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1
2 ( NO HIATUS) .
3 Q. Dr. Hackney, can you tell me what
4 you intend to testify about at trial?
5 A. I assume that I will answer whatever
6 questions are asked of me.
7 Q. Do you have any specific areas that
8 you intend to offer conclusions about at trial?
9 A. Yes.
10 Q. Can you or would you please tell me
11 what those areas are?
12 A. I am prepared to answer questions
13 relating to fungi and bacteria as it relates to
14 decomposition.
15 I am prepared to answer questions
16 about cattail and sawgrass growth.
17 I am prepared to offer testimony
18 relating to facets that influence cattail and
19 sawgrass eliminations, sawgrass zonation.
20 I am prepared to offer opinions as
21 to how a lot of the variables relating to the
22 Everglades fit together and relate to plant and
23 and natural communities, assuming someone asked
24 me.
25 I am prepared to answer questions
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1 about the hydrologic alterations relative to
2 what it could do in the general sense of things,
3 in some cases maybe specific.
4 I am prepared to offer opinions
5 relative to successional ideas. Some of the
6 thoughts are parts of others that I have given
7 you.
8 It seems that I have forgotten
9 something and I can't quite remember what I
10 didn't say.
11 Could you read my answer back.
12 (Thereupon answer was read back as
13 reported.)
14 I would say that my testimony is
15 going to likely center around my two areas that
16 I consider my primary expertise. One relates to
17 energetics wetlands systems, many of the
18 components that I have mentioned.
19 The second relates to community
20 dynamics. Again that is also included in some
21 of the details.
22 Q. So those are the two areas of
23 specific expertise, but they may encompass some
24 of the other areas that you mentioned?
25 A. Well, some of the things that I
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1 mentioned earlier are contained within those,
2 and in fact I would say that is primary to what
3 I will be dealing with relative to those subject
4 areas.
5 I mean those are descriptions of
6 topics that could be extremely broad ranging.
7 But my opinions would primarily be
8 related to those areas as they relate to
9 energetics and community dynamics/ interaction,
10 and I would include in that influences of
11 disturbance for both of those as again subject
12 components.
13 Q. When you say that you are prepared
14 to answer questions related to some of these
15 specific areas, for those areas, do you have
16 opinions that you have generated regarding these
17 topics or are you just willing to answer
18 questions?
19 A. Well, both, to the best of my
20 ability.
21 Some of my answers to specific
22 questions would likely be "I don't know", and
23 some would be probably qualified by the quantity
24 of data available and others might be simply
25 speculation, if that is what was requested.
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1 Q. I am going to go through these and
2 ask you some more specific questions on these.
3 The first area that you intend to
4 offer conclusions to, as you said, and I am of
5 course just paraphrasing what you said, but
6 answering questions relating to fungi and
7 bacteria as it relates to decomposition.
8 Would that encompass more than what
9 is set forth in your reports, your draft reports
10 or does that primarily encompass your
11 conclusions in this area?
12 A. I think it encompasses some of the
13 data, some of background documents in terms of
14 references that I have used and so forth.
15 And that document will, to some
16 degree or the other, also attempt to put the
17 phenominum, the fine scale phenominum into a
18 bigger prospective.
19 Q. Do you have any conclusions as to
20 this fungi and bacteria as it relates to
21 decomposition?
22 Do you have any conclusions as to
23 this area that are not set forth in that report?
24 A. There are none. I will not, let me
25 say based on what I have done to now, the answer
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1 is no.
2 But as I told you, I am still again
3 looking and going through those data and going
4 to be again comparing to what other people have
5 done and I envision there will be a change, it
6 could be less robust interpretation, it could be
7 more.
8 Plus there are two documents that I
9 am hoping to get to see sometime before anyone
10 is asking me this question again.
11 Q. What are those two documents?
12 A. Those two documents relate to -- I
13 am not sure that I have the names correct here,
14 the one is the Kraft Richardson dosing studies
15 in which all that I have seen is the first year.
16 I have seen the report and I have
17 seen a draft submitted publication.
18 The second would be the Newman and
19 Grace study which hopefully will be available
20 fairly soon. There may be others.
21 The two documents that I have seen
22 since you asked for my documents last week, for
23 instance, were additional information,
24 additional views, additional since they say the
25 Chapter 15 and 16 from the Everglades.
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1 And I would say as new information
2 becomes available, I would be constantly looking
3 at those data to see whatever they were and
4 reformulating the information that I have, plus
5 my interpretation of how other peoples data fits
6 into the patterns that I think are there.
7 Q. How much time do you anticipate
8 spending over the next several months on this
9 project?
10 A. I really couldn't tell you because I
11 do not know how much of that information is
12 going to be available and how much more is going
13 to be available.
14 I can tell you that based upon the
15 manuscript, that is one little paper that you
16 have, I am probably going to spend another 40,
17 50 hours just working with you and much of that
18 is going to be what I would say, fine scale
19 rewriting, making sure that every part of the
20 manuscript is clear and concise following the
21 general format for journals.
22 Q. How did you get a draft copy of the
23 Kraft Richardson dosing study?
24 A. Well, I haven't seen a draft copy,
25 except for the first year.
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1 Other than I have had a conversation
2 with I think it was Chris Kraft or it might have
3 been Curt Richardson asking them whether the
4 study was still ongoing and that's been probably
5 a year ago.
6 Q. How did you get a copy of the study
7 for the first year?
8 A. The study for the first year -- I
9 think that I have seen several different kinds.
10 One time was as an editor of the General
11 Wetlands when it was submitted for publication.
12 At that time I mean I know I saw it
13 and went through it pretty carefully and I know
14 that I also saw it in several of the
15 depositions. I think I have Mendelsohn's,
16 probably the latest one and I have probably seen
17 it maybe with the Davis documents too.
18 I just can't recall but I have seen
19 it several times.
20 Q. Was that document produced in
21 response to my notice?
22 A. I don't remember if it was the first
23 time. I don't recall it being produced the
24 second time.
25 No, I don't believe, and again I
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1 would have to check with what was produced the
2 first time.
3 I don't remember if that was with my
4 documents or not.
5 Q. If there wasn't, is there any
6 particular reason why you wouldn't have produced
7 that.
8 MR. HYDE: It is a document that is
9 generally available. I don't know if it is
10 encumbent for us to produce documents that the
11 other sides has.
12 These are documents that both
13 Doctors Richardson and Kraft have talked about
14 in a lot of different forms and I have seen
15 copies of it floating around in a lot of the
16 different contexts.
17 MR. NETTLETON: It is not a question
18 of being available. It is a question of knowing
19 what he is relying on, so we would be prepared
20 to ask the questions.
21 MR. HYDE: Well, I don't know that
22 he even said that he was relying on it at this
23 point.
24 He said that he had reviewed the
25 first year on it. That is different than
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1 relying on it.
2 THE WITNESS: Let me clarify this
3 conversation that you all are having.
4 I think I mentioned this document
5 because it is one that when it gets to the stage
6 in which there is a reasonable amount of
7 information, the design of study is such that it
8 should clarify some of the relationships that
9 heretofore are ambiguous, confused, et cetera
10 between hydrology and nutrients.
11 At least that would be my hope.
12 Q. Did you say that you were the editor
13 for the Journal of Wetlands?
14 A. I am an associate editor.
15 Q. How long have you been in that
16 position?
17 A. I was associate editor from 1982
18 through 1987.
19 Then from 1987 through 1990 I was
20 the technical editor.
21 Then from 1993 through present I am
22 an associate editor again.
23 Q. How does the Kraft Richardson study
24 or the Newman and Grace study relate to how
25 fungi and bacteria relate to decomposition?
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1 A. Well, they relate to how the plant
2 is responding to sets of conditions. I am
3 hoping that those two studies will give me some
4 understanding of how that relates with changes
5 in hydrology and changes in nutrients.
6 As I said, I also don't know what
7 other information is going to be in there.
8 What I do know is that there is
9 almost no information, experimental in nature,
10 that was developed I guess before this whole
11 litigation began that does a clear and clear job
12 of looking at those two variables.
13 I am waiting to see what those two
14 documents say about it.
15 Q. How does the Kraft Richardson study
16 do a clear comparison between the effects of
17 nutrients and hydrology?
18 A. I don't know; I haven't seen the
19 final version yet.
20 Q. What leads you to believe that it
21 would?
22 MR. HYDE: I think he said he was
23 hopeful it would.
24 A. I do not know that it will.
25 As I recall, and I do not remember
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1 the details of the design, but I recall that
2 there were going to be dosing experiments in
3 which responsive cattails and sawgrass -- I lost
4 my train of thought.
5 There were going to be dosing
6 studies where cattails and sawgrass were part of
7 the experimental design.
8 As I said, I did not base my
9 testimony up to now on what has come out of that
10 study. It was just one of the documents that
11 might be extremely interesting in reformulating
12 opinions.
13 I have listed those two because
14 those are two that I am aware of. There maybe
15 others that you know about that I don't know
16 about, and if I see them, they go into the big
17 pool of data and understanding and maybe change
18 things and maybe not.
19 Q. Do you think dosing studies are
20 valuable for studying the effects of nutrient
21 systems on the ecosystem.
22 MR. HYDE: Object to the form of
23 question. It calls for speculation and doesn't
24 identify what dosing studies are?
25 A. It is a very broad question. Under
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1 some constraints it can give you part of the
2 picture, a facet.
3 As I stated earlier, there have been
4 very few studies that were done in which there
5 was an attempt to weed out the components of
6 potential interests.
7 Q. What constraints?
8 A. You would have to -- I said that was
9 a very general question and one can design
10 experiments in which you set up experimental
11 conditions and attempt then to evaluate the
12 influence of those experiments, whatever the
13 experiment happens to be.
14 The experiment can be in a green
15 house, it can be in the field.
16 And each type of experiment carries
17 its own limitations and carries its own
18 advantages.
19 Q. Have you reached a final opinion
20 then relating to the issue of fungi and bacteria
21 as it relates to decomposition?
22 A. I do have an opinion now. It may
23 not be my final opinion. My opinion again may
24 change depending on what I see between now and
25 then.
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1 I don't believe that my data is
2 going to alter my opinion substantially one way
3 or the other.
4 Someone else could provide me with
5 the data that could.
6 Q. Is there a specific date by which
7 you have been told to have a final opinion?
8 A. No.
9 MR. HYDE: I would like to interject
10 just a moment for the record here.
11 Dr. Hackney is ready to give his
12 opinions. I think that Dr. Hackney is saying
13 something that many of the other experts in this
14 case are saying, and that is that they are not,
15 after the deposition is over, turning off their
16 brains.
17 They continue to look at things and
18 will continue to look at things for weeks to
19 come.
20 But I think that he has opinions, is
21 ready to give his testimony about what his
22 opinions will be.
23 But I don't think that he is telling
24 you that we are playing some game with you and
25 we are hiding them from you.
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1 The opinions are ready now. We just
2 don't -- nobody turns off their brains after the
3 deposition is over and new information becomes
4 available that could affect things.
5 But I think that is what everybody
6 has been saying.
7 MR. BARTELL: I appreciate that
8 comment.
9 MR. HYDE: I think the best thing to
10 do is ask him if he has an opinion. I think
11 that he told you that he does.
12 Why don't you ask him about it, ask
13 him the basis for it and we can take it if
14 there. Certainly if something changes between
15 now and then, we will have to address that if
16 and when it does occur.
17 But that is something that could
18 occur with any and all of our expert witnesses.
19 I don't anticipate any bold changes of direction
20 from anybody at this point.
21 Q. Just to clarify, is there any
22 specific date by by which you intend to be
23 finished?
24 A. When I'm dead.
25 Let me give you several points of
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1 time which might be of interest to you.
2 As I said, I intend to have this
3 manuscript ready for peer review at the end of
4 March sometime.
5 At that point in time, I think it
6 will reflect my best understanding of this
7 particular facet of what you are interested in.
8 There are other facets that relate to it which
9 are probably more than the big picture that we
10 have been discussing that I suspect are going to
11 continue to develop and change as I see more
12 information.
13 I have not, for instance, seen the
14 now Duke report. I presume there is one coming
15 sometime. There has been an annual report for
16 sometime. I haven't seen that at all and I have
17 no idea what could be in it.
18 There may be documents in it that
19 various agencies are producing which could
20 influence my overall view of things and how I
21 interpret them. But I don't know when they will
22 be.
23 I am constantly looking at documents
24 any time anyone sends them to me. Feel free to
25 send me documents if you wish.
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1 Q. Do you intend to write any reports
2 or put any other opinions onto paper other than
3 the one draft report pertaining to the fungi
4 bacteria as it relates to decomposition?
5 A. Not relative to the Everglades.
6 Q. Relative to this case?
7 A. That is the only document that I
8 anticipate delevoping relative to fungi and
9 bacteria.
10 Q. Do you intend to generate or draft
11 any other documents pertaining to any of these
12 other approximately six to eight areas that you
13 mentioned that you would be prepared to offer
14 opinions at trial?
15 A. No, I have not been asked to produce
16 any such except these.
17 Q. You indicated another area that you
18 would be offering your conclusions or opinions
19 or questions relating to cattail and sawgrass
20 growth.
21 Can you tell me more specifically
22 what conclusions and opinions that you would
23 offer with regard to this area?
24 A. I would say they would probably
25 relate to the variables that influence
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1 combinations of one or the other.
2 Q. Variables such as what?
3 A. Such as hydrology, nutrient loading,
4 however you want to look at that, potential
5 competition.
6 Q. With regard to the nutrient loading,
7 what is your opinion regarding nutrient loading
8 as it relates to cattail and sawgrass growth?
9 A. My opinion is that it is
10 inextricably connected to hydrology and my
11 opinion is that the data connecting growth of
12 cattails and sawgrass to phosphorous is very
13 confusing in terms of the direct relationship
14 that I would have anticipated.
15 Q. What would you have anticipated?
16 A. I think that as a working
17 hypothosis, I would have anticipated that there
18 would have been more direct relationships
19 between let's say soil phosphorous and cattail
20 growth in some of the studies that have been
21 done than were shown.
22 The Urban study, for instance, I
23 thought was provided in an anonmoulous data set
24 in that I really expected there to be, just
25 looking at the design and how it was carried
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1 out, I really would have anticipated their
2 statistical procedures and analysis to have
3 addressed the relationship of cattail production
4 and Sawgrass production to soil phosphorous and
5 phosphorous in the water, for instance, and it
6 didn't as well as I might have suspected.
7 As I said, that is one of the
8 reasons that I am very interested in waiting to
9 see some of the experimental work because that
10 is what it is designed to do.
11 Q. Do you have evidence of any direct
12 relationship between hydrology and cattail
13 and/or sawgrass dominance?
14 A. There are several facets of evidence
15 that I would probably use.
16 One comes from the Urban paper and I
17 can't recall the draft of this. There was one
18 draft for instance where the reviewers -- this
19 was a reviewed draft-- I shouldn't say
20 reviewers, I am not sure who wrote this, it says
21 the only statistical relationship they could
22 find was due to hydrology.
23 The final manuscript which was
24 published independent, used phosphorous loading
25 as the only variable that had a relationship to
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1 cattail sawgrass growth.
2 And the way that variable is
3 generated could very well be a hydrologic --
4 could have a hydrologic characteristic. I
5 couldn't use that alone, but it was an
6 interesting side line.
7 I would also say that my
8 observations having been out in the Everglades,
9 walked around in waders is they were just about
10 to flood in the winter time, leading me to
11 conclude that within small scale variation, that
12 for a large portion, or the time the cattail
13 would be in water, that was 10, 15, 20
14 centimeters deep where they were existing in
15 solid stands.
16 And in areas in which I would see
17 cattail growing, even in background cites, the
18 water level tended to be somewhat higher.
19 Again that is not a big surprise to
20 anyone I think.
21 I will stop there. I am sure there
22 is possibly something else.
23 Q. The question is what evidence of
24 direct relationship between hydrology and
25 cattail or sawgrass dominance and you mentioned
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1 there were several facets of evidence, one of
2 which was this Urban paper, one of which was
3 your time spent in the Everglades.
4 A. Uh-huh.
5 Q. Is there any other examples?
6 A. Yes. I think in some of the areas
7 where there had been some burns and there were
8 alligator holes, I guess I am not sure whether
9 that is a proper term in these cases, but where
10 there was depression, where the water was
11 deeper, the cattails were clearly dominant and
12 under on the edges, sawgrass was clearly
13 dominant.
14 Q. This was from your own observations?
15 A. Uh-huh.
16 Q. Were these areas that you personally
17 made observations in the Everglades near canals
18 or other sources of nutrients loading or let's
19 say man's activities as opposed to way off in
20 the wilderness.
21 Could you sort of describe where the
22 different areas are?
23 A. I would say they would be all of the
24 above, clearly any disturbed areas, cattails are
25 a major component of the community and disturbed
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1 in this case is referring to canals for
2 instance, areas where there had been fires.
3 Q. What other kind of disturbances
4 could there be up there?
5 A. Those are the two that I can think
6 of right now.
7 There were also some cites that were
8 close to levees on the side of a levee, I guess
9 that would be 2-B for instance, where there was
10 not a canal, but the proximity of a levee was
11 such that I would guess there probably would
12 have been some disturbance while the levee was
13 constructed near some of gates for instance on
14 some islands or what had apparently been tree
15 islands at one time.
16 Q. Doctor, going back to the question,
17 were any of these places far from any of these
18 structures or canals?
19 A. Yes.
20 Q. Can you tell me where some of these
21 other locations were where you made these type
22 of observations?
23 A. There were some in Loxahatchee.
24 Q. Can you be more specific and I don't
25 mean latitude; I mean interior along the edges?
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1 A. There were some on what I believe
2 were transectionals A and B, the Loxahatchee
3 entry.
4 These were-- oh, I'm sorry, they
5 are not shown on this figure.
6 Q. The figure that you are refering to
7 is where?
8 A. Is figure one. In that document I
9 had included a number of transections on the
10 Loxahatchee and some were ergosterol data.
11 And there is none in these in what
12 we would be considering as far as the background
13 transectionals as far as the Loxahatchee.
14 So there were some there. There
15 were some in areas that are in the lower part of
16 2-A that were far away from the entrance of--
17 the phosphorous entrance of 2-A.
18 Q. Were they far away from the
19 perimeters of 2-A?
20 A. They were not in the center of 2-A.
21 They were reasonably close to the canal.
22 I don't know what that means, but
23 they were definitely influenced by water that
24 came off the canal versus water flowing across
25 2-A.
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1 Q. How many days did you spend in the
2 Everglades actually in the field?
3 A. You are asking me to real time
4 again. Let me think.
5 I think as part of this project,
6 these studies, I guess, probably about five
7 individual trips with multiple days plus an
8 aerial survey at another time a little bit
9 farther of the Everglades.
10 In terms of total number of days,
11 probably average maybe thirty-five days per
12 trip, something like that.
13 Q. What times of the year?
14 A. I was there in August. I was there
15 I guess at the end of the summer, through the
16 fall and I know I was there in the winter time.
17 I remember that clearly.
18 I think that probably my trips down
19 there. I think the last time that I was there
20 as part of this was in March, early March.
21 Q. Over how many years did these visits
22 span?
23 A. For this projects. It has been
24 since August of '92.
25 Q. Do you intend to offer any opinions
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1 relating to cattail growth vis-a-vis any other
2 species in the Everglades such as elio ocrus?
3 A. No. Elio ocrus the word and the
4 answer is not specific, other than in a generic
5 sense of community dynamics.
6 Q. Other than those different variables
7 that go into cattails and sawgrass growth, this
8 is still within the second area of testimony
9 that you maybe giving opinions on, is there
10 anything else that you might add that you might
11 be offering opinions about?
12 A. Let me make sure that you are clear
13 that these two are not totally separate areas.
14 Microbials of the soil affects whether or not
15 some nutrients are available to the plants for
16 growth.
17 So these two or disparite entities
18 are connected. They are also probably related
19 to the imbalance issue.
20 Q. Is there or can you just summarize
21 your conclusions regarding the imbalance issue?
22 A. There is an imbalance-- in my
23 opinion there is an imbalance in the Everglades
24 ecosystem which is occurring now and is going to
25 continue to occur.
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1 Q. What is that imbalance?
2 A. That imbalance is caused by invasion
3 of exotic species.
4 Q. What is causing exotic species to
5 invade the Everglades?
6 A. Their introduction would be the
7 first answer, meaning they obviously weren't
8 there before they were introduced.
9 Q. So you think any species that
10 migrates the Everglades without man having
11 introduced them?
12 A. Let me kind of finish that line of
13 thought.
14 In most cases introduction of exotic
15 species are not successful in terms of their
16 establishment.
17 What frequently is involved with
18 their establishment is disturbance, big scale,
19 small scale, but some facet of disturbance is
20 always important in the success of exotics.
21 Q. Okay. Then returning back to my
22 last question, do you feel any of these species
23 have migrated the Everglades without man's
24 involvement?
25 A. Of the ones that I am thinking about
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1 in terms of the ones that could have an impact,
2 they were brought to this area by people.
3 Q. What species are we talking about
4 that caused an imbalance?
5 A. I think the Maleluka is clearly one.
6 I think the potential for exotic fish species is
7 a second and perhaps even exotic birds.
8 Q. Do you think the Maleluka needs a
9 disturbance to become established in the
10 Everglades?
11 A. I think that the Maleluka probably
12 could go anywhere it damn well pleases, but I
13 think that its movement is probably enhanced by
14 disturbance, it spreads.
15 The second facet of introduction in
16 the Everglades is the fact that this is a
17 subtropical system which has been inhabited by
18 predominantly temperate species, particularly
19 fish and larger animals.
20 So there could be pretty good
21 theoretical arguments to be made for the fact
22 that some tropical species, if introduced, could
23 displace the temperate counter parts, even
24 without a huge amount of disturbance.
25 The disturbance could probably be
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1 most important but there would be some areas
2 that wouldn't be absolutely totally necessary.
3 Q. The third area that you talked about
4 was zonation.
5 Could you describe what conclusions
6 or opinions that you would offer regarding the
7 zonation of cattail and sawgrass?
8 A. My opinions regarding zonation are
9 that relatively small changes in physical
10 variables, and I would include hydrology and
11 nutrients, water quality, and when I say water
12 quality, I am not just talking about nutrients,
13 I am also including in that changes in salts,
14 for instance, increases in sodium chlorides,
15 small changes in those variables working
16 independently and synergisticly, can lead to a
17 variety of different communities in a relatively
18 small landscape.
19 Q. Is that the conclusion that you
20 would be offering those for your opinion?
21 It seems to me that you have just
22 described what zonation is, but do you have any
23 opinion as to what that means as far as the
24 Everglades in this case?
25 A. My opinion would be that within
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1 certain ranges for all those variables, the
2 common types would be expected to persist
3 without disturbance.
4 With disturbance, one could predict
5 maybe fairly rapid replacements of one zone by
6 another.
7 Q. What are those ranges?
8 A. I don't know. I know that within
9 for instance 15 centimeters of variations in
10 flooding, that you can find six clear vegetative
11 zones that are within a very small hydrologic
12 change, understanding that there are other
13 physical variables that are influencing which
14 zone given species or group of species occupies.
15 Q. You are saying with no other changes
16 to any other parameters of the environmental
17 disturbance?
18 A. I thought you asked me that before,
19 is it a disturbance.
20 It is one of the physical variables
21 that could influence the zonation or where a
22 species might be found.
23 Q. So it is a variable that could lead
24 to a disturbance?
25 A. If for instance a plant grows faster
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1 and grows better in a particular cite and it has
2 more energy available, then what that allows a
3 plant to do is to expand some of that additional
4 energy getting additional nutrients, getting
5 more oxygen to its roots and so forth.
6 So with the influence of a nutrient,
7 that system could allow a species to move
8 slightly one way or the other in its natural
9 zone were it to get the opportunity.
10 Q. But you wouldn't characterize it in
11 and of itself as a disturbance?
12 A. I am using disturbance and I think I
13 now understand why you keep coming to this
14 disturbance and I keep having a hard time
15 understanding what you are dealing with.
16 Because in ecological succession we
17 separate influences in the environment into two
18 really categories.
19 One, we talk about a limitation
20 which primarily deals with soils and nutrients.
21 And the second is we talk about
22 succession that is influenced by disturbance
23 such as fire and wind and so forth that are not
24 related to soils.
25 Soils and the water that are moving
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1 over systems tends to be in separate categories
2 from those that are dealt with in more
3 disturbances.
4 Again you see how I am separating
5 the two, and the influence of adding fertilizers
6 to an area, for instance, is not going to have
7 the same effect.
8 Q. The fourth subject category,
9 whatever it is that you said that you maybe
10 offering opinions or conclusions regarding,
11 talks about how variables relating to plants and
12 animal communities fit together in the
13 Everglades.
14 Again I may not be stating that
15 exactly as you phrased it.
16 Can you explain what opinions or
17 conclusion that you would offer regarding this
18 area?
19 A. Well, I think what I would offer is
20 the fact that with the body of information, the
21 technical information that is available, there
22 are a number of hypothoses that can explain the
23 zonation that we see.
24 There are multiple variants that
25 could influence zonation and that the available
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1 signs has not conclusively separated any of them
2 out as evidence that I would suggest that if you
3 were to do a corrolation of cattail abundance
4 and sodium chloride in the water salt, you would
5 find a very high corrolation in northern 2-A.
6 You also can find probably pretty
7 good corrolations between distance from the
8 canals and cattail density.
9 What I am saying is that the data
10 that we have available to us now that I have had
11 available, and I presume you have the same
12 mostly the same data set, are not conclusive
13 enough to separate many of the variables that
14 are normally a part of what dries a wetland
15 community in terms of zonation.
16 The difficulty of what we are doing
17 is that we are trying to come up with generic
18 understandings of what is a fairly large system
19 which is different across many of the areas that
20 we are really discussing.
21 Many of the papers that I have read
22 have attempted to ignore one of the basic, the
23 basic premise by which we understand wetland
24 functions and that is that there are three
25 important things in determining wetlands
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1 functions and species composition.
2 Those things are hydrology,
3 hydrology and hydrology. In other words,
4 hydrology and the geology of an area are the two
5 components that typically one looks at first.
6 Secondarily, one looks at salinity
7 of the soil or water or nutrients available and
8 they typically are important, but the ability of
9 the plant to use nutrients is heavily influenced
10 by how much water it is flooded by, how long the
11 soil stays anaerobic.
12 Q. All those things are interconnected?
13 A. I guess if there is a theme to what
14 I am saying is that there are multiple
15 variables, each of which would be expected to be
16 important, but almost all of them are tied into
17 hydrology in some way.
18 And I don't see a body of
19 information available to lead me to an absolute
20 certain conclusion as to what is doing it.
21 Q. You mentioned these corrolations of
22 cattail and salt, distance from canals and
23 cattails.
24 Would you expect to see a
25 corrolation between the level of phosohorous and
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1 levels of phosphorous in the water?
2 A. I did, and that is why I am
3 surprised that the Nancy Urban study didn't show
4 that.
5 I am still amazed everytime I think
6 of it. That is the kind of thing that I am
7 sort of hoping the dosing study would shed some
8 light on.
9 Q. You also mentioned that you might
10 expect to answer questions on hydrologic
11 alterations relative to what it could do in a
12 general sense. Could you explain what your
13 conclusions or opinions would be on this
14 subject?
15 A. Okay. Increasing flooding type of a
16 wetland soil for instance, influences the length
17 of time that the soil is anaerobic which can
18 have a great deal to do with nutrients
19 undertaken by plants.
20 It could have a great deal to do
21 with germination of seedlings, survival of the
22 plant itself.
23 Hydrology is an extremely important
24 variable in all facets of wetlands plants, and
25 when I say hydrology, I am including-- I am
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1 using that term in the very broadest sense to
2 include not just length of flooding, but
3 duration of flooding, how long in years is it
4 flooded, and I would even expand it more to
5 include the larger cycles that exist in all the
6 wetlands.
7 In other words, not just the day
8 night cycle but the long term cycles that exist
9 in the Everglades and in many other systems of
10 decades of years.
11 Q. Lastly you mentioned that you may
12 have opinions relative to successional ideas-- I
13 am having trouble with my handwriting.
14 Can you expand upon what this last
15 area is that you mentioned?
16 A. The term that I was looking for
17 earlier was disclimax from disturbances like
18 hurricanes versus a climax in the biotic sense
19 as a community that persists indefinitely given
20 no change in the basic environmental parameters.
21 It is considered a steady state that is
22 reached in community.
23 Climaxes are an important community
24 type because it can represent the end point of
25 community change.
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1 Most areas, when they are first
2 vegetated before there is any soil or anything,
3 will go through a series of communities,
4 ultimately ending in a stable community that is
5 self maintained, persistent over long periods of
6 time to climax.
7 Succession in the biotics of
8 succession as we understand it, is a sequential
9 movement towards a climax community.
10 In wetlands, however, there is
11 tremendous debate as to whether the biotics
12 succession phenominum really does occur.
13 Our understanding of wetlands, and
14 this is generic including the Everglades, our
15 understanding is that wetlands will move towards
16 a steady state or a balance with respect to
17 their position relative to flooding, and that
18 position is maintained by the loss of organic
19 matter from the soil when it dries during parts
20 of the year, mineralization I think is the best
21 term, and the accumulation rate of organics.
22 So when systems reach a steady state
23 over long periods of time, what you basically
24 have is the accumulation sediments or pieces or
25 whatever we are talking about reaching zero.
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1 The communities that are existing in
2 that steady state are fairly stable persisting
3 long periods of times.
4 When you alter the steady state and
5 that alteration can be purely natural, it can be
6 human induced, there are lots of things that can
7 cause it; you could, for instance, increase the
8 water level or decrease the water level, then
9 what basically happens is that the potential for
10 a shift of the community, doesn't mean it is
11 going to happen.
12 It can mean that it can happen,
13 frequently climaxed communities will persist
14 even after there have been some fairly major
15 environmental changes, increased flooding,
16 increased or decreased nutrients, just about
17 anything that I would want to add to that, these
18 communities will persist in some form or
19 fashion.
20 I have seen them persist for 30 or
21 40 years after dramatic alterations with very
22 little change and then frequently either the
23 change becomes so great that the plants simply
24 cannot survive or something else happens to
25 disturb them, fire, hurricane, a freeze, almost
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1 anything that would impact plants already
2 stressed.
3 Then there is effectively a dramatic
4 community shift, sometimes a little farther over
5 a few years going from one dominant community
6 type to another.
7 This is basically what is referred
8 to as a Gleasonian approach to succession in
9 that it is the environmental conditions that are
10 determining what species of plants are there or
11 not, but there is no organized sequence of
12 things that will follow one another.
13 Q. Do you think that is applicable to
14 the Everglades?
15 A. I do.
16 Q. You said in the wetlands there is a
17 debate on whether this sequential moment occurs.
18 What is your opinion?
19 A. I think that for some situations
20 there is clearly some successional development
21 that occurs and that is probably in wetlands
22 that is becoming newly extracted in which
23 hurricanes leaves a sand bar, a sand bar where
24 there was none before.
25 It probably occurred in many kinds
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1 of new habitats.
2 However, once there is some steady
3 state in the physical structure of the
4 environment, what seems to be the case is the
5 species that gets there first and can grow under
6 that set of conditions, then persist for fairly
7 long periods of times until something comes
8 along to disturb them.
9 Then there can be a change and that
10 could be natural or hyper-energetic.
11 Q. From looking at your CV it appears
12 that you have done a lot of work in costal
13 wetlands.
14 Would you describe what work you
15 have done in fresh water wetland areas?
16 A. Many of the wetlands that I work in
17 are wetlands that are transitions from fresh
18 water to saline wetlands.
19 Much of my work now is what we refer
20 to as oligohaline, very low salinity, or would
21 be in costal plane wetlands which would include
22 coastlines.
23 Q. Would you characterize the
24 Everglades as Oligohaline?
25 A. Parts of it.
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1 Q. How about the area around the water
2 conservation areas?
3 A. No.
4 Q. Would you consider those fresh water
5 wetlands?
6 A. Yes.
7 Q. Would you tell me of any other
8 research that you have done on fresh water
9 wetlands that are not Oligohaline or coastal or
10 influenced by salt water merging with fresh
11 water?
12 A. I have worked in the sub-borrial
13 forests pete system in Wisconsin, those are pete
14 based.
15 I have worked in the wetlands in
16 Illinois, both isolated, what are called I think
17 intermediate primary wetlands and wetlands
18 associated with extreme drainages, riparian type
19 of wetlands.
20 I have worked in wetlands in upstate
21 New York which had colonized former primarily
22 glavca.
23 I have worked in pete based Atlantic
24 white sea wetlands in New Jersey.
25 I have worked in fresh water swamps
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1 in Louisiana. I have worked two different kinds
2 in Louisiana, one was the bottom hard wood swamp
3 in northwestern Louisiana.
4 Another was a lowland wetland swamp
5 in southern Louisiana.
6 I worked in -- now some of these it
7 depends on your definition of costal, I have
8 worked in fresh water marshes in Louisiana.
9 I have worked in swamps in the upper
10 Mobile basin.
11 I have worked on the outer coastal
12 peninsula of North Carolina.
13 I have worked on wetlands on Barrier
14 Islands. Do you want me to keep going?
15 Q. How do you define a wetland?
16 MR. HYDE: Ask the Corps of
17 Engineers.
18 A. I would define a wetland as a system
19 whose soil characteristics are heavily
20 influenced by the presence of water for a long
21 enough periods of time to cause anaerobic
22 metabolism in the soil.
23 Q. Have you ever worked with cattails
24 in fresh water?
25 A. Yes.
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1 Q. Where was that?
2 A. Okay.
3 Q. Is this going to be an extensive
4 list?
5 A. It is, and the reason is that
6 cattails are an important component in many
7 wetlands ecosystems, especially those that have
8 had disturbances of some type.
9 It frequently is an early invader
10 into disturbed wetlands, sometimes invading
11 farming needs, for instance, in the bottoms of
12 the furrows.
13 It is also a fairly important
14 component in tidal wetlands where it is
15 important along the upper land wetland fringe.
16 The wetland that I remember
17 extremely well that was dominated by that type
18 was in Upstate New York which was the dominant
19 species.
20 It is frequently in drained
21 wetland. It is frequently a component of the
22 drainage ditches on the edges of canals in
23 places where they throw spoiled material.
24 The Corp of Engineers no longer
25 calls it spoil. It is dredge material and often
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1 it is an important species of those disturbed
2 areas.
3 I am saying disturbed, but there are
4 many situations in which Cattails are a very
5 normal part, another sequence of species that
6 occupies a wetland, particularly after a
7 disturbance.
8 And their role often is one in which
9 they invade disturbed cites, they create large
10 quantities of the biomass, they are highly
11 productive, these can be highly productive.
12 They are capable of producing lots
13 of biomass and very quickly regenerating holes
14 and if you want to think of any day a
15 disturbance like a fire in which it burns out a
16 piece of pete and leaves a deeper area,
17 Cattails are frequently the species that end up
18 in deeper areas like that.
19 And the later role in the sequence
20 of things is to accumulate organic material
21 which they can do fairly rapidly.
22 And in doing so bringing the
23 community back into balance, if you want to
24 think of it that way, getting the depositional
25 environment to where deposition minus oxydation
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1 or mineralization are equal to zero.
2 They are important in that role.
3 Q. So cattails can help bring a system
4 into balance?
5 A. Yes.
6 Q. Even if they are not native?
7 A. Most wetland ecosystems are driven
8 by what happens with mineral accumulation or
9 organic accumulation, pete sediment, again
10 related towards hydrology.
11 Q. Have you found evidence of a hybrid
12 species of cattails in any of these wetlands?
13 A. Yes.
14 Q. In fresh waser?
15 A. Yes.
16 Q. Where was that?
17 A. In New York.
18 Q. How do you know it was a hybrid
19 species?
20 A. It is a documented hybrid, I think
21 Florida glavca is a hybrid between two species,
22 I don't remember which ones, but between two
23 species.
24 Q. In your opinion has there been an
25 increase of cattails in the Everglades over the
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1 last 20 years?
2 A. Yes.
3 Q. What would you attribute that to?
4 A. I would attribute it to a number of
5 factors.
6 The first I would attribute it to
7 and maybe I shouldn't put these in orders, the
8 two important ones in my opinion are
9 disturbances in hydrology and you may have
10 somewhat of a difficult time separating those
11 two because they are clearly related.
12 The effect of drying the Everglades
13 for some period of time, that absolutely had to
14 influence the loss of organic material from the
15 surface of the Everglades.
16 The natural zonation alone would
17 remove a fair bit of that and you could see what
18 was in some of the EAA area where it has been
19 drained and you can see the lost organics.
20 Fires, of course, can have very
21 quick removal of organics, especially lowering
22 the surface of the marsh or the swamp or
23 whatever.
24 Effectively what is going on is that
25 the ecosystem is attempting to come into balance
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1 with its hydrological regiment that has been
2 imposed on it.
3 There are periods of time for many
4 areas that there was a lower water table.
5 Following that, there was an
6 increase in water in which the system is going
7 to again attempt to come to equilibrium. So
8 that is a disturbance.
9 The fire is a disturbance and again
10 how you interpret a disturbance can vary, but
11 the levees themselves, by backing water up at
12 particular places, has almost certainly caused
13 there to be an alteration of hydrology and other
14 things too, including nutrients.
15 Q. In your opinion will disturbances
16 always lead to an increase in available
17 phosphorous?
18 A. Not all kinds of disturbances.
19 Q. What types wouldn't?
20 A. A hurricane for instance that
21 destroyed many of the islands for instance which
22 blew all the trees over, maybe produced higher
23 water tables, that might not lead to any
24 increases in nutrients.
25 Increases in water levels, for
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1 instance, over long periods of time would
2 probably tend to remove nutrients from the
3 system.
4 They would certainly remove nitrogen
5 through the process of denitrofication.
6 They could very well remove other
7 types of nutrients that would be precipitated
8 out or included in the organic material that is
9 burried, all dead plant material, pete and so
10 forth contain nutrients.
11 So the act of production of pete
12 removes nutrients -- removes available nutrients
13 from the system to one degree or the another and
14 the nutrients vary a lot depending on their
15 sizes also.
16 Q. With regard to disturbances that do
17 cause an increase in phosphorous--, let me
18 restate that.
19 The disturbances that are currently
20 ongoing in the water conservation areas, are
21 they causing an increase in phosphorous?
22 A. That are currently going on.
23 The disturbance ending up in WCA2A I
24 would say no.
25 What is actually going on in that
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1 cite itself, I would say that the plant responds
2 to disturbance is in fact removing phosphorous.
3 Q. So would you expect over time for
4 levels of phosphorous to decrease in water
5 conservation area 2-A if present conditions
6 remained unchanged.
7 MR. HYDE: Object to the form of the
8 question, increase why, where? The water and or
9 in the soil.
10 MR. BARTELL: Let's start with in
11 the water.
12 A. If we are just talking about 2-A and
13 we are talking about an isolated system in which
14 the inputs and outputs are rain fall-- .
15 Q. I am talking about if present
16 conditions remain unchanged as far as how
17 hydrology of water conservation area 2-A
18 currently exists, would you expect over time,
19 over the near future or over a long-term for
20 phosphorous levels to start decreasing?
21 A. Phosphorous where?
22 Q. In the water.
23 MR. HYDE: Just for clarification,
24 is this assuming the same limit of hypergenetic
25 source that maybe continuing into those areas?
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1 MR. BARTELL: Yes.
2 MR. HYDE: And natural ones such as
3 from the atmospheric composition.
4 MR. NETTLETON: Say everything being
5 the same?
6 A. I am not sure what the same means.
7 Given the continued movement of phosphorous into
8 the system, into WCA2A, what is anticipated, the
9 big picture is that the system will continue to
10 accumulate phosphorous.
11 It is going to accumulate that
12 phosphorous in the soil as part of the pete and
13 as individual minerals probably does deposit
14 within the pete and that accumulation is going
15 to occur until the system reaches an equilibrium
16 with the hydrology.
17 When that occurs, then the system
18 will stop storing phosphorous and basically pass
19 the phosphorous through.
20 Q. While it is in this process of
21 storing it until it reaches its equilibrium, is
22 phosphorous increasing or decreasing?
23 A. Where?
24 Q. We are still in the water.
25 A. I think the water phosphorous
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1 concentration in the water right now is highly
2 variable spacially.
3 I mean clearly phosphorous gets
4 removed from the water through a whole variety
5 of means. I would anticipate that one would
6 continue to have a gradient just as one does
7 right now.
8 Q. What do you mean by hydrologic
9 equilibrium?
10 A. When the accumulation of organic
11 material reaches the point where accumulation
12 minus oxydation equals zero, there is no net
13 increase in pete.
14 At that point in time, assuming
15 everything else stays the same, the rain fall
16 pattern stays the same, the amount of water
17 going in there stays the same, at that point in
18 time, then the net loading of the pete is going
19 to cease.
20 Q. With regard to these questions that
21 I have just asked you, I limited that to the
22 phosphorous levels in the water.
23 How would your answers change
24 regarding phosphorous levels in the soil?
25 A. That is clearly the location of
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1 phosphorous in terms of its storage. That is
2 clearly where it is going to be stored.
3 Q. So is it currently increasing from
4 today until next week, is phosphorous levels in
5 the soil increasing or decreasing in 2-A?
6 A. Well, big picture, just generically
7 it is going to be increasing.
8 Q. We went through when I asked you
9 what areas that you anticipated testifying at
10 trial and you listed six areas.
11 Then you said you would be focusing
12 on two areas of specialty, energetics wetlands
13 system, what do you mean by that?
14 A. Energetics is the manner through
15 which energy moves through the tropic levels of
16 an ecosystem.
17 Q. Can you explain to the people what
18 that means?
19 A. When a plant captures sunlight, it
20 basically takes the energy that is in that
21 photon of light energy and it transfers it to a
22 chemical form.
23 The total quantities of energy
24 captured in an ecosystem dictates basically how
25 the ecosystem functions, what kinds of
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1 organisims they are going to be in that
2 ecosystem, how big they are, how stable
3 populations are, et cetera.
4 The energetics is basically looking
5 at those combinations between tropic levels,
6 between species.
7 Clear enough?
8 Q. That helps. Do you consider
9 yourself an expert in this area?
10 A. Yes.
11 Q. You also mentioned community
12 dynamics slash interaction.
13 Is that stuff that we have already
14 discussed or is this something more? I
15 understand that there are some overlapping among
16 these areas?
17 A. Yes, there are.
18 Q. Is there anything specifically you
19 can add to the conclusions that you may have
20 regarding community dynamics or interaction?
21 A. I think that we have discussed many
22 of the facets.
23 Our discussion of succession and how
24 individual communities respond to the
25 environmental attributes of a typical cite, I
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1 would include that in community dynamics, how a
2 species influences other species and that can be
3 in terms of competition, it can be in terms of
4 grazing, gradiation.
5 I would include all of those facets
6 under that umbrella.
7 Again many of those we have already
8 explored to some degree.
9 Q. My understanding or based on going
10 through these questions with you, it seems that
11 I have covered or you have explained to me all
12 the areas that you anticipate giving testimony
13 about or any conclusions that you have to date
14 which may come up in this case.
15 Is there anything else that you
16 might add that you think that you might be
17 offering opinions about or conclusions on at
18 trial?
19 A. Well, I think that some of the
20 central issues of imbalance are included in the
21 energetics as I would discuss it and I think
22 those are the only details that we probably
23 haven't explored very thoroughly that I can
24 think of.
25 Q. This is the central issue of
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1 imbalance within the energetics. That wasn't
2 the question that I asked. Could you explain to
3 me what you mean?
4 A. Well, shifts in energy availability
5 or quantity and quality can effect the types of
6 species that are going to be supported in that
7 community.
8 For instance, shifting from an
9 aqueous environment like the more flooded
10 prairie situation to a less flooded situation,
11 would and could change the species that are
12 likely to be using the energy produced by the
13 plants.
14 Q. What are other examples of shifts
15 that you would calls shifts in energy available
16 besides for instance water levels?
17 A. Well, the removal of large
18 quantities of energy from the available energy
19 pool through pete deposition for instance.
20 The replacement of a species of a
21 primary procedure by another one that was more
22 or less palatable and those are the kinds of
23 things that could professionally lead to changes
24 in species composition.
25 What I would sort of say about that
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1 is again, what you are really looking at depends
2 a lot on scale.
3 If you took any meters squared in
4 just about any ecosystem, you could probably
5 find shifts in the species that are there over
6 some time scale due to purely natural things or
7 due to other things going on.
8 So from a standpoint of species
9 shift, I think you have to look at the whole
10 system.
11 You can't isolate one square meter
12 of cattail or sawgrass and say that's what is
13 going on and, therefore, there is an imbalance.
14 So one has to look at the entire
15 system and see if the system has changed.
16 The example for the Everglades that
17 I will give you, which is a clear example, is a
18 shift from orbaceous species in parts of the
19 Everglades to woody species occupying the same
20 facilities of a hydrologic regimen.
21 Q. What do you think is causing that?
22 A. A change in primary producers from
23 sawgrass, Typha and all the other species that
24 we have discussed, the Maleluka for instance.
25 That clearly is a significant change
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1 in the way in which energy is moving through the
2 system.
3 MR. BARTELL: Let's take a little
4 recess.
5 (Recess taken.)
6 Q. I ask you to please mark this as
7 Exhibit 3.
8 ( Thereupon exhibit 3 was marked for
9 identification).
10 MR. BARTELL: Let the record reflect
11 that we have just had exhibit number three or an
12 exhibit marked as exhibit number three which is
13 Dr. Hackney's draft report and Dr. Hackney is
14 going to make a statement regarding this
15 exhibit.
16 THE WITNESS: For the record, this
17 is a partial draft of a document that will have
18 this title and was not ready for distribution.
19 BY MR. BARTELL:
20 Q. Dr. Hackney I am showing you what
21 has been marked as exhibit number three.
22 Would you please identify this
23 document to the extent that we have not
24 already.
25 A. Why that is the document that was
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1 provided to you per your duces tecum.
2 Q. Is this the first draft of this
3 document?
4 A. It would depends on what you call a
5 draft.
6 I think right now my computer shows
7 that there has been 30 some drafts, but each
8 time someone walks into my office or at some
9 point in time where I stop and I save it, that
10 constitutes a computer draft.
11 That doesn't constitute what I call
12 a draft.
13 I would say this is a preliminary
14 draft.
15 Q. Is this the latest draft?
16 A. I am sure-- I know there are several
17 updates on the computer of this since this was
18 sent, probably at least one or two a day.
19 Q. Are any of those significant
20 changes?
21 A. I am not sure what the word
22 significant--- none of them change any of the
23 points of the documents, but some of the points
24 are not completed in this document.
25 So those changes are going towards
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1 completing some of those ideas, some of which
2 are totally undeveloped in this.
3 Q. As we going through this document
4 and we aren't going to be going through it word
5 by words, would you please if you see an area
6 that has some changes, indentify them.
7 I would like to ask you to turn to
8 Page 3. I don't see a Page 2 to the document.
9 A. There should be a Page 2. There
10 should be because there is an abstract somewhere
11 for this. There is an abstract of Page 2 that
12 was provided.
13 I think there is an abstract on the
14 document that now exists that was on that
15 document.
16 But I would also tell you that I had
17 a nightmare getting that off the computer and it
18 was a matter of it coming off the computer,
19 putting that paper clip on there with that note
20 that you all notice and shipping it to you all.
21 I did not review that document when
22 it came off the computer so I could not swear
23 there was an abstract with it.
24 Q. According to the Bate Stamp there is
25 not a missing page so it seems from what I have
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1 now is how it was provided to us.
2 Nonetheless could I ask that this
3 second page be provided to us?
4 A. Yes.
5 MR. HYDE: No problem.
6 Q. Referring or I would like to ask you
7 to refer to Page 3.
8 In the first paragraph about halfway
9 through this first paragraph there is a sentence
10 that starts " when water levels in wetlands are
11 higher -- I will just read the sentence,"When
12 water levels are higher than normal, organic
13 materials accumulates and when lower than normal
14 decomposition increases and there is a net
15 annual loss of organic matter".
16 But what I would like to ask you is
17 how do you know this. Where did this conclusion
18 come from?
19 A. This conclusion comes from the basic
20 paradigms of how wetlands grow and develop.
21 If you wanted to review this in
22 detail, I would refer you to Mithchell
23 Groslings 1986 book titled Wetlands and it may
24 very well be there. I know that I added a
25 number of additional references, preliminary
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1 draft articles.
2 I normally draft-- it starts out
3 with an introductory set of materials, much of
4 which I then go back and add the reference, the
5 backup statements, like that one.
6 I can't remember if that has been
7 done for this or not.
8 Q. I would like to ask you to turn to
9 page four and just put on the record that page
10 four is 1261768 which is Earl Blank's Bate stamp
11 number.
12 I would like to ask you to refer to
13 the last paragraph and I am looking at the last
14 two sentences which set forth what the study
15 sets out to do.
16 Doctor, I would like to ask you to
17 read those seven answers and then again I am
18 going to ask you to explain to me what this
19 proves or what this is attempting to
20 demonstrate?
21 A. Okay. Would you like me to read
22 these.
23 Q. You can read them to yourself.
24 A. All right.
25 Q. I just want you to understand what
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1 we are talking about. These are the last two
2 sentences on page four.
3 MR. HYDE: It might be clear for
4 record to read them into the record.
5 A. Okay. The first sentence states
6 "This study examined the concentration of fungi
7 in surface pete across the Everglades in areas
8 subjected to increase flooding and nutrient
9 loading and in the areas less impacted by
10 nutrients".
11 This refers to the examination of
12 the quantification of fungi through ergosterol
13 measures in the course that we've discussed
14 earlier.
15 The second sentence goes into the
16 importance of fungi in decomposition of Typha
17 and Cladium leaves was examined under both high
18 and low nutrient conditions in WCA-2A, and this
19 relates to our discussion on respiration
20 earlier.
21 Q. Is that a pretty concise summary of
22 what it is that you were trying to accomplish or
23 what this study does?
24 A. Yes. It doesn't elaborate on all
25 the facets of those. It doesn't discuss the
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1 real importance of fungi and bacteria in the
2 decomposition but yeah, it summarizes them.
3 Q. What I would like to ask you to do,
4 I am going to scuffle to do is if you could, try
5 to explain to me what this would demonstrate or
6 what this demonstrates.
7 I have read your reports and I have
8 to confess I still don't understand what it is
9 that this shows.
10 Can you explain that to me in lay
11 persons terms where I might be able to
12 understand it?
13 A. Okay. Let's start from the
14 beginning.
15 The first thing it shows is that
16 fungi are a component of the soil/pete/root
17 complex within the Everglades and that they are
18 found in both Typha and sawgrass stands, that
19 they are found under high nutrient and low
20 nutrient conditions and that there is a
21 reasonable amount of spacial variation.
22 Q. Between what?
23 A. Between the presence or absence of
24 quantities.
25 In other words, there is not an even
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1 amount scattered everywhere. There is a fair
2 bit of variation within each species and across
3 the Everglades, and the data also show that
4 there does not appear to be any relationship
5 between quantities of fungi and soil phosphorous
6 or nearness to the EEA.
7 Q. Is that the conclusion?
8 A. That is what the study basically
9 shows.
10 Q. That there is no relationship
11 between-- would you fill that in for me?
12 A. There is no relationship between the
13 biomass of fungi as demonstrated through
14 ergosterol measures and one species of plants or
15 others, or with respect to phosphorous quantity
16 and soil or with respect to nearness to the EAA
17 and that measure was basically using latitude
18 and longitude.
19 Q. Now I understand what this report
20 has done and what the conclusion that is reached
21 is. Now what does that mean.
22 So there is no relationship. What
23 does that tell you? What does that have to do
24 with the Everglades?
25 A. There are several questions there.
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1 From a purely scientific standpoint, it is
2 purely fascinating.
3 From the standpoint of your
4 interest, what it says, what it says to me is
5 that it addresses what I would call my working
6 hypothesis.
7 And that working hyphothesis was
8 whether different species of plants, for
9 instance, would have different relationships to
10 fungi and whether increased growth of plants in
11 the high nutrient area alter the quantities of
12 fungi in those areas.
13 The cells could have been in either
14 direction. It could have been that more
15 nutrient availability for instance would fuel
16 more plant growth which would make the habitat
17 better for fungi or it could have been the other
18 way and made it worse for fungi.
19 What I have was an interest in
20 knowing whether there was a changed area in
21 which there appeared to be an identical primary
22 conductive activity.
23 Q. Forgive me but I am trying to
24 understand what is the difference if there is
25 fungi or not. What does that demonstrate?
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1 MR. HYDE: I think that is the
2 point, that tjere isn't a difference.
3 BY MR. BARTELL:
4 Q. I don't mean to be sarcastic, but I
5 mean, so what? What is that showing us?
6 A. It is showing us if for instance
7 let's take the two possible alternatives that we
8 could have seen, one, we could have seen that
9 there was for instance a loss of fungi from the
10 soils under it, increased nutrients, that could
11 tell us something about the impact the nutrients
12 were having on the plants themselves.
13 That could influence the manner in
14 which nutrients are sequestered. It could
15 influence the way pete was accumulating.
16 It would tell us a lot about why one
17 species could maybe have a competitive advantage
18 in terms of soil interactions.
19 On the other hand, if there is no
20 difference between the two, it basically is