STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
SUGAR CANE GROWERS COOPERATIVE OF )
FLORIDA, a Florida Agricultural )
Cooperative Marketing Association, ) CASE NOS. 92-3038
ROTH FARMS, INC., and ) 92-3039
WEDGWORTH FARMS, INC., ) 92-3040
)
and )
)
FLORIDA SUGAR CANE LEAGUE, INC.; )
UNITED STATES SUGAR CORPORATION; )
and NEW HOPE SOUTH, INC., )
) _____________________
and )
FLORIDA FRUIT AND VEGETABLE ) DEPOSITION
ASSOCIATION, LEWIS POPE FARMS, )
W.E. SCHLECHTER & SONS, INC., and ) OF
HUNDLEY FARMS, INC., )
) DR. ROBERT G. QUALLS
Petitioners, ) _____________________
)
vs. )
)
SOUTH FLORIDA WATER MANAGEMENT )
DISTRICT, an Agency of the State )
of Florida, )
)
Respondent, )
)
and )
)
MICCOSUKEE TRIBE OF INDIANS OF )
FLORIDA, the UNITED STATES OF )
AMERICA, and FLORIDA DEPARTMENT OF )
ENVIRONMENTAL REGULATION, and the )
FLORIDA WILDLIFE FEDERATION, )
)
Intervenors. )
___________________________________)
AT DURHAM, NORTH CAROLINA
DECEMBER 9, 1992 - 10:25 A.M.
REPORTED BY: CAROL ANN S. YOUNG
CAROLYN Y. HALL & ASSOCIATES
DR. QUALLS VOLUME II PAGE 123
APPEARANCES:
FOR THE PETITIONERS:
MR. RICK BURGESS MR. WILLIAM H. GREEN
PEEPLES, EARL & BLANK HOPPING, BOYD, GREEN & SAMS
ONE BISCAYNE TOWER 123 SOUTH CALHOUN STREET
SUITE 3636 TALLAHASSEE, FLORIDA 32314
MIAMI, FLORIDA 33131
TELEPHONE: (305) 358-3000 TELEPHONE: (904) 222-7500
FOR THE RESPONDENT-INTERVENOR:
MS. SUZAN HILL PONZOLI MR. PAUL L. NETTLETON
ASSISTANT U.S. ATTORNEY POPHAM, HAIK, SCHNOBRICH &
SOUTHERN DISTRICT OF FLORIDA KAUFMAN, LTD.
155 SOUTH MIAMI AVENUE 4100 ONE CENTRUST FINANCIAL
SUITE 627 CENTER
MIAMI, FLORIDA 33130 100 SE SECOND STREET
MIAMI, FLORIDA 33131
TELEPHONE: (305) 536-4425 TELEPHONE: (305) 530-0050
FOR DUKE UNIVERSITY:
MR. RALPH L. McCAUGHAN
KING, WALKER, LAMBE & CRABTREE
SUITE 100, 3708 MAYFAIR STREET
POST OFFICE BOX 51549
DURHAM, NORTH CAROLINA 27717-1549
TELEPHONE: (919) 493-8411
ALSO PRESENT:
DR. CURTIS J. RICHARDSON
DUKE UNIVERSITY
MR. RONALD D. JONES, Ph.D.
FLORIDA INTERNATIONAL UNIVERSITY
MR. JIM GRIMSHAW, Ph.D.
SOUTH FLORIDA WATER MANAGEMENT DISTRICT
MR. MARK D. MAFFEI, Ph.D.
U.S. FISH AND WILDLIFE SERVICE
MR. SAM ELSWICK
ASPEN SYSTEMS CORPORATION
DR. QUALLS VOLUME II PAGE 124
T A B L E O F C O N T E N T S
E X A M I N A T I O N I N D E X
DEPONENT - DR. ROBERT G. QUALLS - 12/09/92
EXAMINATION BY: PAGES
MS. PONZOLI 125-353
MR. NETTLETON 353-445
MR. GREEN 445-450
MR. NETTLETON 450-452
-------------------------------------------------------
E X H I B I T S I N D E X
NUMBER DESCRIPTION MARKED
(NO EXHIBITS WERE MARKED DURING
THE TAKING OF THE DEPOSITION OF
DR. QUALLS ON DECEMBER 9, 1992.)
-------------------------------------------------------
SIGNATURE PAGE FOR DEPONENT 453
CERTIFICATION OF COURT REPORTER 454
DR. QUALLS VOLUME II PAGE 125
STIPULATIONS
ON MOTION OF COUNSEL FOR THE RESPONDENT-
INTERVENOR, THE DEPOSITION OF DR. ROBERT GERALD QUALLS
MAY BE TAKEN BEGINNING AT OR AROUND 10:25 A.M. ON
DECEMBER 9, 1992, AT THE HILTON HOTEL, DURHAM, N.C.,
BEFORE CAROL ANN S. YOUNG, A NOTARY PUBLIC.
THE SIGNATURE OF THE WITNESS TO THE TRANSCRIPT
OF HIS TESTIMONY IS HEREBY REQUIRED.
- - - - - - - - - - -
WHEREUPON,
ROBERT G. QUALLS,
HAVING BEEN FIRST DULY SWORN, WAS
EXAMINED AND TESTIFIED AS FOLLOWS:
DIRECT EXAMINATION BY MS. PONZOLI:
Q. WOULD YOU STATE YOUR NAME FOR THE RECORD,
PLEASE?
A. ROBERT GERALD QUALLS.
Q. DR. QUALLS, WE -- WE'VE MET BEFORE. I'M SUZAN
HILL PONZOLI, AND I REPRESENT THE UNITED STATES,
A RESPONDENT-INTERVENOR IN THE SWIM CHALLENGE
PROCEEDINGS. I THINK I TOLD YOU BEFORE -- IF I
DIDN'T, I'LL TELL YOU AGAIN -- I'M A LAYMAN, AND
I'LL BE ASKING YOU A NUMBER OF QUESTIONS. IF YOU
DON'T UNDERSTAND MY QUESTION, PLEASE INDICATE AND
DR. QUALLS VOLUME II PAGE 126
WE'LL -- WE'LL WORK TO TRY TO COME UP WITH ONE
THAT YOU CAN UNDERSTAND AND I CAN UNDERSTAND AT
THE SAME TIME---
A. OKAY. YEAH.
Q. ---BECAUSE THERE'S GOING TO BE QUITE A GAP BETWEEN
OUR APPRECIATION OF THE MATERIAL. I'LL BE ASKING
YOU SOME QUESTIONS REGARDING THE DOCUMENTS THAT
YOU PRODUCED -- ABOUT YOUR DOCUMENT PRODUCTION AND
YOUR ANNUAL REPORTS---
A. OKAY.
Q. ---AND THEN JUST YOUR GENERAL WORK IN THE
EVERGLADES ON BEHALF OF THE DUKE WETLAND CENTER.
OKAY?
A. OKAY.
Q. I THINK I'D LIKE TO START WITH THE PUBLICATION
CALLED "FORMS OF SOIL PHOSPHORUS ALONG A NUTRIENT
ENRICHMENT RADIANT---
A. OKAY.
Q. ---IN THE NORTHERN EVERGLADES." I BELIEVE THIS
IS -- IS THIS CHAPTER EIGHT IN THE '92 ANNUAL
REPORT?
A. YEAH, I THINK SO.
Q. OKAY. I AM ADVISED, DR. QUALLS, THAT THIS '92
ANNUAL REPORT IS A DRAFT REPORT, AND WILL BE
DR. QUALLS VOLUME II PAGE 127
COMING OUT IN FINAL FORM SOMETIME IN JANUARY. IS
THAT YOUR UNDERSTANDING?
A. THAT'S RIGHT, YES.
Q. I HAVE BEEN ADVISED OF SOME CORRECTIONS THAT WOULD
BE MADE IN DR. CRAFT'S WORK REGARDING BULK
DENSITIES. ARE THERE ANY CORRECTIONS IN YOUR
WORK, THAT YOU RECALL?
A. YEAH. THERE WERE A FEW, I'D SAY MINOR TYPOS---
Q. OKAY.
A. ---YOU KNOW, NOTHING THAT HAVE TO DO WITH ANY
NUMBERS, SO FAR AS I KNOW YET, AND -- BUT LET'S
SEE, ON ONE FIGURE, WHICH IS ACTUALLY IN CHAPTER
SIX -- CHAPTER SIX -- CHAPTER SIX, FIGURE 6-28,
THE BAR ON THE FURTHEST TO THE RIGHT SIDE, I
BELIEVE---
MR. NETTLETON: WHICH PAGE?
Q. (BY MS. PONZOLI) ONE SECOND, WHICH PAGE DR.
QUALLS?
A. THAT'S 260. THERE'S A BAR ON THE FAR RIGHT-HAND
SIDE, WHICH I BELIEVE SAYS IS APPROXIMATELY 7.9 ON
THE PAGE; AND THAT SHOULD ACTUALLY BE 79, RATHER
THAN 7.9.
Q. IT SHOULD BE---
MR. NETTLETON: THE LIGHT EXPOSED?
DR. QUALLS VOLUME II PAGE 128
WITNESS: THAT'S RIGHT, YES.
MS. PONZOLI: ALL THE WAY UP TO THERE?
DR. RICHARDSON: THAT ONE SHOULD BE 79.
Q. (BY MS. PONZOLI) SO, I'VE ALTERED MINE
ACCURATELY?
(MS. PONZOLI SHOWS DOCUMENT TO WITNESS.)
A. RIGHT, UH-HUH (YES).
Q. OKAY.
A. OH, THAT'S A NICE COLOR, TOO, FOR YOU. SINCE IT'S
LIGHT EXPOSED, IT'S YELLOW.
Q. OKAY. ANYTHING ELSE THAT MIGHT HAVE SUBSTANTIVE
MEANING TO IT---
A. THERE'S NO OTHERS---
Q. ---THAT YOU CAN RECALL?
A. ---NO OTHER REAL SUBSTANTIVE THINGS.
Q. OKAY. IT MIGHT JUST BE A WORD OR A SPELLING OR A
SENTENCE OR SOMETHING?
A. RIGHT, YES.
Q. OKAY. OKAY, I APPRECIATE THAT. IF SOMETHING ELSE
COMES TO MIND IN THE COURSE OF THE DAY, IF YOU
REMEMBER SOMETHING ELSE, LET US KNOW. OKAY?
A. OKAY.
Q. OKAY, RETURNING TO YOUR -- YOUR PAPER, "FORMS OF
SOIL PHOSPHORUS ALONG A NUTRIENT ENRICHMENT
DR. QUALLS VOLUME II PAGE 129
GRADIENT IN THE NORTHERN EVERGLADES," WHICH IS
ESSENTIALLY CHAPTER EIGHT, I'D LIKE TO ASK YOU,
FIRST, JUST SO I HAVE A FRAME OF REFERENCE, AND
BECAUSE OTHER DEPONENTS HAVE BEEN TELLING ME FOR
SEVERAL DAYS IN THE PAST FEW WEEKS THAT THESE WERE
THE QUESTIONS I SHOULD ASK YOU---
A. UH-HUH (YES).
Q. ---I'D LIKE FOR YOU TO DEFINE FOR ME SOME
PARAMETERS AND SOME NUMBERS. I WOULD LIKE FOR YOU
TO DEFINE ENRICHED AND UNENRICHED FOR ME, IF YOU
CAN, IN TERMS OF TOTAL PHOSPHORUS IN THE SURFACE
WATER AND IN THE SOIL. NOW, IT WAS BROKEN
YESTERDAY ON ONE CHART THAT WE DID WITH
DR. CRAFT---
A. UH-HUH (YES).
Q. ---INTO ENRICHED HIGH, AND THEN THERE WAS AN
INTERMEDIATE, AND A LOW---
A. YES.
Q. ---AND THEN THERE WAS AN UNENRICHED.
A. UH-HUH (YES).
Q. CAN YOU DO IT IN THOSE FOUR CATEGORIES FOR ME, OR
DO YOU THINK OF IT ONLY IN TERMS OF THREE?
A. WELL, IN THIS PARTICULAR PAPER, WHEN I USE THE
WORDS ENRICHED---
DR. QUALLS VOLUME II PAGE 130
Q. OKAY.
A. ---AND UNENRICHED, THAT WAS SIMPLY A
SIMPLIFICATION, AND IT'S USED IN A RELATIVE WAY.
AND ENRICHED, I MEAN, BY BEING SIMPLY
SIGNIFICANTLY HIGHER IN VARIOUS FORMS OF
PHOSPHORUS, THAN THE UNENRICHED AREA. AND I
DEFINE UNENRICHED AS REPRESENTING WHAT THE
BACKGROUND OF THE REST OF THE EVERGLADES WOULD
LIKELY BE. AND PART OF THAT WAS ALSO SUPPORTED BY
SOME OF DR. RICHARDSON AND CRAFT'S WORK IN WATER
CONSERVATION AREA 3A, IN THE SENSE THAT THE TOTAL
PHOSPHORUS CONTENT OF THE SOIL WAS FAIRLY SIMILAR
AT OUR FURTHEST PLOTS ALONG THE NUTRIENT
ENRICHMENT GRADIENT IN WATER CONSERVATION
AREA 2A.
IN SUMMARY, IT WAS SIMPLY A RELATIVE TERM
TO SIMPLIFY THE ORGANIZATION OF THE DATA ALONG
WHAT IS REALLY A GRADIENT, AND REALLY MORE OR LESS
VARIES CONTINUOUSLY ALONG THAT NUTRIENT ENRICHMENT
GRADIENT. SO, I WOULD NOT PUT ANY SPECIFIC
DEFINITION OF A CERTAIN LEVEL OF PHOSPHORUS IN THE
SOIL OR IN THE WATER, AS NECESSARY TO BEING THE
CUTOFF FOR BEING ENRICHED, OR UNENRICHED, SIMPLY
RELATIVE TERMS.
DR. QUALLS VOLUME II PAGE 131
Q. ALL RIGHT. LET ME -- LET ME JUST -- WE'RE GOING
TO HAVE TO WORK WITH THIS CONCEPT A LITTLE BIT
HERE. I UNDERSTAND WHAT YOU'VE SAID, OR AT LEAST
I THINK I UNDERSTAND WHAT YOU'VE SAID. AND MAYBE
BECAUSE IT IS SUCH AN IMPORTANT CONCEPT, MAYBE I
SHOULD REPEAT BACK SOME OF WHAT I THINK I'M
HEARING.
A. OKAY.
Q. AS YOU USE ENRICHED AND UNENRICHED IN THIS
PARTICULAR -- I'M LOOKING AT THE DRAFT THAT YOU
SUBMITTED TO SOIL SCIENCE, AND YOU'RE LOOKING AT
CHAPTER EIGHT, I BELIEVE---
A. RIGHT, YEAH.
Q. ---WHICH IS -- THEY'RE PRETTY MUCH THE SAME?
A. RIGHT, UH-HUH (YES).
Q. IN REFERENCE TO ENRICHED AND UNENRICHED IN -- IN
THAT PAPER AND IN THAT CHAPTER, THIS IS A RELATIVE
TERM ALONG THE GRADIENT MOVING FROM THE HIGHEST
FORMS, OR HIGHEST LEVELS -- I'M SORRY -- HIGHEST
LEVELS OF PHOSPHORUS, DOWN TO THE LOWEST ALONG
YOUR GRADIENT?
A. THAT'S RIGHT, YES.
Q. OKAY. ALL RIGHT AS TO THAT. HOWEVER, WE HAVE --
WE HAVE TALKED IN TERMS OF ENRICHED AND UNENRICHED
DR. QUALLS VOLUME II PAGE 132
PHOSPHORUS LEVELS IN THE EVERGLADES---
A. UH-HUH (YES).
Q. ---HONESTLY, FOR DAYS---
A. RIGHT.
Q. ---IN DEPOSITIONS.
A. UH-HUH (YES).
Q. AND I BELIEVE THAT IN THOSE DISCUSSIONS, THEY WERE
NOT CONFINED TO THE GRADIENT, TO THE HIGHEST TO
THE LOWEST IN THE GRADIENT, THEY WERE -- THEY WERE
IN A CONTEXT, AT LEAST, AS I UNDERSTOOD IT---
A. UH-HUH (YES).
Q. ---GOING FROM BACKGROUND OR UNDERSTANDING OF
BACKGROUND---
A. UH-HUH (YES).
Q. ---ALL THE WAY UP TO THE HIGHEST LEVELS YOU WOULD
MEASURE, OF LET'S SAY TOTAL PHOSPHORUS IN THE
SURFACE WATER---
A. UH-HUH (YES).
Q. ---AND THE SOIL?
A. UH-HUH (YES).
Q. ALL RIGHT. SO, WHAT I WOULD LIKE TO ASK YOU,
IS -- AND I MUST BE -- IN ALL FAIRNESS, MANY
PEOPLE HAVE SAID, WHEN I SAID WHAT IS ENRICHED AND
WHAT IS UNENRICHED---
DR. QUALLS VOLUME II PAGE 133
A. UH-HUH (YES).
Q. ---YOU'RE THE ONE THEY SAID TO ASK.
A. UH-HUH (YES).
Q. SO, LET'S -- LET ME SEE IF I CAN FRAME A QUESTION
NARROWLY ENOUGH FOR YOU THAT WE CAN -- WE CAN GET
AN ANSWER---
A. UH-HUH (YES).
Q. ---THAT YOU FEEL COMFORTABLE ANSWERING.
A. OKAY.
Q. IF I WERE TO ASK YOU WHAT TOTAL PHOSPHORUS
CONCENTRATIONS IN SURFACE WATER AND SOIL WATER IN
THE EVERGLADES---
A. UH-HUH (YES).
Q. ---FOR AN UNENRICHED SITE WOULD BE, CAN YOU GIVE
ME A RANGE?
A. FOR AN UNENRICHED SITE?
Q. YES, SIR.
A. WELL, ACCORDING TO THIS TABLE, TABLE 8-1 ON PAGE
339, SIMPLY BY GROUPING, ARBITRARILY, MORE OR
LESS, GROUPING, PLOTS AT D6, C6, A5 AND A6, ALL
INDICATED IN ANOTHER MAP, IN THIS PAPER, BY THE
WAY---
Q. OKAY. WHY DON'T WE GET THAT MAP IN FRONT OF US?
A. OKAY.
DR. QUALLS VOLUME II PAGE 134
Q. BECAUSE I THINK EVERYBODY'S GOT A COPY OF IT, AND
SOME GRAPHS I SUPPLIED, AND---
A. AND THAT IS ON PAGE 323, FIGURE 8-1, AND WE'RE
LOOKING AT A MAP OF WATER CONSERVATION AREA 2A IN
WHICH THE PLOT NUMBERS ALONG OUR THREE TRANSECTS
HAVE BEEN INDICATED.
Q. AND SO FOR UNENRICHED, YOU CHOSE D1, D2 AND C1 AND
C2. IS THAT ACCURATE?
A. FOR THE -- FOR THE ENRICHED PLOTS---
Q. ENRICHED, EXCUSE ME---
A. YES, I CHOSE---
Q. ---EXCUSE ME.
A. ---D1, D2, C1, AND C2. AND FOR THE UNENRICHED
PLOTS, I CHOSE D6, C6, A5 AND A6---
Q. OKAY.
A. ---MORE OR LESS ARBITRARILY, BECAUSE THOSE
REPRESENTED BOTH A DISTRIBUTION OF POINTS FROM
EAST TO WEST, AND THEY ALSO INDICATED THE ONES
THAT WERE FURTHEST DOWN WHAT WE CALL OUR NUTRIENT
ENRICHMENT GRADIENT, AND WHAT WE FELT PROBABLY
REPRESENTED BACKGROUND LEVELS FOR THE EVERGLADES,
AT LEAST THE WATER CONSERVATION AREAS.
Q. NOW, YOU BELIEVE THAT THESE NUMBERS THAT ARE
REPRESENTATIVE OF D6, C6, A5 AND A6 ARE
DR. QUALLS VOLUME II PAGE 135
REPRESENTATIVE OF THE ENTIRE EVERGLADES?
A. NO, NOT NECESSARILY THE ENTIRE EVERGLADES.
Q. OKAY. OKAY.
A. BECAUSE I BELIEVE THAT THERE IS PROBABLY --
THERE'S PROBABLY ORIGINALLY SOMEWHAT OF A
NORTH/SOUTH GRADIENT IN PEAT DEPTH, AND TO SOME
EXTENT IN NUTRIENT CONTENT. NOW, I'M NOT SURE
WHETHER ANYONE HAS EVER PROVED THAT, BECAUSE I
DON'T KNOW IF THERE HAVE BEEN ENOUGH SOIL ANALYSES
DONE SINCE -- IN TIMES BEFORE SAY THE 1920'S,
'30'S AND 40'S TO ACTUALLY PROVE THAT
CONCLUSIVELY.
BUT I BELIEVE THAT THE DEPTH OF THE PEAT, AND
THE CONTENT OF MINERALS BESIDES CALCIUM CARBONATE
WOULD PROBABLY HAVE RESULTED IN SOME SORT OF A
SLIGHT GRADIENT GOING FROM NORTH TO SOUTH, FROM
THE SOUTH SHORES OF LAKE OKEECHOBEE DOWN TO THE
EVERGLADES NATIONAL PARK. AFTER ALL, THAT IS THE
AREA THAT THEY DID DRAIN FOR AGRICULTURAL,
ORIGINALLY, SO I WOULD ASSUME THAT THAT WAS WHERE
THE RICHEST AND DEEPEST SOILS WERE.
Q. NOW, LET ME, JUST SO I'M CLEAR, DO YOU -- YOU
BELIEVE THAT THIS NORTH/SOUTH GRADIENT IN
ENRICHMENT, BEING THE RICHEST NEAR THE LAKE,
DR. QUALLS VOLUME II PAGE 136
GOING PROBABLY INCREASINGLY LESS RICH AS YOU GO
SOUTH?
A. UH-HUH (YES).
Q. IS THAT BASED ON THE LITERATURE?
A. TO SOME EXTENT, BUT IT'S ALSO PARTIALLY A
SUBJECTIVE JUDGMENT, JUST BASED ON, YOU KNOW, THE
FACT THAT THAT'S WHERE THEY DID PUT MOST OF THE
AGRICULTURE, ORIGINALLY, AND -- AND BECAUSE THE
SOILS ARE VERY THIN IN THE SOUTH.
Q. ALL RIGHT. SO, BASED ON YOUR BACKGROUND AS A SOIL
SCIENTIST, THAT WOULD -- YOU WOULD BELIEVE THAT TO
BE SOMETHING YOU WOULD EXPECT TO FIND IF YOU WERE
TO TEST THE SOILS ON A NORTH/SOUTH GRADIENT SUCH
AS THAT?
A. YES, UH-HUH (YES)---
Q. OKAY.
A. ---BUT, I WOULD SAY ALSO THAT THAT WAS PROBABLY
MUCH LESS PRONOUNCED THAN THE GRADIENT WE HAVE IN
WATER CONSERVATION AREA 2A. THAT THIS IS ON A
MUCH SMALLER SCALE THAN WHAT I'M TALKING ABOUT
GOING ALL THE WAY FROM LAKE OKEECHOBEE DOWN TO THE
EVERGLADES NATIONAL PARK. AND I WOULD JUST GUESS
THAT IT WOULD BE MUCH MORE PRONOUNCED ON THIS
SMALLER SCALE.
DR. QUALLS VOLUME II PAGE 137
Q. IT'S MORE PRONOUNCED BECAUSE OF THE SIGNIFICANT
ENRICHMENT COMING OFF OF THE HILLSBORO CANAL, INTO
THE AREA?
A. RIGHT, YEAH. THAT WAS ESSENTIALLY THE CONCLUSION
OF THIS PAPER.
Q. OKAY. DO YOU HAVE ANY DATA THAT SUPPORTS YOUR
LARGER THEORY, THAT THERE IS A NORTH/SOUTH
GRADIENT, LET'S SAY FROM THE LAKE THROUGH THE
PARK?
A. NO, I CAN'T POINT TO ANYTHING RIGHT NOW. IN FACT,
I THINK THAT WOULD BE SOMETHING THAT WOULD HAVE
BEEN USEFUL TO HAVE DONE---
Q. SURE.
A. ---BUT I'M NOT SURE THAT NOW, SINCE VARIOUS AREAS
HAVE BEEN DRAINED, AND THINGS HAVE BEEN CHANGED,
THAT IT REALLY COULD BE DONE AT THIS POINT, TO
DEFINITELY PROVE THAT.
Q. SO, YOU'RE NOT SURE THAT YOU COULD SUPPORT THE
THEORY OF THE NORTH/SOUTH GRADIENT, EVEN BY DATA
COLLECTION ACROSS THAT AREA PRESENTLY?
A. RIGHT, YEAH. I THINK PRESENTLY THAT WOULD BE
DIFFICULT TO SUPPORT THAT---
Q. OKAY.
A. ---SO, I, YOU KNOW, I HAVE TO POINT OUT THAT THAT
DR. QUALLS VOLUME II PAGE 138
IS JUST A SUBJECTIVE IMPRESSION OF MINE.
Q. I UNDERSTAND, I UNDERSTAND. LET ME ASK YOU, DID
YOU HELP ESTABLISH THE TRANSECTS FROM THE 10D,
THE 10C AND THE 10A?
A. NO. ACTUALLY CHRIS CRAFT AND CURT RICHARDSON HAD
ACTUALLY SET UP THOSE POINTS ON A PREVIOUS TRIP
BEFORE I CAME, WHICH WAS IN DECEMBER, 1989, AND
THEY HAD ALREADY SET UP THAT TRANSECT AT THAT
POINT.
Q. OKAY. DO YOU KNOW HOW THEY ESTABLISHED THE D6,
THE C6, THE A5, AND THE A6 AS THE FURTHERMOST
UNENRICHED OR BACKGROUND SITES ALONG THEIR
TRANSECTS?
A. I THINK THAT WOULD PROBABLY BE SOMETHING THAT --
THAT CURT AND/OR CHRIS COULD PROBABLY ANSWER
BETTER.
Q. OKAY.
A. BUT I CAN GIVE MY -- JUST A SUBJECTIVE GUESS ABOUT
THEIR REASONS, WAS THAT IT WAS -- THEY WERE
BASICALLY SET UP APPROXIMATELY ONE KILOMETER
APART, AND I BELIEVE IT WAS TO SOME EXTENT
ARBITRARY. OF COURSE, THE NORTH/SOUTH PLACEMENT
OF THOSE IS, OF COURSE, MEANT TO BE DUE SOUTH OF
EACH OF THE GATES, THAT'S GATE 10D, 10C, AND 10A.
DR. QUALLS VOLUME II PAGE 139
Q. WELL, HAVE YOU DONE TESTING SOUTH OF THOSE SITES,
OF D6, C6, A5 AND A6 IN 2A?
A. YES, WE HAVE DONE SOME LIMITED TESTING---
Q. UH-HUH (YES).
A. ---MAINLY AT OUR SITE, WHICH WE'VE ESTABLISHED FOR
WHAT WE'RE CALLING THE DOSING STUDY.
Q. RIGHT, RIGHT.
A. AND WE HAVE SAMPLED THE SOIL THERE, BUT I WOULD
SAY NOT TO THE EXTENT OF ACTUALLY EXTENDING THOSE
PARTICULAR TRANSECTS.
Q. OKAY. HAVE YOU SAMPLED SURFACE WATER THERE,
ALSO?
A. YES, UH-HUH (YES). WE SAMPLE THAT ON A REGULAR
BASIS.
Q. OKAY. HAVE YOU FOUND CONCENTRATIONS LOWER THAN
D6, C6, A5, AND A6?
A. IN TERMS OF SURFACE WATER, ORTHOPHOSPHATE, YEAH,
WE HAVE FOUND OCCASIONALLY SOME CONCENTRATIONS AT
OUR DOSING STUDY SITE WHICH ARE EVEN LOWER THAN WE
WOULD -- THAN THE AVERAGE AT A6, C6 AND D6.
Q. OKAY. HOW ABOUT TOTAL PHOSPHORUS?
A. IN TERMS OF TOTAL PHOSPHORUS, I'M NOT SURE
RIGHT NOW. I WOULD HAVE TO CHECK THE ACTUAL
NUMBERS.
DR. QUALLS VOLUME II PAGE 140
Q. DO YOU HAVE THOSE AVAILABLE TO YOU ON ANY OF YOUR
GRAPHS THERE IN FRONT OF YOU?
A. NO, WE DON'T HAVE THOSE ON THE GRAPHS IN FRONT OF
ME. WE DIDN'T REALLY PUT ANY DATA OF THE WATER
CHEMISTRY DATA, OR WE ONLY PUT LIMITED WATER
CHEMISTRY DATA FROM OUR DOSING STUDY---
Q. UH-HUH (YES).
A. ---IN HERE AT THIS POINT, SINCE THAT IS
SOMETHING WHICH IS STILL IN THE PROGRESS OF
BEING INITIATED.
Q. OKAY, IN TERMS OF THE LOWER VALUES THAT YOU HAVE
FOUND AT THE DOSING STUDY IN ORTHOPHOSPHATE, WHAT
NUMBERS HAVE YOU FOUND AT YOUR DOSING SITE? AT
BOTH DOSING SITES, ARE YOU TALKING SORT OF ABOUT
THE TWO?
A. THAT'S RIGHT, YEAH, BECAUSE THEY'RE---
Q. RIGHT.
A. ---ONLY MAYBE A HUNDRED YARDS, MORE OR LESS---
Q. SURE.
A. ---APART FROM EACH OTHER SO, THEY'RE REALLY PRETTY
SIMILAR.
Q. OKAY.
A. NOW, I WOULD SAY IN TERMS OF ORTHOPHOSPHATE, JUST
OFF THE TOP OF MY HEAD, I THINK WE HAVE FOUND
DR. QUALLS VOLUME II PAGE 141
CONCENTRATIONS BETWEEN ABOUT SIX MICROGRAMS PER
LITER, UP TO APPROXIMATELY SEVENTEEN MICROGRAMS
PER LITER, AND THAT'S APPROXIMATE. WE MAY HAVE
FOUND CONCENTRATIONS OF FOUR, BUT I DON'T BELIEVE
THAT THE -- THAT OUR CONFIDENCE INTERVAL ON THOSE
SORTS OF ANALYTICAL MEASUREMENTS IS ALL THAT
PRECISE, TO MAKE A DISTINCTION BETWEEN FOUR AND
SIX MICROGRAMS PER LITER.
Q. OKAY. IF WE WERE TO LOOK FOR YOUR DATA, IF YOU'RE
SAYING YOU DON'T BELIEVE YOU CAN LOCATE IT HERE
TODAY AMONG YOUR PAPERS ON TOTAL PHOSPHORUS --
AND I HAVE TO APOLOGIZE, I'M -- AS A LAYMAN, I'M
REALLY -- THE TOTAL PHOSPHORUS IS WHAT I'M MORE
COMFORTABLE IN THINKING---
A. RIGHT, UH-HUH (YES).
Q. ---IN TERMS OF. IN FACT, UNTIL I READ YOUR
PAPERS, I NEVER DREAMED THERE WERE SO MANY
DIFFERENT FORMS OF PHOSPHORUS THAT WE WERE GOING
TO HAVE TO DEAL WITH.
A. UH-HUH (YES).
Q. WHERE WOULD WE LOOK FOR THESE NUMBERS OF TOTAL
PHOSPHORUS AMONG YOUR DATA COLLECTIONS?
A. YOU KNOW, I PRODUCED THOSE IN A VERY RAW FORM IN
ONE OF THE DOCUMENTS. AND I BELIEVE THAT THE
DR. QUALLS VOLUME II PAGE 142
MANILA -- MANILA FOLDER WAS ACTUALLY LABELED,
"DOSING STUDY." AND THOSE HAVE NEVER BEEN
COMPILED IN THE FORM OF A NICE NEAT REPORT, BUT
THEY WERE SIMPLY IN THEIR RAW FORMS AS REPORTS
FROM THE AUTOANALYZER DATA. I'M NOT SURE WHAT
EXHIBIT NUMBER THAT WOULD HAVE BEEN.
Q. I GUESS NOT. THERE WERE HUNDREDS OF THEM, WEREN'T
THERE?
A. RIGHT, SOMEWHERE BETWEEN ZERO AND 129.
Q. OKAY. ALL RIGHT. DO YOU THINK IF I WERE TO GIVE
YOU LIKE AN INDEX ON ONE OF OUR BREAKS, DO YOU
THINK YOU MIGHT COULD LOCATE IT FOR US?
A. I THINK I COULD, YEAH.
Q. OKAY. ALL RIGHT. WE'LL TRY THAT.
A. OKAY.
Q. OKAY. HAVE YOU DONE -- OKAY, WE MAY BE ABLE TO
LOCATE IT. HAVE YOU DONE THAT TYPE OF WHAT I'M
GOING TO CALL -- DO YOU KNOW WHAT I MEAN,
BACKGROUND TESTING AT OTHER SITES, OTHER THAN 2A?
A. NO, NOT REALLY.
Q. OKAY. I THINK YOU HAD SAID YOU WERE GOING -- YOU
DON'T HAVE ANY 3A BACKGROUND DATA?
A. NO, NO. I THINK -- I'VE NEVER REALLY BEEN INTO
THE INTERIOR OF 3A, ACTUALLY.
DR. QUALLS VOLUME II PAGE 143
Q. OKAY. SO, ALL OF YOUR WORK HAS BEEN CONFINED TO
2A AND 2B. IS THAT ACCURATE?
A. YES, EXCEPT FOR SOME SPORADIC SAMPLES I'VE TAKEN
IN VARIOUS CANALS AROUND THE AREA, SAY, LIKE IN
THE MIAMI CANAL, THE NEW RIVER CANAL, AND THE
HILLSBORO CANAL.
Q. OKAY. DO YOU HAVE BACKGROUND NUMBERS FOR 2B?
A. 2B?
Q. WHAT WOULD YOU CALL AN UNENRICHED -- WHAT WOULD BE
THE RANGE FOR UNENRICHED IN 2B?
A. NOW, IN 2B, I HAVEN'T REALLY DEALT WITH 2B TO
ANY EXTENT, EXCEPT IN THE EXTENT OF BASICALLY
HELPING CHRIS OCCASIONALLY WITH HIS FERTILIZER
STUDY IN 2B.
Q. SO, YOU'RE UNABLE TO GIVE US A BACKGROUND RANGE
FOR 2B?
A. WHAT I KNOW ABOUT 2B IS BASICALLY JUST HAVING A
FAMIL -- KIND OF A FAMILIARITY WITH CHRIS CRAFT
AND CURT'S WORK ON THE FERTILIZATION STUDY, AND
LOOKING AT SOME OF THOSE WATER CHEMISTRY NUMBERS.
AND I -- MY SUBJECTIVE IMPRESSION, WITHOUT BEING
ABLE TO POINT AT THE DATA RIGHT AT THE MOMENT --
I'M SURE IT'S SOMEWHERE AROUND HERE -- IS THAT
THE -- THAT THE WATER CHEMISTRY AT THE
DR. QUALLS VOLUME II PAGE 144
FERTILIZATION SITES, THE CONTROL SITES, IS FAIRLY
SIMILAR TO WHAT IT WAS AT THE FURTHEST PLOTS ALONG
THE NUTRIENT ENRICHMENT GRADIENT, THAT IS, D6, C6,
A5 AND A6, REASONABLY SIMILAR.
Q. OKAY.
A. I'M SURE THAT THERE ARE SOME SLIGHTLY DIFFERENT
RANGES, AND SOME SLIGHTLY DIFFERENT NUMBERS,
OCCASIONALLY---
Q. OKAY. WOULD THEY BE---
A. ---BUT I DON'T REMEMBER SEEING ANYTHING THAT WAS
SURPRISING TO ME THAT I THOUGHT WAS DRASTICALLY
LOWER OR DRASTICALLY HIGHER THAN WHAT WE SAW IN
THE SOUTHERN END OF 2B -- 2A -- SORRY.
Q. AT THE END OF THE GRADIENT, YOU MEAN---
A. THAT'S RIGHT, YES.
Q. ---WHEN YOU SAY THE SOUTHERN END, YOU MEAN THE END
OF THE GRADIENT TRANSECT?
A. RIGHT, UH-HUH (YES).
Q. OKAY. I THINK YOU SAID THAT YOU THOUGHT YOU
UNDERSTOOD HOW THEY HAD CHOSEN THE END OF THEIR
GRADIENTS, AND THAT YOU WERE GOING TO GUESS OR
SOMETHING. I'M NOT SURE THAT YOU DID TELL ME,
THOUGH. I MAY HAVE CUT YOU OFF. HOW DO YOU THINK
THEY REACHED THE END OF THEIR GRADIENTS?
DR. QUALLS VOLUME II PAGE 145
A. AS FAR AS WHAT THEY ARBITRARILY DECIDED TO MAKE
THE LAST POINT, SAY, D6, A6 AND C6, I CAN'T REALLY
SAY THAT RIGHT NOW. I'M NOT SURE HOW CURT AND
CHRIS JUST DECIDED THAT THAT WAS THE END OF THE
TRANSECT.
Q. IF I TOLD YOU THAT THE ANSWER I HAD BEEN GIVEN WAS
THAT THEY HAD GONE UNTIL THE NUMBERS LEVELED OFF,
WOULD THAT SOUND ABOUT RIGHT TO YOU?
A. YEAH, I SUPPOSE SO. I'M NOT SURE WHAT NUMBERS YOU
MEAN.
Q. WELL, THE SOIL AND SURFACE WATER, LET'S SAY TOTAL
PHOSPHORUS NUMBERS, THEY JUST STARTED LEVELING
OFF.
A. YEAH, I CAN'T REALLY SAY THAT FOR SURE. I DIDN'T
COME ON TO THE PROJECT UNTIL DECEMBER 10, 1989,
AND -- AND THEN WE STARTED SAMPLING IN JANUARY OF
1990, AND SO I'M JUST NOT ALL THAT FAMILIAR WITH
SOME OF THE SAMPLES THAT THEY HAD TAKEN BEFORE
THAT TIME.
Q. OKAY. WELL, IF YOU WERE ESTABLISHING THIS
GRADIENT -- LET'S ASSUME THAT YOU WERE SENT OUT
TO ESTABLISH THE GRADIENT, HOW WOULD YOU DETERMINE
THAT YOU HAD REACHED BACKGROUND, OR UNENRICHED
LEVELS?
DR. QUALLS VOLUME II PAGE 146
A. PROBABLY, AS YOU SAY, BY LOOKING FOR A POINT IN
WHICH THE CONCENTRATIONS OF PHOSPHORUS, IN
PARTICULAR, SINCE THAT WAS THE ELEMENT THAT MOST
EVERYBODY IS CONCERNED WITH, WHERE THEY DID LEVEL
OFF, AND TO WHERE THEY WOULD OCCASIONALLY MATCH
SOME OF THE GENERAL RANGES THAT YOU WOULD FIND
IN 2B, AND 3A.
Q. WHAT WOULD THOSE GENERAL RANGES FOR GENERAL
BACKGROUND BE IN 2A AND 2B?
A. IN 2A AND 2B?
Q. RIGHT.
A. WELL, I WOULD HAVE TO RETROSPECTIVELY JUST SAY THE
GENERAL RANGES FOR BACKGROUND WOULD PROBABLY BE
WHAT WE FOUND AT A6, D6, AND---
Q. C6? WELL, WHATEVER THE FOUR ARE.
A. --A6, D -- YEAH -- D6 AND C6, RIGHT, AND -- AND
THE FACT THAT THEY WERE NOT TOO DRASTICALLY
DIFFERENT FROM WHAT CHRIS -- CHRIS CRAFT AND CURT
RICHARDSON HAD FOUND IN 2B AND 3A.
Q. SO, YOU'RE BASICALLY WORKING BACKWARDS OFF OF
THEIR PRELIMINARY DATA COLLECTIONS?
A. THAT'S RIGHT, YES.
Q. OKAY. HOW FAR WOULD YOU GO BEYOND THE POINT WHERE
YOU FOUND IT LEVELING OFF? HOW MUCH FURTHER WOULD
DR. QUALLS VOLUME II PAGE 147
YOU EXTEND INTO THE MARSH, ASSUMING THAT YOU HAD
FOUND THAT LEVELING OFF POINT?
A. WELL, GIVEN AN UNLIMITED AMOUNT OF MONEY, AND
PERMISSION TO GO INTO THE EVERGLADES NATIONAL
PARK, I WOULD HAVE GONE ALL OF THE WAY FROM NORTH
TO SOUTH.
Q. TO THE BAY?
A. THAT'S RIGHT, YEAH.
Q. BUT LET'S ASSUME YOU'RE GOING TO STAY WITHIN
WATER CONSERVATION AREA 2A, FOR PURPOSES OF MY
QUESTION---
A. UH-HUH (YES).
Q. ---HOW MUCH FURTHER SOUTH WOULD YOU HAVE GONE?
A. I THINK GIVEN THE TRADE-OFF OF, YOU KNOW, LIMITED
TIME AND MONEY, I BELIEVE THAT PROBABLY THAT A6,
D6 AND C6 WAS REALLY SUFFICIENTLY FAR ENOUGH.
RETROSPECTIVELY, SIMPLY IF YOU LOOK AT A LOT OF
THE CURVES OF THE CONCENTRATIONS OF PHOSPHORUS IN
THE SOIL AND THE WATER, THEY DO TEND TO LEVEL OFF
OR REACH KIND OF A LOWER ASYMPTOTE AT THOSE POINTS
ON THE TRANSECT, AND---
Q. DO YOU HAVE GRAPHS TO SHOW ME THAT I CAN -- THAT I
CAN LOOK AT AND SEE HOW FAR THEY WENT FOR THE
LEVELING OFF, AND THAT YOU WOULD AGREE THAT THAT
DR. QUALLS VOLUME II PAGE 148
WAS THE APPROPRIATE DISTANCE TO GO FOR A LEVELING
OFF?
A. NO. AS FAR AS GRAPHS THAT THEY HAD, SAY, PRODUCED
BEFORE I CAME?
Q. I DON'T KNOW---
A. NO, THE ONLY -- THE ONLY---
Q. ---I DON'T KNOW HOW YOU'RE JUDGING HOW THEY
LEVELED OFF. I MEAN, I WAS SORT OF REFERRED TO
YOU. I HAVE TO BE HONEST---
A. OH, OH -- OH, IN RET---
Q. ---I MEAN, EVERYONE SAID YOU WERE IT. I WAS GOING
TO GET THE ANSWER RIGHT HERE, AND---
A. ---YES, IN RETROSPECT---
Q. ---I'M GOING BACKWARDS.
A. ---IN RETROSPECT, I WOULD POINT TO---
Q. YEAH.
A. ---PAGE 328, FIGURE 8-2---
Q. OKAY.
A. ---WHICH IS A PART OF SURFACE AND SOIL PORE WATER,
ORTHOPHOSPHATE CONCENTRATIONS.
Q. OKAY.
A. AND I BELIEVE THAT IF YOU LOOK JUST APPROXIMATELY
BETWEEN EIGHT AND TEN KILOMETERS ON THIS---
Q. UH-HUH (YES).
DR. QUALLS VOLUME II PAGE 149
A. ---ARBITRARY DISTANCE SCALE---
Q. UH-HUH (YES).
A. ---THEY DO APPEAR TO HAVE LEVELED OFF THERE.
Q. AND YOU'RE SAYING THAT THEY WENT THE SAME DISTANCE
THAT YOU WOULD HAVE GONE, HAD YOU GONE OUT AND
ESTABLISHED THE TRANSECT? THAT WAS MY ORIGINAL
QUESTION. DO YOU THINK THEY WENT THE APPROPRIATE
DISTANCE---
A. YES, I---
Q. ---TO DETERMINE THE LEVELING OFF?
A. ---I THINK THAT, IN RETROSPECT, THAT TURNED OUT TO
BE FAR ENOUGH BASICALLY.
Q. BUT I DON'T THINK YOU'RE EXACTLY TELLING ME THIS
IS HOW YOU WOULD HAVE DONE IT, BUT YOU THINK IT'S
OKAY. IS THAT ACCURATE?
A. YES, UH-HUH (YES).
Q. OKAY. ALL RIGHT. YOU HAVE INDICATED
"ARBITRARILY" A NUMBER OF TIMES. CAN YOU EXPLAIN
TO ME WHY YOU BELIEVE THAT'S AN APPROPRIATE WORD
IN REGARD TO HOW THEY DID THIS?
A. YOU MEAN THAT THE TRANSECTS EXTENDED FAR ENOUGH?
Q. RIGHT.
A. OKAY. IN -- AS I SAY, IN RETROSPECT, FROM LOOKING
AT SOME OF THE DATA THAT WE DID FIND ON THAT
DR. QUALLS VOLUME II PAGE 150
NUTRIENT ENRICHMENT GRADIENT, WE DO BELIEVE THAT
THERE IS A LEVELING OFF SOMEWHERE IN THE RANGE OF
EIGHT TO TEN KILOMETERS ON THIS ARBITRARY DISTANCE
SCALE, BOTH IN THE SURFACE WATER OF PHOSPHORUS
CONCENTRATIONS, AND, TO AN EXTENT, IN THE SOIL
CONCENTRATIONS. AND A SECOND PIECE OF EVIDENCE
WAS WHAT CURT RICHARDSON AND CHRIS CRAFT FOUND IN
WATER CONSERVATION AREA 3, THAT THEY FOUND SOME
FAIRLY SIMILAR CONCENTRATIONS OF TOTAL SOIL
PHOSPHORUS.
Q. THIS IS FROM THEIR PRELIMINARY TESTING THAT THEY
DID ON, LIKE, THEIR FIRST---
A. RIGHT. THEIR -- THEIR---
Q. ---THEIR FIRST TRIPS?
A. ---THEIR PRELIMINARY TESTING, YES, WHICH WAS
REPORTED IN THE FIRST ANNUAL REPORT.
Q. OKAY. IF I'M UNDERSTANDING WHAT YOU'RE SAYING IS,
IS YOU'RE SAYING THAT PERHAPS YOU WOULDN'T HAVE
DONE IT THIS WAY, BUT LOOKING BACK, IT SEEMS TO
HAVE BEEN AN ACCEPTABLE WAY TO HAVE SET THEM UP?
MR. BURGESS: OBJECT TO THE FORM
OF THE QUESTION.
A. RIGHT, YEAH. I THINK, YOU KNOW, I WOULDN'T SAY
THAT I WOULD HAVE DONE IT DIFFERENTLY, I THINK,
DR. QUALLS VOLUME II PAGE 151
BECAUSE WE'RE ALWAYS LOOKING AT A TRADE-OFF OF
TIME AND MONEY, IN SETTING UP THE SCALE OF ANY
SORT OF PROJECT LIKE THIS. AND SO I BELIEVE, YOU
KNOW, GIVEN LIMITED TIME AND LIMITED MONEY, THAT
THAT WOULD HAVE BEEN A REASONABLE SETUP FOR THREE
TRANSECTS. IN FACT, I'LL TELL YOU JUST MY
SUBJECTIVE IMPRESSION, WHEN I WAS FIRST
CONSIDERING TAKING THIS JOB, THAT, YOU KNOW,
WHEN I LOOKED AT THE FACT THAT THEY HAD THREE
TRANSECTS, COVERING A LARGE GEOGRAPHIC AREA,
THAT JUST MY FIRST THOUGHT WAS THAT THAT WAS AN
EXCELLENT TYPE OF STUDY. BECAUSE THERE HAVE BEEN,
IN THE PAST, LOTS OF ECOLOGICAL STUDIES WHICH ARE
DONE USING ONE TRANSECT, GOING UP A PARTICULAR
SORT OF ENVIRONMENTAL GRADIENT, AND I HAD, IN SOME
OF MY TRAINING BEFORE, AND FROM SOME OF THE
EXPERIENCE THAT I HAD HAD, I HAD REALIZED THAT,
YOU KNOW, ONE TRANSECT IS NOT A PARTICULARLY GREAT
THING TO BASE YOUR ECOLOGICAL CONCLUSIONS ON, AND
THAT THREE REPLICATED TRANSECTS LIKE THIS,
COVERING A LARGE UNIT OF THE LANDSCAPE, SEEMED TO
BE AN EXCELLENT DESIGN TO ME.
Q. IF YOU WANTED TO KNOW THE BACKGROUND TOTAL
PHOSPHORUS CONCENTRATIONS IN THE EVERGLADES,
DR. QUALLS VOLUME II PAGE 152
DR. QUALLS, WOULD YOU START IN AREAS THAT YOU KNOW
ARE RECEIVING PHOSPHORUS INPUTS, OR WOULD YOU GO
TO AREAS FAR FROM THOSE INPUTS?
A. IF I WANTED TO -- CAN YOU REPEAT THAT?
Q. IF YOU'RE TRYING TO ESTABLISH BACKGROUND LEVELS,
UNENRICHED LEVELS---
A. UH-HUH (YES).
Q. ---WOULD YOU, AS A SOIL SCIENTIST, IMMEDIATELY GO
TO THOSE AREAS THAT YOU KNOW ARE GETTING
PHOSPHORUS INPUTS, OR WOULD YOU TRY TO SEEK OUT
AREAS THAT YOU KNOW ARE PROBABLY REMOTE FROM
PHOSPHORUS INPUTS?
A. RIGHT, YEAH, IF I WANTED TO ESTABLISH THE
BACKGROUND LEVELS, OBVIOUSLY, I WOULD GO TO AREAS
THAT ARE FAIRLY REMOTE FROM THE AREA RECEIVING
PHOSPHATE INPUTS.
Q. OKAY.
A. BUT AT THE SAME TIME, I WOULD ALSO TAKE INTO
ACCOUNT THE POSSIBILITY THAT THERE MIGHT BE ANY
PREEXISTING GRADIENTS AND BY SOME WAY TRY TO
SCREEN OUT THAT NATURAL BACKGROUND, OR PREHIS --
PREEXISTING OR HISTORIC---
Q. UH-HUH (YES).
A. ---GRADIENT FROM THE ONE THAT WAS CREATED BY THE
DR. QUALLS VOLUME II PAGE 153
VARIABLE THAT WE'RE LOOKING AT, IN THIS CASE,
PHOSPHATE.
Q. AND HOW WOULD YOU DO THAT? HOW WOULD YOU SCREEN
OUT THOSE MAN-INDUCED GRADIENTS OR WHATEVER YOU
WOULD CALL THEM?
A. WELL, OBVIOUSLY, THE BEST WAY TO DO THAT IS TO BE
ABLE TO HAVE SAMPLES COMING FROM BEFORE THE TIME
OF AGRICULTURE IN THE EVERGLADES. GIVEN THAT WE
CAN'T DO THAT, WHAT WE CAN DO THEN IS -- IS LOOK
BOTH AT GRADIENTS GOING FROM BOTH NORTH TO SOUTH
AND EAST TO WEST.
Q. YOU HAD SOME DIFFICULTY WITH THE WAY THESE NORTH
SOUTH GRADIENTS WERE SET UP, DID YOU NOT?
A. NO.
Q. YOU WEIGHTED -- YOU WEIGHTED YOUR NUMBERS, THOUGH,
BECAUSE OF FLOW, DID YOU NOT?
A. OH, OH---
Q. YOU HAVE WEIGHTED DISTANCE. ISN'T THAT -- IS IT
CALLED WEIGHTED DISTANCE?
A. THAT'S RIGHT, YES.
Q. IS THAT WHAT YOU DID?
A. YES, WEIGHTED DISTANCE, THAT'S RIGHT.
Q. UH-HUH (YES).
A. AND THE REASON FOR DOING THAT WAS, FIRST OF ALL,
DR. QUALLS VOLUME II PAGE 154
TO FIND SOME WAY TO EXPRESS ALL THE DATA ON ONE
PARTICULAR AXIS IN A WAY THAT WAS EASIER TO DIGEST
FOR THE READER, NUMBER ONE, AND TO FIND SOME WAY
TO DEAL WITH THE FACT THAT THERE WAS A MUCH HIGHER
NUTRIENT LOAD COMING THROUGH THE "D" GATE THAN
THROUGH THE "A" GATE.
Q. I WILL HAVE TO TELL YOU, I'M A LITTLE DISTRESSED.
I STARTED OUT WITH WHAT I THOUGHT WAS GOING TO BE
THE SIMPLEST QUESTION OF THE MORNING---
A. UH-HUH (YES).
Q. ---AND I SEEM TO BE CAUGHT IN THE MUCK HERE.
IF YOU WENT OUT AND FOUND THESE NATURAL AREAS
THAT YOU THOUGHT WERE FOR BACKGROUND, WOULDN'T
YOU WANT SOME -- SOME REDUNDANCY, AT LEAST TWO LOW
SAMPLING STATIONS TO ESTABLISH YOUR BACKGROUND
NUMBERS?
A. WELL, YES. AND IN THE SENSE THAT WHAT CURTIS
RICHARDSON AND CHRIS CRAFT HAD FOUND IN WATER
CONSERVATION AREA 3, BASED ON THEIR PRELIMINARY
ANALYSES THERE, IT SEEMED LIKE THAT THE SOIL
PHOSPHORUS CONCENTRATION WAS FAIRLY SIMILAR AT
THOSE FURTHEST POINTS ON THAT NUTRIENT ENRICHMENT
GRADIENT.
Q. THE 3A, YOU SAID?
DR. QUALLS VOLUME II PAGE 155
A. YES, THE 3A.
Q. OKAY. OKAY. LET'S GO BACK TO YOUR CONCEPT OF
TIME AND MONEY IMPEDING EVERYTHING THAT WE DO.
A. UH-HUH (YES).
Q. LET'S ASSUME THAT TIME AND MONEY WERE NOT A
FACTOR---
A. UH-HUH (YES).
Q. ---AND THAT YOU WERE AN ENDOWED SCIENTIST WHO
COULD DO THINGS IN A PERFECT WORLD---
A. UH-HUH (YES).
Q. ---HOW WOULD YOU ESTABLISH YOUR TRANSECTS IN 2A?
A. WELL, WITHIN 2A, PROBABLY BY BASICALLY SAMPLING
MORE POINTS. THE MORE THE POINTS THE BETTER, UP
TO THE POINT WHERE YOU'VE SAMPLED EVERY SQUARE
INCH OF SOIL. YOU KNOW, THAT WOULD BE GIVEN
UNLIMITED TIME AND MONEY. BUT, OF COURSE, THAT
NEVER REALLY IS THE SITUATION OF UNLIMITED TIME
AND MONEY---
Q. YOU---
A. ---SO, IT'S ALMOST A---
Q. ---YOU WOULD HAVE DONE SOME TYPE OF A---
A. ---A KIND OF A FANTASY.
Q. RIGHT. YOU WOULD HAVE DONE SOME TYPE OF A
TRANSECT ACROSS ALL OF 2A?
DR. QUALLS VOLUME II PAGE 156
A. POSSIBLY.
Q. UH-HUH (YES). HAS THAT, IN FACT, BEEN DONE BY
OTHER SCIENTISTS OUT THERE?
A. YES, I -- YES, I UNDERSTAND THAT RAMESH REDDY AND
SOME OTHER CO-AUTHORS HAVE DONE A FAIRLY EXTENSIVE
GRID---
Q. RIGHT. GRID, I'M SORRY.
A. ---IN WATER CONSERVATION AREA 2A, YES.
Q. THANK YOU. OKAY. HAVE YOU COMPARED THOSE NUMBERS
TO YOUR NUMBERS---
A. NOW---
Q. ---THEIR DATA COLLECTIONS TO YOUR DATA COLLECTIONS
TO SEE IF -- IF BACKGROUND APPEARS TO BE THE SAME?
A. NOW, AS FAR AS SPECIFIC NUMBERS OF TOTAL
PHOSPHORUS, NO, I HAVEN'T.
Q. UH-HUH (YES).
A. AND ONE REASON THAT IT'S A LITTLE BIT DIFFICULT
RIGHT OFF THE BAT TO COMPARE THEM, WITHOUT
ACTUALLY DOING SOME CALCULATIONS, IS THAT THEY
USED A MUCH DEEPER AND -- SAMPLING INTERVAL AND
PULLED THAT ENTIRE SOIL SAMPLE, I BELIEVE---
Q. UH-HUH (YES).
A. ---WHEREAS, WE DIVIDED THE SOIL UP INTO MUCH FINER
INCREMENTS. FOR INSTANCE, SINCE CHRIS WAS WORKING
DR. QUALLS VOLUME II PAGE 157
WITH THE DATING, HE USED, I THINK -- I BELIEVE IT
WAS TWO CENTIMETER INCREMENTS. AND IN THIS STUDY,
I USED---
Q. LET'S GO TO THE SURFACE WATER. I MEAN, YOU COULD
COMPARE SURFACE WATER, COULDN'T YOU?
A. SURFACE WATER, THAT'S RIGHT, YES.
Q. OKAY. DID DR. REDDY DO SURFACE WATER, ALSO?
A. YES, I BELIEVE SO.
Q. OKAY. COULDN'T YOU COMPARE SURFACE WATER, YOUR
SURFACE WATERS TO HIS SURFACE WATERS?
A. YES, UH-HUH (YES).
Q. HAVE YOU DONE THAT?
A. NO. RIGHT OFF THE BAT, I CAN'T REALLY MAKE ANY
COMPARISON WITHOUT -- I COULD LOOK AT HIS PAPER
RIGHT NOW AND DO IT, THOUGH, IF---
Q. AND WOULD YOU BE ABLE---
A. ---IF YOU HAVE IT HANDY, BUT---
Q. NO, I DON'T HAVE REDDY'S PAPER HANDY. BUT I WAS
JUST -- WHAT I'M TRYING TO GET BACK AT IS THIS
CONCEPT OF, THERE SEEMS TO BE AN ENORMOUS
IMPORTANCE IN ALL OF OUR MINDS---
A. UH-HUH (YES).
Q. ---PLACED ON WHAT IS AN UNENRICHED BACKGROUND
NUMBER.
DR. QUALLS VOLUME II PAGE 158
A. UH-HUH (YES).
Q. AND I REALLY THOUGHT THIS WAS GOING TO BE AN EASY
QUESTION---
A. HUH-UH (NO).
Q. ---I REALLY DID. HAVE YOU COMPARED ANY PORE WATER
NUMBERS FROM DR. REDDY TO YOURS?
A. (NO RESPONSE.)
Q. YOU SAY YOU HAVEN'T COMPARED SURFACE WATER
NUMBERS?
A. NO, NOT SPECIFICALLY.
Q. OKAY. HAVE YOU COMPARED PORE WATER NUMBERS?
A. YES, I BELIEVE I DO REMEMBER LOOKING AT THE PORE
WATER NUMBERS. AND, JUST SUBJECTIVELY, WITHOUT
HAVING MEMORIZED ANY OF THE NUMBERS IN THEIR
STUDY---
Q. I UNDERSTAND.
A. ---I REMEMBER BEING IMPRESSED BY -- THAT THEY WERE
IN THE SAME GENERAL BALLPARK.
Q. OKAY. FOR TOTAL PHOSPHORUS?
A. FOR ORTHOPHOSPHATE.
Q. OKAY. ORTHOPHOSPHATE, OKAY. AND WHAT WERE THOSE,
DO YOU REMEMBER?
A. NOW, IN PORE WATER, LET ME POINT OUT THAT---
Q. ALL RIGHT.
DR. QUALLS VOLUME II PAGE 159
A. ---TOTAL PHOSPHORUS INCLUDES THE SUSPENDED
PARTICLES, AND THAT'S RELATIVELY MEANINGLESS IN
SOIL, BECAUSE AFTER ALL, SOIL IS, YOU KNOW, MADE
UP OF A LOT OF PARTICLES. SO, WHEN WE'RE TALKING
ABOUT PHOSPHORUS IN SOIL WATER, I THINK WE HAVE TO
RESTRICT OURSELVES TO EITHER ORTHOPHOSPHATE, AND
DISSOLVED ORGANIC PHOSPHORUS---
Q. ALL RIGHT, FOR ORTH---
A. ---IT'S A LITTLE BIT DIFFERENT.
Q. OKAY. I'M SORRY. FOR ORTHOPHOSPHATE, WHAT WERE
THE RANGE -- WHAT IS THE RANGE OF NUMBERS THAT
YOU REMEMBER DR. REDDY HAVING, THAT YOU BELIEVE
ARE COMPARABLE TO THE RANGE OF NUMBERS THAT
YOU'RE FINDING AT YOUR UNENRICHED SITES ON THE
GRADIENT?
A. YEAH, WITHOUT LOOKING AT THE REPORT RIGHT NOW, I
CAN'T EVEN---
Q. RIGHT.
A. ---CAN'T EVEN REMEMBER A SPECIFIC NUMBER. I JUST
REMEMBER WHEN I LOOKED AT IT, I WAS IMPRESSED BY
THE FACT THAT THEY SEEMED TO BE IN THE GENERAL
BALLPARK IN SOIL PORE WATER.
Q. SO, WHEN WE LOOK AT THE WRITINGS OF THE VARIOUS
PEOPLE FROM THE DUKE WETLAND CENTER.
DR. QUALLS VOLUME II PAGE 160
A. UH-HUH (YES).
Q. AND THEY'RE TALKING ABOUT UNENRICHED EVERGLADES,
DO YOU BELIEVE THAT THEY MEAN PHOSPHORUS
CONCENTRATIONS OF 28, PLUS OR MINUS 14 MICROGRAMS
PER LITER? IS THAT WHAT YOU THINK?
MR. BURGESS: OBJECT TO THE FORM
OF THE QUESTION.
Q. (BY MS. PONZOLI) YES, OR NO? YOU CAN SAY YES OR
NO, OR YOU CAN -- OR YOU CAN---
A. CAN YOU RESTATE THE QUESTION AGAIN?
Q. WHEN I'M -- WHEN I'M READING UNENRICHED IN THE
EVERGLADES THROUGHOUT THE ANNUAL REPORT---
A. UH-HUH (YES).
Q. ---WHAT DOES IT MEAN?
A. I THINK THROUGHOUT ALL THESE STUDIES, IT'S USED
IN A RELATIVE SENSE, TO STATE THAT IT IS LESS
ENRICHED THAN THE AREAS IN THE NORTHERN END OF
2A. SO---
Q. JUST LESS? ANYTHING LESS WOULD BE UNENRICHED?
THERE MUST BE A RANGE. I MEAN, I KNOW YOU HAVE A
RANGE IN MIND. I'M NOT TRYING TO PIN YOU TO ONE
NUMBER. I -- I'LL ACCEPT -- A RANGE OF NUMBERS
IS PERFECTLY FINE. BUT, I MEAN, IT'S BEEN YEARS
WE'VE BEEN WORKING OUT THERE, TALKING ABOUT
DR. QUALLS VOLUME II PAGE 161
ENRICHED AND UNENRICHED---
A. UH-HUH (YES).
Q. ---AND IF YOU HAVE TO GIVE IT TO ME IN
ORTHOPHOSPHATE, GIVE IT TO ME IN ORTHOPHOSPHATE.
IF YOU WANT TO GIVE IT TO ME IN TOTAL PHOSPHORUS,
OBVIOUSLY, I'M MORE COMFORTABLE IN TOTAL
PHOSPHORUS. BUT THAT'S OKAY---
A. UH-HUH (YES).
Q. ---YOU GIVE IT TO ME HOWEVER YOU CAN. BUT I
BELIEVE THERE MUST BE SOME NUMERICAL BENCHMARK
AGAINST WHICH PEOPLE ARE MENTALLY PINNING THESE
WORDS. ISN'T THAT A REASONABLE ASSUMPTION ON A
READER'S PART?
A. OKAY. NOW, IF WE WANT TO SAY WHAT CONCENTRATIONS
OF ORTHOPHOSPHATE ARE FOUND IN SURFACE WATER, IN
AREAS WHICH WE FEEL ARE PROBABLY NOT UNDER THE
INFLUENCE OF ANY SORT OF PHOSPHORUS COMING OUT OF
THE CANALS, YOU KNOW, I WOULD SAY JUST FROM
COMPARING OUR LOOK AT A6, D6, AND C6, ALL I CAN
REALLY DO IS POINT TO THE DATA, WHICH IS -- WHICH
IS REPORTED ON PAGE 233 -- 232, FIGURE 6-13. AND
OUR MOST REMOTE PLOTS SHOW A RANGE OF, YOU KNOW,
APPROXIMATELY FIVE MICROGRAMS PER LITER, UP TO
OCCASIONALLY A RANGE OF, AS MUCH AS FORTY
DR. QUALLS VOLUME II PAGE 162
MICROGRAMS PER LITER, AND THAT ARBITRARILY IS
WHAT WE'RE CALLING RELATIVELY UNENRICHED, IN
THAT AREA---
Q. WHAT IS THE RELATIVELY---
A. ---BUT, AGAIN, I'LL HAVE TO -- I'LL HAVE TO POINT
OUT THAT THE WORD ENRICHMENT, I KNOW THAT THAT'S
A -- IT'S BEING USED IN A RELATIVE SENSE. AND
THAT DOES NOT IMPLY THAT THAT WOULD BE THE
CONCENTRATION WHERE WE WOULD BEGIN TO GET CHANGES,
SAY, IN THE ALGAL COMMUNITY OR IN THE PLANT
COMMUNITY.
Q. NO, WE'RE NOT TALKING THRESHOLD HERE. IS
THRESHOLD WHAT YOU'RE TALKING ABOUT?
A. RIGHT, I'M TRYING TO SAY THAT THAT'S NOT NEC --
I'M NOT IMPLYING THAT THAT IS ANY SORT OF
THRESHOLD.
Q. NO, I'M NOT ASKING YOU ABOUT---
A. RIGHT.
Q. ---THE THRESHOLD. I HAVEN'T EVEN -- I HAVEN'T
EVEN GOTTEN TO THE HARD QUESTIONS---
A. UH-HUH (YES).
Q. ---I'M TALKING ABOUT THE EASY ONE -- WHAT IS AN
UNENRICHED SITE? AND I GUESS YOU'RE TELLING ME
IT'S ALL RELATIVE, THAT WE DON'T HAVE ANY -- WE
DR. QUALLS VOLUME II PAGE 163
DON'T HAVE ANY BENCHMARKS OUT THERE. IS THAT WHAT
YOU'RE TELLING ME?
A. NO, I HAVE SEEN SOME DATA FROM THE EVERGLADES
NATIONAL PARK---
Q. UH-HUH (YES).
A. ---AT LEAST THAT PART WHICH WAS REPORTED IN THE
SWIM PLAN.
Q. UH-HUH (YES).
A. AND I -- I REMEMBER THAT THEIR APPROXIMATE
CONCENTRATIONS WERE IN THE RANGE OF, SAY, FROM
FIVE TO, YOU KNOW, MORE OR LESS TWENTY MICROGRAMS
PER LITER, BUT -- BUT I CAN'T REMEMBER THE EXACT
NUMBERS, WITHOUT ACTUALLY LOOKING AT THE SWIM
PLAN.
Q. OKAY. SO, AS OPPOSED TO THE FIVE TO FORTY THAT
YOU NORMALLY THINK OF AS RELATIVELY UNENRICHED,
YOU BELIEVE THAT THOSE FIGURES SHOWED FIVE TO
TWENTY MICROGRAMS PER LITER OF ORTHOPHOSPHATE?
A. RIGHT, YEAH---
MR. BURGESS: WELL, OBJECT.
EXCUSE ME---
A. ---AS FAR AS THAT UPPER RANGE, I---
MR. BURGESS: OBJECT -- EXCUSE ME,
DOCTOR. PLEASE STOP. I'VE GOT AN OBJECTION
DR. QUALLS VOLUME II PAGE 164
TO THE FORM OF THAT QUESTION. AND IT'S A
LITTLE BIT CONFUSING, BECAUSE I THINK HE'S
TESTIFIED THAT HE THINKS THERE'S A HISTORICAL
GRADIENT. HE'S BEEN UNABLE TO SAMPLE IN THE
PARK. AND I DON'T WANT HIM TO -- I THINK
YOUR QUESTION WAS UNINTENTIONALLY MISLEADING,
BECAUSE IT'S ASKING HIM WHAT THE BACKGROUND
LEVEL IS WHERE HE'S ALREADY TESTIFIED IT'S
FIVE TO FORTY. AND NOW YOU'RE SAYING, WELL,
IS THAT THE SAME AS THE ONE IN THE PARK? I
JUST WANT TO BE SURE YOU UNDERSTAND THE
QUESTION.
WITNESS: UH-HUH (YES).
MR. BURGESS: AND PLEASE, ASK IT AGAIN,
IF YOU WOULD, OR HE CAN ASK -- ANSWER IT IF
HE UNDERSTANDS IT.
MS. PONZOLI: I THINK YOU MISSTATED HIS
ANSWER. YOU SAID THAT THE BACKGROUND -- YOU
STATED HIS ANSWER HAD BEEN THE BACKGROUND,
FIVE TO FORTY MICROGRAMS PER LITER, AND HE
SAID THAT RELATIVELY UNENRICHED---
MR. BURGESS: RIGHT, I AGREE WITH THAT.
MS. PONZOLI: ---WAS FIVE TO FORTY---
MR. BURGESS: RIGHT.
DR. QUALLS VOLUME II PAGE 165
MS. PONZOLI: ---MICROGRAMS PER LITER.
MR. BURGESS: RIGHT.
WITNESS: RIGHT.
A. YEAH, ALL -- ALL I WAS DOING AT THAT POINT WAS
POINTING OUT WHAT THE GENERAL RANGE OF DATA IS
AT---
Q. OUTSIDE OF EVERGLADES NATIONAL PARK?
A. ---IN WATER CONSERVATION AREA 2A---
Q. OKAY.
A. ---AT THE ENDS OF OUR TRANSECTS, BASICALLY.
Q. OKAY. OKAY, SO THE FIVE TO FORTY IS AT THE ENDS
OF THE TRANSECTS.
A. IN WATER CONSERVATION AREA 2A.
Q. IN 2A.
A. THAT'S RIGHT.
Q. AND I THINK YOU HAVE SAID THAT YOU BELIEVE THAT
THAT IS RELATIVELY COMPARABLE TO 2B DATA THAT YOU
HAVE EITHER PULLED OR SEEN?
A. NO, I WAS BASING THAT NOT ON CONCENTRATIONS OF
PHOSPHORUS IN THE WATER, BUT IN---
Q. I'M SORRY.
A. ---IN THE SOIL---
Q. OKAY.
A. ---WHICH CHRIS CRAFT AND CURT RICHARDSON HAD
DR. QUALLS VOLUME II PAGE 166
SAMPLES, AS PART OF AN EARLIER STUDY, WHICH WAS
REPORTED IN THE FIRST YEAR'S ANNUAL REPORT.
Q. OKAY. SO, THIS FIVE TO FORTY IS IN THE SOIL, IS
THAT RIGHT?
A. NO. I WAS AT THAT POINT TALKING ABOUT
ORTHOPHOSPHATE IN SURFACE WATER. I'M SORRY.
Q. OKAY. OKAY. AND THEN HOW DID WE SLIP TO THE
OTHER? I DON'T KNOW HOW THAT---
A. THAT WAS JUST IN GENERAL A SUBJECTIVE IDEA OF WHAT
WOULD CONSTITUTE THE BACKGROUND LEVEL -- THAT THE
SOIL PHOSPHORUS CONCENTRATION WAS FAIRLY SIMILAR
AT THOSE SITES RELATIVELY FAR AWAY ON THAT
TRANSECT IN WATER CONSERVATION AREA 2A, TO WHAT
WAS FOUND IN WATER CONSERVATION AREA 3. NOW, AS
FAR AS ORTHOPHOSPHATE IN SURFACE WATER, I CAN'T
RECALL WHAT THE CONCENTRATIONS WERE IN WATER
CONSERVATION AREA 3. SO, AT THAT POINT, I WAS
TALKING ABOUT SOIL LEVELS.
Q. AND THAT YOU'RE TALKING ABOUT D6, C6, A5, AND A6?
A. THAT'S RIGHT, YES.
Q. OKAY.
(THEREUPON, MS. PONZOLI AND MR. JONES CONFER.)
Q. (BY MS. PONZOLI) DR. QUALLS, ARE YOU SURE THAT
THE FIVE TO TWENTY MICROGRAMS PER LITER FOR
DR. QUALLS VOLUME II PAGE 167
EVERGLADES NATIONAL PARK, THAT YOU INTENDED TO SAY
THOSE WERE ORTHOPHOSPHATE?
A. I'M NOT SURE WHETHER -- THAT'S PROBABLY -- I THINK
THEY ARE PROBABLY REPORTED AS TOTAL PHOSPHATE---
Q. OKAY.
A. ---AND, BY THE WAY, THOSE NUMBERS, WITHOUT LOOKING
AT THE SWIM PLAN, I CAN'T SAY WHETHER THOSE --
THOSE ARE THE NUMBERS OR NOT. THAT WOULD JUST BE,
IF I WERE FORCED TO GUESS, WITHOUT BEING ABLE TO
LOOK AT THE SWIM PLAN.
Q. RIGHT, I HAVE ONE I COULD GIVE YOU. BUT I -- YOU
KNOW, WE CAN -- IF YOU WANT TO, I'LL DO IT, BUT I
DON'T THINK IT'S THAT NECESSARY. BUT IF YOU -- I
MEAN, I DON'T WANT YOU TO BE UNCOMFORTABLE.
THAT'S NOT THE PURPOSE OF MY QUESTIONS.
A. YEAH. THAT'S JUST A SUBJECTIVE IMPRESSION FROM
HAVING LOOKED THROUGH THE APPENDIX OF THE SWIM
PLAN.
Q. OKAY.
(THEREUPON, MS. PONZOLI AND MR. JONES CONFER.)
Q. (BY MS. PONZOLI) NOW, THAT WE'RE THROUGH WITH THE
EASY PART, WE'LL MOVE ON. I'M NOT PROMISING NOT
TO RETURN TO THAT ONE, DR. QUALLS. I'M TROUBLED.
A. OKAY.
DR. QUALLS VOLUME II PAGE 168
Q. OKAY. STARTING IN YOUR "FORMS OF SOILS PHOSPHORUS
ALONG A NUTRIENT ENRICHMENT GRADIENT IN THE
NORTHERN EVERGLADES," WHICH I BELIEVE IS PRETTY
MUCH CHAPTER EIGHT, YOU TALK IN TERMS OF NATIVE
PHOSPHORUS AND ADDED PHOSPHORUS, STORED OVER THE
PAST THIRTY YEARS, AND I'D LIKE TO KNOW WHAT YOU
MEAN BY NATIVE PHOSPHORUS.
MS. PONZOLI: PARDON? YEAH, YOU CAN
WORK ON THE EXHIBITS. YOU HAVE A COPY OF</