ÿWPCDFRUIT AND VEGETABLE CASE NOS. 92-3038
9 ASSOCIATION, LEWIS POPE FARMS, 92-3039
W.E. SCHLECHTER & SONS, INC., and 92-3040
10 HUNDLEY FARMS, INC.,

11 Petitioners,

12 vs.

13 SOUTH FLORIDA WATER MANAGEMENT
DISTRICT,
14
Respondent,
15
and
16
MICCOSUKEE TRIBE OF INDIANS OF
17 FLORIDA, the UNITED STATES OF
AMERICA, FLORIDA DEPARTMENT
18 OF ENVIRONMENTAL REGULATION, and
FLORIDA WILDLIFE FEDERATION,
19
Intervenors.
20 . . . . . . . . . . . . . . . . . . . /

21

22 VOLUME II

23 DEPOSITION OF PAUL C. PARKS, Ph.D

24 September 23, 1992

25



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 10 Certificate of Merit

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A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 10

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A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôfamiliar with the purpose of this

17 letter?

18 A It was to, it says, "We believe it is time for you

19 to call the sugar industry to account for its lack of

20 performance." That referred back to promises made at the

21 time that the farm bill came up, and Senator Graham had

22 argued that the sugar industry needed the 18 cent per pound

23 federal price support in order to pay for cleaning up the

24 Everglades, and this is a letter pointing out that that

25 hadn't actually happened, and asking Senator Graham to put



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô uncultivated, as is the Holeyland, and it is to the west of

19 the Holeyland on the other side of the Miami Canal, and

20 north of 3A.

21 Q Do you have an opinion concerning whether either

22 of those tracts would be appropriate for use as stormwater

23 treatment areas?

24 A Yes.

25 MS. PONZOLI: Object to the form.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôed that meeting other than

5 yourself?

6 A Secretary Browner, the lieutenant governor, I

7 think Jim Webb was there, Charles Lee was there, Dana

8 Minerva and Dean Saunders.

9 Q Do you recall what was discussed at that meeting?

10 A Not specifically.

11 Q Was this --

12 A The Everglades remedy, the Everglades -- situation

13 with the Everglades, how the District was responding, and

14 what to do about cleaning up the water quality violations

15 in the Everglades, that was the general area.

16 Q Were there any followup meetings with Lieutenant

17 Governor MacKay of this type that you are aware?

18 A I don't recall any.

19 Q Dr. Parks, with regard to the case that we are

20 here today about, you have been listed by the United States

21 of America as an expert witness who will discuss violations

22 of state water quality standards and permitting

23 requirements of Florida law, and standing.

24 Are you familiar with the United States'

25 Designation of Expert Witnesses document?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô
15 water quality, changes in -- well, any change that might be

16 expected to affect the quality of the discharge.

17 Q Anything else?

18 A Well, not without going through the rules.

19 Q Nothing else that you can recall at this time?

20 A No.

21 Q Dr. Parks, what is the basis for your opinion that

22 DER permits are required for pump stations S-5A, S-6, S-7

23 and S-8?

24 A We, they are certainly stationary and they are

25 sources of pollution as, in terms of the definition of



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôl, Dr. Parks, I am intending to focus on the



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôn the designation.

2 With regard to what you just testified, you indicated that

3 many of the deleterious ecological impacts caused by

4 hydroperiod changes associated with construction of the

5 project can be mitigated with management and structural

6 changes.

7 What management and structural changes do you have

8 in mind there?

9 A The general need is to have a hydroperiod within

10 what was the River of Grass which rises and falls more like

11 the, more like the original, and that would mean using the

12 conservation areas less as impoundments and more as

13 natural, as a flow-way which had a natural hydroperiod, and

14 it would mean releasing water into the upstream end of the

15 Everglades longer into the dry season so as to extend the

16 hydroperiod in time.

17 So those changes that would make the downstream

18 flow more natural as opposed to running down to the

19 impoundment and sitting there, and those changes which

20 would enable water to be admitted to the upstream end

21 towards the end of the rainy, towards the beginning of the

22 dry season, so as to extend the hydroperiod, those are the

23 kinds of management, those are the objectives of that

24 management of the structural changes.

25 Q Are you aware of any studies or analyses



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ônt District has long discussed

8 better distribution of discharges into conservation area 3A

9 as a consequence of building an STA down along the southern

10 part of the EAA.

11 I think there is some debate about whether you

12 want to put water of the proposed interim quality into

13 areas that have been, that have never received water of

14 that phosphorus concentration before; so while there might

15 be a benefit in terms of water quantity, it might be

16 outweighed by an effect on water quality if the discharge

17 only meets the interim's requirement.

18 Q What is that interim?

19 A 50 parts per billion.

20 Q Of --

21 A Phosphorus.

22 Q All right.

23 A But that has been discussed as a benefit to the

24 system in the north end of conservation area 3A.

25 Q Are there any other water quantity issues in south



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722ÔEverglades pollution?

18 Q Yes, as referenced in the United States'

19 Designation of Expert Witnesses on page 13?

20 A Not that I recall.

21 Q Dr. Parks, I am continuing to go through the

22 topics on page 13 of the United States' Designation of

23 Expert Witnesses, and there is a topic, Assessment of SWIM

24 Planning Process and Proposed Remedies. Have you been

25 asked to make an assessment of the SWIM planning process



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 194






1 parts per billion on the Everglades, and I concluded it

2 was reasonable.

3 BY MR. GREEN:

4 Q What is the basis for your conclusion that it was

5 reasonable?

6 A It is, there is information which is described and

7 cited in the SWIM Plan which provides a very clear

8 indication that water of at least 30 parts per billion

9 causes imbalance in aquatic flora and fauna. This means

10 that 50 parts per billion is not excessively stringent and

11 you can, therefore, conclude that it is an interim,

12 appropriate interim. You would not want an interim value

13 to be more than was necessary to achieve the final limit,

14 and we have clear indication that 50 parts per billion is

15 not more than is necessary, is not more removal or more

16 stringent than that which will be necessary to meet water

17 quality standards.

18 Q Anything else?

19 A Based on reports that have been presented and

20 material presented in the SWIM Plan that 50 parts per

21 billion can be achieved by the means proposed in the SWIM

22 Plan.

23 Q Have you made an independent judgment of whether

24 50 ppb can be achieved by the measures proposed in the SWIM

25 Plan?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 14 phosphorus discharge concentrations be required in order to

15 accomplish ultimate compliance with state water quality

16 standards for discharges from the EAA to the Everglades?

17 A Yes.

18 Q What is the basis for that opinion?

19 MS. PONZOLI: It has been asked and answered.

20 BY MR. GREEN:

21 Q Let me ask another question, then.

22 What is the -- what rules of the Florida

23 Department of Environmental Regulation would support that

24 conclusion, if any?

25 A Now you have that conclusion being that more will



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 25 of Expert Witnesses, beginning at the bottom of page 13,



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôory, quote, "Scientific Application of

2 DER Water Quality Rules and Regulations to Specific

3 Particular Sites," end quote.

4 Have you been asked to evaluate the application of

5 DER water quality rules and regulations to specific

6 particular sites by the United States?

7 A Yes.

8 Q What sites were those?

9 A The points of discharge into the Everglades

10 Protection Area.

11 Q And have you carried out that task?

12 A I have.

13 Q Have you carried it out with regard to pump

14 station S-5A?

15 A Yes.

16 Q What were the results of your evaluation?

17 A That the receiving waters require a site-specific

18 determination of the numerical surrogate for the

19 Department's narrative nutrient standard, and that that

20 determination should include imbalance in natural

21 populations of aquatic flora and fauna, compliance with

22 other standards of the Department, particularly those

23 related to dissolved oxygen and biological integrity, and

24 that that numerical surrogate should consider substances

25 and amounts which create nuisance growths of aquatic



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô asked to give any opinions with

15 regard to the application of DER water quality rules and

16 regulations to those other structures, that is, the

17 structures I just mentioned?

18 A I have not been asked to give an opinion about

19 S-10.

20 MR. HYDE: S-10?

21 THE WITNESS: 10.

22 MS. PONZOLI: Read his answer back again, please.

23 (Whereupon, the court reporter read the requested

24 portion of the record.)

25 BY MR. GREEN:



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô204






1 A No.

2 Q Are the opinions that we have asked you about this

3 morning final at this point, or are you doing more work on

4 them?

5 A Well, if some new factual information came to

6 light as a consequence of discovery, I might reevaluate

7 something, but other than that, I believe they are final

8 opinions.

9 Q Granted that that could occur, in your mind, do

10 you know what facts might change your opinions? I mean,

11 have you thought about that?

12 MS. PONZOLI: Object to the form.

13 THE WITNESS: No.

14 MR. GREEN: I have concluded all of what I had at

15 this point, Ms. Ponzoli.

16 MS. PONZOLI: I would like to take, Mr. Hyde, if

17 you don't mind, one second to clarify a point that I

18 think was confusing at the beginning of Mr. Green, it

19 is just for clarification, on the production of Dr.

20 Parks's documents.

21 EXAMINATION

22 BY MS. PONZOLI:

23 Q Dr. Parks, do you recall in the beginning of Mr.

24 Green's examination where he showed you Exhibit No. 1,

25 which was your Notice of Deposition Duces Tecum, and there



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722ÔTHE WITNESS: I am not sure of the exact number,

16 but in the -- the second load of stuff that I took over

17 to the Sierra Club Legal Defense Fund office was partly

18 all stuff that had been produced in the previous, in

19 the federal lawsuit, reports, agency reports, bound

20 volumes of agency stuff, and -- but then it also

21 included some stuff that had not been produced in the

22 first, in the federal case. We went through the latter

23 of the stuff that had not been previously produced.

24 MS. PONZOLI: Thank you.

25 MR. HYDE: Is that all?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 1 Q For what purpose?

2 A I wanted to work with Florida Wildlife

3 Federation. I wanted to be associated with Florida

4 Wildlife Federation.

5 Q Did you have a specific proposal for them to

6 consider, such as doing work in the Everglades, for

7 example, or a specific project in mind, or was it more in

8 the nature of a general inquiry about prospective future

9 employment?

10 A I wished to be associated with Florida Wildlife

11 Federation for the purpose of working on Lake Okeechobee-

12 Everglades issues.

13 Q What did -- what were your first tasks for the

14 Federation in general terms?

15 MR. WHITE: I object to the form of the question.

16 THE WITNESS: What do you mean by tasks for the

17 Federation?

18 BY MR. HYDE:

19 Q What projects have you become engaged in, again,

20 in the context of Lake Okeechobee-Everglades issues?

21 A Well, my association with the Federation is such

22 that I determine the work that I do. My association with

23 Florida Wildlife is such that I determine the work that I

24 will do.

25 Q Well, take me through in general terms what you



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô misrepresents Dr. Parks' testimony with regard to his

12 relationship with the Florida Wildlife Federation.

13 MR. HYDE: Okay, so noted.

14 THE WITNESS: Could you repeat the question?

15 BY MR. HYDE:

16 Q At what point did you begin initiating contacts

17 with affected regulatory agencies concerning Everglades

18 issues, roughly speaking? I am not trying to pin you down

19 to a specific date.

20 MS. PONZOLI: I still object to the form of the

21 question. I think it assumes things that I don't

22 believe are on the record.

23 THE WITNESS: I have been in contact with state

24 agencies dealing with the Everglades and Lake

25 Okeechobee, you know, in one way or another since 1973,



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôry.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô the discharge if it was an existing

3 discharge. I would determine whether dissolved oxygen was

4 the only issue, whether some other constituents of a

5 discharge might preclude a mixing zone. I would, of

6 course, look at the classification of the receiving waters,

7 particularly with respect to outstanding Florida waters.

8 Beyond that, I would make a preliminary assessment

9 of the nature of the mixing processes in order to, in order

10 to form a rough estimate of whether the discharge might

11 qualify under the rule for mixing zones, and at that point

12 I would prepare a detailed analysis of what else, what else

13 might have to be done to establish a mixing zone at that

14 particular location.

15 Q You highlighted the possibility of the discharge

16 being in an outstanding Florida water. Let me ask, are

17 OFWs eligible for mixing zones?

18 Let me state it differently. Can a discharge to

19 an OFW be granted a mixing zone?

20 A Well, if it doesn't lower ambient quality, but I

21 can't see why anyone would want one.

22 Q But theoretically, at least, under the rule, an

23 OFW is not automatically precluded from having a mixing

24 zone, would that be correct?

25 A I would like to refer to the rule.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô A Yes, I am.

8 Q Is that consistent with your understanding of the

9 agency's practice?

10 A No.

11 Q Okay.

12 A There are other criteria in the rules which a

13 mixing must meet.

14 Q I would like to refer you now to Exhibit 5-A, in

15 particular, Rule 17-4.244(1)(f) and (g). That is on page

16 14 of that document.

17 A Yes.

18 Q Both of those subsections list a number of water

19 bodies in which, I guess the basic point is how large the

20 mixing zone can be in those water bodies. The first,

21 section (f), speaks to canals, rivers, streams, and other

22 similar water bodies, and section (g) speaks to lakes,

23 estuaries, bays, lagoons, bayous, sounds, and coastal

24 waters.

25 What are the water conservation areas or what



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôhe cattails and they

21 also don't have phosphorus.

22 Where you have the phosphorus, you have cattails.

23 Where you have the same hydroperiod, you may or may not

24 have cattails, depending on the constituency of the water.

25 Secondly, the Everglades is a highly oligotrophic



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôly not privy to the

4 design of the major features of the settlement agreement.

5 I did on one occasion review -- it was proposed language

6 changes in a draft, in one of the drafts. I assume that

7 there were many drafts as time went on, but there was just

8 this one, and I was asked to take a look at the wording,

9 which I did, and to look at the wording that was there, and

10 the wording that was proposed, and I commented on that.

11 Comments did not really have to do with the broad

12 substance of the settlement agreement. I just never was

13 involved in that. It really had to do with kind of like,

14 how does this language, is this language clear, that kind

15 of thing.

16 Q Were you kept advised by the U. S. Attorney's

17 office or anyone else as to the progress of those

18 settlement negotiations?

19 A I was not kept apprised by the U. S. Attorney's

20 office --

21 Q Did you --

22 A -- or anyone else. I heard rumors all of the time

23 from various people.

24 Q Did you discuss with the other, I am calling them

25 conservation intervenors in the federal lawsuit, the



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô Everglades National Park were designated as outstanding

17 Florida waters, in my opinion the pumping stations that

18 affect the quality of waters in Loxahatchee and the

19 Park, those being S-5A, S-6, S-7 and S-8, those pumping

20 stations required a DER permit, and therefore, their

21 effect on ambient water quality should not be used in

22 the baseline determination of the OFW water quality

23 which, which is the point of determination whether

24 ambient quality has or has not been lowered.

25 BY MR. HYDE:



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 226






1 action is required and it is the point of closest discharge

2 that requires regulation.

3 Q I believe you also testified that a series of

4 management and structural changes were necessary to

5 mitigate the adverse environmental consequences of the

6 hydroperiod alteration that has been effected over the

7 years, and I was wondering if when you were referring to

8 structural changes, were you intending to refer to anything

9 other than the stormwater treatment areas?

10 MS. PONZOLI: Object to the form.

11 THE WITNESS: In my previous answer to that

12 question, I tried to make it clear that I considered,

13 shall we call it, hydroperiod, hydroperiod improvement

14 a distinct and separate endeavor from pollution

15 control, and while the STAs could make some

16 contribution to hydroperiod control, their most

17 important function is to control the pollution.

18 Otherwise, there will not be any, the Everglades will

19 be damaged and it will not make, there wouldn't be any

20 point in improving the hydroperiod.

21 Very little has been done towards actually,

22 towards really exploring the management and structural

23 possibilities for Everglades hydroperiod improvement,

24 but I believe that those structural changes could,

25 would encompass structures other than the STAs.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 12 A I think that is a legal conclusion that is beyond

13 my --

14 Q Okay. You stated earlier that a further decrease

15 in phosphorus concentrations will ultimately be necessary,

16 and you cited as your support the SWIM Plan. Could you be

17 more specific what portions of the SWIM Plan you were

18 actually referring to?

19 A You said a further decrease in phosphorus

20 concentration --

21 Q Will ultimately --

22 A Could you be more specific?

23 Q I think you testified that a further increase in

24 phosphorus concentrations below the interim standard of 50

25 parts per billion will ultimately be necessary. You cited



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô normal rainfall, depending on antecedent conditions, the



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô as a consequence of lack of

2 rainfall. Water may be released from the water

3 conservation areas to canals that supply urban wellfields.

4 The conservation areas, of course, by virtue of

5 being wet, wet as in having water on them, also serve to

6 some extent to recharge the Biscayne aquifer, although

7 extensive efforts have been made to prevent that by

8 constructing conservation area 3B and 2B. Seepage was

9 occurring into the areas where they didn't want the water,

10 but some recharge still takes place.

11 Q You stated this morning that you felt the

12 phosphorus limitations being proposed would apply at the

13 point of discharge, and that some allowance would have to

14 be made for hydraulic impact, words to that effect. Could

15 you explain what you meant by "hydraulic impact"?

16 A The areas of hydraulic impact are very limited

17 geographical areas where the velocity of the discharge

18 water almost always in conjunction with construction

19 downstream of the discharge point combines to make, it

20 would create a different ecosystem, even in the absence of

21 pollutants, and in that limited place, you simply wouldn't,

22 there is not Everglades habitat, there would not be

23 Everglades habitat even in the absence of the pollutants in

24 the EAA discharge. In those cases it doesn't make sense to

25 apply the same criteria that you would in Everglades marsh,



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôhrough.

8 A I have used the term Everglades marsh. There are

9 other types of Everglades habitat, basically tree islands,

10 sloughs, wet prairies and marshes, and, because some of the

11 discharges are concentrated, put another way, improperly

12 diffused, this water tends to be deeper there. In the

13 absence of excess phosphorus I believe those areas would

14 represent, would be biologically equivalent to sloughs, and

15 therefore, I would confine my, the scope of the area of

16 impact to those areas where the water velocity precludes

17 one of the, any of the major Everglades habitats, or where

18 excavation, a manmade excavation precludes the existence of

19 one of the native Everglades habitats.

20 Q How, if at all, does the dilution of waters from

21 the EAA factor into the 50 parts per billion interim

22 limitation?

23 MS. PONZOLI: Object to the form. I honestly do

24 not understand your question, counsel. I -- can you

25 reword it? Because I even have difficulty letting him



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôa,

15 is that correct?

16 A I believe I went back and corrected that statement

17 about the S-12s.

18 Q So it would be S-5A and 6 structures would have to

19 meet the OFW criteria?

20 A The OFW criteria would have to be met in

21 Loxahatchee Refuge. It is only affected by discharges from

22 S-5A and S-6 and to some extent from the Acme Improvement

23 District. The OFW standards must be met in Everglades

24 Park, and the water quality is determined by all of the

25 discharges into the EPA. The major, the major discharges



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôl, can you, or do you know what water quality

2 standards are allegedly being violated? Isn't it a purpose

3 of the SWIM planning process and the stormwater treatment

4 areas and the like to remedy some alleged violations of

5 water quality standards?

6 A Well, certainly -- would you read that back,

7 please?

8 (Whereupon, the court reporter read the pending

9 question.)

10 MS. PONZOLI: Object to the form. Do you want him

11 to answer the last question, Mr. Hyde? There were a

12 couple of them there.

13 BY MR. HYDE:

14 Q Let me see if I can do it.

15 The way I understand it, the following water

16 quality standards are allegedly being violated: one,

17 narrative nutrient standard; two, a nuisance species

18 standard; three, dissolved oxygen standard; and four, a

19 biological integrity standard.

20 Then there has been some mention of the anti-

21 degradation standard as well as the OFW no significant

22 degradation standard.

23 Are there any other standards, to your knowledge,

24 that are allegedly being violated?

25 MS. PONZOLI: Object to the form.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô I believe in a previous deposition in the federal

14 case you may have made some observations or statements to

15 the effect that there may be violations of the ammonia

16 standard and/or the pH standard. Is that something that

17 you believe?

18 A That is true, ammonia, pH, and sulfide. If we are

19 trying to get an exhaustive list here perhaps I should go

20 through the rule parameter by parameter.

21 Q It is not necessary to do that. I would like to

22 ask you some questions about causation in the context of

23 violations of water quality standards.

24 MS. PONZOLI: Can you explain how you tie the two

25 together?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722ÔLI: You don't have to answer a question



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô Mr. Hyde, if we are going to spend the afternoon

3 making up hypotheticals and facts that are not in the

4 record -- we are not going to spend the afternoon doing

5 that. I have to tell you this isn't going to go on all

6 afternoon. I have been very, very generous in letting

7 you and Mr. Green go far afield, but this is going

8 beyond the pale.

9 MR. HYDE: Ms. Ponzoli, the only thing you have

10 been generous in is making repeated objections. All I

11 would like to do is ask some questions that are

12 directed to the issue of how one determines causation

13 in water quality violations.

14 MS. PONZOLI: I don't think that is actually what

15 Dr. Parks has been listed as an expert for the United

16 States in offering an opinion on, and in my opinion you

17 have no right to be questioning him on it at all, and I

18 think I have been generous and I wish to be given the

19 same generosity in the depositions I will be doing of

20 your experts and of Mr. Green's experts, and we will

21 just see what happens when we get there.

22 If you will form single questions to Dr. Parks,

23 this would probably go easier. Most of your questions

24 are compound questions, and that just adds to the

25 problem.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô

8 It is a fairly, it is a fairly complex problem, but it

9 is one that is well understood and it has been done for

10 a long time by the Department.

11 BY MR. HYDE:

12 Q Are you familiar with the biological integrity

13 standard?

14 A Somewhat.

15 Q If compliance with the biological integrity

16 standard is demonstrated, can shifts in benthic

17 microinvertebrate populations still be regarded as

18 indicative of other water quality violations? Do you

19 understand that question?

20 MS. PONZOLI: May I have it back again, please?

21 (Whereupon, the court reporter read the pending

22 question.)

23 MS. PONZOLI: The first question was, do you

24 understand the question?

25 THE WITNESS: I would have to rely on an expert



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô
23 domain, and the -- really, the memoranda, the DER memoranda

24 and reports speak for themselves better than I can; but my

25 recollection is it was limited Hester-Dendy data, but that



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôe, the Everglades Protection

9 Area?

10 A Yes.

11 Q As background conditions?

12 A By background --

13 Q Well, as, in areas that are not phosphorus-

14 enriched, so to speak?

15 A What kind of concentration are you talking about?

16 Q Background.

17 MS. PONZOLI: Counsel, if he cannot answer it

18 because you don't have a common understanding of

19 "background," you may have to give him --

20 MR. HYDE: Naturally occurring conditions in the

21 Everglades.

22 MS. PONZOLI: I think the problem is it would, the

23 problem is what you are calling background and what he is

24 calling background may be different.

25 THE WITNESS: The description of dissolved oxygen



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722ÔR. HYDE:

24 Q Why not?

25 A How much phosphorus are we talking about? What



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 253






1 are the conditions? Is the phosphorus just passing through

2 or has it been there for a while, long enough to alter the

3 community of organisms? Did it come from a bird or an

4 outfall? You know.

5 Q Well, isn't really what you are saying that if the

6 low DO can somehow be traced to a man-induced condition, it

7 is a violation, but if it is natural condition, it is not?

8 A No.

9 Q Could you explain to me why not?

10 MS. PONZOLI: Why isn't that his explanation?

11 Isn't that what he is really saying? Are you asking

12 him to give the same answer he gave before again in a

13 different way?

14 MR. HYDE: No, I postulated something that he did

15 not agree with, and I am asking him to explain why my

16 postulate is incorrect by his lights.

17 MS. PONZOLI: What I am saying to you is, you

18 reframed his answer and you said isn't that what he is

19 saying, and he said, no, that is not what I am saying.

20 He gave you his answer previously, so now you are

21 asking him to give his answer a second time. Is that

22 what you are asking for?

23 MR. HYDE: I am trying to better understand his

24 answer, Ms. Ponzoli.

25 MS. PONZOLI: Then you are going to have to frame



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôtself, contained oxygen-consuming substances or substances

10 that, by virtue of microbial action, would consume oxygen,

11 or could consume it directly through inorganic reactions.

12 If the biochemical oxygen demand in the water is

13 increased as a consequence of the discharge, either through

14 increased rate of productivity of organic carbon or through

15 direct introduction of oxidizable materials, then you know

16 that there will be an increased rate of oxygen

17 consumption. That could conceivably be compensated by some

18 characteristic of a discharge, compensated for by some

19 characteristic of the discharge.

20 Q Was that a follow-up to your first --

21 A I am still answering, I am still answering the

22 question.

23 Q All right.

24 A The -- if the discharge flunked that test, so to

25 speak, meaning it had, it did increase the biochemical



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôproblem lies with the original

19 question, and it doesn't get better every time.

20 Now, if you want to go back and read back whatever

21 your question is, if Dr. Parks can answer it, he is

22 certainly free to answer it. If he cannot answer it

23 without building more hypotheticals for you, then you

24 are going to have to frame a question for him that he

25 can answer.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 13 constructive examples, and it seems to me there would

14 be a whole host of these that could affect dissolved

15 oxygen concentrations, at least my reading leads me to

16 believe that. One is, as you suggested, water flow.

17 MS. PONZOLI: And your question to him is to list

18 everything he can think of that will affect dissolved

19 oxygen in the Everglades?

20 MR. HYDE: Yes.

21 MS. PONZOLI: Have you listed all that you know,

22 Dr. Parks?

23 THE WITNESS: No.

24 MS. PONZOLI: Would you do a list for him without

25 explanation? He wants a list.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 262






1 A For example?

2 Q Periphyton, p-e-r-i-p-h-y-t-o-n.

3 A Would the type of periphyton affect?

4 Q Yes.

5 A I don't know about differences in the rate of

6 consumption of oxygen per unit mass of different types of

7 periphyton.

8 Q So you are not sure of that particular factor?

9 A I am not exactly sure what the question is. Is

10 the question, can periphyton affect dissolved oxygen?

11 Q Yes.

12 A Yes.

13 Q How would you say that it affects it?

14 A They would use oxygen, they consume oxygen.

15 Q Is it sort of a wash? They consume some during a

16 portion of the day and release it during other portions of

17 the day?

18 MS. PONZOLI: Object to the form. Are you talking

19 about the same --

20 MR. HYDE: I am asking for my benefit.

21 THE WITNESS: No, it is not necessarily a wash.

22 BY MR. HYDE:

23 Q Do they produce more than they consume, or is it

24 vice-versa?

25 MS. PONZOLI: Object to the form. You have not



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôanic

3 carbon is fixed, is consumed in the water column or

4 not, and whether the oxygen escapes to the atmosphere.

5 BY MR. HYDE:

6 Q I would like to provide you with a document which

7 we shall label Exhibit 31.

8 (Whereupon, Exhibit No. 31 was marked for

9 identification.)

10 BY MR. HYDE:

11 Q Dr. Parks, I found this document in the boxes that

12 you produced for my benefit on Monday, and it is being

13 given to you just as I found it.

14 Do you recognize both the cover routing and

15 transmittal slip and the attached memorandum?

16 A Well, it has a DER transmittal slip which is

17 addressed to me. I can't read who it is from.

18 Q Is that perhaps the signature of Jay Thabaraj?

19 A It could be.

20 Q Does the date stamp on the cover slip of February

21 5, 1986, indicate the date that you received it?

22 A Probably.

23 Q Are you familiar with the attached document, the

24 memorandum?

25 A No.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôy, look at 17-302.200, the definition of

10 nuisance species.

11 What, after having looked at that definition, what

12 do you consider to be examples of nuisance species in the

13 context of the water conservation areas? Perhaps I should

14 ask you specific questions.

15 Do you consider meleleuca to be a nuisance species

16 under this definition?

17 A Yes.

18 Q What about Brazilian pepper?

19 A Where are we talking about?

20 Q In the water conservation areas.

21 A I don't know that it occurs other than on spoil

22 areas.

23 Q Would you still consider it to be a nuisance

24 species if it occurred in waters of the State?

25 MS. PONZOLI: Object to the form of the question.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôre caused or result from

23 phosphorus concentrations in water discharged from the EAA,

24 or are caused or result from hydroperiod mismanagement.

25 Can you differentiate between the two?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôl allow

11 him to answer it again.

12 THE WITNESS: Since very early in the discussion

13 of water quality violations in the Everglades,

14 ecological changes and so on, there have been

15 statements by various lay people associated with the

16 sugar industry about the idea that cattails were

17 somehow caused by hydroperiod rather than nutrients.

18 In all of these years, I have yet to see a report by a

19 scientist backed up by any kind of data that suggests

20 that hydroperiod alone could create the kind of dense

21 monocultures of cattail that are found in the vicinity

22 of the points of discharge from the EAA, nor do I, as a

23 scientist, know of any hypothesis that would support

24 that, and I know of considerable evidence to the

25 contrary. There is nothing to distinguish.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôphorus which may contribute to the growth and

12 expansion of the cattail communities, which appears to

13 be a scientific fact that most everybody that I have

14 read seems to acknowledge.

15 MS. PONZOLI: Then you don't need Dr. Parks, Mr.

16 Hyde.

17 MR. HYDE: I am trying to ascertain if he

18 subscribes to that as well, or if he believes that the

19 expansion of these cattail communities is solely being

20 caused by phosphorus in the waters.

21 MS. PONZOLI: He has explained his belief

22 regarding the expansion of cattail communities several

23 times in his two-day deposition. You are framing a

24 question presently that, in my opinion, cannot be

25 answered. It is a non-real-world situation by the



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô MS. PONZOLI: The original question was, what do

20 you measure?

21 BY MR. HYDE:

22 Q What is the unit of measurement for determining

23 this body of water?

24 A Generally speaking, you wouldn't go out somewhere

25 and determine a violation. You would have set limits on



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ônt standard and all

7 other nutrient standards.

8 Q Let's say you are not in the permitting context.

9 Let's say you are in a notice of violation mode.

10 MS. PONZOLI: Object to the form.

11 BY MR. HYDE:

12 Q How do you determine whether a discharger has

13 violated this standard in terms of impacts upon the body of

14 water?

15 MS. PONZOLI: Object to the form. I think he has

16 indicated several times what he considers a violation

17 situation. Maybe I am mistaken, Dr. Parks.

18 THE WITNESS: This is simply a hypothetical that

19 wouldn't, in my experience, wouldn't occur. Either the

20 discharger has a permit that the owner is not complying

21 with, or else he has no permit and the violation is not

22 having a permit.

23 If he has a permit, it has effluent limits that

24 produce the result of no violation of this standard.

25 BY MR. HYDE:



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôcan give you and he

8 will give you the best answer he can. You have got to

9 ask a decent question.

10 MR. HYDE: I have been asking, Ms. Ponzoli, other

11 than your repeated coaching of the witness.

12 MS. PONZOLI: I am not coaching the witness. You

13 are asking poor questions, and I am not going to have

14 him answering poor questions just because you will not

15 form a single decent question.

16 That is the problem. It is not the problem that I

17 will not let him answer. I will -- I have a record for

18 a day and a half of letting this man answer virtually

19 everything.

20 BY MR. HYDE:

21 Q Well, I will ask this one final question and it

22 may be a repeat. I want to see if you can repeat it for my

23 benefit so we can move on to some different point.

24 Do you know whether there is a geographical

25 component to determining whether there is a violation of



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôquestion?

17 A Well, trophic state is a biological consequence of

18 water quality. They are not totally independent.

19 Q Do you intend to offer any opinions at the final

20 hearing in this matter concerning the stormwater treatment

21 areas, their design, treatment efficiencies, capabilities,

22 or the like?

23 MS. PONZOLI: He has not been asked to.

24 THE WITNESS: "Or the like"? I don't know what

25 else you would cover. Would you be more specific?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô.

6 Q Their sizing?

7 A No.

8 Q You seemed to hesitate when you said no that time.

9 Is that just an interpretation?

10 A Well, I was going to ask you to qualify sizing. I

11 assume I might be asked, is this a reasonable first step to

12 take, and I have given an opinion on that, and that

13 includes size.

14 Q Would you be offering an opinion as to whether,

15 for example, the stormwater treatment areas ought to be

16 35,000 acres or 50,000 or 70,000?

17 A An opinion based on what?

18 Q I am asking you whether you are going to offer an

19 opinion in that realm?

20 A No.

21 Q During the course of the last two days we have

22 been talking an awful lot about phosphorus, almost as if it

23 is, there is only one type of phosphorus. Is that in fact

24 true?

25 A No. Phosphorus -- no, it is not true.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722ÔOver the long haul, it is

9 going to all get equalized out.

10 Q Are you saying -- let me give you sort of an

11 example to see if you agree with me. A certain type of

12 phosphate might be more readily usable by microphytes such

13 as cattails, thereby promoting their growth, at a greater

14 rate than an equivalent loading of some other type of

15 phosphate, is that a conceivable scenario?

16 A I don't know the answer to that with respect to

17 cattails.

18 Q Will the proposed stormwater treatment areas

19 remove better certain of these categories than others?

20 MS. PONZOLI: I am going to object to the form, I

21 am going to object to the question. He has already

22 testified that he will not be offering testimony of

23 treatment efficiencies of STAs.

24 THE WITNESS: Could you repeat the question?

25 (Whereupon, the court reporter read the pending



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôyou just referred to in August of

22 1988?

23 A At any time?

24 Q Yes, at any time prior to the initiation of the

25 lawsuit.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôfirst occasion?

11 A I am just trying to remember. I think that

12 Charles Lee was there, I think that Jim Webb was there, and

13 I don't really recall who else. There were others.

14 Q What was your purpose of meeting with the U. S.

15 Attorney at that time?

16 A He invited me.

17 Q Do you know why he invited you?

18 A I think that he wanted to ask conservationists

19 what their views were on the state of the Everglades and

20 what should be done about it.

21 Q To your knowledge, had he been solicited by anyone

22 else to take some affirmative action regarding the

23 Everglades?

24 A I don't have any knowledge of that.

25 Q Did he ever discuss with you different theories of



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô to this line of

16 questioning, that is, discussions between counsel and

17 organizations that were involved in the federal

18 lawsuit, to the extent it goes into privileged

19 communications between counsel and the organizations.

20 MR. HYDE: I am just trying to determine whether

21 any recommendation was made as to pursuing a cause of

22 action under state law. I don't think that is cause

23 for any privileged information.

24 MR. WHITE: If you are asking the witness to

25 disclose what advice he was getting from his counsel



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôanges in wording, but there

15 has not been any fundamental difference in my role, nor do

16 I know that there were actual changes in wording. I just

17 don't know for sure.

18 Q Are these contracts just for a short period of

19 time, are they renewed periodically, or are they, do they

20 reflect changes that might reflect a difference in the

21 scope of your services?

22 MS. PONZOLI: Object to the form. I think he just

23 answered your question, or actually you have combined

24 several questions in one. First was a time question

25 and then what is the scope. The scope has been



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô It is a memo from me to several conservationists.

18 Q What is the subject matter of the memorandum?

19 A A meeting with Lieutenant Governor MacKay.

20 Q It is entitled, "Concepts to be presented at

21 January 30 meeting with Lieutenant Governor MacKay."

22 Were these issues contained in the memorandum and,

23 in fact, discussed with Mr. MacKay? I am speaking just in

24 general terms, now.

25 MS. PONZOLI: What was the question?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô per billion, using the design algorithm that is described

25 in the SWIM Plan.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô Were you privy to any of the discussions with the

14 people negotiating the settlement agreement when they

15 latched onto this 50 parts per billion interim limitation?

16 A No.

17 MS. PONZOLI: Object to the form of the question.

18 BY MR. HYDE:

19 Q Are you familiar with an entity known as the

20 coordinating committee?

21 A Just the coordinating committee?

22 Q Yes.

23 A No, I don't think so.

24 Q Are you familiar with any organization that might

25 have those two terms in its title?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôments ago prior to our last break you

21 noted that the, at least one of the purposes of the South

22 Florida Geographic Initiative was to investigate mercury

23 contamination in south Florida. To your knowledge, is that

24 Initiative going to be looking into whether waters leaving

25 the EAA might be causing or contributing to that problem?



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ôs as described by Dr. Hahn, with

23 respect to EAA?

24 BY MR. HYDE:

25 Q Yes.



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 6 MS. PONZOLI: Objection to the form. I don't know

7 what you mean by "breakup." I have never heard that

8 term.

9 MR. HYDE: It is commonly used in a whole host of

10 public and private presentations.

11 MS. PONZOLI: Okay, fine. If Dr. Parks knows

12 what it means, then he can respond.

13 THE WITNESS: What I know is if you add

14 phosphorus, the mat disappears.

15 BY MR. HYDE:

16 Q Do you assume by its mere presence it is the cause

17 of the mat's disappearance, or can you relate it to some

18 other chemical or biological activity?

19 A I think the clearest indication is in the Park's,

20 Everglades National Park's dosing studies which took place

21 in Shark River Slough, an area of very extensive periphyton

22 mats, and in, actually in both the channel that received

23 phosphorus and the channel that received nitrate, the

24 periphyton mat disappeared.

25 Now, you know, what the primary cause was, and the



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 18 land. It is not draining cultivated land, and I would

19 expect that there would be less soil oxidation and

20 therefore differences in quality.

21 Q Do you know whether it is better quality water or

22 worse quality water, particularly in the context of

23 phosphorus?

24 A I don't know.

25 Q Do you know whether that -- first of all, do you



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô-5A water.

18 Q Do you know whether the Department of

19 Environmental Regulation is trying to bring it under the

20 same kind of permitting that the, say, the S-5 structure is

21 being brought under?

22 A Well, the SWIM Plan describes all of the tributary

23 inflows into the Everglades Protection Area and proposes a

24 schedule for dealing with those, and I assume that when DER

25 approved the SWIM Plan that it did so in anticipation that



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô 21
my seal this _____ day of _________________________, 1992;
22
said instrument was acknowledged before me by _____________
23
who is personally known to me.
24
________________________________
25 Notary Public



A-1 STENOTYPE REPORTERS TALLAHASSEE,FLA 904-224-0722Ô