98
1 DIVISION OF ADMINISTRATIVE HEARINGS
DEPARTMENT OF ADMINISTRATION, STATE OF FLORIDA
2
SUGAR CANE GROWERS COOPERATIVE )
3 OF FLORIDA; ROTH FARMS, INC.; and )
WEDGWORTH FARMS, INC., )
4 )
Petitioners, )
5 vs. )DOAH Case No. 92-3038
SOUTH FLORIDA WATER MANAGEMENT )
6 DISTRICT, an agency of the State )
of Florida; et al., )
7 Respondents. )
- - - - - - - - - - - - - - - - - x
8 FLORIDA SUGAR CANE LEAGUE, INC., )
UNITED STATES SUGAR CORPORATION; )
9 and NEW HOPE SOUTH, INC., )
Petitioners, )
10 vs. )DOAH Case No. 92-3039
SOUTH FLORIDA WATER MANAGEMENT )
11 DISTRICT, an agency of the State )
of Florida; et al., )
12 Respondents. )
- - - - - - - - - - - - - - - - - x
13 FLORIDA FRUIT AND VEGETABLE )
ASSOCIATION; LEWIS POPE FARMS; )
14 W.E. SCHLECHTER & SONS, INC., )
and HUNDLEY FARMS, INC., )
15 Petitioners, )
vs. )DOAH Case No. 92-3040
16 SOUTH FLORIDA WATER MANAGEMENT )
DISTRICT, an agency of the State )
17 of Florida; et al., )
Respondents. )
18 - - - - - - - - - - - - - - - - - x
19 100 Southeast 2nd Street
Miami, Florida
20 January 27, 1993
9:30 a.m. - 5:10 p.m.
21
DEPOSITION OF ROBERT JOHNSON
22 VOLUME II - P.M. SESSION
23 Taken before RICHARD BURSKY, Registered
Professional Reporter and Notary Public in and for
24 the State of Florida at Large, pursuant to Notice of
Taking Deposition filed in the above cause.
25
99
1 AFTERNOON SESSION
2 1:10 p.m.
3 MR. KOBELINSKI: Back on the record.
4 BY MR. KOBELINSKI:
5 Q. Good afternoon, Mr. Johnson.
6 If I could direct your attention, sir, to
7 what previously has been marked as Exhibit 1, and the
8 final page of that exhibit which has Bates number
9 0961523 marked on it, and also has a stamp labeled as
10 Government Exhibit 6B. But before I direct your
11 attention to that, off the record.
12 (Discussion off the record)
13 (A six-page document listing computer
14 files from computer disks was marked Johnson
15 Deposition Exhibit 2 for identification)
16 BY MR. KOBELINSKI:
17 Q. Mr. Johnson, I am showing you what has
18 been marked as Exhibit No. 2 to your deposition and I
19 would ask you as part of the documents and
20 information you provided in response to your notice
21 of deposition duces tecum did you provide us some
22 computer disks with information on them?
23 A. Yes, I did.
24 Q. I would represent to you that this is just
25 a listing on the various sheets of the directories of
100
1 those tapes, and they are essentially, there were
2 five disks -- I shouldn't say tapes, they are disks
3 -- five disks and I don't believe that the five are
4 in any particular order. However, as you can see
5 next to each directory we have gone ahead and
6 provided a number for that disk.
7 Could you go through and identify for us
8 what is in those files? Because we had some
9 difficulty trying to determine exactly what they
10 were.
11 A. Okay.
12 Most of the file names are MN and then at
13 the end an S and then usually a three digit number
14 and those are monthly flows for whatever particular
15 structure you are referring to. So then the third
16 letter there is either an N or a P indicating whether
17 it is positive or negative flows, because many of the
18 structures in the system have flow in both
19 directions. So depending on which sub-basin was
20 analyzed we would either list it as a positive flow
21 or negative flow depending on whether it was to the
22 north or south, east or west.
23 Q. Is there a particular period of time that
24 these flows relate to?
25 A. These are the monthly flows from the
101
1 period '65 through '89 that we are using for the
2 water budget and water allocation study.
3 Essentially these are the files that are
4 used in the South Florida Water Management Model. So
5 this is basically the same format, monthly total
6 flows as would be data from the model.
7 Q. When you say these are the files used by
8 the South Florida Water Management Model, are these
9 the files used by the Park in relation to that model
10 or are these essentially that particular model's
11 files?
12 A. They would be the same ones used by the
13 Park and the District. And the version of model,
14 these are the same historical flow files that we
15 would have received from the District directly.
16 Q. Perhaps for clarification, looking at this
17 Exhibit 2, on the first page there it has actually
18 what has been labeled as disk 5, and it is just an
19 arbitrary number we provided, the first file is
20 FLBAY.WP5. What would that be?
21 A. The Florida Bay and the Florida Bay PRE
22 are WordPerfect files, that's what the WP5 would
23 indicate. And based on the date they would be
24 probably some background information that I printed
25 up in order to prep for the presentation to the South
102
1 Florida Water Management District governing board
2 which was made on the 13th of November.
3 The next one --
4 Q. Which is FLOWL?
5 A. Right. That is the file that specifies
6 the row and column number for the particular flow
7 lines in the South Florida Water Management District
8 Model that we analyzed for flow volume comparisons.
9 So it is just a file that lists for one
10 particular line, you know, this row and column
11 number, then the next row and column number, as you
12 go across the line either east-west or north-south.
13 That is just a file to keep track of how the flow
14 lines were oriented. And there should be some
15 explanation in there along with the actual numbers
16 that explains what the line was used for, whether
17 outflow to EAA or inflow to the Water Conservation
18 Areas or inflow to the Lower East Coast.
19 Q. And the next two files, one is FREQMON
20 space RUN, and the other one is FREQSEA space RUN.
21 A. These are two frequency analyses that were
22 run on I assume all of this monthly data. The first
23 one, MON ending is based on monthly data. And the
24 second one is based on seasonal data. And the RUN
25 extension tells me that it is the command lines to
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1 run probably an SPSS program to do exceedance
2 frequencies. So this is some of the, I call them run
3 cards, back from the old days of key punch. That's
4 why they have the RUN extension on them.
5 Q. Then going down, the next number of files
6 are the MN files I believe you just discussed a few
7 moments ago.
8 A. Yes.
9 Q. After them comes an NSM file.
10 A. That is probably an overall file that
11 includes flow data for a series of the flow lines out
12 of the Natural System Model based on the orientation
13 from the lines from the file FLOWL. It would
14 probably be monthly totals and annual total flows for
15 I think at that time we were looking at, this would
16 be version 4.0 of the Natural System Model. And it
17 would be for something like 15 different flow lines
18 spread all around the grid of the Natural System
19 Model.
20 At the top of each of the columns of data
21 there should be some explanation about which
22 particular name was given to that flow line and they
23 should match up to something in FLOWL.
24 Q. Which is the third one down?
25 A. Right.
104
1 Then below that the NSMANN and NSMANN with
2 two different extensions are the annual total flow
3 volumes, probably taken from the NSM file and just
4 separated out as annual totals. And the DAT tells me
5 it is an ASCII file and the WQ1 tells me it is a file
6 that was probably massaged in Quattro Pro. I
7 probably did something like the annual totals or
8 something like that within Quattro Pro.
9 And then the Natural System Model flow
10 MON, the next three files are Natural System Model
11 flow monthly data, one would be the raw data, DAT in
12 ASCII format, the NSMFLMON with the STA extension is
13 the statistics that is output most likely from SPSS
14 program. It probably would include basic descriptive
15 statistics like means and medians and mins and maxes
16 as well as probably some sort of frequency analysis
17 on the data.
18 Q. Okay.
19 A. The next one down with the same file name
20 and extension WQ1 would be the Natural System Model
21 flow monthly data in Quattro Pro format.
22 Q. All right.
23 A. NSMFLOW.DAT looks like it is some sort of
24 streamlined version of the original NSMFLOW file in
25 ASCII format. It is slightly smaller than the other
105
1 one. Maybe I pulled out the annual data from that
2 and renamed it.
3 The next two, NSMFLSEA are the seasonal
4 breakdowns, wet-dry season breakdown over that
5 period.
6 And the first one is an ASCII data file
7 DAT extension, the next one is the output again
8 probably from SPSS program with the STA extension.
9 And again it would have the results of a statistical
10 analysis, something like descriptive statistics or
11 frequency analysis or something of that type.
12 I think that's probably the extent of any
13 statistical analysis I did on the data at this time.
14 And then the next two, NSMQ annual dot DAT
15 and Q annual dot WK1 are much older files. And
16 anything with the date in 1991, these November '91
17 dates are more than likely version 3.6 of the model.
18 We switched over sometime in early 1992.
19 And those would be again Natural System
20 Model discharge annual total flows in ASCII format
21 with the DAT and in Lotus format it looks like with
22 the WK1 extension.
23 And then the next file down, NSMSFWMM with
24 the extension Q would be a comparison file of the
25 flow data for the Natural System Model and the South
106
1 Florida Water Management Model.
2 The next one down would be output from the
3 South Florida Water Management Model. I am assuming
4 it is probably discharge based on all the rest of the
5 stuff in the files.
6 The last one on this disk is SSQMON.WK1
7 and that is the Shark Slough discharge monthly data.
8 And I would say based on the date it is probably the
9 Water Management Model output, something like that,
10 for that particular date.
11 Most of the files have some sort of
12 explanation header inside the top of the file to tell
13 you what, whether the data is a model output or
14 historical data from structures and if it is a model
15 output it will usually tell you it is a Natural
16 System Model or Water Management Model.
17 Q. The dates that are to the right of the
18 number of bytes, are those the last revision date or
19 is that the file creation date?
20 A. I believe it would be the revision date if
21 a change had been made.
22 Q. Going on to the bottom of that page and
23 what follows on the next page, what we have labeled
24 as disk 4.
25 A. That would be the same basic information,
107
1 annual flows from the Natural System Model and annual
2 totals from the Natural System Model.
3 These are I believe compilation tables on
4 those sub-basins that I referred to earlier. They
5 probably would be a table for the EAA inflows and
6 outflows, the Lower East Coast inflows and outflows
7 and the water conservation area inflows and outflows
8 on here in this case with the extension NSM meaning
9 those are the inflows and outflows under the Natural
10 System Model, based on their size. They are
11 relatively small.
12 The flow is the most likely the flow over
13 a series of flow lines and the total is probably some
14 summary of all that. So it is combined data for a
15 couple of different flow lines or something like
16 that.
17 Then again all of the MN structure name
18 files with the N or the P are again the individual
19 structure files.
20 And they more than likely are the same
21 files as what you see on disk 5 because the file date
22 and size are all exactly the same. It is just a
23 duplicate set that I have for some reason, they were
24 probably generated and stored on another file at the
25 same time.
108
1 And that monthly flow information extends
2 all the way down to the last set of files. Again,
3 the NSM flow data files and NSM discharge annual
4 files in ASCII and in Lotus format are the last three
5 files.
6 And again based on the date I would say
7 those are version 3.6 of the Natural System Model.
8 And you can see the last two are very
9 small files, just a summary of the annual data.
10 Q. Going to that second page on to what we
11 have indicated as disk 3.
12 A. All right. This is mostly compilation
13 data for a paper that I did on water allocations and
14 water management in the Everglades.
15 The first one, ASCEPAP is the actual
16 document in WordPerfect format. I don't know if it
17 is the final version or not but it is WordPerfect
18 copy of that file.
19 Q. Is that paper for one of the projects we
20 had been discussing?
21 A. It is called Water Management and
22 Ecosystem Restoration in the Everglades. It is in
23 the folder of papers I provided to you. It is one of
24 the papers that was done on the side.
25 The next one, Atlantic.DAT is flow data
109
1 that would be discharging off the Atlantic coastal
2 ridge into the coastline so it would be flow to
3 tidewater.
4 And it would probably be the sum of all of
5 the outflow structures from Palm Beach County south.
6 I believe there are some 30 or 40 structures that
7 would be included in that. And more than likely
8 there is some breakdown in the file about which ones
9 are in each county.
10 The next file down, BARALLOC.WK1 is a file
11 I was putting together to do bar graphs of water
12 allocation between different parts of the system. So
13 it is a file that includes the data for those
14 sub-basins, the EAA, the Water Conservation Areas,
15 the Lower East Coast, that would probably have inflow
16 and outflow annual totals. And then somewhere in
17 that file is information to set up the graphics, to
18 actually generate the bar codes.
19 Combined flow annual is more than likely
20 the raw data files that went into developing that bar
21 code file. And it is just, it is the annual flow
22 data combined for the sub-basins.
23 There are data files and Quattro Pro files
24 and the last one in that group, there are two listed
25 as AN and the third one is CM and that was converted
110
1 to millions of cubic meters and that was because of
2 the ASCE Journal I submitted it to was doing it in SI
3 units and since I don't work in SI units I had to
4 make a conversion and store it someplace else for use
5 on that paper.
6 And then the next file is a combined Shark
7 Slough flow, ASCII file.
8 And the DEMANDS, again it has something to
9 do with this water allocation paper. I don't know
10 specifically what is in there referred to as demands.
11 It is probably something like the inflows to the
12 Water Conservation Areas, the inflows to the lake and
13 the inflows to the Lower East Coast, just a
14 comparison of inflows between those.
15 All the rest of them are based on
16 breakdown of those sub-basins.
17 There is EAAFLOW which more than likely
18 would be the inflows and outflows.
19 Then there is a series of them called
20 EAAIN and there is a data file. The one with the LAB
21 looks like just a label of some type, probably
22 something set up for graphics purposes. They are
23 very small files.
24 Then there is EAAOUT files, and again
25 there is an ASCII file, Quattro Pro version and a
111
1 label file of some type.
2 And then there is inflows to ENP.
3 The next two are FORTRAN programs that
4 are, actually they are output of FORTRAN programs
5 that are part of the South Florida Water Management
6 District. If I can remember, FORT.11 is a
7 sub-routine that calculates weekly flows for the
8 Shark Slough flow section based on the same time step
9 as the current rainfall-based formula and FORT.80 is
10 another output file from the South Florida Water
11 Management Model, another FORTRAN output file. And I
12 believe FORT.80 is a set of end of month water levels
13 for selected grid cells. In this case I would have
14 to look at the original FORTRAN program to figure out
15 which grid cells we selected.
16 But the program, if you look at that file
17 it will give you end of month readings and there
18 should be a header at the top of that which explains
19 which stations are included. It is just standard
20 output in the South Florida Water Management Model.
21 You can go in and specify you want end of month water
22 level information and specify row and column
23 information and it will pump out end of month water
24 level data on any row or column you want. And
25 FORT.80 just happens to be the sub-routine that you
112
1 go into to specific the row and column number.
2 Q. All right.
3 A. So it should have been renamed, you know,
4 but that was the original file and that probably
5 generated output for other analyses.
6 The FY92PROJ.WP5 and BK is a listing of
7 fiscal year '92 projects in the hydrology group that
8 I worked on, and backup file to that in WordPerfect
9 format. So it would just be some sort of breakdown
10 of all the projects we are working on. It would
11 probably specify who is working on it and what the
12 planned timetables of the projects are, that kind of
13 stuff.
14 Q. Just a quick side question. You mentioned
15 a hydrology group. Is that a separate group within
16 the --
17 A. It is probably.
18 Q. -- analytical group we discussed?
19 A. Based on the date, it is the group of
20 people I work with currently in the research group
21 that are all hydrologists. There are nine of them
22 within the research group and I am the head of that.
23 As I said, I am not program manager but I am sort of
24 a supervisor of project leaders in that group. Those
25 would be the projects of the group which I am
113
1 responsible for.
2 Q. That is essentially what you said is a
3 group of hydrologists?
4 A. There are nine people total, there are
5 four of us that are hydrologists, actually, five of
6 us that are hydrologists counting myself and the rest
7 are technicians or cooperators.
8 Q. When you say cooperators, those are
9 outside ENP or outside Park Service individuals?
10 A. Outside of the Park Service, generally
11 university people like I mentioned Trupti Bhatt
12 previously. She is a research associate with Florida
13 International University but she is a full-time
14 employee on our project. So she is a member of our
15 group.
16 Q. Are these outside individuals you
17 mentioned, are they also hydrologists or what
18 specialties are they?
19 A. Mostly all hydrologists. Trupti is, her
20 master's is in environmental engineering so she is
21 water quality and chemistry is her area of expertise,
22 although she is not working in that.
23 Q. What is she working in?
24 A. She does primarily computer applications
25 for us. She has a lot of experience in programming
114
1 and GIS applications so most of what she does is in
2 ARCINFO applications of output from models and that
3 kind of work. So that would probably be all the
4 projects at the beginning of 1992 we were going to be
5 working on over the course of that year.
6 Q. Would it be indicative of which ones
7 should have been complete?
8 A. There are probably dates in that document
9 that specify when we were supposed to have things
10 done by.
11 Q. The next?
12 A. The next group all deal with Lower East
13 Coast flows, those would be the flows along the
14 series of flow lines, well, between L-30 and L-36.
15 It is the levee alignment along the eastern side of
16 the Water Conservation Areas. So it would be the
17 flow across that boundary between the Water
18 Conservation Areas and the Lower East Coast. And it
19 would be Lower East Coast flows annual dot, DAT is
20 annual flows across those flows line in ASCII format.
21 Then the next file down below that with
22 just FLOW is probably the monthly and annual flow.
23 The one below that is the same data in Quattro Pro
24 format.
25 Then it has been broken out to have just
115
1 the inflows to the Lower East Coast and then the next
2 set that have MAN and then a FLOW next to them are
3 some sort of output from the South Florida Water
4 Management Model. The MAN refers to managed versus
5 natural. Any time you see NSM versus MAN, it is just
6 a distinction between those two model outputs.
7 Again it would be output from the Water
8 Management flow data in ASCII files.
9 The first two, MANSS would mean managed
10 data for the Shark Slough flow section.
11 And then the group underneath that that
12 all begin with MN and have different designations
13 after that is the monthly flow. If there is an N,
14 two Ns or an N and a P then there is a split between
15 the north-south east-west flows negative versus
16 positive. If there isn't M or N after it that means
17 there is only flow in one direction.
18 The first one there is monthly AGQs and
19 that's -- it is a file referred to as AGQ, it comes
20 out of, I believe it is the 298 Districts in the
21 northern part of the EAA and it would be
22 theoretically I guess input to Lake Okeechobee. All
23 the other ones just refer to whatever other structure
24 you can talk about G-136, G-88, hurricane gate S-3,
25 hurricane gate S-4, hurricane gate S-5.
116
1 L-8 canal, Lake Worth Drainage District,
2 and then there is a, there is a north and south
3 direction for the AGQ indicating there must be some
4 flow from the lake back into the 298 Districts.
5 Again there is all of the monthly data we
6 were working with for the water allocation study. It
7 looks like that continues down to the next page until
8 we get to the last file NSM-MAN.DAT and that would be
9 a comparison between the Natural System Model and the
10 Water Management Model using ASCII data. And the
11 size tells me it is probably something like annual
12 totals, it is a small file.
13 Again continuation on the next page, this
14 is all in disk 3, is more comparisons between the
15 Natural System Model and the managed system. The STA
16 again is the output from a statistics package. The
17 WQ1 is the Quattro Pro version.
18 And then Natural System Model flow annual
19 and then the monthly data are the next three files.
20 There are a lot of duplicate files. I had a tendency
21 to lose files so I save them on multiple disks now.
22 The next set is the Natural System Model
23 for Shark Slough.
24 The next one is a WordPerfect file. It is
25 a recommendation document for Dr. David Moon for a
117
1 job in Queensland, Australia. How it got on this
2 disk, I don't know.
3 The next one is a compilation of annual
4 rainfall data in Lotus format and that is, in this
5 case, the annual data would be for the five rainfall
6 basins that were analyzed by the District in their
7 analysis of rainfall extremes that George Shih did in
8 the 1980s. And his file runs essentially from the
9 start of rainfall records in the 1800s up through
10 sometime in 1989 so this is probably the rain, annual
11 rainfall data from that file.
12 The RAINASCE is some probably subset of
13 that rainfall data I was looking at for the ASCE
14 paper that I did that I explained on the previous
15 page.
16 The next file, REGBUDG, is something
17 having to do with budgets associated with regulation
18 stages in the conservation areas. I don't know
19 specifically without looking at it.
20 Then more files on a monthly and annual
21 flow to Shark Slough. Then there is Shark Slough
22 QWEEK which is weekly data for the, most likely for
23 the period of the rainfall formula which would be '85
24 to current.
25 Water Conservation Area flows annually and
118
1 then Water Conservation Area inflows and outflows are
2 the next set and that is part of the sub-basin water
3 budget comparisons.
4 And the last one is another recommendation
5 document for David Moon to the Young Science Students
6 Program in I believe South America somewhere.
7 Q. The first one was Australia?
8 A. Yes.
9 The next diskette --
10 Q. They bear the same date.
11 A. It is probably a very similar document
12 just with a change of location, change of address. I
13 don't think I spent much more time than that.
14 MR. KOBELINSKI: Off the record.
15 (Discussion off the record)
16 BY MR. KOBELINSKI:
17 Q. And that would finish off disk 3, is that
18 correct?
19 A. That is correct.
20 Q. Then going on to what again we have marked
21 as disk 2, you only have three files there.
22 A. Right. CANALS.WQ1 would be a compilation
23 of all of the monthly historical flow data for the
24 major canals essentially from Lake Okeechobee
25 southward. This would be the published data produced
119
1 by the USGS as well as whatever older data I could
2 compile. It is an uncompleted file listing that is
3 associated with this Water Management Changes in the
4 Everglades paper that goes from 1940 to 1989. So it
5 would be monthly flow data from 1940 to 1989.
6 Actually it probably stops around 1966 because most
7 of the other flow data is in all the other previous
8 files so I wouldn't have, after 1966 or so I wouldn't
9 have compiled it any more because it is probably
10 already in those other files.
11 Then WCA-WL are I believe daily water
12 levels for historical gauges in the Water
13 Conservation Areas that were collected as part of the
14 Everglades gauging program. So they would be the
15 early gauges established by the US Army Corps of
16 Engineers in 1951 that ran through the early sixties.
17 And that again was more data that was compiled for
18 this historical review paper. And again they will be
19 incomplete files because there are still a couple of
20 stations I haven't updated the record on.
21 The next file is empty for some reason.
22 Q. And going on then to the final disk which
23 again we have labeled as 1.
24 A. And again, most of this is associated with
25 the Water Management and Ecosystem Restoration in the
120
1 Everglades paper that I discussed earlier.
2 Again here's the final, according to the
3 title anyway, final version of this paper in
4 WordPerfect format. And here is ASCII versions of
5 the paper because my coauthor doesn't work in
6 WordPerfect.
7 Q. Does the final which bears date 9-6-91,
8 does that sound about?
9 A. It can't be because that is earlier than
10 the ASCEPAP file on disk 3, so it is probably not the
11 final.
12 I take that back. I am looking at two
13 different ones. One is a paper for the American
14 Society of Civil Engineers and one is the American
15 Institute of Hydrologists. So this is probably the
16 final for this paper.
17 So I have confused the two. So this one
18 is on Issues of Hydrologic Modeling in the Everglades
19 and that was a paper also included in that bundle of
20 papers that I submitted.
21 And then the ASCII files are versions,
22 portions of the document that were done with a full
23 screen text editor, not WordPerfect.
24 Then there are allocation files that are a
25 comparison between the flows between the different
121
1 sub-basins within the overall Everglades study area.
2 So I am not exactly sure what the difference is
3 between allocation and ALLONEW.
4 Q. What was AIHPAP?
5 A. American Institute of Hydrologists paper.
6 It means some portion of the document that was put
7 together to complete this final report, but the first
8 one is an ASCII file, the next one is a WordPerfect
9 file and a backup to the WordPerfect file which is
10 probably an early draft of, or, yes, early draft
11 portions of the final paper.
12 Q. And that final is the first file?
13 A. That's correct.
14 Then all the allocation ones, the next two
15 files, there are allocation comparisons between those
16 different sub-basins. I can't tell you specifically
17 what are in the files offhand.
18 Then ATLANTIC.DAT is outflow data from the
19 coastal ridge to the Atlantic.
20 For some reason there is an AUTOEXEC.BAT
21 file in there.
22 There is a bar allocate dot WK1, that is a
23 Lotus file which probably has bar graphs set up in
24 it, so just inputting of all that allocation data
25 into a Lotus or some sort of file just to generate a
122
1 graphic.
2 DEMANDS is the same way, probably an
3 imported set of the allocation data to generate some
4 sort of graphic.
5 Then again there is a breakdown of the EAA
6 inflows and outflows both monthly and annual data.
7 The next three, actually the next six are all
8 breakdowns between total EAA flows, then the inflows
9 monthly, then the inflows annually, then another
10 inflow file and then the outflow files monthly and
11 annually both in ASCII and Lotus format.
12 The next one is just a batch file for
13 K-Edit. It is just an editing sub-routine that we
14 use for text editing.
15 Then the next batch are Lake Okeechobee
16 outflows, again it would be data from this water
17 budget study.
18 And then Lower East Coast budget
19 information, both in ASCII and Lotus format and Lower
20 East Coast combined which would mean both inflows and
21 outflows, more than likely.
22 Then the last one there on that page is
23 Lower East Coast monthly flows. I try to give them
24 names so at least I can remember later on.
25 Then the next batch on the top of the page
123
1 are the same way, Lower East Coast inflows, monthly
2 and annual, and the ASCII versus Lotus format, Lower
3 East Coast outflows monthly and annual. I am not
4 sure, I assume LOCOUT is Lake Okeechobee. I don't
5 know what else it would be. I don't know what else
6 it would be unless it could be just a typo. It
7 should be Lower East Coast or something, I don't know
8 without looking at the data.
9 Then the managed flow on a monthly basis.
10 And then this whole series of files that
11 would include monthly flow data, either north or
12 south or east or west for all the different
13 structures, again. And there may be, part of these
14 may be an older or newer version than what was on the
15 original disks.
16 I had gotten it out of the model on a
17 couple of different occasions for different projects
18 and I think there actually are some updates over the
19 course of time. So whichever set of monthly data has
20 the last date on it. These are 8-22-91 primarily.
21 There is another set that is 1-24-92 so I would
22 assume the latest date is the most up to date and
23 corrected output. We occasionally go back to the
24 District and ask them, what is their newest version.
25 There is a discrepancy between what is in
124
1 the model and what is in the major data base so we
2 always go with the data in the model because that's
3 what they are using for most of their analyses.
4 These would be the monthly flow data for
5 all those structures again all the way through to the
6 middle of the next page.
7 Then there is just a weird collection of
8 files after that that are batch files for Quattro Pro
9 and which is, you know, the spreadsheet, and for
10 Sigma Plot which is a graphics package that we use.
11 There is a PRO file, file for K-Edit which is a file
12 that sets up certain parameters within the text
13 editor program, K-Edit, that we use.
14 The next four, TEST.DAT, TEST.FOR and
15 TEST.OBJ as well as SYM are some sort of FORTRAN
16 program that I was running at the time. I couldn't
17 tell you right now what it was for.
18 The DAT extension is the data file that
19 went into it. The dot FOR is the source code. The
20 OBJ is the object code. And then the SYM is probably
21 some simulated data or output file from whatever was
22 generated by running the FORTRAN program. Obviously
23 it wasn't too important because I used it as a test
24 file.
25 The next one looks like it is some sort of
125
1 variable table, WordPerfect document, probably just
2 some document I put together trying to keep track of
3 all of the station names so I would know what they
4 were. Probably just some explanation of different
5 station names.
6 And then it is the Water Conservation Area
7 inflows and outflow data in monthly and annual format
8 both in ASCII files and Lotus files.
9 And then PRN is just an output from -- it
10 is a print file out of Lotus.
11 And then the last set of files, YR either
12 a P or a N and then the structure name are the yearly
13 flows for all of these structures. And the N and P
14 is negative or positive flow for all the different
15 structures.
16 And that should be it.
17 Like I said, there are a lot of
18 duplication of files or updated versions of files as
19 the project continued. This would be primarily for
20 the water allocation studies, water budget studies
21 and the comparisons between the Natural System Model
22 and the Water Management Model work that was being
23 done.
24 Q. Just out of curiosity, I saw only one or
25 two '93 files. I believe they are primarily on,
126
1 there are two on disk 5. Are there any additional
2 files in this regard that you are currently working
3 on?
4 A. Not probably that I have been working
5 with. I would say, I haven't done any data analysis
6 in '93. I have spent most of my time not doing
7 technical work. I would say I probably haven't
8 updated any of these files or done any additional
9 analysis on these files. Most of these projects
10 haven't been worked on on some time based on the
11 dates of the files.
12 Q. Drawing your attention then, Mr. Johnson,
13 to what has been marked as Exhibit 1, and as I said
14 the final page of that exhibit which bears Bates
15 number 0961523 and also has a stamp on there,
16 Government Exhibit 6B, I ask whether or not you have
17 ever seen that particular page before.
18 A. Yes, I have.
19 Q. Are you aware that you have been
20 designated as an expert witness on behalf of the
21 United States Government in the SWIM, Everglades SWIM
22 Plan administrative proceedings?
23 A. Yes, I am.
24 Q. Are you familiar with the topics of your
25 expert testimony?
127
1 A. Yes.
2 Q. Have you reached final expert opinions
3 with regard to those topics?
4 A. Yes, assuming that I don't gain additional
5 information between now and the hearing, I would
6 assume that I have final opinions on all of those
7 topics.
8 Q. Are you doing any ongoing research right
9 now that you believe would impact or affect your
10 final opinions?
11 A. I am doing -- I am doing a little bit and
12 I am anticipating doing some additional work
13 primarily looking at hydroperiods in portions of the
14 Water Conservation Areas 1 and 2, in areas that are
15 referred to as nutrient impacted, and then comparing
16 those to hydroperiods in areas referred to as
17 background.
18 Q. With what background, sir?
19 A. Areas that are referred to as background
20 in terms of water quality. And I have just begun
21 some of that work.
22 Q. When did you commence that work?
23 A. I have been compiling the data over the
24 last couple of months but I haven't actually started
25 to do most of the hydroperiod and water depth
128
1 statistical analysis.
2 And I have been doing a literature review
3 of primarily vegetation studies in those areas,
4 basically going through bibliographies trying to pick
5 out if there is information on historical vegetation
6 patterns in the area.
7 Q. What data have you thus far collected with
8 regard to the study you just referred to with regard
9 to hydroperiod in high impact areas compared to
10 hydroperiod in background areas?
11 A. It would be the water level information
12 for the continuous water level recorders in the marsh
13 within Water Conservation Area 1 and 2 as well as the
14 water control structures such as the headwater and
15 tailwater for the S-10 structure and headwater and
16 tailwater for the S-11s.
17 Q. Where exactly are the high impact areas
18 that you will be studying or are currently studying?
19 A. The areas I am essentially compiling all
20 the hydrologic data for are in the southern end of
21 Water Conservation Area 1 and northern end of Water
22 Conservation Area 2. So it is whatever recorders are
23 in that general area. And then I will be looking at
24 other recorders within Water Conservation Areas 1 and
25 2 and 3 to try to find areas that are generally away
129
1 from water delivery inputs but have comparable
2 hydroperiods.
3 Q. Have you already located any?
4 A. I have located stations that I want to
5 analyze but I haven't completed the analysis to
6 confirm that they have the same general hydroperiods.
7 Q. What are the stations that you have thus
8 far identified for study?
9 A. Well, the stations that are in Water
10 Conservation Area 1 would be 1-7, 1-8C and 1-8D, 1-9,
11 2A-17, 2B-21, 2A-15, 2A-19. Those would be the marsh
12 stations in those two basins and the structures would
13 be the S-10 and S-11 structures primarily.
14 And then in Water Conservation Area 3A
15 they would be station 3A-3, 3A-4, 3A-28 and I believe
16 3A-2. And then the water control structures would be
17 the S-11s, S-151 and the S-12 structures headwater.
18 And then --
19 Q. I didn't hear the last part. I am sorry.
20 A. The headwater for the S-12 structures.
21 But essentially all I am doing right now is trying to
22 compile all the data.
23 Q. With regard to the stations that you had
24 just listed out, were those the background stations
25 that you referred to?
130
1 A. I haven't really specified for any one
2 station whether it is background or in an impacted
3 area. I know from previous reviews of the SWIM plans
4 which stations are in the areas most likely impacted
5 by nutrients.
6 Q. Of the stations you have just listed, if
7 you can go back and tell me which are the ones you
8 are going to be researching to determine whether or
9 not they are background.
10 A. I would assume it would be the stations
11 furthest away from the water delivery points such as
12 Water Conservation Area 3A-3 and 3A-4, 3A-2 and 3A-28
13 as well as the station in Water Conservation Area 1
14 such as 1-7, in Water Conservation Area 2 such as
15 2B-21. Then there is I think a couple of other
16 stations I looked at that have very short records
17 like the 3-39 and 3-40 structures in the Miami Canal.
18 Q. How far have you gotten in your data
19 collection?
20 A. I am still trying to compile all the data,
21 running into problems with not available data from
22 the Army Corps of Engineers for the last couple of
23 years.
24 Q. During what period of time are you
25 reviewing?
131
1 A. I will be looking at period of record data
2 so I will be compiling data from whenever the station
3 began. In many cases these are gauges that were
4 established as part of the Everglades gauging program
5 and either started in 1951 or 1953. Most of the
6 stations I am talking about have a continuous record
7 from the fifties rather than stations with short-term
8 records although some of them are only available from
9 the sixties or seventies.
10 Q. Have you gathered any of the data yet for
11 these stations or structures?
12 A. Much of the data was already gathered as
13 part of the study I am looking at for History of
14 Water Management in the Everglades from 1940 through
15 1990. A number of these stations I already have the
16 data for that purpose.
17 Q. Which stations are you missing or what
18 data are you missing them?
19 A. I don't believe, other than structure data
20 for S-10 and S-11 which I haven't requested yet, I
21 don't believe I am missing any of the marsh data. I
22 believe I have it all.
23 It all has not been set up in a format so
24 I can do the analysis. Some of it still is just hard
25 copy, unless I can acquire it from an another source,
132
1 in particular like gauges 2-15 and 2-19 I believe all
2 I have is hard copy currently.
3 Q. And the remainder you have on disk format?
4 A. I believe so.
5 Q. What is the intent of this study?
6 A. Essentially looking at the characteristics
7 of hydroperiods throughout the study and to try to
8 key in on stations that have similar hydroperiods in
9 different areas of the Everglades that could then be
10 used to look at differences in vegetative type, water
11 quality or other parameters associated with those
12 changes in hydroperiod.
13 Essentially we are trying to pick two
14 stations with the same hydroperiod with different
15 water quality or environmental characteristics.
16 Q. What are the characteristics other than
17 water quality?
18 A. I am not personally looking at vegetation
19 but I would be finding out from botanists, what are
20 the vegetation communities at different sites as well
21 as underlying soil types.
22 Q. Who is looking at the vegetation for you?
23 A. No one directly. I have been contacting
24 people who have done previous studies or going
25 through the literature and finding previous studies
133
1 that will describe the vegetation community in a
2 particular area or looking at generated vegetation
3 maps that you would find such as what is printed in
4 the SWIM Plan or other documents.
5 Q. Who are you using for information on the
6 soil types?
7 A. I assume that would be again, it would be
8 work that was collected by the Soil Conservation
9 Service or University of Florida IFAS or someone who
10 had done soil studies previously or a specific
11 research project, that had gone to a site and
12 collected some information like some of the early
13 studies on periphyton in the Everglades have done
14 soil studies.
15 But again, I am looking at very general
16 levels in terms of soils, whether they are peats or
17 marls and overall soil depths. I am not looking at
18 detailed soil comparisons.
19 Q. Have you already selected someone with
20 regard to the soil types?
21 A. No, not really. Based on knowing the
22 locations and knowing people who have studied the
23 area, I have a general idea what the soil types of
24 each one of those majors areas are, most of which are
25 Everglades peat.
134
1 Q. Do you intend to do any actual sampling or
2 have a sampling of any sort done with regard to this
3 study?
4 A. No.
5 Q. Do you intend to have any vegetative study
6 or mapping with regard to this study?
7 A. No.
8 Q. Same question with regard to the soil
9 sampling or soil studies?
10 A. No, it would all be with whatever
11 available literature I can find.
12 Q. Drawing your attention back to a comment
13 you had made and you state that there were from time
14 to time discrepancies between the data in the
15 District's main data base and the South Florida Water
16 Management Model, why would there be discrepancies
17 between the data?
18 A. Apparently the process that updates the
19 Water Management main data base referred to as
20 DBHYDRO is not done at the same frequency that many
21 of the researchers and engineers need for their
22 studies. So over the years there has been a process
23 of people developing their own data base for a lot of
24 work, particularly everything associated with the
25 South Florida Water Management Model. Most of those
135
1 data bases are maintained by people running those
2 models and the data in those data bases are not
3 necessarily the same or updated with the same
4 frequency as what is in DBHYDRO.
5 Since we are using output from the model
6 we will generally go back to whatever the District
7 staff is using in the model at that time as the most
8 appropriate data so we would be maintaining
9 consistency with anything we do on the model and they
10 do on the model.
11 I would say it is mainly a problem with
12 data management, not being able to keep up with huge
13 volumes of data coming in.
14 Q. With regard to this study you were just
15 referring to on the comparison of hydroperiod in a
16 high impact area and to hydroperiod in a background
17 area, when do you believe you will be finished with
18 your study?
19 A. I would assume in the next two months.
20 Q. Has your study progressed to the point
21 where you do have opinions with regard to the results
22 of the study?
23 A. I have some opinions because I have looked
24 at hydroperiods, water depths for a number of those
25 stations already as part of my historical review of
136
1 the Everglades paper.
2 Q. These are all areas outside of the Park,
3 is that correct?
4 A. That's correct.
5 Q. How much study have you done of areas
6 outside the Park over the past, I guess it would be
7 ten years you have been working for the Park?
8 A. Relatively limited detailed studies.
9 Mostly studies that look at water management over the
10 system such as the water allocation and water budget
11 studies that I referred to earlier.
12 The only real detailed work I have done on
13 hydrologic data outside the Park would be limited to
14 areas, say, south of Alligator Alley such as in the
15 modified water deliveries project which analyze data
16 essentially throughout Water Conservation Area 3A, 3B
17 and Everglades National Park.
18 Q. With regard to the researchers updating
19 the South Florida Water Management Model prior to the
20 update of the DBHYDRO, where did they get the data
21 they were updating the model with?
22 A. From data management, they get it from
23 resource operations, whoever happens to have the most
24 updated data.
25 Many times what you are seeing is data
137
1 that goes into the planning department's files before
2 it gets updated on DBHYDRO. So it is just a
3 difference in the amount of time it takes for DBHYDRO
4 to be updated. Other times it is someone reviewing
5 the data and selecting out portions of the data that
6 they would rather work on DBHYDRO there is a huge
7 range of data for any station you can pick from. So
8 they have eliminated that down to just particular
9 data bases that they are going to use.
10 Q. Does the Park review how that selection
11 process is made?
12 A. We will usually understand where they got
13 their data sources from. We won't necessarily have
14 direct access to it.
15 Q. Drawing your attention then to this final
16 page of Exhibit 1, it states as to the first
17 paragraph there, it says, "Mr. Johnson has formed the
18 following opinions." And although they are not
19 numbered the first one there states, "Alterations of
20 the natural Everglades ecosystem at the microbial and
21 macrophyte levels can not be accounted for solely on
22 the basis of man-induced alterations in hydroperiod."
23 Is that an opinion that you have reached
24 at this point in time?
25 A. Yes.
138
1 Q. What microbial or macrophyte studies have
2 you done in the Everglades ecosystem?
3 A. It is not based on any work I have done,
4 it is based on literature review or visits in the
5 field of either field sampling sites or general marsh
6 locations. But I have not done any work personally
7 in macrophytes or microbial ecology.
8 Q. You stated that this is based also on
9 field, and I am not sure if you used the terms
10 visits. Are you drawing a distinction between a
11 field study and a visit? Again, I am not sure, I
12 believe that's the word I thought you had said.
13 A. It would be trips that I have made to
14 different parts of the Everglades, either on, either
15 going to a field site within Everglades National Park
16 like our nutrient dosing study site and working at
17 that site for a day or two with the people or going
18 to other sites in the Everglades such as the nutrient
19 impacted areas in Water Conservation Area 2A or 1.
20 Q. With regard to the dosing site, what study
21 have you done at the dosing site within the Park?
22 A. I have done no work other than assistance
23 in the field with the normal data collection. I went
24 out in the field and assisted with the sampling of
25 periphyton and I did some of the laboratory work on
139
1 chlorophyll A, again, just so I would be familiar
2 with the methods that they were using out of my own
3 curiosity, not that I was assigned to the project.
4 Q. You had stated you did some sampling of
5 periphyton. Did you actually study whether there was
6 a change in the periphyton mat?
7 A. No.
8 Q. Or algal changes or the cause of those
9 changes?
10 A. No. I just assisted with the replacement
11 of the periphytometers, basically assisted with the
12 field work, not the analysis.
13 Q. You also mentioned WCA-2A, the work being
14 done, I believe you said work being done at 2A?
15 A. Right.
16 Q. What work is being done at 2A?
17 A. Simply site -- the only things I have done
18 there, I have gone and done site visits in the area
19 downstream of the S-10 structures.
20 Q. How many times have you visited areas
21 downstream of the S-10 structures?
22 A. Approximately five times since the late
23 1980s and probably before that in the early eighties
24 maybe once or twice.
25 Q. What was the purpose of your visits, the
140
1 five visits in the late eighties?
2 A. Generally orientation with the Justice
3 Department staff and new members of Everglades
4 National Park towards areas in the Everglades that
5 are nutrient impacted and what the differences
6 visually are between marsh communities in nutrient
7 impacted area and a non-impacted area.
8 Q. When you say orientation, do I understand
9 that you essentially would take these people out
10 there and say, this is a nutrient impacted marsh and
11 we will now go and I will show you what a background
12 marsh is?
13 A. Yes, I would go with them on the trip. I
14 wouldn't necessarily be the person leading the trip
15 but I attended a number of those trips.
16 Q. Did you do any testing while on these
17 trips?
18 A. No.
19 Q. How did you make the determination of what
20 was a nutrient impacted marsh?
21 A. Differences in vegetation type.
22 Q. Have you done any studies to determine
23 what the differences in vegetative type are in a
24 nutrient impacted marsh?
25 A. Other than visual examination in the field
141
1 myself, no, I have done no quantitative analysis.
2 Q. Have you done any studies to determine
3 whether or not the vegetative community of that marsh
4 was the result of the impacts of nutrients?
5 A. I have not personally done any studies,
6 no.
7 Q. Have you done any studies in the areas you
8 visually identified as nutrient impacted marsh to
9 determine whether or not there were other factors
10 that impacted the marsh community?
11 A. I have reviewed literature to get an
12 understanding of what the parameters that were
13 collected by other scientists in an area had
14 determined.
15 Q. Other than a literature review have you
16 done any other additional studies?
17 A. No. I should say literature review or
18 discussions with scientists working in the area.
19 Q. And have you had any, done any studies of
20 whether or not there were factors exclusive of
21 nutrients that resulted in the vegetative changes in
22 what you visually identified as nutrient induced
23 marshes?
24 A. Other than literature review and
25 discussions with other scientists, no.
142
1 Q. Is it your expert opinion that nutrients
2 are impacting the microbial and macrophyte levels in
3 the natural Everglades ecosystem?
4 A. Yes.
5 Q. Is my understanding correct that that is
6 not based upon field tests but rather based upon
7 literature review and discussions with other
8 scientists?
9 A. And selected site visits, yes.
10 Q. These are the visual site visits we
11 discussed?
12 A. That's correct.
13 Q. Have you had any other site visits that we
14 haven't discussed?
15 A. No, I have not done any field trips where
16 I have done any sampling at these sites.
17 Q. What literature are you basing that
18 opinion upon?
19 A. I have reviewed literature on periphyton
20 communities, I have reviewed literature on the
21 microbial community and I have reviewed literature on
22 macrophyte community changes in background and
23 nutrient impacted areas.
24 Q. I am sorry, I believe you said macrophyte,
25 periphyton and?
143
1 A. Microbial communities.
2 Q. Let's start with periphyton. What are the
3 literature studies or papers that you are basing your
4 opinion on?
5 A. The earliest papers I remember reviewing
6 was work by Pat Gleason in the 1970s. I believe he
7 has two publications in 1974, one is a technical
8 report and the other one is a professional
9 publication with Spackman in 1974 where they did
10 studies of the periphyton communities in Water
11 Conservation Areas 1 and 2A, compared the periphyton
12 communities in those areas to nutrient sampling,
13 water chemistry.
14 Q. Any other periphyton studies and
15 literature studies?
16 A. Yes. The next studies I would have
17 reviewed, probably work by Joan Browder who did work
18 at several different locations in the Everglades
19 including Everglades National Park and examined the
20 periphyton communities in different types of marsh
21 areas and did some comparisons with water chemistry.
22 Q. Were there particular papers or reports of
23 Ms. Browder that you reviewed?
24 A. I don't know if I could remember the dates
25 but she had a paper in early 1980s on periphyton
144
1 communities in Everglades National Park.
2 Q. Other than the early eighties paper in the
3 Park, are there any other papers --
4 A. She has a late 1980s paper that was, it is
5 going into the Everglades Symposium proceedings,
6 whenever that comes out. And whatever, it hasn't
7 been published yet so I don't know what the date is
8 yet but she submitted a paper on periphyton community
9 related to water quality in the Everglades, to the
10 Everglades Symposium.
11 Q. These papers that you are referring to
12 with regard to the Everglades Symposium, are these
13 all going to be chapters in a book being published?
14 A. That's correct.
15 Q. Is Ms. Browder then going to be the author
16 of a chapter in the book?
17 A. That's correct.
18 Q. And it will be dealing with nutrient
19 impacts upon the periphyton community?
20 A. I would say she is going to be an author
21 on one of the papers that is probably in a chapter,
22 probably a series of chapters that focus on different
23 either environmental communities or stresses on the
24 system. She will be one of the authors that has a
25 paper in a section that deals with, I assume,
145
1 periphyton and water quality.
2 Most likely there will be other authors
3 who have papers on water quality and vegetation. I
4 know Steve Davis has a paper in the Everglades
5 Symposium proceedings.
6 Q. Other than Steve Davis and Joan Browder
7 are you aware of any other author --
8 A. Steve Davis.
9 Q. Let me finish that question. I am sorry
10 to cut you off.
11 (Continuing) who will be submitting papers
12 that will become part of that book that are dealing
13 with water quality and any of the vegetative or
14 periphyton algal community, microbial community?
15 A. I think Pat Gleason has a paper that was
16 submitted to the Everglades Symposium but I don't
17 know specifically. He studies periphyton so I assume
18 he will have a paper on periphyton in the Everglades
19 but I don't know specifically. I never reviewed his
20 paper.
21 Q. Have you reviewed either Steve Davis' or
22 Ms. Browder's paper?
23 A. I have seen a copy of Steve Davis' paper.
24 I have only heard the presentation for Joan Browder's
25 paper. I have never seen a copy of it.
146
1 Q. Was that a presentation at the Everglades
2 Symposium?
3 A. That's correct. And I have discussed with
4 her on other occasions since the symposium her
5 findings, mainly just running into her at meetings,
6 general conversation.
7 Q. When you say you have seen Steve Davis',
8 you were not doing any type of a peer review, were
9 you?
10 A. No, it just happens to be one of the
11 papers I had a copy of at one time I got from I
12 believe John Ogden. Steve Davis and John Ogden are
13 the two editors on the documents so they have a
14 compiling of almost all the papers that are being
15 submitted.
16 Q. Are you on the peer review committee?
17 A. I am on the advisory committee, whatever
18 it is called, advisory peer review, I don't know what
19 it is. Something like that, steering committee,
20 there you go. It is called the steering committee
21 for the Symposium proceedings. I am on the steering
22 committee.
23 Q. Going back then to periphyton, we have
24 discussed Pat Gleason's 1974, he had two technical
25 publications, or excuse me, two publications, one
147
1 technical and one a private, I believe?
2 A. Right.
3 Q. Joan Browder had an early eighties and
4 late eighties which is actually some of it still
5 sounds like it is in progress?
6 A. Right.
7 Q. Any other literature that you have
8 reviewed with regard to periphyton?
9 A. Yes. I have reviewed I believe three
10 papers by David Swift, a Water Management District
11 technical report in 1981, a publication in 1984 on
12 the environments of South Florida, Volume 2, I
13 believe, and his 1987 paper with Nicholas, I believe
14 was the coauthor, all dealing with periphyton and
15 water quality in the Everglades.
16 Q. What was the last one?
17 A. I think it is --
18 Q. '86 did you say?
19 A. '87 I believe was his last one. Swift and
20 Nicholas, I believe, are the two authors.
21 Q. Any other literature on periphyton?
22 A. Yes. I have reviewed work by Sonny Hall
23 and Ramona Rice, a technical report submitted to the
24 Park I believe in 1988 dealing with periphyton work
25 with, at the nutrient uptake study site, ENP dosing
148
1 study.
2 Q. What was the year of that paper?
3 A. I believe it came out in 1988. It was a
4 draft report in '87 but I believe the copy I read was
5 a 1988 report.
6 Q. That was on the dosing study site?
7 A. That's correct. That paper is strictly on
8 the periphyton communities, one of three papers on
9 the dosing study.
10 Q. You mentioned Sonny Hall and Ramona Rice.
11 They were coauthors on that?
12 A. Ramona Rice was the original investigator
13 on the periphyton dosing study. She left and went to
14 another university and Sonny Hall was hired by the
15 Park to complete the analysis. And she did a joint
16 publication.
17 Q. When you say she left and went to another
18 university, is she doing a cooperative study at
19 another university?
20 A. On the original study she was in the
21 biology department at Florida International
22 University and she was under contract for the Park
23 Service to do the periphyton work on the nutrient
24 dosing study. After all the field work was done she
25 left FIU before completing on the analysis, so much
149
1 of the identification and species composition work on
2 the periphyton was done by Sonny Hall. Then they
3 jointly got together and put out the paper.
4 Q. Is Sonny Hall with the Park Service?
5 A. No. He is a phycologist with the St.
6 Johns River Water Management District.
7 Q. What is a phycologist?
8 A. Someone who studies periphyton, algal
9 communities.
10 MR. KOBELINSKI: Off the record.
11 (Thereupon, a brief recess was taken,
12 after which the following proceedings
13 were had)
14 MR. KOBELINSKI: Back on the record.
15 BY MR. KOBELINSKI:
16 Q. Before the break we were I believe
17 finishing off discussing the Sonny Hall-Ramona Rice
18 study, and I guess faster than having the court
19 reporter read it back, I believe I asked whether
20 Sonny Hall was a member of the Park Service.
21 A. And I said, no, he was working for the St.
22 Johns River Water Management District.
23 Q. I believe you already told me where Ramona
24 Rice is now.
25 A. She is in Kansas.
150
1 Q. Kansas. Is she with the university up
2 there?
3 A. I believe so. I am not sure if it is the
4 University of Kansas or what school. She is at a
5 university teaching.
6 Q. Any additional periphyton literature?
7 A. There was a paper by I think a woman named
8 Owens, I can't remember if she was the senior author
9 or second author, that came out in the late 1980s.
10 And she did a dosing study in Water Conservation Area
11 3B, I believe. I don't know how she got permission
12 to do it. And it is in a publication that deals with
13 wetlands use of, the use of wetlands to filter
14 wastewater treatment.
15 Q. Do you know her first name?
16 A. No. I remember seeing the paper and
17 looking at it very quickly because it was something
18 that was reviewed around the same time that the
19 nutrient dosing study reports were being completed at
20 the Park.
21 Q. Do you know if she did that in cooperation
22 with any particular state or government agency?
23 A. I believe it was a Sea Grant project with
24 the University of Miami, something like that. It may
25 not have been but I think that rings bell.
151
1 Q. Any other periphyton papers or
2 publications?
3 A. I am sure I reviewed others but those are
4 the only ones that I remember by author and date.
5 Q. Going then on to macrophyte studies and
6 papers.
7 A. Why don't we do microbial next because
8 that's the most closely related.
9 Q. All right.
10 A. In terms of microbial community studies,
11 the work by I think it is Reeder and Davis in the
12 late 1980s, that looked at the composition of
13 bacteria and fungi communities in Water Conservation
14 Area 2A, I believe, and looked at rates of microbial
15 decomposition and dissolved oxygen.
16 A study by I think it is Ballanger and
17 Platko, also in the late 1980s, at several different
18 sites within the Water Conservation Areas, I believe
19 they did studies in Water Conservation Area 1 and 2A,
20 again looking at microbial community composition,
21 function and relationship with dissolved oxygen.
22 Work by Ed Maltby, I believe his paper
23 came out in 1988 on rates of decomposition of
24 cellulose related to nutrient impacts. His work was
25 at the dosing study site at Everglades National Park.
152
1 And then --
2 Q. Is he with the Park Service?
3 A. No, he is a cooperator with -- what is
4 that school? I don't even know what the school is.
5 He is from a university in England but I am not sure
6 what the exact title of the school is.
7 Let me see what other studies.
8 I reviewed a number of studies Ron Jones
9 has done. There is a paper by Amador and Jones in
10 1992, I believe, that looks at rates of microbial
11 respiration experimentally, adding phosphorus to
12 Everglades peats to look at microbial metabolism and
13 effect it has on rates of respiration and again
14 related to dissolved oxygen.
15 And then I guess lastly a paper that Dan
16 Scheidt did along with I think Ballanger, they did a
17 paper back in 1990, I think it was on dissolved
18 oxygen and microbial activity in the Everglades. And
19 that went into the North American Lakes Management
20 Society, something like that.
21 Those are I believe most of the papers I
22 could think of anyway that deal with microbial
23 communities.
24 Q. And next would be macrophyte.
25 A. On macrophytes, a couple of papers by
153
1 Steve Davis on macrophyte community changes and
2 competition with cattails in the Everglades, I think
3 he did a 1991 publication, a 1992 publication. And
4 then there was a mid-eighties publication that he did
5 primarily on work in Water Conservation Area 2A and
6 looked at uptake rates and decomposition rates on
7 sawgrass and cattail communities relative to nutrient
8 levels in marshes.
9 A paper by Dave Walker on the macrophyte
10 community changes at the nutrient dosing study. That
11 came out in 1988.
12 The work by Bob Doren and a couple of
13 other botanists at the Park dealing with vegetation
14 communities related to nutrient gradients in the
15 Everglades. And they did work in all three of the
16 conservation areas and in the Park.
17 Q. What year approximately was the Doren and
18 other --
19 A. Last time I saw it it was in press. So I
20 don't know if it is '92 or '93. I believe it
21 probably has come out. I haven't seen a final copy.
22 It is Doren and Lou Whitaker and Tom Armentano all
23 three of which are botanists that worked for
24 Everglades National Park, Whitaker left, and Ron
25 Jones from Florida International University.
154
1 Q. With regard to the Dave Walker study on
2 nutrient dosing in the Park, what year was that?
3 A. I believe the report I saw was a 1988
4 publication. Actually it wasn't a publication, it
5 was a report to the superintendent, I believe.
6 There have been a large amount of
7 publications I have reviewed associated with the ENR
8 project by Marguerite Cook and I think some stuff by
9 Sue Newman, work by Kadlec, mostly documents I have
10 reviewed in the last two years either associated with
11 the ENR project design or the STA project design
12 where they looked at the ability of marsh species to
13 uptake and store nutrients and then the effects they
14 have on the macrophyte community structure.
15 I think that's probably all the ones I can
16 think of by author and title or author and year.
17 Q. With regard to the Cook publications on
18 the ENR project, do you recall what years those were?
19 A. It wasn't the ENR project but work in
20 Water Conservation Area 2A, I believe it was a 1992
21 publication that I can remember where she did some
22 followup work on sawgrass and cattail communities in
23 2A, I think the same basic sampling sites that Steve
24 Davis has done.
25 Q. And the work or publication by Sue Newman?
155
1 A. It is a joint publication by I think
2 Newman and Kadlec that came out in 1992.
3 A. Again it was a document provided to the
4 SAGE committee or STA committee or something like
5 that that I got copies of.
6 And also the other work I have reviewed is
7 work by John Richardson in Water Conservation Area 1
8 done on contract with the Fish and Wildlife Service
9 and I think he has a 1990 and a 1991 publication, I
10 believe, on vegetation community related to water
11 quality and nutrients within Water Conservation
12 Area 1.
13 Q. That was '90 and '91?
14 A. I think a '90 and '91 publication I read.
15 One of them is probably like an annual report to the
16 Fish and Wildlife Service, a progress report kind of
17 thing, and the other one was a publication, I can't
18 even remember where it was published. It is
19 Richardson and Wiley Kitchens and a couple of other
20 cooperators that work in the Fish and Wildlife
21 Service cooperative unit at the University of
22 Florida. So it is a group paper by multiple people.
23 But those are most of the papers I could think of.
24 Q. Have you done any studies to determine
25 what impacts hydroperiod has on macrophyte
156
1 communities in the Everglades?
2 A. I personally have not done any work
3 although I have seen references to impacts of
4 hydrology on macrophytes and other vegetation by
5 authors in literature, but no personal field work or
6 laboratory work.
7 Q. With regard to the literature you just
8 referred to, was there a determination that
9 hydroperiod did have an impact upon macrophyte
10 communities or did not?
11 A. On most of the literature I think they
12 would say that hydroperiod does have an impact on
13 macrophyte communities.
14 Q. Are you basing your opinion in part then
15 upon that literature?
16 A. Yes.
17 Q. Is there anything else you are basing your
18 opinion upon with regard to hydroperiod impacts on
19 macrophyte communities?
20 A. Just my review of the literature and site
21 visits I have made around the Everglades where I have
22 seen water depth and hydroperiod conditions relative
23 to vegetation community, either field work I have
24 done or reviews of maps and that kind of stuff
25 related to hydrologic data.
157
1 Q. And on those field trips or site visits
2 have you been able to visually determine whether or
3 not hydroperiod has had an impact on macrophyte
4 communities?
5 A. I can based on looking at the vegetation
6 communities and the hydrologic record and reviewing
7 the literature, I can form an opinion on how much of
8 the overall vegetation community structure is related
9 to the hydroperiod of the area that they are
10 occurring in. Basically what I am saying is the
11 literature reviews and the site visits have shown me
12 there is a gradation of hydrologic conditions that
13 characterize each of the major vegetation communities
14 within the Everglades.
15 Q. Just so I understand you, you just
16 essentially are referring to the fact that a slough
17 community typically has a longer and deeper
18 hydroperiod as opposed to a bush or relatively dry --
19 A. As compared to a sawgrass community or,
20 yes, other communities, that's right.
21 Q. Do you have any opinions as to whether or
22 not alterations in hydroperiods, man-induced
23 alterations have any impact upon vegetative
24 communities?
25 A. Yes. I believe alterations of,
158
1 man-induced alterations of hydroperiod do have an
2 impact on vegetation communities.
3 Q. Is this something you have studied?
4 A. I haven't done any literature -- I haven't
5 done any research myself. I have done literature
6 review and I have visited in areas in the field where
7 there has been major changes in hydrologic parameters
8 and seen the history of changes in vegetation at
9 those sites either through review of aerial
10 photography or actually visiting the site myself over
11 a number of years.
12 Q. Let's start with macrophyte communities.
13 Has alteration of hydroperiod impacted macrophyte
14 communities?
15 A. Yes.
16 Q. How are you able to visually distinguish
17 between alterations in macrophyte communities
18 resulting from hydroperiod as opposed to resulting
19 from nutrients or other factors?
20 A. I don't know if I could quantitatively
21 isolate the difference between hydroperiod and other
22 factors except in areas where the other factors
23 aren't important such as in areas of the Everglades
24 that are far away from delivery or inflow points
25 which theoretically would have background levels of
159
1 water quality throughout the vegetation communities
2 so nutrient wouldn't be a factor or areas that had
3 uniform soil characteristics so soil type and depth
4 wouldn't be a factor.
5 Q. How do you intend to distinguish then in
6 the study you referred to that you are still in the
7 process of doing which is as I understand it you were
8 going to attempt to differentiate between
9 quantification impacts resulting from altered
10 hydroperiod as opposed to those resulting from
11 nutrients?
12 A. I don't know if I am going to be
13 quantifying the vegetation impacts due to hydroperiod
14 versus nutrients. What I will be doing is looking at
15 a series of sites that have similar hydroperiod or
16 water depth conditions and trying to factor out the
17 effects of hydrology and then seeing if there is
18 still a difference in nutrients or water quality
19 between those sites.
20 Q. Are you going to look at sites that have
21 similar water quality but differences in or altered
22 hydroperiods to see whether or not there are
23 differences or impacts upon the vegetative
24 communities at the sites?
25 A. I would assume you would have to really
160
1 quantify that difference. Until I get all the data
2 and look at the ranges of hydroperiod I don't even
3 know what the possible ranges in hydroperiod and
4 water depth would be yet. I haven't analyzed that
5 much date for Water Conservation Area 1 and 2.
6 Q. With regard to impacts related to
7 hydroperiod, are we referring to impacts related to
8 shortened or lengthened hydroperiods?
9 A. I have visually seen impacts associated
10 with both and I have read literature reviews,
11 literature citations that show impacts on vegetation
12 communities associated with both lengthening and
13 shortening of hydroperiods.
14 Q. In your literature review have you seen
15 any studies that have attempted to differentiate or
16 quantify in any manner impacts resulting from
17 hydroperiod as opposed to those resulting from
18 nutrients?
19 A. Several of the studies I cited earlier by
20 David Swift state clearly in there that there was
21 water depth hydroperiod sampling over the period of
22 study and sites with same water depths and
23 hydroperiods have vastly different vegetation
24 communities and they are attributing that to the
25 water chemistry or nutrients. David Swift I know has
161
1 shown a relationship where there is very little
2 differences in periphyton communities associated with
3 hydrologic parameters as compared to water quality.
4 The work by Gleason and Spackman in the
5 1970s came to the same conclusion, that periphyton
6 did not vastly vary in response to hydrologic
7 parameters as you go from one water depth or
8 hydroperiod characteristic area to another but showed
9 the greatest correlation or quantitative relationship
10 with water quality and nutrients.
11 I believe the same thing has been shown by
12 work by Steve Davis on macrophytes along nutrient
13 gradients in Water Conservation Area 2A where they
14 have sampled water depth and hydroperiod along a
15 gradient and shown areas with similar hydroperiod and
16 water depth have vastly different vegetative
17 communities and they correlated that with nutrients
18 and water quality trends.
19 Q. You just mentioned a Spackman?
20 A. Right.
21 Q. With Gleason?
22 A. Yes.
23 Q. I don't recall you mentioning that before.
24 A. I think I mentioned a paper in 1974 with
25 Gleason and Spackman done on periphyton communities
162
1 in Water Conservation Areas 1 and 2A.
2 Q. That paper is in conjunction with the one
3 by Pat Gleason you mention before?
4 A. Right, Gleason and Spackman were the two
5 authors.
6 Q. With regard to the impacts on macrophyte
7 community resulting from alterations in hydroperiod,
8 what literature are you relying upon in formulating
9 your opinion?
10 A. A lot of old literature starting with the
11 work by John Davis in 1943. He did not a
12 quantitative analysis but he did a qualitative
13 comparison between hydrologic conditions and
14 vegetative types.
15 So did Loviss in the late 1950s, I
16 believe, 1959, did a study and qualitatively showed
17 differences in hydrology versus vegetation.
18 A number of studies in the seventies
19 including work by Ben McPherson of the USGS, Michael
20 Duever of the Audubon Society, I think.
21 I think Bill Robertson had some work in
22 the 1970s, late, doing bird studies I think, but
23 looking at hydrology and vegetation community
24 relative to bird communities.
25 In the eighties a series of papers I know
163
1 I have reviewed by Olmsted, Zafke. Olmsted was
2 something like a 1987 publication on vegetation
3 communities in Everglades National Park and she tried
4 to quantify the hydroperiod characteristics of
5 different communities.
6 The paper by Mike Zafke was an '84
7 publication, I believe primarily on Water
8 Conservation Areas, but he also did some work in the
9 lower eastern panhandle of Everglades National Park.
10 A paper by Dewey Worth I think came out in
11 1986 on the vegetation community in Water
12 Conservation Area 2A where he quantified hydroperiod
13 relative to vegetation communities.
14 A number of publications by Lance
15 Gunderson who is a botanist or was a botanist for the
16 Park in 1988, 1989 and 1990, where he looked at
17 hydroperiod versus vegetation communities both
18 throughout the Everglades and also did some
19 experimental studies of flooding, impacts of flooding
20 on different vegetation types, plants and buckets
21 kind of studies.
22 Q. Does that cover it?
23 A. Off the top of my head those are probably
24 the major studies that I can remember where someone
25 tried to either qualitatively or quantitatively
164
1 relate hydroperiods to vegetation changes at the
2 macrophyte level, not counting the ones we talked
3 about dealing with periphyton.
4 Q. That's what I was getting to next.
5 Let me back up. Have you conducted any
6 studies or testing to determine what impacts if any
7 altered hydroperiods have upon the Everglades
8 periphyton community?
9 A. No.
10 Q. Have you conducted any studies to
11 determine what impacts if any altered hydroperiods
12 have on the Everglades microbial community?
13 A. No.
14 Q. Do you have an opinion as to whether or
15 not altered hydroperiods do have an impact on
16 periphyton communities in the Everglades?
17 A. I have reviewed literature and talked to
18 people who work in that field and I have an opinion.
19 Q. This is periphyton?
20 A. Yes, periphyton.
21 Q. What is that opinion?
22 A. That the changes in community composition
23 and productivity are primarily related to changes in
24 water chemistry and nutrients and other than one
25 study I don't know of any that related differences in
165
1 hydroperiod to differences in periphyton community
2 composition or productivity.
3 And then one study I believe there was a
4 study by -- I can't remember the woman's name --
5 there was a study in Everglades National Park in the
6 early 1980s where a woman came in and looked at the
7 periphyton communities throughout the Park and her
8 findings were that periphyton communities were
9 related to hydroperiod and water depth. But I don't
10 believe she did any sampling near any water delivery
11 structures, she did all her sampling out in open
12 marsh areas relatively far away from -- she was
13 looking at differences in periphyton communities I
14 believe related to macrophytes, how periphyton
15 communities were related to differences in, say, open
16 water prairies or sawgrass areas or sloughs.
17 She was comparing, I believe she was
18 comparing periphyton communities between those kind
19 of macrophyte communities. So she really wasn't
20 looking at water quality. I don't believe she did
21 any water quality sampling.
22 So her findings were that periphyton was
23 associated with or could be quantitatively correlated
24 with differences in hydroperiod and water depth.
25 But other than that study, the work that
166
1 Pat Gleason has done and the work that Dave Swift has
2 done, the work that Ramona Rice and Sonny Hall have
3 done, to my knowledge have all shown that water
4 chemistry and nutrients are the parameters that drive
5 changes in periphyton community composition and
6 productivity.
7 And in several studies such as the dosing
8 studies, hydroperiod and water depth and flow
9 conditions have been factored out because you are
10 comparing in channels that are similar in terms of
11 hydrologic parameters and the only difference between
12 them is the nutrient inputs.
13 So those are probably the best
14 quantitative analyses you could probably see
15 something where you are physically isolating the
16 effects of one set of parameters and only making a
17 change in another set. So those I would say are
18 probably the most conclusive.
19 Q. Going to the microbial community, do you
20 have an opinion as to whether or not altered
21 hydroperiods have any impact upon the Everglades
22 microbial community?
23 A. To my knowledge in my literature review I
24 have not seen any information that would suggest
25 microbial community is heavily affected by changes in
167
1 hydroperiod or water depth.
2 Q. I believe you already testified you have
3 not done any studies in that --
4 A. That's correct.
5 Q. You said heavily impacted. Has it been
6 shown essentially no impact, just so I understand
7 what you mean by heavily?
8 A. When you are talking about microbial
9 community activity and you are talking about diurnal
10 changes in dissolved oxygen, there is marked
11 differences in the range of fluctuations of dissolved
12 oxygen in the water depending on the type of
13 community you are in, usually microbial -- I mean
14 macrophyte community, so that sawgrass communities
15 have different ranges of dissolved oxygen than do
16 open prairies than do sloughs. But the effects of
17 nutrients are vastly different than the variations
18 that occur between those communities.
19 Q. Just so I understand your opinion, you are
20 saying other than the natural changes in microbial
21 communities resulting from, for instance, the
22 difference between a slough community/microbial
23 community and a macrophyte, a sawgrass community,
24 hydroperiod has no impact upon microbial communities?
25 A. In the literature that I have reviewed I
168
1 haven't seen hydroperiod has an effect.
2 Q. Other than the literature that you have
3 reviewed do you base your opinion upon anything else?
4 A. Discussions with people working in the
5 field such as Ron Jones and others, but no direct
6 field work.
7 Q. Would the literature review that you
8 already mentioned with regard to the microbial
9 communities essentially cover the literature that you
10 are basing your opinion on?
11 A. Yes. I should say the only other source
12 of literature that I have reviewed that I think goes
13 into all these communities is something like the
14 Everglades SWIM Plan because it basically has
15 summaries of periphyton, microbial and macrophyte
16 community dynamics that summarizes the findings of
17 lots of different studies and I have reviewed those
18 documents.
19 Q. Do you understand that you are providing
20 an expert opinion in support of the findings of the
21 SWIM Plan, is that correct?
22 A. That's correct.
23 Q. So essentially in your review of the SWIM
24 Plan you have not found anything contradicting your
25 opinion, is that what you are telling me?
169
1 A. Or I have --
2 Q. You are not supporting your opinion upon
3 the findings that your --
4 MR. FITZGERALD: Allow the witness to
5 answer.
6 A. The SWIM Plan document references work by
7 a number of different authors. In general I have
8 gone back to the original source on those authors and
9 reviewed theirs findings and what I see in the SWIM
10 Plan in terms of their conclusions is consistent with
11 what the original authors had stated. I don't see
12 any inconsistencies with what is in this SWIM Plan.
13 Q. Are there any additional authors who you
14 have not mentioned in providing the literature that
15 you reviewed in the past half hour, hour?
16 A. Not that I can think of right now.
17 Q. Given your experience as a hydrologist,
18 how would you go about setting up a test or is there
19 a means as far as you know of studying to determine
20 whether or not alterations in hydroperiod do have an
21 impact upon the periphyton community in the
22 Everglades?
23 A. Probably the best thing to do would be
24 some sort of controlled experiment where you
25 establish a series of small test cells or flow ways
170
1 where you introduce a different hydroperiod or water
2 depth and run that for a long period of time and see
3 if existing periphyton community changes relative to
4 those variabilities.
5 The kind of experiments that would be
6 proposed in the ENR project in the test cells portion
7 of that project, I know they have proposed to do
8 those kind of studies on macrophyte communities. I
9 don't know if they have also proposed to do those
10 kind of studies on periphyton because I am not sure
11 if there is still a plan used for periphyton in the
12 ENR project, like there was originally.
13 But that in my mind that would be the most
14 ideal way of testing it because you are controlling
15 all the other parameters.
16 Q. Have any of the literature that you have
17 reviewed done that type of test?
18 A. From the closest thing is the Everglades
19 National Park dosing study where instead of
20 controlling hydroperiod they maintained hydroperiod
21 normal and modified nutrient input, but I have not
22 seen a comparable situation where they have kept
23 water chemistry the same and altered hydroperiod. To
24 my knowledge I don't know of anyone who has ever done
25 that.
171
1 Q. Would the dosing study be able to indicate
2 what impacts hydroperiod would have then?
3 A. No.
4 Q. Does the periphyton community change, for
5 instance, are there differences in the Everglades
6 generally based upon your knowledge between the
7 periphyton community in a slough as opposed to a
8 macrophyte marsh?
9 A. There are some differences. The
10 differences seem to be more pronounced not between a
11 slough versus an open marsh but between portions of
12 the Everglades that have different substrate and
13 water chemistry, like in pristine areas of Water
14 Conservation Area 1 versus Water Conservation Area 2
15 or 3 there are different macrophyte communities,
16 because the substrate in Water Conservation Area 1,
17 the peat is slightly different, the water chemistry
18 in Water Conservation Area 1 is more acid and is
19 softer water, has lower total dissolved solids,
20 whereas in the other Water Conservation Areas the
21 environment is more alkaline and has higher total
22 dissolved solids so those differences in chemistry
23 and slight differences in substrate have been shown
24 to produce different periphyton species in
25 communities.
172
1 Q. Could you just generally describe to me
2 the different type of ecosystem or vegetative
3 communities you find in the Everglades such as for
4 instance an open slough, a macrophyte or sawgrass
5 marsh?
6 A. You mean name those categories?
7 Q. Yes, go through the categories.
8 A. I believe there are nine major categories
9 going from an open water marsh which would be like an
10 Eleocharis marsh or slough environment, sawgrass
11 communities, they are usually something like a
12 coastal prairie community that is dominated by
13 coastal grasses like, what is it, Spartina patens or
14 alternaflora, normal coastal marsh grass communities.
15 Q. Is that sort of a combined, is that where
16 the freshwater marsh sort of meets up with the
17 saltwater marsh?
18 A. Right, that's usually why they occur.
19 There are the mangrove forest communities and usually
20 different ranges of mangrove forests.
21 There is a cypress community, either
22 cypress domes or usually dwarf cypress forests that
23 occur with different mixed understory grasslands
24 underneath it.
25 There is in the wetter communities there
173
1 are bay heads and usually willow heads, tree islands,
2 hardwood hammocks, tropical hardwood hammocks.
3 I think that's -- I don't know if that is
4 nine or not but that's the major communities that I
5 would think of in terms of gross scale differences in
6 vegetation communities.
7 Q. If you were to conduct a study again as a
8 hydrologist to determine what if any impacts
9 hydroperiod or altered hydroperiods have on microbial
10 community, how again would you do that type of study?
11 A. You would have to probably do the same
12 kind of a study, take samples of similar substrates,
13 Everglades peat, and in a test situation impose
14 different hydroperiods on them, either in some sort
15 of closed cells or in a flow way situation, maintain
16 the same water chemistry and other parameters and
17 only alter water depth and hydroperiod.
18 Q. If you wanted to go ahead and eliminate
19 the impacts of water quality, is there a means of
20 doing that so you could, to the extent possible, just
21 determine what the hydroperiod impacts are as opposed
22 to water quality impacts?
23 A. Sure, induce the same water chemistry to
24 all of the samples.
25 Q. So, for instance, you could do one whole
174
1 set of tests with different hydroperiods using
2 pristine water?
3 A. Right.
4 Q. And again keeping the same soil type, et
5 cetera, you could do the same series of hydroperiods
6 using a different or a let's call it a nutrient
7 impacted water quality, is that correct, or high
8 nutrient?
9 A. Yes, that's true, but then I think, if you
10 wanted to compare between the two sets of runs you
11 would be comparing across water chemistry parameters,
12 not just hydroperiod.
13 What you could do is take samples of
14 different substrates in the Everglades and test them
15 with the same water chemistry at different
16 hydroperiods, take samples of substrates for marl
17 soils and different type of peat soils and impose
18 different hydroperiods and see how they react, and
19 keep the water chemistry the same.
20 Q. Would there be any way to then do, be it
21 one test or series of tests, to attempt to
22 differentiate or quantify changes due to hydroperiod
23 as opposed to changes due to water quality?
24 A. You would have to do a series of
25 controlled experiments, as we talked about.
175
1 Some experiments that have different types
2 of -- if you wanted to test on macrophyte communities
3 impose on certain macrophyte communities the same
4 water chemistry, the same substrate conditions and
5 only alter hydrologic periods, water depth
6 hydroperiods. Do the same thing, keep hydroperiod
7 the same, keep the sediment, whatever parameters, the
8 same, and only alter water chemistry.
9 You could do a series of tests like that
10 and then the same thing on periphyton, the same thing
11 on microbial community could be done.
12 Q. What you have previously identified as,
13 what you identified as a nutrient-impacted marsh --
14 A. Right.
15 Q. -- which I believe you said was the
16 northern end of 2A?
17 A. That's one area.
18 Q. Are you referring to downstream of the
19 S-10 structures?
20 A. That's correct.
21 Q. Do you know whether or not that has
22 experienced altered hydroperiods?
23 A. It has experienced altered hydroperiods
24 over the long term, meaning that there is a normal
25 variability due to climatic changes that have
176
1 occurred so on an annual basis the hydroperiod has
2 changed over time. Spatially I don't believe most of
3 the area south of the S-10s has been affected by
4 significantly altered hydroperiods, which means if
5 you went to an area 2 kilometers downstream of the
6 S-10 or 4 kilometers downstream of the S-10 I believe
7 you would find very similar water quality and water
8 depth and hydroperiod characteristics.
9 Q. In that situation how would you go about
10 determining what impacts if any in the macrophyte
11 community were due quantitatively to hydroperiod
12 changes and what impacts if any were due
13 quantitatively to nutrient changes? And then perhaps
14 there would be other factors that may have an
15 influence. How would you go about doing that as a
16 hydrologist?
17 A. I mean under controlled conditions you
18 would want to maintain the same hydroperiod
19 conditions throughout the system over the study
20 period and look at whatever the effect of, in this
21 case, nutrient addition has been. So if there is a
22 trend of increasing nutrients to the system but the
23 hydroperiods really remain the same you would tend to
24 factor out hydroperiod as a cause to the vegetation
25 change, or if the substrate conditions are relatively
177
1 the same along a particular transect you would assume
2 that differences in substrate changes in soil type or
3 something like that isn't the cause of the vegetation
4 community shifts.
5 It is much more difficult in a natural
6 system like the 2A canal just because it is not
7 maintained uniformly over time, normal climate
8 patterns alter the hydrology and water depths.
9 Q. Have you seen any studies that have done
10 the series of tests we have just discussed to
11 determine what impact if any changes in hydroperiod
12 has had on the microbial communities?
13 A. No, I have not seen any studies that have
14 altered hydroperiod and looked at the effects on the
15 macrophyte community.
16 Q. I believe we asked that question with
17 regard to microbial.
18 A. I am sorry, microbial community.
19 Q. Have you seen a series of tests on
20 macroph