HAVE SOME EXHIBITS THAT I DON'T BELIEVE ARE YOURS, IS THAT CORRECT--- A. THAT'S CORRECT. Q. ---LET ME JUST SHOW THEM TO YOU? A. THAT'S CORRECT. Q. DO YOU KNOW WHOSE THEY ARE? A. THEY ARE EITHER THE DISTRICTS, OR I THINK DR. WALKER'S WORK. Q. OKAY. ONE OF THEM APPEARS TO BE DR. WALKER'S, AND I DON'T KNOW IF THIS IS DR. KADLEC'S OR DR. WALKER'S. A. OKAY. Q. CAN YOU TELL ME WHY YOU HAVE THESE? A. AGAIN, DR. RICHARDSON PASSES INFORMATION ON TO ME THAT HE THINKS I MIGHT FIND OF USE OR HELPFUL OR INTERESTING. AND SO, AGAIN, I DID NOT -- HE DID NOT ASK ME TO REVIEW ANY OF THAT KIND OF INFORMATION, THOUGH. Q. OKAY. DID YOU ACTUALLY READ THROUGH THE STUFF? A. WELL, I LOOKED THROUGH IT. I'M NOT A MODELER, SO A LOT OF THAT I'M NOT SURE IF I REALLY UNDERSTOOD IT, SO -- I THINK CONCEPTIONALLY I UNDERSTAND IT, BUT I'M NOT A COMPUTER MODELER SO I'M THE WRONG DR. CRAFT VOLUME II PAGE 404 PERSON TO ASK ABOUT THAT--- Q. BELIEVE ME, I DON'T INTEND TO TRY. A. ---YOU'D GET NOTHING OUT OF ME, NOT BECAUSE I DON'T WANT TO, BUT BECAUSE I DON'T KNOW ANYTHING ABOUT IT. Q. I'D LIKE TO LOOK AT CRAFT NUMBER THIRTY. I THINK THIS WAS REPRINTED IN FULL FOR YOU, THE WHOLE EXHIBIT, IS IT NOT? YEAH. A. I BELIEVE SO, YES. Q. OKAY. WAS THIS PAPER PRESENTED AT A INTERNATIONAL SYMPOSIUM ON CONSTRUCTIVE WETLAND? A. I BELIEVE SO. THIS IS A PAPER THAT DR. RICHARDSON TOOK THE LEAD ON. Q. OKAY. SO, IN OTHER WORDS, SINCE HIS NAME IS FIRST, THEN HE TOOK THE LEAD, HE AUTHORED THIS? A. HE WAS CERTAINLY THE PRIMARY AUTHOR. I MEAN, I WOULD REVIEW IT FOR HIM, BUT--- Q. OKAY. WHEN YOU COME TO THE CONCLUSIONS ON PAGE 14 AND 15, YOU SEE AT THE BOTTOM RIGHT BEFORE IT SAYS "CONCLUSIONS" SORT OF AS A TITLE? A. YES. Q. AND IT TALKS ABOUT WETLANDS CONTAINING PEAT SOILS ARE NOT EFFICIENT SINKS FOR PHOSPHORUS ESPECIALLY UNDER HIGH LOADING RATES. CAN YOU DEFINE FOR ME DR. CRAFT VOLUME II PAGE 405 WHAT A HIGH LOADING RATE IS? A. I REALLY CAN'T DEFINE IT. THAT'S -- AGAIN, HE TOOK THE LEAD AND WAS, YOU KNOW, THE SENIOR AUTHOR ON THIS. Q. OKAY. WE'LL JUST HAVE TO WAIT UNTIL JANUARY. A. YEAH. I JUST DON'T KNOW. DR. RICHARDSON HAS HAD A LOT MORE EXPERIENCE WORKING WITH WETLANDS AND PHOSPHORUS THAN I HAVE. Q. OKAY. DO YOU THINK THAT -- DO YOU THINK THERE'S A BETTER WAY, DR. CRAFT, TO CONTROL THIS PHOSPHORUS COMING OUT OF THE EAA INTO THE WATER CONSERVATION AREAS THAN SOME TYPE OF A CONSTRUCTIVE WETLAND? A. I DON'T KNOW. I KNOW THERE HAVE BEEN SOME OTHER ALTERNATIVES THAT HAVE BEEN LOOKED AT, BUT, AGAIN, I DON'T KNOW HOW EFFECTIVE SOME OF THOSE WOULD BE EITHER. I THINK ONE WAS THAT AQUIFER STORAGE. AND RECOVERY WAS ONE MECHANISM. AND ADDING, I THINK, CALCIUM CARBONATE TO TRY TO PRECIPITATE PHOSPHORUS IS ANOTHER ONE. I THINK IT IS CERTAINLY WORTHWHILE TO LOOK AT A LOT OF DIFFERENT ALTERNATIVES. AND CERTAINLY CONSTRUCTIVE WETLANDS ARE A POTENTIALLY GOOD, YOU KNOW, ALTERNATIVE, TOO, SO. DR. CRAFT VOLUME II PAGE 406 Q. OKAY. ARE WETLANDS CONTAINING PEAT EFFICIENT SINKS FOR PHOSPHORUS UNDER THE LOADING RATES THAT WATER CONSERVATION AREA 2A RECEIVES? A. I THINK ACCORDING TO MY PAPERS, I SAY SOMETHING TO THAT EFFECT AT THE CURRENT LOADING RATES. Q. AND THAT'S THAT CONCERN I'M NEVER QUITE CLEAR ON, WHY YOU'RE SO CONCERNED ABOUT THEM INCREASING. DO YOU HAVE REASON TO BELIEVE THEY WILL INCREASE? A. NO. BUT I UNDERSTAND THAT RAINFALL IN FLORIDA, YOU KNOW, CAN VARY FROM THIRTY INCHES ONE YEAR TO SEVENTY OR EIGHTY IN ANOTHER YEAR, AND THAT JUST MEANS MORE WATER IN ONE OF THOSE HEAVY RAINFALL YEARS. AND, YOU KNOW, THERE'S -- IT'S DIFFICULT TO HOLD THAT WATER, IT'S GOING TO HAVE TO MOVE INTO -- THEY'RE GOING TO HAVE TO PUMP IT INTO THE WCA'S. WATER'S -- YOU KNOW, SOMETIMES THERE'S TOO MUCH DOWN THERE, AND SOMETIMES THERE DOESN'T JUST SEEM TO BE ENOUGH, SO. Q. ON PAGE 16 IN THE "ACKNOWLEDGEMENTS," WAS THIS WRITTEN BY DR. RICHARDSON? Q. ON--- A. YES. IS THERE A TABLE NUMBER? Q. PARDON? A. DO YOU HAVE A TABLE NUMBER? DR. CRAFT VOLUME II PAGE 407 Q. I'M -- I JUST SORT OF THINK -- I THINK I JUST WENT "UM." ON PAGES 24 AND 25--- A. OKAY. Q. ---YOU HAVE THE MAXIMUM PHOSPHORUS ACCUMULATION BEING .63, IS THAT RIGHT? A. YES, BASED ON -- AGAIN, THIS WAS PRELIMINARY DATA WHEN THIS WAS WRITTEN UP. Q. OKAY. HOW MANY CORES WAS THIS BASED ON -- THE NEXT PAGE, THE FORTY AVERAGE AND THE SIXTY-THREE MAXIMUM -- HOW MANY CORES ARE WE TALKING ABOUT TO COME UP WITH THESE NUMBERS? MR. GREEN: EXCUSE ME, COUNSEL, WE DON'T HAVE THAT MANY PAGES, IS THAT -- I DON'T HAVE--- MS. PONZOLI: IT WAS NOT A DELIBERATE OVERSIGHT. I DON'T KNOW. MR. GREEN: I'M NOT SUGGESTING IT WAS, I JUST DON'T HAVE IT. WHAT--- MS. PONZOLI: IT WAS TAGGED. SO, NORMALLY, WE WOULD HAVE MADE A COPY OF THAT LAST -- TABLE NUMBER 4, MR. GREEN. YOU DIDN'T GET IT? MR. GREEN: I DON'T THINK SO. I'LL LOOK ON. DR. CRAFT VOLUME II PAGE 408 MS. PONZOLI: WE GAVE THE DISTRICT A COPY, BUT NOT THE COOPERATIVE. MR. GREEN: THAT APPARENTLY IS THE CASE. MR. BURGESS: ON PURPOSE, NO DOUBT. MS. PONZOLI: BUT WE GAVE THE LEAD ONE. MR. GRIMSHAW: NO, I HAD IT COPIED MYSELF. MR. GREEN: WE DON'T ALWAYS HAVE THE SAME THINGS THAT THE LEAD HAS. MS. PONZOLI: NOR DO WE. Q. (BY MS. PONZOLI) SO, HOW MANY CORES DID YOU SAY? I'M SORRY, WE GOT DIVERTED. A. I HAVEN'T SAID YET. THE MAXIMUM IS JUST THE ONE CORE; THAT WAS THE CORE THAT HAD THE HIGHEST RATE. Q. OKAY. A. AND THE MEAN, IF I GO BACK TO LOOK AT THE METHODS HERE, IS BASED ON FIVE CORES. Q. SO, THE FORTY IS BASED ON FIVE? A. YES. Q. OKAY. AND WHAT TYPE -- ENRICHED OR UNENRICHED SITES? A. THEY ARE ALL FROM ENRICHED. AS YOU CAN SEE TO THE LEFT THERE, IT SAYS NUTRIENT ENRICHED. DR. CRAFT VOLUME II PAGE 409 Q. OKAY. WHERE AM I -- WHERE AM I MISSING IT -- TO THE LEFT, IT SAYS NUTRIENT ENRICHED? A. ON TABLE 3. OH, I'M BACK ON TABLE 3. IT'S THE SAME NUMBERS, I THINK. Q. RIGHT. A. ---AND IT SAYS, MEAN FOR 2A, (NUTRIENT ENRICHED) IN PARENTHESIS. Q. OKAY. OKAY. SO, THE FORTY IS BASED ON FIVE CORES IN AN ENRICHED SITE; AND THE SIXTY-THREE IS BASED ON ONE CORE IN A -- I CAN'T REMEMBER -- WAS IT UNENRICHED OR ENRICHED? A. NO. IT'S ENRICHED. THAT WAS THE HIGHEST CORE -- HIGHEST RATE OF ACCUMULATION IN THE ENRICHED ZONE OF THOSE FIVE. Q. OKAY. NOW, YOU SAY THIS WAS PRELIMINARY DATA. AND I GUESS WE HAVE MORE DATA NOW. A. RIGHT. Q. HAVE YOUR NUMBERS CHANGED BASED ON MORE DATA? A. THE AVERAGE NOW IS AROUND .45. Q. OKAY. A. AND, AGAIN, IT MIGHT BE .44; IT MIGHT BE .46. Q. RIGHT. A. SO, IT'S GONE UP A LITTLE BIT. AND THE HIGHEST ONE HAS GONE UP TO ABOUT .80 OF THE CORES THAT WE DR. CRAFT VOLUME II PAGE 410 HAVE COLLECTED. Q. OKAY. DOES THAT ALTER THE NUMBERS THAT YOU WOULD NEED IN SIZING IN HECTARES FOR A CLEAN-UP AREA TO DO THE JOB THAT WAS DESCRIBED? A. IN TERMS OF THE -- IT TENDS TO BRING THEM UP A LITTLE BIT. IT TENDS TO -- THE ACCUMULATION RATE TENDS TO COME UP A LITTLE BIT, A LITTLE BIT HIGHER, SO THE ACREAGE WOULD GO DOWN A LITTLE BIT. Q. DO YOU KNOW ABOUT WHAT PERCENTAGE? A. I WOULD JUST -- I WOULD HAVE TO LOOK AT THE INFORMATION TO SEE. BUT IF IT WENT FROM .40 TO .45, THAT'S ABOUT, YOU KNOW, TWELVE PERCENT (12%) OR SOMETHING LIKE THAT, TEN -- TEN TO TWELVE PERCENT (10% TO 12%). Q. OKAY. WE'RE GETTING CLOSER TOGETHER. A. I DON'T THINK WE WERE EVER THAT FAR APART, TO BEGIN WITH. Q. YOU WOULDN'T BELIEVE IT LOOKING AROUND THIS TABLE. A. I KNOW. Q. I'D LIKE TO ASK YOU ABOUT CRAFT NUMBER EIGHTEEN. (THEREUPON, DOCUMENT GIVEN TO DR. CRAFT.) Q. AND I THINK IN CRAFT EIGHTEEN, IT'S A LARGER FILE AGAIN, DR. CRAFT, DATA AND STATISTICS, AND I HAVE DR. CRAFT VOLUME II PAGE 411 PULLED JUST A SINGLE PAGE TO QUESTION YOU ON. AND IF YOU WANT TO -- IF YOU THINK THERE IS ANYTHING ELSE IN HERE YOU WANT TO TALK ABOUT, PLEASE FEEL FREE -- I'LL HAND YOU MY COPY -- BUT I ONLY HAD QUESTIONS ABOUT THIS ONE PAGE. A. OKAY. Q. WHAT DOES THIS REPRESENT, THIS DATA? A. I BELIEVE THIS IS THE WATER LEVEL DATA THAT WE TALKED ABOUT EARLIER THAT DR. QUALLS COLLECTED, THE SAME -- I'M PRETTY SURE IT'S THE SAME NUMBERS. AND, AGAIN, I WAS TRYING TO RELATE INCREASED PEAT ACCRETION TO WATER LEVEL. Q. DID YOU DRAW ANY CONCLUSIONS FROM THAT? A. THERE WAS NO CLEAR RELATIONSHIP. AND, AGAIN, I THINK, ONE YEAR OF WATER LEVEL DATA IS JUST NOT ENOUGH. Q. ARE YOU SURE THAT OTHER WATER LEVEL DATA WAS '91? I JUST CAN'T REMEMBER IF IT WAS '91 OR '92. A. I DIDN'T HAVE A DATE ON THAT, BUT I THINK IF YOU WENT BACK AND LOOKED, YOU'D SEE THE NUMBERS ARE THE SAME NUMBERS. Q. OKAY. DO YOU CONSIDER 3.7 AN ENHANCED HYDROPERIOD? IF YOU LOOK DOWN UNDER 10D1--- A. NO, NO. DR. CRAFT VOLUME II PAGE 412 Q. ---IT'S GOT 3.7. A. I MEAN, IT'S RELATIVE TO THE OTHER ONES. IT'S CERTAINLY DRIER THAN THE OTHER ONES. Q. OKAY. CRAFT NUMBER EIGHT IS THE NEXT ONE I WOULD LIKE TO ASK YOU ABOUT AND AGAIN I PROBABLY HAVE ONLY REPRODUCED A SINGLE PAGE THAT I'D LIKE TO -- WELL, NO, I THINK THE WHOLE FILE MAY HAVE BEEN DONE FOR YOU. A. I HAVE QUITE A BIT. Q. OKAY. THIS FILE IS ENTITLED "EVERGLADES COORDINATES." WHAT IS THIS FILE? A. THESE ARE THE LATITUDINAL AND LONGITUDINAL COORDINATES FOR OUR -- FOR THE VARIOUS SAMPLING POINTS. Q. THESE HAVE EXISTED THROUGH TIME FOR HOW LONG NOW? HOW LONG HAVE YOU HAD THESE ESTABLISHED? A. THE PLOTS? Q. RIGHT. A. THESE HERE WERE ESTABLISHED, I BELIEVE, IN JANUARY OF 1991. I THINK THAT'S RIGHT--- Q. DO YOU HAVE A--- A. ---NO, NO, WAIT A MINUTE LET ME BACKUP--- MS. PONZOLI: ARE YOU LOOKING FOR THE EXHIBIT, MR. BURGESS? DR. CRAFT VOLUME II PAGE 413 MR. BURGESS: YEAH. MS. PONZOLI: DO YOU WANT US TO WAIT FOR YOU? MR. BURGESS: THANK YOU. A. ---I THINK THEY WERE ESTABLISHED IN JANUARY OF '90 OR SO. Q. IT'S NUMBER EIGHT. ALL RIGHT, IT STARTS WITH -- ARE THESE -- THESE ARE LORAN READINGS OR GPS, I DON'T EVEN KNOW. A. THE MOST RECENT ONES HERE, THE FIRST PAGE, ARE GPS. Q. DID YOU -- YOU STARTED WITH LORAN AND THEN SWITCHED? A. YES. Q. DO YOU BELIEVE THAT YOUR SITES ARE PRETTY ACCURATE? A. I BELIEVE THAT MAY 25, 1992, ARE PRETTY ACCURATE. Q. THESE ARE GPS? A. YES. Q. I GUESS WHAT I WAS ASKING WAS WHEN YOU SWITCHED OVER, DO YOU THINK YOU'RE REALLY LOCATING THE SAME SITES, IS WHAT I'M TRYING TO SAY? A. WELL, WE HAVE -- WE HAD PERMANENT PLOTS SET UP WITH PVC PIPE AND THOSE SORTS OF THINGS, SO, WE DR. CRAFT VOLUME II PAGE 414 KNEW WHEN WE FOUND IT. BUT THE LORAN IS REALLY NOT -- IT WAS NOT VERY GOOD, SO. Q. OKAY. I WANT TO GO FIVE PAGES IN, AND THERE'S SORT OF A BLURRY DRAWING OF THE ENRICHED AREA, I BELIEVE OF WATER CONSERVATION AREA 2A. WHOSE DRAWING IS THIS? A. THIS IS MINE. Q. OKAY. AND WHAT IS IT REFLECTING? A. THIS IS -- I THINK, WE TOOK THE VEGETATION DATA THAT WAS MAPPED BY PAUL LARSON, OR IT WAS FROM THE DISTRICT -- THE CATTAIL SAWGRASS DISTRIBUTION -- AND JUST TRIED TO OVERLAY OUR PLOTS ON IT TO GET A RELATIVE IDEA OF WHERE WE WERE. Q. OKAY. I THINK THERE IS SOME LARSON INFORMATION AS WE GO FURTHER BACK. I GUESS IT'S IN THIS FILE. LET'S GO TO THE LETTER FROM MR. LARSON BACK TO MR. EARL. A. OKAY. Q. DR. CRAFT, YOU ARE CC'D ON THIS LETTER ALONG WITH DR. DAVIS, DR. PATRICK, AND DR. RICHARDSON. HAVE YOU COORDINATED WITH THESE THREE OTHER GENTLEMEN IN RELATION TO YOUR WORK IN WATER CONSERVATION AREA 2A? A. NO. THIS WAS THE FIRST DAY ON THE JOB, IN FACT, DR. CRAFT VOLUME II PAGE 415 OR THE SECOND DAY, AND I WENT OUT IN THE FIELD TO COLLECT THE CORES, AND ALL THESE FELLOWS WERE THERE, TOO. Q. THEY JUST HAPPENED TO BE THERE THE SAME DAY YOU WERE? A. NO. I MEAN, I DON'T KNOW WHAT, YOU KNOW, THE RELATIONSHIP WAS. I WAS HIRED TO LOOK AT PEAT ACCRETION AND NUTRIENT ACCUMULATION, AND, OF COURSE, I WAS OUT THERE DOING THE CORE TAKING. AND I RECALL ONE OF THOSE GUYS -- I THINK JOHN DAVIS -- WAS OUT THERE AND HAD A MOBILE PHONE AND WAS STANDING IN THE MIDDLE OF THE EVERGLADES TALKING ON THE PHONE, WHICH I THOUGHT WAS KIND OF--- Q. BUT, THIS WAS AT THE TOP OF WATER CONSERVATION AREA 2A? A. I RECALL THAT WAS ACTUALLY OUT IN THE SOUTHWEST PART IN ONE OF -- IN A DRIED UP SLOUGH. THIS WAS IN, I THINK, THAT 1989 DROUGHT. IT WAS VERY DRY OUT THERE, YOU COULD WORK IN YOUR TENNIS SHOES. Q. SO, YOU WEREN'T WITH THE SIXTEEN FOOT ALLIGATORS AND JOHN DAVIS? A. I DON'T KNOW WHERE THEY WERE. I DON'T KNOW IF A DR. CRAFT VOLUME II PAGE 416 SIXTEEN FOOT ALLIGATOR COULD EAT HIM. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER.) Q. (BY MS. PONZOLI) I TAKE IT, THEN, YOU DID NOT GO ON THE AERIAL TOUR WITH THEM? A. ON THAT DATE -- ON THOSE DATES, I DID, BECAUSE WE TOUCHED DOWN IN A LOT OF PLACES, OR IN SEVERAL PLACES, AND I TOOK SAMPLES. Q. OKAY. SO, YOU DON'T KNOW WHO SET UP ALL OF YOU TO GO OUT THERE TOGETHER, IS THAT ACCURATE? A. THAT'S CORRECT. Q. ALL RIGHT. BUT YOU WERE IN THE LONG RANGER? A. WE WERE IN ONE OF THOSE CRESCENT AIRWAY'S HELICOPTERS. I REMEMBER I WAS MOTION SICK, I THOUGHT I WAS GOING TO BARF ON SOMEBODY. CURT CAN ATTEST TO THAT. Q. I WON'T EVER GO IN A HELICOPTER WITH YOU. A. I TAKE THOSE PATCHES NOW, AND IT'S A LOT BETTER. Q. I CAN SEE WHY ACCESSIBILITY WAS IMPORTANT FOR THE FERTILIZER STUDY. A. IT'S JUST -- YOU DON'T -- IT'S HARD -- YOU DON'T WANT TO HAVE TO -- IF YOU WANT TO GET WORK DONE, DR. CRAFT VOLUME II PAGE 417 YOU DON'T WANT TO HAVE TO DEPEND ON SOMEBODY TO TAKE YOU IN AN AIR BOAT OR IN A HELICOPTER. Q. OKAY. SO, YOU DON'T KNOW WHO SET THIS UP, BUT THE PEOPLE WHO WERE ON THIS TRIP WERE MR. LARSON, YOURSELF, DR. DAVIS, DR. PATRICK, AND DR. RICHARDSON? A. YES. I DON'T -- I REMEMBER EVERYBODY, I THINK, BUT BILL EARL. THE OTHER THREE PEOPLE, I DEFINITELY, YOU KNOW, REMEMBER THEM. AND I'M SURE HE WAS THERE, BUT I CAN'T VISUALIZE HIS FACE. Q. YOU DON'T REMEMBER MR. EARL? A. NO. HE'S MAYBE ONE OF THOSE FORGETFUL KIND OF PEOPLE. Q. IT'S NOT MY IMPRESSION. ANYWAY, SO YOU -- TELL ME WHAT YOU DID. YOU SPENT A WHOLE DAY DOING WHATEVER YOU DID? A. WE TOUCHED DOWN IN, I THINK, THREE LOCATIONS IN CONSERVATION AREA 2A, AND I TOOK SOIL SAMPLES. I THINK WE ALSO TOOK SOME ABOVEGROUND PLANT SAMPLES OF SAWGRASS AND CATTAIL AND ALSO WE TOOK SOME ROOT SAMPLES. Q. WAS ANYONE TAKING SAMPLES OTHER THAN YOURSELF? A. I DON'T BELIEVE SO. I THINK I WAS -- WELL, DR. RICHARDSON AND I WERE TAKING THE SAMPLES. BUT DR. CRAFT VOLUME II PAGE 418 I THINK BEYOND US TWO, I DON'T THINK SO. Q. OKAY. YOU TOOK SOIL SAMPLES, YOU TOOK VEGETATION SAMPLES, AND YOU TOOK ROOT SAMPLES? A. AND WE MAY HAVE TAKEN SOME WATER SAMPLES WHERE WE COULD FIND WATER, BUT I -- AS I RECALL, IT WAS REALLY BONE DRY OUT THERE. Q. OKAY. THREE LOCATIONS, YOU BELIEVE? A. IN 2A, YES. Q. UH-HUH (YES). ARE THEY REFLECTED ON THE MAP THAT'S A COUPLE OF PAGES AHEAD OF THAT ESTABLISHED 9/30/89, SOMETHING ANOTHER -- IS IT RICHARDSON AND CRAFT? A. THEY ARE ON ONE OF THESE, AND I CAN PROBABLY FIND THAT FOR YOU. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. YEAH, I THINK THAT'S IT. IS THAT FURTHER ALONG--- Q. WELL, WHY--- A. ---TOWARD THE BACK? Q. ---DON'T YOU JUST LOOK THROUGH IT AND GET FAMILIAR -- THERE'S A PAGE FOLLOWING -- A COUPLE OF PAGES BEYOND--- A. THAT'S GOT TO BE--- Q. ---BEYOND THE LETTER. A. ---BECAUSE THIS WAS ALL ONE BIG HANDOUT. YOU CAN DR. CRAFT VOLUME II PAGE 419 SEE A LETTER FROM BILL EARL -- OR NOT BILL EARL, BILL EVANS. YES. THIS ONE HERE, YOU CAN SEE THESE CIRCLES; THEY ARE LIKE BULL'S-EYES HERE. THOSE WERE TWO OF THE LOCATIONS. Q. OKAY. A. AND THEN THE THIRD LOCATION WAS DOWN HERE WHERE IT SAYS -- IT'S NEAR THE WORDS "ALERT AREA," THERE'S KIND OF A BULL'S-EYE DOWN IN THE SOUTHWEST PART--- Q. OKAY. A. ---SOUTHWEST OF THE CANAL. Q. AND AT THESE SITES, YOU PULLED SOIL, VEGETATION, ROOT, AND WATER, YOU BELIEVE? A. DEFINITELY SOILS AND VEGETATION. THE WATER, I JUST DON'T -- WE MAY HAVE BEEN PREPARING TO TAKE WATER, BUT THERE JUST WASN'T ANY OUT THERE. Q. OKAY. SO, YOU WENT INTO 2A. WHERE ELSE DID YOU GO? A. I THINK OTHER THAN THAT -- I THINK WE MADE THAT BIG FLY-OVER -- WE FLEW DOWN ACROSS 3A ALONG THE TAMIAMI TRAIL, AND THEN WE FLEW UP ALONG THE BOARDER BETWEEN THE EVERGLADES AND THE BIG CYPRUS, AND THEN I THINK WE FLEW BACK TO THE WEST PALM BEACH AIRPORT. Q. OKAY. IS THAT WHERE YOU LEFT FROM WAS THE PALM DR. CRAFT VOLUME II PAGE 420 BEACH AIRPORT? A. I THINK SO. I THINK, BECAUSE -- I'M PRETTY SURE WE DID LEAVE FROM THERE. Q. DID ANYONE EXPLAIN THE SYSTEM TO YOU THAT DAY? A. WHAT DO YOU MEAN THE SYSTEM? Q. WELL, DID SOMEONE NARRATE THE HELICOPTER TRIP, AND SAY, NOW YOU'RE LOOKING AT 2A AND THIS IS WHAT YOU'RE SEEING; AND NOW YOU'RE LOOKING AT 3A AND--- A. I THINK -- I THINK PAUL LARSON MAY HAVE DONE THAT, BUT, AGAIN, I'M NOT A HUNDRED PERCENT SURE. Q. OKAY. DO YOU RECALL THE TYPE OF THINGS HE WAS TELLING YOU? A. JUST OTHER THAN THE PARK IS OVER HERE, AND THIS IS CONSERVATION AREA 3A. AND I DO BELIEVE WE FLEW ALONG THE EDGE OF THE EVERGLADES AGRICULTURAL AREA BECAUSE I THINK WE SAW SOME CATTLE AND SOME SUGARCANE FIELDS. Q. YOU SAW CATTLE? A. YEAH, I DO REMEMBER THAT. AND MY HEAD WAS HANGING OUT THE WINDOW, BELIEVE ME. THAT WAS A BAD EXPERIENCE. I WAS SO THANKFUL WHEN THEY LANDED. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION DR. CRAFT VOLUME II PAGE 421 WHICH WAS NOT REPORTED BY THE COURT REPORTER.) Q. (BY MS. PONZOLI) DID YOU UNDERSTAND WHAT ROLE THESE OTHER GENTLEMEN HAD ON THIS HELICOPTER TRIP? A. NO. I MEAN, I REALLY -- THIS WAS THE FIRST TIME, WITH THE EXCEPTION OF BILL PATRICK, WHO I'VE MET AT MEETINGS, THAT I HAD EVER MEET THESE GENTLEMEN, SO--- Q. OKAY. DO YOU NOW UNDERSTAND WHAT ROLE, LET'S SAY, FOR EXAMPLE, DR. PATRICK HAS IN THE EVERGLADES? A. NOT REALLY. I THINK HE'S MAYBE A CONSULTANT TO ONE OF THE INTERESTED PARTIES. Q. DO YOU KNOW WHAT TYPE OF WORK HE'S DOING? A. THAT I DON'T KNOW. I MEAN, IN TERMS OF HIS SCIENTIFIC RESEARCH, GENERALLY, I KNOW WHAT TYPE OF WORK HE'S DOING. Q. WHAT DOES DR. PATRICK DO GENERALLY? A. HE'S A -- WELL, HE MANAGES A WETLAND SOILS LAB AT LOUISIANA STATE UNIVERSITY, HE'S THE DIRECTOR, AND HE'S JUST A VERY WELL-KNOWN, VERY WELL-RESPECTED WETLAND SOIL SCIENTIST -- HAS, YOU KNOW, PUBLISHED PROBABLY HUNDREDS OF PAPERS, SO I KNOW HIM DR. CRAFT VOLUME II PAGE 422 PROFESSIONALLY. HIS CONSULTING WORK, I REALLY DON'T KNOW ABOUT. Q. OKAY. SO, YOU KNOW NOTHING ABOUT THE CONSULTING WORK THAT HE'S DOING FOR ONE OF THE INTERESTED PARTIES? A. NO. I'M NOT--- Q. DO YOU EVEN KNOW WHICH INTERESTED PARTY HE'S DOING IT FOR? A. WELL, I SUSPECT IT HAS TO DO WITH THE AGRICUL -- SOMEBODY WITH AGRICULTURE. BUT BEYOND THAT, I DON'T KNOW. Q. OKAY. HOW ABOUT MR. DAVIS? A. I'M AWARE THAT HE'S A CONSULTANT, I THINK TO SOME OF THE AGRICULTURAL INTERESTS, ALSO. Q. DO YOU KNOW WHAT KIND OF WORK HE'S DOING? A. THAT I DON'T KNOW. I KNOW THAT HE'S THE HEAD OF THE -- OR HE'S ENVIRONMENTAL SERVICES AND PERMITTING, I'M AWARE OF THE NAME OF THE COMPANY HE'S WITH, OR THAT HE'S THE HEAD OF. Q. UH-HUH (YES). ARE YOU EVER GIVEN ANY OF DR. PATRICK'S OR DR. DAVIS' WORK TO LOOK AT IN THE SAME WAY YOU WERE GIVEN DR. KADLEC'S AND DR. WALKER'S? A. I HAVEN'T SEEN ANY OF THAT, EXCEPT I THINK MAYBE DR. CRAFT VOLUME II PAGE 423 I HAD ONE PAGE THAT WAS GIVEN TO ME FROM DR. PATRICK, OR NOT DIRECTLY FROM HIM, BUT THAT WAS PASSED ON TO ME SEVERAL YEARS AGO. AND, AGAIN, I THINK IT'S IN ONE OF THOSE FILES THAT YOU ALL XEROXED. Q. WHAT WAS IT ON? A. I THINK IT HAD TO DO WITH THE IDEA OF SALT AND THE ROLE OF SODIUM CHLORIDE MAYBE IN CATTAIL ENCROACHMENT. Q. DID HE THINK THERE WAS A RELATIONSHIP? A. I THINK HE THOUGHT THAT IT WOULD BE WORTH TAKING A LOOK AT. I'M NOT SURE IF HE THOUGHT THERE WAS A RELATIONSHIP, BUT IT WAS SOMETHING THAT SHOULD BE PERHAPS LOOKED INTO. Q. OKAY. SO, YOU WENT TO 2A. DID YOU UNDERSTAND THE ROLES OF ANYONE ELSE THAT DAY, OF WHAT THEY WERE DOING? A. NO. I MEAN, ALL I KNEW WAS THAT I WAS DOING MOST OF THE WORK. BUT THAT'S TO BE EXPECTED WHEN, YOU KNOW, WHEN YOU'RE FIRST BROUGHT ON. Q. WAS THAT A CLUE? A. WELL, YOU FIGURED THEY WERE BIG SHOTS. BUT OTHER THAN THAT, I DON'T KNOW. Q. ALL RIGHT. HAVE YOU COME SUBSEQUENTLY TO DR. CRAFT VOLUME II PAGE 424 UNDERSTAND THE ROLES THAT ANY OF THESE OTHER PEOPLE HAVE? A. OTHER THAN WHAT I'VE TOLD YOU, AND I KNOW BILL EARL, HE'S A -- I GUESS A LAWYER, OR I THINK RICK WORKS WITH HIS PARTY, I THINK. BUT OTHER THAN THAT, I DON'T KNOW. Q. HAVE YOU SEEN ANY DOCUMENTS -- HAVE YOU SEEN ANY OTHER LARSON DOCUMENTS FOLLOWING THESE? A. I DON'T KNOW. I MAY HAVE SEEN SOMETHING AGAIN. I KNOW HE WAS INVOLVED IN THE VEGETATION MAPPING AND THE CATTAIL DISTRIBUTION. AND I DON'T THINK CURT PASSED ANYTHING ON TO ME, BUT HE MAY HAVE SHOWN ME SOMETHING AT ONE TIME, BUT--- Q. OKAY. WHEN YOU PULLED YOUR SOIL SAMPLES, WERE THESE CORES? A. YES. Q. OKAY. YOU PULLED THE TRADITIONAL RICHARDSON CORE? A. RIGHT -- CORRECT, YES. Q. AND YOU DID -- DID YOU DO THE FULL RANGE OF TEST ON IT THAT WE'VE DISCUSSED IN REGARD TO OTHER CORES? A. YES. WE MEASURED THE CESIUM, THE BULK DENSITY, PHOSPHORUS, THE OTHER ELEMENTS THAT WE WERE LOOKING AT. DR. CRAFT VOLUME II PAGE 425 Q. DO YOU KNOW -- DO YOU KNOW WHAT DR. RICHARDSON DOES IN RELATION TO ALL OF THIS? A. I'M JUST AWARE OF HIS ROLE AS DIRECTOR OF THE WETLAND CENTER AND OVERSEEING THE, YOU KNOW, OUR RESEARCH RELATING TO THE EVERGLADES -- TO THE WHATEVER, THE EVERGLADES PROTECTION DISTRICT. Q. OKAY. ARE YOU AWARE THAT HE'S AN EXPERT WITNESS, ALSO? A. YES, I AM AWARE THAT HE IS AN EXPERT WITNESS AND I'M AWARE DR. RADER, I THINK, IS AN EXPERT WITNESS, TOO. Q. OKAY. AND YOU'RE AWARE THAT -- AT LEAST, I KNOW DR. RADER'S IS COMPENSATED. AND I ASSUME DR. RICHARDSON IS COMPENSATED FOR THAT SEPARATELY. ARE YOU AWARE OF THAT? A. I FIGURED AS MUCH, BUT I DON'T -- YOU KNOW, IT'S NONE OF MY BUSINESS. Q. OKAY. I HAVE TO ASK YOU, ARE YOU BEING COMPENSATED? A. I'M JUST BEING COMPENSATED AS A EMPLOYEE OF DUKE UNIVERSITY. I MEAN, I WORK FOR DUKE UNIVERSITY AND THAT'S THE ONLY SOURCE OF INCOME RELATING, YOU KNOW, TO WORK THAT I GET. Q. YOU GET NO OTHER FEES FOR CONSULTATION--- DR. CRAFT VOLUME II PAGE 426 A. NO, NO. Q. ---OR PULLING CORES--- A. I'M NOT SURE WHETHER I'D WANT TO EITHER; I HAVE MIXED FEELINGS ABOUT THAT. Q. OKAY. HAVE YOU EVER HAD CONVERSATIONS WITH MR. LARSON FOLLOWING THIS, REGARDING YOUR VEGETATION WORK OR HIS VEGETATION WORK? A. YES. THERE WAS ONE TIME HE CALLED. AND, IN FACT, I HAVE SOME INFORMATION IN THIS DOCUMENT. HE INFORMED US -- HE WAS THE ONE THAT INFORMED US THAT OUR COORDINATES, HE THOUGHT, WERE NOT RIGHT USING LORAN-C, BECAUSE HE WENT OUT AND FOUND THAT THE GPS GAVE DIFFERENT COORDINATES. AND THAT WAS ONE REASON WE DECIDED WE SHOULD GO OUT AND REASSESS THE LOCATION OF OUR PLOTS. Q. WHEN WAS THIS? A. I THINK IT WAS ABOUT A YEAR AGO. I MEAN, IT HAS BEEN WITHIN THE PAST, I WOULD SAY, TWELVE TO EIGHTEEN MONTHS. IT'S -- YOU KNOW, IT'S BEEN A YEAR, BUT I CAN'T SAY FOR CERTAIN WHEN IT WAS. Q. ANY OTHER CONVERSATIONS WITH MR. LARSON? A. I DON'T THINK SO. Q. WHY DID HE FORWARD THESE -- HOW DID YOU GET THESE DR. CRAFT VOLUME II PAGE 427 DOCUMENTS -- OH, YOU GOT THESE DIRECTLY FROM MR. LARSON--- A. I THINK I WAS A -- RIGHT. Q. ---YOU WERE CC'D? A. YEAH. Q. WHY DID HE SEND THESE TO YOU? A. WELL, WE WANTED TO KNOW THE LOCATION OF WHERE WE TOOK THE CORES. THAT WAS THE WHOLE POINT. Q. OKAY. A. THIS ALL CAME AS ONE BIG LUMP, I BELIEVE, OR MOST OF THIS -- THESE THREE CERTAINLY. AND I DON'T KNOW ABOUT THIS ONE HERE, BUT THIS MAY HAVE COME WITH HIS, ALSO. Q. OKAY. AND WHAT YOU ARE TALKING ABOUT IS FIGURE TEN, SUMMARY OF RESULTS--- A. RIGHT. A. ---7/12/89 VEGETATION SURVEYS? A. RIGHT. THAT PROBABLY CAME -- SINCE IT HAS HIS NAME ON IT, IT PROBABLY CAME WITH ALL THIS. Q. OKAY. IS THIS MR. LARSON'S VEGETATION SURVEY? A. THAT, I'M NOT -- I DON'T KNOW. I THINK -- I ALWAYS HAVE TROUBLE TELLING WHOSE -- WHETHER IT'S THE DISTRICT'S WORK, OR HAS BEEN SOME OF HIS WORK. I'M ASSUMING IT'S HIS, SINCE IT'S ON LARSON AND DR. CRAFT VOLUME II PAGE 428 ASSOCIATES PAPER. Q. I'VE WAITED YEARS TO SEE THIS. A. SERIOUSLY? Q. SERIOUSLY. A. YOU SHOULD HAVE CALLED ME UP. Q. IF I'D ONLY KNOWN. THE HOLY LAND--- A. YES. Q. ---IS THE LAST, 9/27/89. I TAKE IT YOU DID NOT DO THIS THAT DAY? A. NO. AND ACTUALLY THE PREVIOUS PAGE, WE TOOK SOME MORE CORES IN SEPTEMBER OF '89. AND AGAIN, I GUESS PAUL LARSON WAS INVOLVED IN THIS, ALTHOUGH I DON'T REMEMBER THAT TRIP LIKE THE FIRST ONE. Q. YOU HAD THE PATCHES ON? A. UH-HUH (YES). Q. OKAY. LOOKING AT THE HOLY LAND, WHEN WAS THIS -- THIS WAS 9/27/89? A. IT WAS SEPTEMBER '89, YES. Q. OKAY. WHAT WAS THE PURPOSE OF THIS TRIP? A. AGAIN, WE WERE JUST TRYING TO GET A HANDLE ON JUST WHAT THE AREAS THAT WE WERE ABLE TO SAMPLE -- WHAT THE RATES OF PEAT ACCRETION AND NUTRIENT ACCUMULATION WERE. AND, ALSO, I THINK WE PROBABLY TOOK SOME PLANT SAMPLES AND SOME WATER SAMPLES DR. CRAFT VOLUME II PAGE 429 HERE--- Q. OKAY. A. ---WE TOOK TWO CORES, AS YOU CAN SEE MARKED. Q. RIGHT. RIGHT. DID YOU DO ANYTHING WITH THIS DATA? A. WE ANALYZED IT, AND THE CESIUM PROFILES WERE NOT -- THEY DIDN'T COME OUT. AND THEN I FOUND OUT THAT THEY USE TO USE THE HOLY LAND AS A BOMBING RANGE, SO I COULD SEE WHERE CESIUM MIGHT NOT WORK SO WELL. Q. I DON'T MEAN TO BE STUPID, BUT WOULD IT HAVE JUST BEEN MESSED UP; I MEAN, THOSE WOULDN'T HAVE BEEN RADIOACTIVE TEST OUT THERE? A. NO. BIG CRATERS--- Q. OH, BIG CRATERS WOULD JUST--- A. ---WOULD DISTURB THE PEAT. Q. ---JUST DISTURB THE WHOLE BENCHMARK? A. YEAH. Q. OKAY. WHO WENT ON THIS HELICOPTER TRIP TO THE HOLY LAND? A. I DON'T REMEMBER, BUT I'M SURE IT WAS DR. RICHARDSON AND MYSELF AND THE PILOT. AND I REALLY DON'T REMEMBER WHO ELSE, IF ANYBODY. Q. HAVE YOU DONE -- OTHER THAN THIS 9/27/89 TRIP TO DR. CRAFT VOLUME II PAGE 430 THE HOLY LAND, HAVE YOU DONE OTHER TRIPS TO THE HOLY LAND? A. THIS WAS THE ONE -- ONE TIME -- ONE SHOT DEAL, I GUESS. Q. OKAY. I'D LIKE TO LOOK BACK AT ONE OTHER OF THESE MAPS AND JUST ASK YOU SOME QUESTIONS. (MS. PONZOLI LOOKS THROUGH DOCUMENTS.) Q. OKAY. GOING BACK TO, I GUESS, THE ONE I HAD ASKED YOU BEFORE, ESTABLISHED 9/30/89, AND IT SAYS RICHARDSON AND CRAFT. ARE YOU WITH ME? A. NO, BUT I'M WORKING ON IT. (THEREUPON, WITNESS LOOKS FOR DOCUMENT.) A. HOW FAR IN IS THAT -- IS IT BACK QUITE A FEW PAGES? Q. IT MAY BE PRETTY MUCH IN THE MIDDLE. A. OKAY. YEAH, I THINK I'M THERE -- RIGHT HERE? Q. OKAY. IS THAT BENCHMARK -- IS THAT YOURS OR WHOSE? A. THIS IS -- I'M PRETTY SURE THIS IS WHAT THE HELICOPTER PILOT WAS DOING WHILE WE -- HE HAD THE LORAN WITH THE HELICOPTER. AND WHEN WE WERE COLLECTING SAMPLES, HE WAS, YOU KNOW, TRYING TO SET UP OR DETERMINE WHERE WE WERE -- THE COORDINATES. DR. CRAFT VOLUME II PAGE 431 Q. SO, THESE ARE JUST YOUR COORDINATES, IS THAT RIGHT? A. RIGHT. Q. THERE ARE SOME MORE LARSON DOCUMENTS IN ANOTHER FILE THAT I'D LIKE TO ASK YOU ABOUT. IT'S CRAFT NUMBER ELEVEN. I DON'T KNOW IF WE -- DID WE REPRODUCE THAT ONE PRETTY MUCH IN ITS ENTIRETY FOR YOU? A. I HAVE A LOT OF INFORMATION, YES. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. OKAY. WHAT IS THIS PARTICULAR FILE? A. THIS LOOKS LIKE THIS WAS THE -- WHEN WE WENT OUT AND MEASURED, WE FIRST SET UP OUR PERMANENT VEGETATION PLOTS AND MEASURED THE SPECIES COMPOSITION IN 1990. Q. WHAT -- IF YOU'D TURN TOWARD THE BACK, YOU HAVE -- WE HAVE -- I GUESS IT'S A FAX FROM LARSON AND ASSOCIATES IN 2/11/91 TO DR. QUALLS. HOW DID YOU COME TO HAVE THIS DOCUMENT, DR. CRAFT? A. I THINK JERRY OR DR. QUALLS PROBABLY PASSED IT ON TO ME SINCE I WAS DOING THE VEGETATION WORK. Q. OKAY. A. AND I'M NOT QUITE SURE WHY HE ENDED UP GETTING IT, YOU'LL GET TO ASK HIM THAT. DR. CRAFT VOLUME II PAGE 432 Q. SO, THE NOTE, "PLEASE REVIEW RELATIVE TO CHANGES OBSERVED ON YOUR TRANSECTS," REALLY IS A NOTE PROBABLY TO YOURSELF? A. WELL, THAT'S HIS WRITING, BUT I'M ASSUMING WHAT HE'S TALKING ABOUT IS MAYBE, SINCE HE HAD SOME GOOD VEGETATION DATA, MAYBE TRYING TO COMPARE OUR DATA TO WHAT HE FOUND ON HIS LINES. Q. OKAY. SO, YOU DID CONSULT AT THIS TIME WITH -- DID YOU TALK WITH MR. LARSON? A. NO. AGAIN, I THINK THIS WAS MORE FOR JUST MY BENEFIT. AND, SEE, HIS LINES ARE NOT THE SAME AS OUR TRANSECT, SO IT'S--- Q. RIGHT. A. ---YOU CAN'T REALLY DIRECTLY COMPARE THEM, YOU CAN JUST KIND OF GET AN EYEBALL, YOU KNOW, JUST SORT OF ESTIMATE. Q. OKAY. A. AND I DON'T SEE -- WELL, YOU CAN SEE SOME OF OUR POINTS ON THE NEXT TO THE LAST PAGE. IT LOOKS LIKE SOMEBODY -- MAYBE JERRY -- DRAWN IN D1, D2, D3, AND D4, AND YOU CAN SEE HIS TRANSECTS TEND TO RUN IN-BETWEEN OURS. Q. I'M NOT WITH YOU EXACTLY. SHOW ME WHAT YOU'RE--- (THEREUPON, WITNESS POINTS TO DOCUMENT.) DR. CRAFT VOLUME II PAGE 433 A. NEXT TO THE LAST PAGE. Q. IS THIS IT? A. SEE WHERE IT LOOKS LIKE SOMEBODY'S WRITTEN D1 -- WELL, D2, D3, D4 -- JUST SORT OF KIND OF SO WE CAN SEE WHAT HE FOUND AND SEE IF OUR NUMBERS SORT OF JIVE WITH THAT OR ARE SIMILAR. Q. OKAY. OKAY. SO, THIS IS NOT -- THIS VEGETATION WORK REFLECTED HERE, LIKE CATTAIL, PIGWEED, SAWGRASS, ETCETERA--- A. RIGHT. Q. ---THIS IS NOT YOUR VEGETATION WORK--- A. NO. THIS IS SOME WORK HE APPARENTLY DID. Q. ---THIS IS MR. LARSON'S? A. YEAH. Q. OKAY. AND THEN THE LAST PAGE, IS THAT THE SAME? A. I BELIEVE THAT'S THAT FIGURE WE SAW IN THE PREVIOUS EXHIBIT. Q. AND YOU BELIEVE THIS IS LARSON'S WORK? A. WELL, JUST -- I THOUGHT IT SAID AT THE TOP ON THE OTHER PAGE IT WAS FROM LARSON AND ASSOCIATES, SO, YEAH, I THINK THIS IS HIS WORK. Q. OKAY. DID YOU COMPARE YOUR WORK WITH THIS? A. I THINK I JUST LOOKED AT IT TO -- JUST TO GET A RELATIVE IDEA. THE ONE THING IS -- YOU KNOW, WITH DR. CRAFT VOLUME II PAGE 434 A MAP LIKE THIS, IT'S HARD TO REALLY PIN -- WE CAN PUT OUR PLOTS ON THERE, BUT YOU SEE HIS DETAIL IS NOT THAT GREAT -- FIFTY PERCENT (50%) OR MORE SAWGRASS, FIFTY PERCENT (50%) OR MORE CATTAIL, OTHER, YOU KNOW, WHEREAS WE ACTUALLY TRIED TO, YOU KNOW, GO INTO MORE DETAIL WITH THE INDIVIDUAL SPECIES. Q. WERE YOU ON THE JULY 12, 1989, SURVEY? I CAN'T REMEMBER THE DATES THAT YOU WERE WITH DUKE. A. NO, NO. I WAS NOT INVOLVED IN THAT. Q. OKAY. A. I WENT OUT IN JUNE OF '89, SEPTEMBER OF '89, IN A HELICOPTER, AND JANUARY OF '90. Q. DO YOU HAVE ANY IDEA, IF YOU LOOK AT THIS MAP FROM LARSON--- (THEREUPON, MS. PONZOLI SHOWS WITNESS DOCUMENT.) A. OKAY. I WILL FIND IT. I HAVE IT. Q. DO YOU HAVE ANY IDEA IF THIS SURVEY LIMITS LINE IS AS FAR AS THEY WENT? A. I DON'T KNOW. SOMETHING LIKE THAT WOULD SOUND TO ME LIKE THAT IS AS FAR AS THEY WENT, BECAUSE THEY SHOW THEIR TRANSECTS NOT GOING ANY FARTHER THAN THAT. Q. YOU HAVE NO IDEA OF HOW THE SURVEY LIMIT LINE WAS DR. CRAFT VOLUME II PAGE 435 DETERMINED EXCEPT THAT THAT WOULD APPEAR JUST RATIONALLY FROM THE WAY IT'S DRAWN? A. RIGHT. Q. OKAY. ALL RIGHT. THE MECHANISMS FOR CATTAIL MAINTENANCE FOR SAWGRASS COMMUNITIES--- A. IS THIS IN THE SAME EXHIBIT? (THEREUPON, MS. PONZOLI SHOWS WITNESS DOCUMENT.) A. OKAY. I HAVE IT. Q. OKAY. DID YOU WRITE THIS? A. YES. Q. YOU EXTRAPOLATED LARSON'S DATA TO YOUR LOCATIONS, RIGHT? A. RIGHT. Q. BUT YOU JUST ACCEPTED HIS FIGURES AS BEING ACCURATE BECAUSE YOU HAD NO WAY OF CONFIRMING THEM YOURSELF? A. OH, RIGHT, CERTAINLY--- Q. OKAY. A. ---I MEAN, THIS IS A SORT OF EXTRAPOLEE. Q. SURE, SURE. AND YOU ASSIGNED THE FIFTY PERCENT TO THE 10D2 SITE AND THE THIRTY PERCENT TO THE 10D3, IS THAT RIGHT? A. I SAY THAT, YES. Q. RIGHT. OKAY. YOU'RE TALKING THROUGH HERE ABOUT DR. CRAFT VOLUME II PAGE 436 THE BURN AND THE FREEZE AND ITS EFFECT ON THE CATTAIL. AND THEN, I THINK, YOU'VE GRAPHED SOME OF THAT ON THE FOLLOWING PAGE. IS THAT ACCURATE? A. YES. Q. OKAY. YOU SHOW IN FEBRUARY OF '91 THAT THE CATTAIL IS RECOLONIZING. IS THAT ACCURATE? A. WHICH ONE ARE WE TALKING ABOUT HERE? Q. BOTH. ACTUALLY BOTH. A. BOTH. OKAY, I SEE--- Q. D2 AND D3. A. ---THERE IS AN INCREASE IN CATTAIL OVER AUGUST OF 1990. Q. RIGHT. WHAT -- YOU DON'T THINK IT'S RECOLONIZING THOSE PLOTS? A. NO, NO. I'M SAYING THERE IS AN INCREASE COMPARED TO AUGUST OF 1990. Q. OH, OKAY. SINCE WE'RE IN '92 MOVING ON INTO '93, HAVE YOU BEEN BACK TO THESE SITES, AND CAN YOU TELL ME HOW THESE BARS WOULD LOOK TODAY? WOULD THEY HAVE MORE CATTAIL REFLECTED ON THEM? A. WE'VE BEEN BACK. I WOULD HAVE TO LOOK AT THE DATA TO SEE, BUT WE WERE BACK THIS PAST MAY TO THESE PLOTS. Q. BUT YOU DON'T RECALL WHETHER THEY'VE -- THERE'S DR. CRAFT VOLUME II PAGE 437 BEEN MORE COLONIZATION OF THE CATTAIL SINCE THE TIME IN FEBRUARY '91? A. NO. I MEAN, BUT THE INFORMATION IS THERE, YOU KNOW, AND IT COULD BE LOOKED AT. Q. WHERE WOULD THAT BE IN YOUR DATA? JUST TELL ME, I DON'T WANT TO LOOK FOR IT. A. IN THAT -- IN ALL THAT VEGETATION STUFF WE'VE BEEN TALKING ABOUT, YEAH. Q. OH, IS IT JUST AHEAD OF IT; IS THAT JUST AHEAD OF IT? A. IT'S PROBABLY ALL -- YEAH, ALL -- IT MAY ALL BE IN THIS--- Q. IS THIS ALL IN THIS SAME FILE? A. I THINK SO. LOOK AT THE DATE. WELL, NOW THIS IS 1990. DO YOU HAVE THE '92 STUFF IN HERE? Q. I HAVE SOME '92. I THINK SOMEONE'S WHISPERING TO ME THAT IT MAY BE IN NUMBER TEN. A. NO TALKING OVER THERE. (THEREUPON, WITNESS REVIEWS DOCUMENT.) Q. THAT'S FINE, I CAN LOOK AT IT. A. OKAY. Q. HAVE YOU FORMED ANY CONCLUSIONS, DR. CRAFT, REGARDING THE USE OF FIRE AS A MECHANISM FOR CONTROLLING CATTAIL? DR. CRAFT VOLUME II PAGE 438 A. I HAVEN'T FORMULATED ANY CONCLUSIONS, BUT I THINK IT'S CERTAINLY WORTH LOOKING AT TO SEE IF PERIODIC FIRE CAN BE USED TO MANAGE -- TO MAINTAIN SAWGRASS. I MEAN, I THINK THAT'S SOMETHING THAT SHOULD BE INVESTIGATED. Q. AND YOU WOULD CONSIDER PERIODIC HOW OFTEN? A. THAT'S WHAT I DON'T KNOW ENOUGH ABOUT -- PERHAPS, MAYBE EVERY TWO OR THREE YEARS, I DON'T KNOW. THAT'S WHERE I THINK THESE PERMANENT PLOTS BY GOING BACK AND LOOKING EVERY COUPLE OF YEARS AND SEEING HOW THE PLANTS CHANGE. Q. AND HOW WOULD YOU -- I MEAN, I DON'T MEAN TO BE FACETIOUS -- I REALLY DON'T -- BUT HOW WOULD YOU CONTROL THESE FIRES? A. THEY'D HAVE TO BE PRESCRIBED BURNS, AND I'M NOT, YOU KNOW, SOMEBODY WHO DOES THAT, SO YOU'D CERTAINLY HAVE TO TALK TO SOMEBODY WHO IS -- WHO DOES THAT FOR A LIVING AND SEE. I MEAN, CERTAINLY YOU WOULDN'T WANT TO TRY TO GO OUT THERE AND BURN IN SEPTEMBER WHEN THERE'S THREE FEET OF WATER. THE TIME OF YEAR WOULD BE IMPORTANT TO -- YOU KNOW, I WOULD THINK YOU WOULD WANT TO HAVE WATER MAYBE JUST AT THE SURFACE. I THINK YOU'D NEED A COMBINATION OF BURNING AND THEN MAYBE A CHANGE IN DR. CRAFT VOLUME II PAGE 439 THE WATER LEVEL, TOO, BUT I DON'T KNOW ENOUGH ABOUT IT. I THINK IT'S SOMETHING THAT SHOULD BE LOOKED THOUGH. Q. SO, YOU'D NEED ENOUGH WATER THAT THE PEAT WOULDN'T BURN--- A. RIGHT. Q. ---YOU DON'T WANT IT SO DRY THAT THE PEAT'S BURNING, BUT--- A. YOU WANT IT DRY ENOUGH TO WHERE IT BURNS DOWN TO THE BASE OR PRETTY CLOSE TO IT. YOU MAYBE WOULDN'T HAVE TO HAVE SURFACE WATER. BUT IF YOU HAD IT RIGHT BELOW THE SURFACE, THE PEAT WOULD STILL STAY MOIST. Q. IS THE THEORY OF THIS THAT A SCORCHED EVERGLADES IS BETTER THAN ONE FILLED WITH CATTAILS? MR. GREEN: OBJECT TO THE FORM. A. WELL, NO. I'M NOT SURE IF THE -- IT'S NOT A THEORY. BUT, YOU KNOW, I THINK FROM WHAT YOU READ IN THE LITERATURE, FIRE WAS AN IMPORTANT COMPONENT OF THE HISTORICAL EVERGLADES AND THAT MAY HAVE HELPED MAINTAIN SAWGRASS AGAINST OTHER SPECIES IN THE PAST. Q. DO YOU THINK THAT CONTROLLING CATTAIL IS IMPORTANT FOR MANAGING THE EVERGLADES? DR. CRAFT VOLUME II PAGE 440 A. I THINK IT'S IMPORTANT IF PEOPLE DON'T WANT CATTAIL. THAT'S -- I DON'T KNOW IF THAT'S MY DECISION TO MAKE. IF THEY WANT TO MAINTAIN SAWGRASS, THEN MAYBE THEY NEED TO THINK ABOUT, YOU KNOW, CONTROLLING CATTAIL. Q. IS THERE LITERATURE THAT INDICATES THAT FIRE CONTROLS CATTAIL? A. I DON'T KNOW. I'M NOT AWARE OF IT. BUT, AGAIN, THIS IS NOT SOMETHING I'M REALLY KNOWLEDGEABLE ABOUT. Q. IS DR. RICHARDSON MORE AN EXPERT ON FIRE IN THE EVERGLADES? A. I DON'T KNOW. I'M NOT SURE. HE MAY KNOW MORE THAN ME, BUT, YOU KNOW, I'M NOT SURE IF HE'S AN EXPERT ON FIRE IN THE EVERGLADES. Q. OKAY. I'D LIKE TO MOVE ON TO CRAFT NUMBER SEVENTEEN, AND I DON'T KNOW IF I DID THE WHOLE FILE FOR YOU. THIS IS THE FILE FROM WHICH IT CAME. A. I HAVE SOME PAGES HERE. Q. YEAH. IT LOOKS LIKE YOU HAVE THE WHOLE FILE. THIS IS THE AREA OF ENHANCED PHOSPHORUS ACCUMULATION. IS THAT RIGHT? A. UH-HUH (YES). DR. CRAFT VOLUME II PAGE 441 Q. I WOULD LIKE TO GO TO THE FIRST PAGE OF DATA AND ASK YOU TO EXPLAIN WHAT THIS DATA REFLECTS. A. WE TOOK OUR DATA ON PHOSPHORUS ACCUMULATION IN 2A AND TRIED TO DETERMINE WHAT THE SIZE OF THIS AREA OF ENHANCED PEAT ACCUMULATION IS, AND THIS WAS OUR ATTEMPT TO DO THAT. Q. OKAY. I ASSUME THAT THE AREAS OF ENRICHMENT INCLUDE HIGH ENRICHMENT, MODERATE ENRICHMENT, AND LOW ENRICHMENT. IS THAT ACCURATE? A. RIGHT, WHICH I JUST BROKE OUT ARBITRARILY. Q. OKAY. AND THAT THAT IS DISTINGUISHED FROM THE UNENRICHED AREA? A. CORRECT. Q. OKAY. WHAT IS THIS TOTAL AREA OF FOURTEEN THOUSAND FIVE HUNDRED HECTARES? A. THAT AREA IS THE ELEVEN THOUSAND FIVE HUNDRED ENRICHED AREA PLUS THE ADDITIONAL THREE THOUSAND HECTARES THAT OUR TRANSECTS EXTENDED FURTHER SOUTH OUT OF THE ENRICHED ZONES. SO IT'S JUST THAT YOU ADD THOSE UP. Q. IS THIS THE TOTAL WATER CONSERVATION AREA 2A? A. NO. NO. NO. THIS IS THE ENRICHED AREA PLUS THE UNENRICHED AREA THAT WE SAMPLED. Q. OKAY. AND THEN THE NEXT PAGE REFLECTS WHAT? DR. CRAFT VOLUME II PAGE 442 A. THESE ARE THE PLANIMETER WORK THAT LORI SUTTER CALCULATED TO DETERMINE THE AREA. Q. AND IS SHE COMPARING -- IS THIS YOUR WRITING, OR HERS? A. NO. THIS IS HERS. Q. OKAY. AND WAS SHE COMPARING DR. REDDY'S WORK WITH YOURS? A. WELL, WE WERE JUST TRYING TO DETERMINE -- DR. REDDY'S DONE A LOT OF WORK IN CONSERVATION AREA 2A, AND WE WERE JUST LOOKING AT HIS DATA TO SEE HOW FAR HIS ZONE OF ENRICHMENT EXTENDED VERSUS OUR ZONE OF ENRICHMENT. Q. OKAY. ALL OF THESE ARE STAMPED WITH "DRAFT." IS THAT CUSTOMARY THAT YOU WOULD STAMP YOUR DATA SHEETS DRAFT? A. NOT CUSTOMARY. BUT SINCE THIS NUMBER SEEMS TO BE OF INTEREST TO A LOT OF PEOPLE, WE WOULD LIKE TO MAKE SURE WE HAVE IT RIGHT, OR WE THINK WE HAVE THE BEST ESTIMATE BEFORE, YOU KNOW, WE RELEASE IT, OR, YOU KNOW, LET IT OUT FOR THE PUBLIC TO SEE. Q. OKAY. SO, WHEN YOUR DOCUMENTS WERE PULLED TOGETHER, WERE THEY STAMPED "DRAFT" AT THAT TIME? DR. CRAFT VOLUME II PAGE 443 A. I DIDN'T STAMP THEM DRAFT, SO, I'M NOT SURE. I THINK DR. RICHARDSON MAY HAVE LOOKED AT THESE AND STAMPED THEM, BECAUSE THIS IS SUCH KIND OF A CONTENTIOUS ISSUE. Q. OKAY. DID DR. RICHARDSON REVIEW YOUR DOCUMENTS BEFORE THEY WERE TURNED OVER TO THE UNITED STATES? A. HE DIDN'T REVIEW THEM, BUT I THINK HE LOOKED AT SOME OF THEM. Q. DO YOU KNOW WHO DID CHOOSE TO MARK YOUR DOCUMENTS DRAFT? A. NO, I'M NOT SURE WHO STAMPED THEM -- THIS PARTICULAR ONE. I KNOW THAT IT WASN'T ME, SO. Q. DID YOU MAKE THE DECISION TO STAMP THIS "DRAFT," OR DID DR. RICHARDSON? A. I DID NOT MAKE THE DECISION, SO. Q. YOU DON'T KNOW WHO MADE IT? A. RIGHT. Q. OKAY. HOW DID YOU DISTINGUISH IN THIS ONE BETWEEN THE HIGH, THE MEDIUM, AND THE LOW ENRICHMENT? A. FIRST, WE DEFINED UNENRICHED VERSUS ENRICHED AS AN ACCUMULATION RATE OF .15 GRAMS PER METER SQUARED PER YEAR OR GREATER. WELL -- SO, THAT'S DR. CRAFT VOLUME II PAGE 444 THE OVERALL ENRICHED ZONE. SO, THE LOW AREA GOES FROM .15 TO .40 GRAMS PER METER SQUARED PER YEAR--- Q. OKAY. A. ---THE MEDIUM GOES FROM .40 TO .65. AND THE HIGH GOES FROM .65 TO .90. Q. AND THE LOW WAS THE .15 TO .40--- A. YES. Q. ---WAS THAT THE -- OKAY. ALL RIGHT. I'M SORRY, I THOUGHT THAT WAS UNENRICHED, AND I GOT IT WRONG. A. SO, THE UNENRICHED IS LESS THAN .15. Q. OKAY. THANK YOU. ALL RIGHT. I'D LIKE TO LOOK AT CRAFT NUMBER EIGHTY-EIGHT--- A. I DON'T KNOW WHERE THAT IS. (THEREUPON, WITNESS LOOKS FOR DOCUMENT.) A. OH, OKAY. Q. ---AND I PROBABLY REPRODUCED THE WHOLE DOCUMENT, BUT THERE'S REALLY A PAGE -- A FEW PAGES FROM THE END -- FOUR PAGES FROM THE END THAT I WOULD LIKE TO ASK YOU ABOUT--- A. OKAY. Q. ---THIS PAGE RIGHT HERE. (THEREUPON, MS. PONZOLI SHOWS WITNESS DOCUMENT.) DR. CRAFT VOLUME II PAGE 445 A. OKAY. I HAVE IT. Q. I WOULD LIKE FOR YOU TO TELL ME WHAT THESE DATA ARE. A. THESE ARE THE SOIL TOTAL P AT THE PRETREATMENT COURSE THAT WERE COLLECTED BETWEEN THE PLOTS BEFORE WE STARTED THE STUDY. Q. OKAY. AND THE ASTERISKS ON THIS DATA MEAN WHAT? A. I'M NOT SURE WHAT THEY MEAN -- OH, THEY'RE REVERSED. YOU CAN SEE THE TUBE NUMBERS REVERSE, SEE HOW THEY'RE IN SEQUENTIAL ORDER IN THE BLOCK NUMBER? Q. YES. WELL, NO, I'M SORRY, IT SAYS SEVEN, EIGHT, NINE. A. OKAY. I SEE THESE TWO ASTERISKS WAY DOWN HERE--- Q. YES, SIR. A. ---IF YOU GO TO THE SECOND COLUMN BLOCK NUMBER--- Q. YES, OH, I SEE. A. ---SEE HOW IT STARTS AT ONE. Q. SURE. OH, I SEE, SURE. A. SO, WHAT HAPPENED WAS THOSE TWO JUST GOT REVERSED IN THE BLOCK, AND WE JUST WANTED TO BE AWARE OF THAT AND MAKE SURE WE HAD THE RIGHT NUMBERS. Q. OKAY. ON THE NEXT PAGE, IT HAS SOMETHING ABOUT AN ASTERISK AND IT SAYS "THROWN OUT." WHAT DOES THAT DR. CRAFT VOLUME II PAGE 446 MEAN -- WHAT DOES THAT ASTERISK REFER TO? A. WELL, I'M NOT EXACTLY SURE, BUT IT MEANS THAT WE PROBABLY DIDN'T INCLUDE THE SAMPLING, REDIGESTED IT BECAUSE WE HAD PROBLEMS WITH IT. BUT I DON'T REALLY SEE WHAT--- Q. WAS THAT FROM SAMPLE 1D, PERHAPS, AT THE TOP? A. THAT'S SAMPLE ID--- Q. I'M SORRY, ID. A. ---AND THEN THE ASTERISK IS BELOW THAT, AND I DON'T SEE ANY IDENTIFICATION WITH IT. THAT'S THE THING -- THAT'S NINE, TEN, ELEVEN -- UNLESS IT'S THESE TWO ON THE PREVIOUS PAGE THAT HAVE THE ASTERISKS WITH THEM. MAYBE WE THREW THEM OUT BECAUSE WE DIDN'T KNOW WHICH ONES THEY EXACTLY WERE, ALTHOUGH -- IF WE'D GOTTEN THEM REVERSED. Q. SHOULD THEY HAVE BEEN CLOSER TOGETHER IN THEIR TOTAL PHOSPHORUS? YOU SEE THERE, ONE IS ALMOST DOUBLE THE OTHER. A. WELL, I DON'T KNOW. THAT MAY BE -- I DON'T KNOW WHETHER WE RERAN THOSE SAMPLES OR WHAT. BUT THERE'S A LOT OF VARIABILITY IN THE SOILS OUT THERE. THESE WERE ZERO TO THIRTY CENTIMETER DEEP CORES THAT WERE DRIED AND GROUND UP. DR. CRAFT VOLUME II PAGE 447 Q. DO YOU HAVE EXHIBITS LEFT THAT I HAVEN'T QUESTIONED YOU ON, BECAUSE I HAVE RUN THROUGH MINE? A. WELL, I WASN'T SEQUENTIALLY MOVING THEM OVER UNTIL LATER ON SO. Q. DO YOU HAVE A TWENTY-ONE AND A TWENTY-NINE? A. UH-HUH (YES). MAYBE THESE ARE THE TWO THAT REMAIN. MR. BURGESS: TWENTY-ONE AND TWENTY-NINE? WITNESS: YES. TWENTY-ONE AND TWENTY-NINE. (THEREUPON, MS. PONZOLI AND MR. MAFFEI CONFER.) MS. PONZOLI: I JUST HAVE A FEW QUESTIONS FROM THE ANNUAL REPORTS. WITNESS: CAN WE BACK UP, ARE WE GOING TO DEAL WITH TWENTY-ONE AND TWENTY-NINE? MS. PONZOLI: NO. WITNESS: OKAY. MS. PONZOLI: DO YOU WANT TO? WITNESS: NO, I JUST SAW MARK HANDING THEM TO YOU, SO, I DIDN'T KNOW IF WE WERE DONE ON THIS. DR. CRAFT VOLUME II PAGE 448 MS. PONZOLI: NO, I DON'T THINK I HAVE ANYTHING ON EITHER. WITNESS: OKAY. Q. (BY MS. PONZOLI) I DO HAVE A QUESTION FROM THE ANNUAL REPORT 1992, FROM YOUR CHAPTER ONE. I DON'T HAVE COPIES OF THIS. IF YOU NEED TO SEE IT, I'LL SHOW IT TO YOU. IT'S CHAPTER ONE, THE FERTILIZER STUDY, "RESPONSE OF EVERGLADES PLANT COMMUNITIES TO NITROGEN AND PHOSPHORUS ADDITIONS," ON PAGE 13, UNDER "EXPERIMENTAL DESIGN," YOU TALK IN THE -- I BELIEVE THE SECOND FULL SENTENCE REGARDING "THE THREE COMMUNITIES ARE FOUND ALONG A HYDROPERIOD GRADIENT WITH SAWGRASS EXTENDING ON THE DRIER END OF THE GRADIENT AND SLOUGH COMMUNITY OCCUPYING THE WETTER END." MAYBE I'VE JUST FORGOTTEN, DR. CRAFT, DID WE DISCUSS HOW YOU SET UP A GRADIENT OF HYDROPERIOD? A. WE DIDN'T SET UP A GRADIENT. WE SET UP THE PLOTS AND THEN WE MONITORED WATER LEVELS. AND, BASICALLY, ALL IT SHOWS IS THE WATER LEVEL DATA -- ON PAGE 15 -- SHOWS THAT THE SITES DO APPEAR TO EXIST ON A HYDROPERIOD GRADIENT. THAT WAS NOT AN INTENT. THAT WAS MORE JUST SOMETHING WE OBSERVED DURING, YOU KNOW, ONCE THE STUDY WAS SET UP. DR. CRAFT VOLUME II PAGE 449 Q. UH-HUH (YES). WHEN YOU LOOK AT PAGE 15, AT THE GRAPH, DO YOU BELIEVE THAT YOU ARE SEEING A DIFFERENCE EXCEPT WHEN THE GATES ARE OPENED? A. WELL, IF YOU COMPARE THE SAWGRASS AND THE SLOUGH SITE, THE DIFFERENCE SEEMS TO OCCUR YEAR ROUND. YOU CAN SEE THE SAWGRASS AND THE SLOUGH SITE REALLY SEEM TO MIMIC EACH OTHER IN TERMS OF GOING UP AND DOWN, BUT THE SAWGRASS SITE IS JUST DRIER. THE MIXED SITE SEEMS TO SHOW THAT WHEN THE GATES ARE OPEN, YOU SEE THESE BIG FLUCTUATIONS THERE IN THE MIDDLE OF THE SUMMER. Q. UH-HUH (YES). DO YOU HAVE A HYDROPERIOD STUDY ALSO LOCATED IN 2B? A. DR. RICHARDSON HAS THE LEAD IN A -- IN A NUTRIENT HYDROPERIOD DISTURBANCE STUDY IN 2B. Q. OKAY. NOW, BACK ON 13, YOU SAY, "THE MIXED SAWGRASS-CATTAIL COMMUNITY REPRESENTS AN INTERMEDIATE POSITION ALONG THE HYDROLOGIC GRADIENT." LOOKING AT THE GRAPH ON 15, OTHER THAN THE MIXED SITE RESPONDING SIGNIFICANTLY TO THE OPEN GATES, DOESN'T IT APPEAR THAT THE MIXED SITE IS PRETTY CLOSE TO THE SAWGRASS SITE IN ITS HYDROPERIOD? A. YEAH, I THINK YOU'RE RIGHT. I MEAN, I THINK THAT DR. CRAFT VOLUME II PAGE 450 MAY NOT BE A CORRECT STATEMENT. Q. OKAY. I HAVE PICTURES OF SOME OF YOUR SLIDES--- WITNESS: CAN WE TAKE A BREAK, OR ARE WE GETTING PRETTY CLOSE. MS. PONZOLI: NO. LET'S TAKE A BREAK, I'D LIKE A BREAK, AND I'LL GET A COKE. WITNESS: OKAY. MS. PONZOLI: WHAT -- TEN MINUTES, FIVE MINUTES? WITNESS: OKAY, WE'LL TAKE A BREAK NOW FOR TEN MINUTES? MS. PONZOLI: FIVE MINUTES IS FINE WITH ME. (THEREUPON, THERE WAS AN OFF-THE-RECORD DISCUSSION WHICH WAS NOT REPORTED BY THE COURT REPORTER, AND A SHORT BREAK WAS TAKEN.) MS. PONZOLI: READY? WITNESS: YES. EXAMINATION BY MS. PONZOLI CONTINUES: Q. DR. CRAFT, MY FINAL QUESTIONS ARE REALLY TO HAVE YOU EXPLAIN SOME REPRODUCTIONS FROM YOUR SLIDES THAT WE WOULD JUST LIKE SOME -- TO UNDERSTAND WHAT DR. CRAFT VOLUME II PAGE 451 THEY MEAN. THIS IS DEPOSITION EXHIBIT NUMBER 112, WHICH WERE YOUR SLIDES -- NO, I'M WRONG -- OH, THEY WERE A DIFFERENT SET. I GUESS IT'S NUMBER 113. NO, IT'S NUMBER 117, DEPOSITION EXHIBIT NUMBER 117 CRAFT. AND SINCE THERE IS A SINGLE SET OF THESE, DR. CRAFT, MAYBE IF YOU WOULD JUST EXPLAIN TO EVERYONE SIMULTANEOUSLY WHAT IT REPRESENTS, I WOULD APPRECIATE IT. DO YOU WANT ME TO TURN IT AROUND FOR YOU, OR CAN YOU--- A. IF I WANT TO LOOK AT IT, I'LL JUST -- I CAN PICK IT UP AND JUST LOOK. Q. OKAY. AND WOULD YOU EXPLAIN THIS FIRST PHOSPHORUS ACCUMULATION GRAMS PER METER SQUARED PER YEAR? A. THIS IS A SLIDE THAT I'VE USED TO CONFUSE A LOT OF PEOPLE, INADVERTENTLY. BUT, BASICALLY, THIS IS DATA THAT COMES OUT OF THAT PAPER ON PEAT ACCRETION AND NUTRIENT ACCUMULATION ALONG THE EUTROPHICATION GRADIENT. AND IF YOU LOOK AT THIS,