DR. RICHARDSON VOLUME III PAGE 1634 (THEREUPON, A BREAK WAS TAKEN FROM 11:53 A.M. TO 1:30 P.M.) EXAMINATION BY MR. REID CONTINUES: Q. DR. RICHARDSON, YESTERDAY WE HAD A COUPLE THINGS THAT YOU WERE GOING TO TRY TO RESEARCH FOR ME, ONE OF WHICH WAS SOME OF THE HISTORY OF THESE THREE NEW CORES THAT SOMEBODY CONNECTED WITH DUKE DID. DID YOU HAPPEN TO HAVE A CHANCE TO CHECK THAT? A. I DID. I WENT BACK AND HAD A CHANCE TO CHAT WITH DR. CRAFT. Q. CAN YOU GIVE ME THE STATUS OR SOME INFORMATION ABOUT THOSE CORES? A. RIGHT. I WAS A LITTLE BIT IN ERROR YESTERDAY AS TO THE EXACT TIMES. AS YOU REMEMBER, I COULDN'T QUITE REMEMBER. BUT DR. CRAFT -- AS I TOLD YOU EARLIER, WE HAD HAD THIS CONVERSATION, AND HE -- HE THOUGHT THAT WE HAD TURNED THESE OVER AT MY LAST DEPOSITION, BECAUSE THEY WERE IN THIS FILE THAT WAS STAMPED. I THINK IT -- IN FACT, HAD A MARKER ON THE FOLDER. BUT WHEN WE WENT BACK AND LOOKED AT THE DATES, HE -- HE DOESN'T KNOW WHETHER WE TURNED OVER THE FINAL ANALYSIS. WHAT HE DOES KNOW IS -- HE DOESN'T KNOW -- HE THINKS WE TURNED OVER SOME OF THE PRELIMINARY INFORMATION. OKAY, THAT -- SO, I CAN'T ATTEST TO DR. RICHARDSON VOLUME III PAGE 1635 WHETHER WE GAVE YOU THE FINAL NUMBERS AT DEPOSITION, AND I DON'T THINK WE DID -- WELL, I KNOW WE DIDN'T, ACTUALLY, BECAUSE THE DATES ON THOSE CORES -- WHEN HE PRINTS THEM OUT, THEY HAVE A DATE AT THE TOP, AND THEY -- THEY WERE, I -- I CAN'T REMEMBER EXACTLY, BUT IT WAS LIKE FEBRUARY 28TH OR SOMETHING LIKE THAT ON IT. AND I WOULD NOT -- THAT WAS WHEN HE COMPLETED THEM, AND I WOULD NOT HAVE GOTTEN THEM UNTIL MARCH, SOMETIME IN MARCH OF THAT -- I DON'T REMEMBER--- Q. WHEN WERE THE CORES ACTUALLY TAKEN, DO YOU KNOW? A. NO, I DID NOT ASK HIM THAT. THEY WERE TAKEN -- LET'S SEE, THAT WOULD BE FEBRUARY OF '93. THEY WOULD HAVE BEEN TAKEN THE SUMMER, SOMETIME -- THE SUMMER, MAYBE LATE FALL, OF '93, I THINK, WOULD BE MY BEST ESTIMATE. I HAVE TO GO BACK AND -- I DON'T REMEMBER -- IT DOESN'T SAY ON THE PRINTOUT WHEN THE ANALYSIS DONE, IT'S WHEN THEY WERE ACTUALLY TAKEN. MR. GREEN: WOULD YOU REPEAT THAT LAST ANSWER? MR. REID: YOU MEAN 1992? YOU SAID '93, BUT YOU MEANT '92, I ASSUME. WITNESS: '92. I'M -- YES. I'M SORRY. Q. (BY MR. REID) SO, THEY WERE TAKEN IN THE DR. RICHARDSON VOLUME III PAGE 1636 SUMMER TO LATE FALL OF '92. NOW, WHAT HAPPENED IN FEBRUARY OF '93? A. THAT'S WHEN HE COMPLETED THE ANALYSIS TO ACTUALLY HAVE A -- THAT'S WHAT IT SHOWS ON THE EXCELL PRINTOUT SHEET. THAT'S WHEN THE -- THE FINAL CALCULATIONS, ALL THIS STUFF WAS DONE, I THINK IT WAS LITERALLY THE LAST DAY OF FEBRUARY '93, WAS WHEN THEY WERE DONE. AND I DID NOT GET THEM IMMEDIATELY, MY RECOLLECTION IS. AND THAT'S HIS, TOO, THAT HE FINISHED THEM -- WELL, AMONG OTHER CORES -- HE'S BEEN WORKING ON ALL KINDS OF THINGS -- THESE WERE JUST MORE CORES THAT WE TOOK. AND THAT I WOULD HAVE GOTTEN THEM, OBVIOUSLY, SOMETIME IN MARCH OF '93, SO THAT WOULD BE AFTER MY DEPOSITION, WHICH I BELIEVE WAS IN JANUARY OF '93. Q. OKAY. THERE WAS SOMETHING ELSE YOU WERE GOING TO CHECK ON FOR ME. DO YOU REMEMBER WHAT THAT WAS? A. NO. Q. IT WILL COME BACK TO ME IN A MINUTE. A. DOCUMENTS, I WENT -- I ACTUALLY WENT BACK TO THE CENTER, AND I GOT SOME -- WE DON'T HAVE MANY OF THE -- WE'VE GIVEN OUT FOUR HUNDRED OF THESE REPORTS. IN FACT, I ONLY HAVE ONE COPY OF THE -- A LOT OF THE '91'S -- I ONLY HAVE ONE OF THE '92, SO. Q. WOULD THE -- ANY OF THE DATA RELATING TO THESE DR. RICHARDSON VOLUME III PAGE 1637 THREE NEW CORES HAVE BEEN INCLUDED IN WHAT WAS PRODUCED FOR THIS DEPOSITION? A. YES, I TURNED -- I TURNED--- Q. AND WHAT WOULD IT LOOK LIKE? HOW WOULD I FIND IT TO IDENTIFY THAT IT WOULD BE THESE THREE CORES? A. I THINK THEY'RE EXCELL -- EXCELL SHEETS, AND AS I WAS MENTIONING THE OTHER DAY, I BELIEVE IT SAYS ON THEM A1/2, D1/2 AND C1/2. Q. OKAY. OKAY. A. THAT'S MY RECOLLECTION. Q. WELL, I'LL LOOK AND SEE IF I CAN FIND THEM. YESTERDAY YOU TOLD ME THAT AT ONE OF THE MEETINGS YOU'D HAD WITH THE LAWYERS, YOU WERE ASKED TO COLLECT YOUR THOUGHTS AND BEGIN PUTTING TOGETHER SOME THOUGHTS ABOUT YOUR OPINIONS. DO YOU RECALL THAT? A. UH-HUH (YES)--- Q. ALL RIGHT. A. ---YES. Q. NOW, HAVE YOU DONE THAT? A. WELL, THAT'S WHAT I THOUGHT WE'D BEEN DOING THIS MORNING. THAT'S WHAT--- Q. SO, WHAT YOU'VE BEEN TELLING ME IS THE PRODUCT OF THAT EXERCISE? MR. BURGESS: OBJECT TO THE FORM. DR. RICHARDSON VOLUME III PAGE 1638 A. WELL, I WASN'T GIVEN ANY SPECIFIC DIRECTIONS EXCEPT TO ESSENTIALLY TAKE -- TAKE MY PARTICULAR RESEARCH WHERE IT WAS AT THE STAGE AND WHAT I HAVE BEEN WORKING ON AND TRY TO PULL TOGETHER SOME THOUGHTS THAT WERE APPROPRIATE AS IT RELATES TO THE SWIM CHALLENGE. Q. DO YOU HAVE ANY ADDITIONAL THOUGHTS THAT YOU HAVEN'T DISCLOSED TO ME AT THIS POINT, IN THE FORM OF OPINIONS OR OTHERWISE? MR. BURGESS: OBJECT TO FORM. A. ANY ADDITIONAL THOUGHTS. PROBABLY LOTS OF THOUGHTS. Q. AS PART OF THIS PROCESS THAT YOU'RE GOING THROUGH. A. WELL, I GUESS ONE OF THE THOUGHTS THAT I HAVE RELATED TO THE EVERGLADES ITSELF RELATES TO THE CURRENT STATUS AND HEALTH OF THE EVERGLADES. Q. OKAY. TELL ME WHAT OPINIONS YOU HAVE ABOUT THE CURRENT STATUS AND HEALTH OF THE EVERGLADES. A. WELL, JUST SO WE -- WE'RE CLARIFYING -- AND I THINK WE TOUCHED A LITTLE BIT OF IT THIS MORNING AND SOME OF THE ASPECTS. AS I SAID, IT'S -- IT'S A -- IT'S AN ALTERED WETLAND ECOSYSTEM THAT IS MANAGED -- THE WATER -- WHOSE WATER MANAGEMENT REGIME IS NOT MANAGED TO OPTIMIZE WETLAND FUNCTIONS. IT'S BASICALLY -- THE DR. RICHARDSON VOLUME III PAGE 1639 SYSTEM WAS PUT IN PLACE, I REALIZE, BY LAW FOR OTHER PURPOSES. AND, SO, IT'S A STRESSED ECOSYSTEM THAT HAS HAD ITS HYDROLOGY, HYDROPERIOD, QUANTITY OF WATER SERIOUSLY ALTERED, AND HAS REACHED SORT OF A NEW BASELINE FROM WHAT IT ONCE WAS; ALBEIT, IT IS STILL FUNCTIONING AS AN EVERGLADES ECOSYSTEM; THERE ARE LARGE PORTIONS OF IT STILL FUNCTIONING AS AN EVERGLADES AND, IN MY OPINION, WILL CONTINUE TO FUNCTION AS AN EVERGLADES ECOSYSTEM, ALBEIT AT A DIFFERENT BASELINE OR -- OR, OBVIOUSLY, DIFFERENT THAN IT DID SORT OF IN PRE-DISTURBANCE TIMES. SO, WE HAVE AN ECOSYSTEM THAT IS A WETLAND ECOSYSTEM WITH A DRASTICALLY REDUCED HYDROPERIOD. BUT ALBEIT THAT, SINCE A NUMBER OF THE SPECIES, BUT NOT ALL OF THEM, ARE ABLE TO MAINTAIN NORMAL -- WITHIN THE BOUNDS -- SOME NORMALCY OF A WETLAND FUNCTION, ALBEIT THEY'VE BEEN STRESSED AMAZINGLY HARD DUE TO EXTREME DRY PERIODS AND EXTREME WET PERIODS. BUT I WOULD SAY THAT UNDER THE PRESENT CONDITIONS AS THERE, IT IS GOING TO EXIST. I HEAR STATEMENTS THAT THE EVERGLADES IS GOING TO CEASE TO EXIST IN FIVE YEARS OR TEN YEARS. AND I'VE HEARD THIS -- EVERYTHING FROM DAN RATHER'S SHOW, TO A NUMBER OF ENVIRONMENTALISTS, TO A NUMBER OF PEOPLE. AND IT'S MY OPINION, AS A WETLANDS ECOLOGIST, THAT THE DR. RICHARDSON VOLUME III PAGE 1640 EVERGLADES WILL CONTINUE TO EXIST LONG AFTER WE'RE DEAD AND GONE AND THAT WE HAVE SOME TIME TO, BASICALLY, SOLVE THIS PROBLEM CORRECTLY. Q. WHAT DO YOU CONSIDER MAKES UP THE -- WHAT YOU CALL THE EVERGLADES ECOSYSTEM? A. WHAT MAKES UP THE EVERGLADES ECOSYSTEM? Q. YEAH. A. ARE YOU ASKING ECOLOGICALLY, OR--- Q. AS AN ECOLOGIST, YEAH. A. WELL, WHAT THE -- THE REMAINING PORTIONS OF THE EVERGLADES -- THERE'S THE EVERGLADES PARK, WATER CONSERVATION AREA 3, WATER CONSERVATION AREA 2, WATER CONSERVATION AREA 1. Q. I MEANT WHAT COMPONENTS MAKE UP THE -- WHAT YOU WOULD CONSIDER TO BE PART OF THE EVERGLADES ECOSYSTEM. A. WHAT COMPONENTS? MR. BURGESS: OBJECTION TO FORM. Q. WELL, LIKE THE SOILS; YOU'D CONSIDER THAT PART OF THE ECOSYSTEM? A. I WOULD CONSIDER SOILS PART OF THE ECOSYSTEM. Q. THE WATER? A. I WOULD CONSIDER THE WATER. Q. THE VARIOUS TROPHIC LEVELS THAT EXIST? DR. RICHARDSON VOLUME III PAGE 1641 A. THE TROPHIC LEVELS, THE SPEC -- THE PLANTS AND ANIMALS THAT EXIST. Q. WOULD YOU CONSIDER THE MACROINVERTEBRATES PART--- A. I WOULD CONSIDER THE MACROINVERTEBRATES. Q. ---OF THE EVERGLADES ECOSYSTEM? A. I WOULD. Q. AND THE PERIPHYTON? A. I WOULD. Q. ALGAL MATS AND OTHER ALGAL COMMUNITIES? A. YES, ALBEIT THEY'RE NOT -- THEY'RE NOT IDENTICAL FROM STEM TO STERN. IN OTHER WORDS, THERE ARE VARIATIONS IN THAT--- Q. SURE. A. ---FROM THE NORTH TO THE SOUTH, BUT TO THE DEGREE THAT THEY VARY WITHIN THAT SYSTEM, YES, THEY'RE INTEGRAL PARTS OF THAT SYSTEM. Q. YOU SAID THAT THE EVERGLADES SYSTEM WAS STRESSED HYDROLOGICALLY. A. YES. Q. IS IT STRESSED IN ANY OTHER MANNER? A. WELL, IT'S STRESSED -- IT HAS BEEN STRESSED. I MEAN, THAT'S -- THE EVERGLADES IS -- IS, AS I MENTIONED EARLIER, ONE OF THE MOST STRESSFUL DR. RICHARDSON VOLUME III PAGE 1642 ENVIRONMENTS FOR ORGANISMS TO HAVE EVOLVED IN. FOR EXAMPLE, THE TEMPERATURES IN THE SUMMERTIME GO UP TO FORTY DEGREES CENTIGRADE IN THE WATER; THERE'S VERY LOW OXYGEN CONCENTRATION AT CERTAIN TIMES OF THE DAY IN THE WATER COLUMNS UNDER NATURAL CONDITIONS; AMAZING AMOUNTS OF FIRE; THERE ARE DROUGHT CONDITIONS; EXTREME HEAT. SO, WHILE ALL ECOSYSTEMS ARE STRESSED, THE EVERGLADES HAS BEEN -- HAS EVOLVED AS A SYSTEM THAT IS QUITE STRESSED; AND ON TOP OF THAT, WE OVERLAY -- NOW, WE GET TO THOSE SORT OF MAN-INDUCED STRESSORS. WE HAVE -- I THINK I PUT TOGETHER IN MY REPORT, SORT OF A SIX-PART MODEL THAT BASICALLY DESCRIBES THE COMPONENTS THAT CONTROL THE ECOLOGY OF THE EVERGLADES. Q. IT'S STRESSED BY HYDROPERIOD; I THINK YOU SAID "DRASTICALLY REDUCED HYDROPERIOD"? A. IN SOME PLACES, REDUCED; IN SOME PLACES, ELEVATED; IN SOME PLACES, THE QUANTITY OF WATER; IN SOME PLACES, THE PULSING OF WATER; SOME PLACES, THE FUNNELING OF WATER. ALL OF THOSE. Q. OKAY. AND, NOW, THE ONE THING YOU HAVEN'T MENTIONED IS NUTRIENTS. IS IT STRESSED BY NUTRIENTS? A. IN SOME PLACES, IT IS STRESSED BY NUTRIENTS. Q. WHERE? A. AND I -- I WILL REPHRASE THAT IN ONE SENSE. I DR. RICHARDSON VOLUME III PAGE 1643 DON'T CONSIDER ALL NUTRIENTS TO BE STRESSFUL, FOR EXAMPLE, BUT THERE'S A POSSIBILITY, FOR EXAMPLE, THAT SOME OF THE SODIUM ADDITIONS TO THE NORTHERN END OF 2A, WHICH ARE ELEVATED, MAY CAUSE A STRESS ON SOME SPECIES. Q. WELL, LET'S LIMIT IT TO PHOSPHOROUS. IS IT STRESSED BY PHOSPHOROUS? A. I DON'T WANT TO USE THE TERM "STRESSED BY PHOSPHOROUS." PHOSPHOROUS IS -- IS NOT A -- THE LEVELS I SEE, I DON'T SEE AS STRESSED. Q. WELL, THEN, A MINUTE AGO WHEN YOU SAID IT IS STRESSED BY NUTRIENTS IN SOME PLACES, WHAT NUTRIENTS ARE STRESSING IT? A. WELL, ALTHOUGH IT'S NOT MAYBE AS ESSENTIAL AN ISSUE, AS I MENTIONED, SODIUM COULD BE A POSSIBILITY. Q. SODIUM IS STRESSING THE EVERGLADES? A. IN--- Q. WHERE? A. ---SOME PLACES, IT COULD--- Q. WHERE? A. IN 2A -- THE NORTHERN PART OF 2A, THERE'S ELEVATED SODIUM LEVELS THAT WE SEE. Q. WHAT'S THE IMPACT OF THIS ELEVATION OR STRESS CAUSED BY SODIUM LEVELS? A. WELL, IT COULD BE THE REMOVAL OR WEAKENING OF DR. RICHARDSON VOLUME III PAGE 1644 SOME OF THE SPECIES MAY NOT BE ABLE TO SURVIVE UNDER HIGHER SODIUM LEVELS. Q. CAN YOU GIVE ME SOME EXAMPLES? A. WELL, I THINK SOME SPECIES OR SOME -- OR, I THINK SOME OF THE ECO TYPES OF SAWGRASS THAT EXIST THERE MAY NOT BE ABLE TO WITHSTAND HIGH SODIUM LEVELS. SOME OF THE ALGAL SPECIES MAY BE AFFECTED BY THIS, AND SOME OF THE MACROPHYTES. IT'S A POSSIBILITY SOME OF THE -- ESPECIALLY SOME OF THE FLOATING AQUATICS WOULD BE AFFECTED BY SODIUM, FOR EXAMPLE. Q. SOME OF THE WHAT? A. FLOATING AQUATICS. Q. AND THIS WOULD ALL BE IN THE NORTHERN PART OF 2A? A. WELL, THAT'S THE ONE PLACE THAT I'VE STUDIED IN GREAT DETAIL, BUT I SEE WHAT'S COMING THROUGH THE GATES AND CANALS THERE. THERE ARE MANY OTHER THINGS BESIDES PHOSPHOROUS; THAT'S MY POINT I'M TRYING TO MAKE. Q. WELL, WE'RE TALKING ABOUT SODIUM RIGHT NOW. A. I KNOW. BUT, AS I SAY, THERE ARE LOTS OF OTHER THINGS BESIDES PHOSPHOROUS. THERE ARE SODIUM AND CALCIUM AND CHLORIDES AND SULFATES--- Q. WELL, LET'S -- LET'S JUST LIMIT IT TO SODIUM, DR. RICHARDSON VOLUME III PAGE 1645 AND THEN WE'LL TALK ABOUT THOSE OTHERS IN TURN. ANY OTHER EFFECTS OR IMPACTS OF THE STRESS CAUSED BY SODIUM TO THE NORTHERN PORTION OF 2A IN THE EVERGLADES? A. WELL, SODIUM -- HIGHER CONCENTRATIONS OF SODIUM CAN CAUSE SOIL STRUCTURE TO DECREASE. IN TERMS OF THE STRUCTURE OF THE SOIL, THE POSITIVE IONS IN THE SOIL CAN CAUSE THE SOIL TO -- WHEN WE HAVE POSITIVE CHARGES, LARGE NUMBERS OF POSITIVE CHARGES BOUND TO PARTICLES, THEY HAVE A TENDENCY TO REPEL EACH OTHER, WHICH CREATES A VERY UNSTRUCTURED SOIL BY COMPARISON. Q. THAT'S HAPPENING IN THE NORTHERN PART OF 2A? A. THERE ARE PARTS OF IT WHERE THE SOILS ARE VERY -- THEY ARE LOOSER THAN SOME OF THE OTHER SOILS YOU SEE WHICH MAY BE THE CASE. Q. AND WHAT'S THE PRACTICAL EFFECT OF THIS STRESS? A. WELL, IT DOESN'T -- FOR EXAMPLE, IN THIS CASE, IF IT'S PEAT, IT DOESN'T MAKE A STRUCTURE TO PEAT AS YOU MIGHT HAVE; BUT THE MAJOR EFFECT MAY BE THAT THE ROOTS OF CERTAIN SPECIES ARE EXPOSED TO HIGHER SODIUM LEVELS THAN NORMAL. Q. OKAY. WHAT IS THE NEXT NUTRIENT THAT YOU HAD IN MIND WHEN YOU SAID THAT SOME PLACES IN THE EVERGLADES ARE STRESSED BY NUTRIENTS? DR. RICHARDSON VOLUME III PAGE 1646 A. WELL, I SAY STRESSED OR ALTERED, I MEAN--- Q. WELL, DO YOU CONSIDER THOSE TWO TO BE THE SAME THING? A. NOT QUITE. Q. OKAY. WELL, LET'S TALK ABOUT STRESS. A. STRESSED -- THERE ARE SOME -- I'D HAVE TO GO BACK AND LOOK AT MY REPORT, BUT I THINK THERE ARE SOME METALS AND THINGS THAT ARE -- THAT ARE FOUND IN THE SOILS IN THE GLADES. Q. ANY PARTICULAR METALS? A. I'D HAVE TO GO BACK AND -- THERE MAY BE SOME TRACE ELEMENTS AND--- Q. OF WHAT? A. I'M TRYING TO THINK -- JUST GIVE ME A MINUTE. Q. OH, I'M SORRY. A. WELL, THERE ARE THINGS LIKE SULPHATE, FOR EXAMPLE, THAT -- THAT ARE PLACED THROUGH SOME OF THOSE GATES, WHICH ARE -- WHICH ARE AT ELEVATED LEVELS. Q. AND IS THIS, AGAIN, IN THE NORTHERN PART OF 2A? A. CORRECT. Q. DOES THIS AREA OF NUTRIENT STRESS EXTEND TO AN IDENTIFIABLE POINT IN 2A? A. YES, FOR THE SODIUM, I CAN SAY THAT. DR. RICHARDSON VOLUME III PAGE 1647 Q. AND TO WHERE -- TO WHAT POINT DOES THE SODIUM STRESS EXIST? A. IT -- MY RECOLLECTION IS IT COMES DOWN TO -- I'D HAVE TO DO IT POINT BY POINT, BUT WE -- WE ACTUALLY MENTION THAT IN THE LAST ARTICLE THAT DR. CRAFT AND I WROTE. I'D HAVE TO JUST BE GUESSING UNLESS I LOOKED AT THAT, BUT I THINK IT'S FOUR TO FIVE KILOMETERS, SOMEWHERE IN THAT REGION. Q. THAT WOULD BE THE SODIUM? A. YEAH. IT CLOSELY -- CLOSELY MATCHES THE CATTAIL ZONE, THE MAJORITY OF THE CATTAIL ZONE. Q. OKAY. YOU SAID YOU FOUND -- WE WERE TALKING ABOUT METALS, AND YOU SAID IN SOIL THERE WAS -- THERE WERE SULFATES THAT YOU BELIEVE WERE STRESSING THE NORTHERN PART OF 2A? A. OR I SAID ALTERING. YOU KNOW, THEY ARE TWO DIFF--- Q. WELL, NO, YOU SAID STRESSING, AND, THEN, YOU SAID STRESSING OR ALTERING, AND THEN YOU SAID YOU DIDN'T THINK THOSE TWO MEANT THE SAME THING. WHAT DO YOU MEAN BY STRESS? WE'LL CLEAR IT UP. A. STRESS CAN RESULT IN THE REDUCTION OF A NORMAL FUNCTION OF AN ORGANISM. IT CAN BE PRODUCTION, IT CAN BE REPRODUCTION, IT CAN BE SURVIVAL. IT DEPENDS -- DR. RICHARDSON VOLUME III PAGE 1648 THERE ARE VARIOUS TYPES OF STRESSES. REDUCED PHYSIOLOGICAL FUNCTION. Q. AND WHAT IS ALTERED? A. WELL, ALTERED IS A TERM THAT COULD BE USED AS SIMPLY CHANGE THE PATTERNS OF OR THE RATES BUT MAY NOT RESULT IN -- THEY COULD BE UP OR DOWN. IN OTHER WORDS, THEY COULD BE INCREASED. CERTAIN ASPECTS COULD BE INCREASED. Q. OKAY. NOW, THE METALS. WE WERE -- JUST TO REMIND YOU, WE WERE TALKING ABOUT THE VARIOUS NUTRIENTS THAT YOU BELIEVE ARE STRESSING THE EVERGLADES. A. WELL, I -- AS A GENERAL RULE, I WOULDN'T SAY NUTRIENTS ARE STRESSING. AS I MENTIONED TO YOU, SODIUM IS NOT REALLY A -- IT WOULD BE CONSIDERED AS SORT OF A MINOR NUTRIENT. IT'S NOT A MAJOR NUTRIENT, LIKE NITROGEN AND PHOSPHOROUS AND POTASSIUM AND CALCIUM. SODIUM -- LESSER AMOUNTS OF A NUTRIENTS AREA. I'M TRYING TO BE CLEAR HERE SO YOU'LL--- Q. LET ME -- LET ME ASK--- A. ---MAYBE IF I SAY OTHER IONS, THAT WOULD BE CLEAR. Q. ---LET ME ASK THIS QUESTION. DO YOU BELIEVE -- STRIKE THAT. WE WERE TALKING ABOUT -- WELL, STRIKE THAT. I'LL START -- I'LL GET IT RIGHT THIS DR. RICHARDSON VOLUME III PAGE 1649 TIME. YOU TESTIFIED EARLIER THAT THIS ECOSYSTEM WAS BEING STRESSED DUE TO A DRASTICALLY-REDUCED HYDROPERIOD, AND THEN YOU ALSO SAID, "AND SOME OTHER HYDROLOGICAL FACTORS." A. OR INCREASED HYDROPERIOD IN SOME PLACES, YES. Q. I THEN ASKED YOU WHAT OTHER THINGS ARE STRESSING, SUCH AS NUTRIENTS, AND YOU SAID THAT IT WAS BEING -- THE EVERGLADES WAS BEING STRESSED BY NUTRIENTS IN SOME PLACES; AND I ASKED, "WHAT NUTRIENTS ARE YOU TALKING ABOUT?" AND YOU TOLD ME SODIUM. A. THAT'S CORRECT. Q. AND THEN YOU TOLD ME SOME METALS. SPECIFICALLY, YOU MENTIONED SULFATES. A. WELL, THEY -- THAT WOULDN'T BE A METAL. THAT WOULD BE AN ANION. Q. AND, SO, MY QUESTION NOW IS, WHAT OTHER NUTRIENTS DO YOU BELIEVE ARE STRESSING THE EVERGLADES AT ANY POINT, IF THERE ARE ANY? A. WELL, I'M TRYING TO THINK NOW WHAT I WOULD PUT INTO -- NOW THAT WE ARE CAREFULLY DEFINING THIS, WHAT DO I PUT INTO THAT. I WOULD SAY RIGHT NOW WITH THE EVIDENCE I HAVE -- I'D HAVE TO GO BACK AND LOOK AT THE ANNUAL REPORT -- BUT I WOULD SAY SODIUM WOULD BE THE -- POTENTIALLY, ONE OF THE HIGHER STRESSORS OR THE MAJOR DR. RICHARDSON VOLUME III PAGE 1650 STRESSOR THAT I HAVE INFORMATION ON AT THE MOMENT. Q. SO, IS IT FAIR TO SAY AS YOU SIT HERE RIGHT NOW, YOU CAN'T THINK OF ANY OTHER NUTRIENTS THAT ARE STRESSING THE EVERGLADES SYSTEM? A. ONLY IN THE SENSE THAT SOMETIMES THE LACK OF NUTRIENT CAN BE SOMETIMES REFERRED TO AS A STRESS, IN A SENSE, OR A LIMITING NUTRIENT. Q. OKAY. WELL, LET'S -- WE'LL PUT -- WE'LL GET TO THAT NEXT, BUT I'M NOW TALKING ABOUT ANY NUTRIENTS THAT ARE COMING INTO THE SYSTEM WHICH YOU BELIEVE ARE CREATING STRESS, AS YOU DEFINED IT. CAN YOU THINK AS YOU SIT HERE OF ANY OTHER NUTRIENTS? A. THE POSSIBILITY THAT HIGH AMMONIA LEVELS--- Q. WHERE WOULD THAT BE? A. THERE ARE SOME -- SOME AMMONIA LEVELS THAT ARE QUITE HIGH IN -- IN THE NORTHERN PART OF 2A, THOUGH WE -- WE HAVE FAIRLY HIGH NITROGEN LEVELS THROUGHOUT THE WHOLE GLADES, BUT--- Q. DO YOU BELIEVE THAT IT'S BEING STRESSED BY THAT NITROGEN? A. I'M NOT SURE OF THAT. I HAVE NO -- I HAVEN'T REALLY -- I'M SAYING THAT THEY'RE EXTREMELY HIGH, THAT THERE COULD BE SOME ORGANISMS THAT COULD BE AFFECTED BY IT, BUT I DON'T HAVE ANY DIRECT EVIDENCE OF THAT AT THE DR. RICHARDSON VOLUME III PAGE 1651 MOMENT. Q. ALL RIGHT. ANY OTHER NUTRIENTS? A. I THINK THAT WOULD COVER IT. Q. OKAY. NOW, WHO IS RESPONSIBLE, OR WHAT IS RESPONSIBLE FOR THE SODIUM THAT IS COMING INTO THE EVERGLADES THROUGH THE CANALS? A. THAT'S A GOOD QUESTION. MR. REID: THAT'S WHY I ASKED IT. I ONLY ASK GOOD QUESTIONS. MR. GREEN: I'LL OBJECT TO THE FORM OF THAT. YOU CAN GO AHEAD AND ANSWER. MR. REID: I WAS GOING TO SAY -- I THOUGHT THERE'D BE -- CAN'T GET A RISE OUT OF THESE GUYS AFTER LUNCH. MR. GREEN: YOU JUST WANTED TO SEE IF I WAS AWAKE. MR. REID: THAT'S RIGHT. GO AHEAD. WITNESS: DEPENDS ON HOW HEAVY A LUNCH YOU HAD. MR. REID: YEAH. A. THE SODIUM -- AND WE LOOKED AT THE SODIUM AND SODIUM CHLORIDE -- PROBABLY THERE ARE SEVERAL POTENTIAL SOURCES. ONE COULD BE THE DEEP-CUT CANALS WHICH COULD BE SOME OF THE -- THE RESULT OF SOME OF THE ANCIENT DR. RICHARDSON VOLUME III PAGE 1652 MARINE SALTS, FOR EXAMPLE, COULD BE COMING UP THROUGH THAT -- THAT ZONE. Q. BY "CANALS," YOU MEAN THE CANALS THAT WERE PUT IN AS PART OF THE PROJECT? A. CORRECT. Q. AND YOU'RE SAYING THAT THE -- SOME OF THE -- FROM EARLY -- PREVIOUS ERAS--- A. RIGHT. THERE COULD BE SOME CONTRIBUTIONS FROM THAT. IN FACT, I BELIEVE THERE'S -- I'VE READ SOME EVIDENCE, IN FACT, THAT IS THE CASE FOR SOME OF THE -- I THINK I'VE SEEN SOME USGS REPORTS AND THAT THERE IS SOME EVIDENCE FOR THAT IN CERTAIN LOCATIONS. THERE COULD BE SOME -- WELL, THERE'S DEFINITELY SOME IN ALL THE WATER THAT'S MOVING THROUGH THE CANAL, SO--- Q. IS THERE ANY THAT YOU WOULD ATTRIBUTE TO FARMING? A. I HAVEN'T STUDIED THE FARM DIRECTLY IN TERMS OF THAT. I HAVEN'T LOOKED AT IT. Q. WELL, DO YOU KNOW WHETHER OR NOT SODIUM WOULD COME FROM FARMING? A. I THINK IT'S POSSIBLE. Q. IN WHAT FORM WOULD THAT TAKE -- WHAT FORM WOULD THAT TAKE? A. SODIUM ION. DR. RICHARDSON VOLUME III PAGE 1653 Q. WOULD THAT BE PART OF FERTILIZER THAT WOULD BE ADDED TO THE CROPS, OR SOME OTHER SOURCE? A. I DON'T THINK THEY WOULD -- NO ONE WOULD -- NO ONE WOULD ADD SODIUM AS A FERTILIZER. THAT WOULD BE--- Q. NO, I MEANT WOULD IT BE A COMPONENT OF FERTILIZER, PERHAPS? A. I WOULDN'T THINK THEY WOULD USE THE SODIUM FORM OF FERTILIZER. THAT WOULDN'T REALLY MAKE--- Q. OKAY. SO, HOW WOULD -- HOW COULD IT POSSIBLY BE CONNECTED WITH AGRICULTURE, THEN? A. WELL, IF THERE WAS SOME NATIVE SODIUM IN THE SYSTEM ITSELF AND YOU HAD OXIDATION, THERE COULD BE SOME REMOVAL THERE, ALTHOUGH THE ORGANIC SOILS IN THE EAA -- SODIUM IS -- CAN BE BOUND TO THE ORGANIC MATTER. IF IT WAS HOOKED ON THAT, I GUESS IT COULD MOVE THROUGH THAT. IT COULD BE COMING FROM VIA THE LAKE. IT COULD BE -- IT COULD BE A NUMBER OF PLACES. I'M REALLY NOT QUALIFIED TO -- AT THIS STAGE, I HAVE NOT LOOKED AT THE WATER QUALITY DATA TO SAY. Q. WHERE WOULD THE SULFATES BE COMING FROM? A. WELL, YOU COULD HAVE -- ALSO, FROM THE MARINE WATER, YOU COULD HAVE SULFATES COMING -- YOU COULD HAVE SOME COMING FROM THE DEEPER DEPOSITS OF THAT. Q. HOW ABOUT AGRICULTURE? DR. RICHARDSON VOLUME III PAGE 1654 A. YOU COULD HAVE SOME COMING FROM AGRICULTURALLY. Q. SO, THE SOURCES COULD BE -- WOULD BE SOMEWHERE TO THE SODIUM SOURCES? A. CORRECT. I JUST HAVEN'T QUANTIFIED IT, SO I--- Q. WHAT ABOUT THE METALS; WHAT WOULD THE SOURCE BE OF THOSE? A. WELL, SOME OF THE METALS, I MEAN, IRON AND ALUMINUM AND MAGNESIUM AND CALCIUM AND SO FORTH, I THINK SOME OF THOSE WOULD BE IN THE RAINWATER, WOULD BE IN THE CANAL WATER, WOULD BE IN THE LAKE WATER, AND THERE WOULD BE SOME COMING OFF THE FARMLAND -- ESPECIALLY THE CALCIUM. I THINK THERE'S A FAIR AMOUNT OF CALCIUM THAT COMES OFF IN SOME OF THAT LAND. Q. NOW, DO YOU BELIEVE THAT PHOSPHOROUS IS STRESSING THE EVERGLADES? A. I WOULDN'T DEFINE IT AS A STRESS. Q. OKAY. SO, IT'S FAIR TO SAY, THEN, THAT YOU BELIEVE SODIUM IS HAVING MORE OF A NEGATIVE IMPACT ON THE EVERGLADES THAN PHOSPHOROUS? MR. BURGESS: OBJECT TO FORM. A. IN A LOCALIZED REGION WHERE WE SEE THAT, I SAID IT IS MORE LIKELY TO BE PUT IN THE STRESSOR DR. RICHARDSON VOLUME III PAGE 1655 CATEGORY THAN IT WOULD PHOSPHOROUS. PHOSPHOROUS IS GENERALLY NOT CONSIDERED A STRESSOR TO ORGANISMS. Q. WELL, IF WE USE THE WORD -- THE DEFINITION THAT YOU GAVE US OF STRESS, THAT IT REDUCES THE FUNCTION OF AN ORGANISM, IS IT YOUR TESTIMONY THAT PHOSPHOROUS WOULD NOT BE CONSIDERED -- COULD NOT BE CONSIDERED A STRESSOR AT ANY LEVEL? MR. GREEN: OBJECT TO FORM. A. AT ANY LEVEL; NO, I WOULDN'T SAY AT ANY LEVEL. THE POINT IS HARDLY ANYONE -- I'VE HARDLY EVER SEEN A STUDY WHERE -- OH, WELL, LET'S SEE, HOW DO I SAY THIS? I THINK THERE'S -- YOU KNOW, SCIENTIFICALLY, THERE'S ALWAYS SOME LEVEL BY WHICH YOU PUT SOMETHING ON THAT WILL EVENTUALLY, EVEN BY JUST THE SHEER WEIGHT ITSELF, WILL CAUSE SOME PROBLEMS BUT--- Q. WELL, LET'S LIMIT IT TO THE LEVELS THAT YOU'VE ACTUALLY FOUND OUT THERE IN THE EVERGLADES IN YOUR STUDIES, AT THE LEVELS AT WHICH YOU FOUND PHOSPHOROUS. A. WHERE? Q. IN 2A. A. IN 2A. Q. DO YOU CONSIDER -- USING YOUR DEFINITION OF STRESS, DO YOU CONSIDER THAT THAT PHOSPHOROUS IS STRESSING THE SYSTEM? DR. RICHARDSON VOLUME III PAGE 1656 A. IN TERMS OF OVERALL FUNCTIONING OF THAT SYSTEM, I WOULD SAY, FOR THE MOST PART, IT'S BEEN A SUBSIDY RATHER THAN A STRESS. Q. WHAT DO YOU MEAN BY A SUBSIDY? A. WELL, IF YOU FOLLOW THE ODUM MODEL OF SUBSIDY STRESS, USUALLY FUNCTIONS GO DOWN WHEN THEY'RE STRESSED AND THEY GO UP WHEN THEY'RE SUBSIDIZED; AND SINCE THE EVERGLADES IS A REDUCED OR PHOSPHOROUS-LIMITED SYSTEM, WHEN YOU ADD SOMETHING THAT IS A NUTRIENT LIKE THAT, YOU GET AN INCREASE IN PRODUCTION, AN INCREASE IN GROWTH, AN INCREASE IN BIOMASS, AN INCREASE IN VOLUME. Q. YOU ARE ALSO, I TAKE IT, THEN, OPINE THAT SULFATES ARE A MORE SERIOUS PROBLEM IN 2A THAN IS PHOSPHOROUS? MR. BURGESS: OBJECT TO FORM. A. I DON'T BELIEVE I SAID THAT. I SAID--- Q. NO--- A. ---THEY WERE SOMETHING THAT MAY BE COMING IN AT HIGHER LEVELS. Q. YEAH. THAT WAS ONE OF THE NUTRIENTS THAT YOU TOLD ME WAS STRESSING THE EVERGLADES. A. NO. I THINK -- I THINK I SAID IT COULD ALTER. I THINK I CHANGED IT. Q. OKAY. ALL RIGHT. IS PHOSPHOROUS ALTERING THE DR. RICHARDSON VOLUME III PAGE 1657 EVERGLADES SYSTEM? MR. GREEN: OBJECT TO THE FORM. A. WELL, AS I SAID, I THINK IT'S CAUSING -- IT'S A SUBSIDY, SO IT WOULD BE CAUSING SOME CHANGES IN THE SYSTEM IF YOU'RE -- IF YOU'RE TALKING ABOUT THAT, IN TERMS OF INCREASES OF SOME ASPECTS OF THE EVERGLADES. Q. DO YOU THINK THESE ARE POSITIVE CHANGES? A. WELL, POSITIVE IS PROBABLY IN THE EYE OF THE BEHOLDER, BUT IT'S -- I CAN TELL YOU AS AN ECOLOGIST WHAT IT'S DOING. Q. IT IS POSITIVE IN THE EYES OF AN ECOLOGIST? A. WELL, IT'S INCREASING THE GROWTH OF SAWGRASS AND PLANT SPECIES. AND AT SOME LEVELS, IT IS -- AT SOME LEVELS, IT'S AN INCREASE IN WHAT IS THERE. IT WOULD BE A SUBSIDY. Q. SO, MY QUESTION IS -- YOU SAID THAT IT IS ALTERING THE SYSTEM. MY QUESTION IS, IS IT ALTERING IT IN A POSITIVE WAY OR IN A NEGATIVE WAY, AS AN ECOLOGIST? A. IT'S ALTERING IT, AS I SAID, FOR THE MOST PART, IN A POSITIVE WAY--- Q. OKAY. A. ---IT WOULD BE -- SUBSIDY WOULD BE A POSITIVE. Q. AND, ACCORDINGLY, THERE WOULD BE NO REASON TO DR. RICHARDSON VOLUME III PAGE 1658 DECREASE THE INFLOW OF PHOSPHOROUS IF IT'S HAVING A POSITIVE EFFECT ON THE EVERGLADES, WOULD THERE? MR. BURGESS: OBJECT TO THE FORM. A. I DON'T BELIEVE I SAID THAT, EITHER. Q. I'M ASKING YOU THAT QUESTION. DOES THAT FOLLOW FROM WHAT YOU JUST SAID? A. DOES -- DOES WHAT FOLLOW? Q. OKAY, I'LL SAY IT AGAIN, YOU JUST TOLD ME THAT THE PHOSPHOROUS WAS ACTING AS A POSITIVE ON THE EVERGLADES, AND MY QUESTION IS, DOES IT THEN FOLLOW THAT YOU WOULD GIVE THE OPINION, SINCE IT'S ACTING AS A POSITIVE, THAT IT'S LEVEL SHOULD NOT BE REDUCED? A. I DON'T THINK THOSE ARE CONNECTED. I--- Q. WHY NOT? A. ---I THINK WHAT I SAID WAS THAT IN A LOCALIZED AREA, YOU ARE GETTING SOME INCREASES IN SOME FUNCTIONS. I DIDN'T SAY OVERALL THAT PHOSPHOROUS -- AS A RESULT OF THAT, YOU WOULD THEN THEREFORE SAY THAT PHOSPHOROUS SHOULD NOT BE REDUCED. Q. WELL, DON'T YOU GET THE SAME EFFECT OF PHOSPHOROUS? WHEREVER IT IS, YOU GET THE SAME EFFECT, DON'T YOU? A. NOT -- NOT EXACTLY, BUT YOU -- GENERALLY, YOU DO. DR. RICHARDSON VOLUME III PAGE 1659 Q. THE EXTENT OF IT MIGHT VARY, BUT IT'S THE SAME EFFECT. SO, GIVEN THAT IT'S THE SAME EFFECT, IS IT FAIR TO SAY THAT YOU BELIEVE THAT THE PHOSPHOROUS IS A POSITIVE--- MR. BURGESS: OBJECT TO THE FORM. Q. ---IN ITS ALTERATION OF THE SYSTEM? MR. BURGESS: SAME OBJECTION. A. I THINK I SAID THAT I THOUGHT WHERE IT WAS ENTERING THE SYSTEM, BY AND LARGE, IT WOULD BE CONSIDERED A SUBSIDY FOR MOST OF THE ORGANISMS THAT WERE THERE. Q. AND THEN MY NEXT QUESTION IS, DO YOU CONSIDER THAT TO BE A POSITIVE AS OPPOSED TO A NEGATIVE? A. I CONSIDER IT TO BE A SUBSIDY, NOT A STRESS. Q. WELL, HELP ME UNDERSTAND. IS A SUBSIDY GOOD AND A STRESS IS BAD? A. A SUBSIDY RESULTING IN INCREASE IN SOME OF THE FUNCTIONS. I'M NOT SURE I WANT TO SIMPLIFY IT DOWN TO JUST SAYING, YOU KNOW, POSITIVE OR NEGATIVE. I THINK THAT'S A BIT NAIVE AND SIMPLISTIC. Q. DO YOU BELIEVE THAT SINCE IT IS ACTING AS A SUBSIDY, THERE'S ANY REASON TO REDUCE THE AMOUNT OF PHOSPHOROUS COMING IN? MR. BURGESS: OBJECT TO FORM. DR. RICHARDSON VOLUME III PAGE 1660 A. I THINK I SAID EARLIER TODAY THAT I THINK AFTER STUDYING THE EVERGLADES NOW FOR FIVE YEARS THAT I BELIEVE THAT PHOSPHOROUS SHOULD BE REDUCED GOING INTO THE EVERGLADES. Q. OKAY. AND HOW DOES THAT SQUARE WITH YOUR SAYING THAT IT'S A SUBSIDY AND NOT A STRESSOR? WHY SHOULD IT BE REDUCED IF IT'S A SUBSIDY AND NOT A STRESSOR, I GUESS IS MY QUESTION? A. WHY SHOULD IT BE REDUCED? Q. YEAH, IF IT'S A--- A. WELL, I THINK--- Q. ---SUBSIDY AND NOT A STRESSOR. A. I THINK THE MAGNITUDE OF THE PHOSPHOROUS IN SOME LOCALIZED AREAS MAY BE TOO HIGH. WE TALKED ABOUT WHERE SUBSIDY HAS OCCURRED; THERE MAY BE SOME AREAS WHEREBY EITHER THE CONCENTRATION OR THE LOAD MAY HAVE EXCEEDED THE CAPACITY OF THAT SYSTEM TO FUNCTION, AND THEN YOU HAVE -- YOU HAVE THE PROBLEM THAT SUBSIDY DOES NOT CONTINUE IN A LINEAR FASHION AD INFINITUM. IT REACHES SOME POINT WHEREBY YOU -- FROM MY STUDIES AND OTHER PEOPLES -- THAT, IN FACT, IT BECOMES TOO MUCH. SO, THERE OBVIOUSLY IS A THRESHOLD OR SOME BOUNDARY WHERE YOU WOULD NOT LIKE TO EXCEED THIS. Q. WHERE DO YOU BELIEVE IT HAS -- THE DR. RICHARDSON VOLUME III PAGE 1661 PHOSPHOROUS -- OR THE MAGNITUDE OF THE PHOSPHOROUS HAS BECOME TOO GREAT? A. WHERE? Q. WHERE, YEAH. A. I WOULD SAY THAT IT DEPENDS -- REALLY, THAT REALLY RELATES TO WHAT YOU WANT TO MAINTAIN AS A COMMUNITY, IF YOU'RE -- WHAT YOUR OBJECTIVES ARE FOR THE COMMUNITY. IF -- IF, FOR EXAMPLE, YOU WANT TO MAINTAIN A CERTAIN ECOLOGICAL COMMUNITY, THEN I CAN GIVE YOU SOME RELATIVE IDEA WHERE I THINK THAT LEVEL, AT LEAST -- OR WHETHER OR NOT, IN FACT, WE SHOULD CONSIDER REDUCTIONS. FOR EXAMPLE, I THINK I HAVE SAID BEFORE THAT THERE ARE CERTAIN PARTS OF THE EVERGLADES THAT ARE A LITTLE BIT MORE UNIQUE THAN OTHERS AND, SO, ONE MIGHT NOT WANT TO PLACE ELEVATED LEVELS OF NUTRIENTS INTO THOSE SYSTEMS. Q. ALL RIGHT. WHERE -- WHICH PARTS ARE MORE UNIQUE, THAT IN YOUR OPINION SHOULD NOT HAVE ELEVATED LEVELS OF PHOSPHOROUS? A. WELL, I THINK THE PARK, PER SE, WHICH IS SEVENTY MILES SOUTH OF OKEECHOBEE, HAS PROBABLY HISTORICALLY RECEIVED THE LOWER LEVELS -- LOWEST LEVELS OF PROBABLY PHOSPHOROUS AND, SO, I THINK THEY SHOULD -- IT SHOULD CONTINUE TO RECEIVE LOWER LEVELS OF DR. RICHARDSON VOLUME III PAGE 1662 PHOSPHOROUS. Q. ANYWHERE ELSE? A. I THINK THE LOXAHATCHEE AREA, AS I MENTIONED, TOO, EARLIER, IS -- IS SOMEWHAT UNIQUE FOR DIFFERENT REASONS. ESPECIALLY IN THE LAST, LET'S SAY, FEW HUNDRED YEARS TO A THOUSAND YEARS, SINCE IT HAS THAT MORE OF AN OMBROTROPHIC NATURE AND HAS BEEN RAINFALL FED, I BELIEVE THAT AREA SHOULD NOT BE RECEIVING -- IN FACT, FOR THE MOST PART, I DON'T BELIEVE WE SHOULD BE RECEIVING ANY WATER WHATSOEVER OTHER THAN RAINFALL. Q. WE'RE TALKING ABOUT PHOSPHOROUS NOW, NOT WATER. A. WELL, SOMETIMES IT'S HARD TO REMOVE THE PHOSPHOROUS FROM THE WATER. Q. YOU TESTIFIED THAT THERE'S SOME AREAS WHICH ARE UNIQUE, WHICH SOMEONE MAY MAKE THE DECISION THAT THE PHOSPHOROUS LEVEL SHOULD BE KEPT LOW. YOU TOLD ME ENP WAS ONE OF THESE, AND NOW YOU'RE TELLING ME THE LOXAHATCHEE IS ONE. A. I'M TELLING YOU THE LOXAHATCHEE IS AN AREA THAT I THINK ESPECIALLY THE CENTER PORTION IS PROBABLY ONE OF THE MOST LEAST MAN-UNDISTURBED SYSTEMS WE HAVE. Q. ANY OTHER AREAS THAT YOU BELIEVE ARE UNIQUE AND, ACCORDINGLY, THE PHOSPHOROUS SHOULD BE KEPT LOW? DR. RICHARDSON VOLUME III PAGE 1663 A. WELL, I CAN'T SAY THEY'RE ALL, YOU KNOW, UNIQUE. WE BEGIN TO USE UNIQUE -- IF WE USE UNIQUE TOO MANY TIMES, THERE'S NOTHING LEFT THAT'S -- LET'S SAY -- LET'S SAY THESE AREAS ARE MORE REPRESENTATIVE OR CLOSER TO, EVEN THOUGH THEY'RE ALTERED, CLOSER TO MAYBE WHAT THE ORIGINAL BASELINE OF THE EVERGLADES WAS. LET'S REDEFINE IT THAT WAY. SO, I WOULD THEN INCLUDE IN THAT, PROBABLY, 3 AS THE NEXT AREA. Q. OKAY. ANYWHERE ELSE? A. WELL, I THINK THAT COVERS PRETTY MUCH. I WOULD SAY THAT 2 HAS BEEN -- I MENTIONED BEFORE -- THE MOST HIGHLY ALTERED OF ALL THE SYSTEMS THAT I'VE SEEN, AND IT WOULD BE QUITE DIFFICULT TO DEFINE THAT AS CLOSE -- CLOSE TO THE -- AT LEAST, THE NORTHERN END, WHAT IT WAS PRIOR TO THE CANALS GOING IN. THERE ARE PORTIONS TO THE WEST AND TO THE SOUTH, I STILL THINK MAINTAIN, OTHER THAN THAT PULSED HYDROLOGY, SOME SEMBLANCE OF WHAT IT WAS. Q. WELL, DOES THAT MEAN, THEN, THAT YOU WOULD NOT WANT TO KEEP THE PHOSPHOROUS LEVELS LOW IN THE PART OF 2A THAT IS NOT SIMILAR OR CLOSE TO ITS BASELINE, HISTORICAL BASELINE? MR. GREEN: OBJECT TO THE FORM. A. LOW, I'M NOT SURE WHAT YOU MEAN BY LOW, BUT--- DR. RICHARDSON VOLUME III PAGE 1664 Q. THE SAME WAY WE'VE BEEN TALKING ABOUT IN THE LAST -- FOR THE LAST FIVE MINUTES. A. RIGHT. WELL, I WOULD THINK THERE'D BE DIFFERENT -- I THINK I COULD SAY THAT IT PROBABLY WOULD NOT MAKE MUCH DIFFERENCE FOR A CONSIDERABLE PERIOD OF TIME IF YOU LOWERED THE WATER PHOSPHOROUS CONCENTRATIONS AS LONG AS YOU KEPT PUMPING WATER THROUGH THERE TO THAT PARTICULAR ZONE. IN THE NORTH, ESPECIALLY SINCE IT'S NOW, I THINK, JUST SOUTH OF THE STRUCTURES -- WELL, IT'S HIGHLY ELEVATED IN PHOSPHOROUS. THE SOIL PORE WATER CONCENTRATIONS ARE A THOUSAND MICROGRAMS PER LITER; SO, I DON'T THINK ADDING LOW PHOSPHOROUS WATER IS GOING TO HAVE A MAJOR IMPACT ON THAT ZONE. THAT'S, OF COURSE, SEVERAL KILOMETERS, BECAUSE I THINK 2A HAS, AS WE'VE TALKED ABOUT THIS MORNING, UNDERGONE SO MANY DIFFERENT ALTERATIONS. Q. WELL, IS IT YOUR OPINION, THEREFORE, THAT THERE SHOULD BE NO ATTEMPT MADE TO REDUCE THE PHOSPHOROUS LEVEL ENTERING 2A? A. I DIDN'T SAY THAT. Q. OBVIOUSLY, I DON'T KNOW IF YOU DID OR NOT. THAT'S WHY I ASK YOU IF THAT'S YOUR OPINION. A. I THINK, AS I SAID BEFORE, THAT -- THAT -- AND I'VE RECOMMENDED THIS TO AGRICULTURE BEFORE -- IS THAT DR. RICHARDSON VOLUME III PAGE 1665 THEY SHOULD -- I THINK I STARTED THIS IN '88 OR '89 -- THAT THEY SHOULD CONSIDER, SINCE THE EVERGLADES WAS AN OLIGOTROPHIC SYSTEM, BY AND LARGE, THEY SHOULD CONSIDER BMP'S AND OTHER TECHNOLOGIES THAT COULD BE UTILIZED TO REDUCE THE PHOSPHOROUS LEVELS TO AS LOW A TECHNOLOGICAL LEVEL THAT THEY COULD, WITHOUT CAUSING OTHER -- THERE'S A POSSIBILITY YOU'D CAUSE OTHER ECOLOGICAL PROBLEMS -- AND THAT THEY WOULD HAVE TO -- IT WAS THEIR PROBLEM IN TERMS OF CONSIDERING THESE ALTERNATIVES. I WAS NOT GOING TO BE INVOLVED WITH THESE ALTERNATE TECHNOLOGIES, BUT IT WAS MY RECOMMENDATION THAT THEY PROCEED FORWARD WITH THIS. Q. DID THEY? A. TO MY KNOWLEDGE, THEY HAVE BEEN TRYING IN THE LAST FEW YEARS. I HAVE HAD CONTACT WITH ANY NUMBER OF CONSULTANTS AND SCIENTISTS AND PEOPLE WHO HAVE CONTACTED ME OR SHOWN ME OR TALKED ABOUT VARIOUS AND SUNDRY POSSIBLE PHOSPHOROUS-REDUCING MECHANISMS, AND I'VE SEEN PRESENTATIONS ON HALF A DOZEN. THERE ARE MORE SCHEMES TO REDUCE PHOSPHOROUS THAN YOU CAN ALMOST COUNT. Q. ISN'T IT A FACT THAT THERE WAS REALLY NOTHING DONE VERY SUBSTANTIAL TO REDUCE IT UNTIL THE RULE, THE BMP RULE, TOOK EFFECT? DR. RICHARDSON VOLUME III PAGE 1666 MR. BURGESS: OBJECTION. MR. GREEN: OBJECT TO THE FORM. A. I'M NOT SURE WHEN THE BMP RULE TOOK EFFECT. Q. WITHIN THE LAST TWO TO THREE YEARS. MR. BURGESS: OBJECT TO FORM. A. WELL, I -- I CAN'T SAY THAT -- I CAN'T SAY THAT, LOOKING AT SOME OF THE DOCUMENTS, THAT THE FARMERS DID NOT, FOR EXAMPLE, REDUCE SOME AMOUNTS OF PHOSPHOROUS. I DO KNOW, FOR EXAMPLE, THAT, MAYBE BY SERENDIPITY, BUT, THAT THEY REDUCED THE AMOUNT OF PHOSPHOROUS ON -- WHICH WAS A SURPRISE TO ME, BUT IT TURNED OUT TO BE -- FOR ECONOMIC REASONS, BUT IT WORKED OUT JUST AS WELL. THEY STOPPED -- REDUCED -- THEY REDUCED THE AMOUNT OF PHOSPHOROUS ON SUGARCANE LAND BECAUSE IT PRODUCED BIG EARS BUT LESS SUGAR, BIG LEAVES BUT THE SUGAR CONTENT WENT DOWN, SO I THINK THEY HAVE BEEN LOOKING AT THAT, AND I THINK THEY HAVE BEEN PROVIDING RESEARCH DOLLARS TO IFAS FOR A NUMBER OF YEARS LOOKING AT -- THERE WERE SOME EARLY STUDIES THAT I HAD LOOKED AT THAT BASICALLY LOOKED AT SOME NUTRIENT BUDGETS AND SOME THINGS THAT THEY TRIED TO AT LEAST LOOK AT THAT. NOW, IN TERMS OF IMPLEMENTATION, THEY ARE MORE -- LET'S PUT IT THIS WAY, I THINK THEY ARE FAR MORE ACTIVE IN THE LAST TWO OR THREE YEARS THAN THEY DR. RICHARDSON VOLUME III PAGE 1667 HAVE BEEN IN THE PREVIOUS DECADE. Q. DID YOU SAY THAT -- DID YOU SAY YOU UNDERSTOOD THAT THE SUGAR YIELD WAS REDUCED BY ADDITIONAL PHOSPHOROUS AND IT WAS CUT BACK? A. NO. WHAT IT DOES IS, I THINK YOU END UP WITH MORE CARBON PER SUGAR YIELD. IN OTHER WORDS, WHAT HAPPENS, I THINK, IS -- AS I UNDERSTAND; I'M NOT AN EXPERT IN THIS AREA -- BUT AS I'M TOLD, ORIGINALLY, IT'S SORT OF LIKE WHAT YOU DO WITH MILK WEIGHT. AND GROWING UP ON AND BEING A FARM BOY, I CAN GIVE YOU THIS ANALOGY. YOU PRODUCE POUNDS OF MILK, BUT YOU GET PAID BY THE POUNDS TIMES THE BUTTER FAT CONTENT. SUGARCANE, YOU USED TO GET PAID BY THE TON, BUT I THINK YOU NOW GET PAID BY THE TON TIMES THE SUGAR DENSITY -- THE AMOUNT OF SUGAR IN THE CANE. SO, IF YOU PRODUCE LOTS OF TONNAGE WITH LOWER SUGAR CONTENT, AND YOU DIDN'T TAKE THAT INTO ACCOUNT, THEN BECAUSE IF YOU HAD MORE TONNAGE AND YOU WERE PAID ONLY BY TONNAGE, SOME INDIVIDUALS GOT MORE -- GOT MORE TONNAGE THAT WAY. BUT NOW, THEY'VE -- BY IMPLEMENTING THAT POLICY, THEY WOULD BE ACTUALLY NOT, I THINK, ECONOMICALLY AS FEASIBLE DOING IT THAT WAY. Q. SO, BY REDUCING THE PHOSPHOROUS, THEY, IN EFFECT, INCREASE THEIR PROFIT ON THE PER TON, OR DR. RICHARDSON VOLUME III PAGE 1668 INCREASE THE--- A. I DON'T THINK I SAID THAT, EITHER. I THINK -- I THINK IT'S SIMPLY--- Q. WELL, THEY GET MORE MONEY. A. I'M NOT SURE HOW THE MONEY SITUATION -- I'M SIMPLY TELLING YOU THE BIOLOGY OF WHAT HAPPENS TO THE PLANT. AND I DON'T KNOW HOW THE ECONOMICS ALL WORKED OUT. I THINK THEY -- BUT I BELIEVE IF YOU LOOK AT SOME OF THE IFAS REPORTS, I MEAN, THEY WENT TO BEDDING AND -- I MEAN, NOT BEDDING BUT I MEAN BASICALLY TRYING TO PLACE FERTILIZER. MOST FARMERS, BECAUSE OF SIMPLE ECONOMICS, HAVE BEEN TRYING TO REDUCE ANY COSTS THEY HAVE, AND FERTILIZER WOULD BE A COST, SO, THERE WOULD HAVE BEEN SOME EFFORT TO DO THAT. AS I SAID, I THINK IT'S BEEN FAR MORE ACCURATE IN THE LAST TWO OR THREE YEARS -- I'M NOT TRYING TO PORTRAY THAT IN ANYTHING DIFFERENT THAN THAT -- THAN IT WAS IN THE PREVIOUS DECADE. Q. SINCE THE RULE TOOK EFFECT? MR. BURGESS: OBJECT TO FORM. MR. GREEN: OBJECT TO THE FORM. A. WELL, I CAN'T REALLY ATTEST TO--- Q. OKAY. THE -- GOING BACK TO YOUR DESCRIPTION OF THE CURRENT STATUS AND HEALTH, YOU SAID THAT THE DR. RICHARDSON VOLUME III PAGE 1669 EVERGLADES WOULD BE OPERATING WITH A NEW BASELINE; WHAT DO YOU MEAN BY THAT? A. AS A NEW HYDROPERIOD REGIME FOR MANY PORTIONS OF IT; AS A NEW -- IT'S STARTED TO FUNCTION AS A PULSED SYSTEM IN PLACES. IN OTHER WORDS, IT RECEIVES ITS WATER AND NUTRIENTS ON A PULSED BASIS IN MANY LOCATIONS. THERE ARE BARRIERS TO FLOW THAT EXIST, SO -- I GUESS WITH FOURTEEN HUNDRED MILES OF CANALS. THERE ARE SECTIONS THAT, IN THE SOUTHERN END OF MANY OF THOSE CONSERVATION AREAS, WERE DESIGNED TO HOLD WATER, AND THAT'S WHAT THEY DO. THEY HOLD DEEP WATER IN THE SOUTHERN END. THE LOXAHATCHEE IN THE SOUTHERN END HAS WATER HELD IN IT FROM A PERIOD OF TIME WHICH IT NORMALLY WOULD NOT HAVE HAD, I WOULD THINK, WITHOUT THAT DIKE THERE. Q. IS THERE ANY -- IN THIS NEW BASELINE, IS THERE ANY COMPONENT RELATED TO PHOSPHOROUS? MR. BURGESS: OBJECT TO FORM. A. I THINK THE PHOSPHOROUS IN THE MAJOR PORTIONS OF THE EVERGLADES -- LIKE THE PARK, BOTH OF -- THE LOXAHATCHEE, PORTIONS OF 3A -- HAVE NOT SUBSTANTIALLY CHANGED. THERE ARE AREAS NEAR THE DIKES AND RELEASE POINTS AND IN 2A THAT HAVE SUBSTANTIALLY CHANGED, ALBEIT I THINK MAYBE RAINFALL VALUES MAY HAVE INCREASED DR. RICHARDSON VOLUME III PAGE 1670 A BIT, BUT YOU WOULD EXPECT THAT WITH ALL THE ACTIVITY OF HUMANS. Q. DO YOU CONSIDER THE PHOSPHOROUS FROM RAINFALL TO BE THE EQUIVALENT OF PHOSPHOROUS FROM BULK DEPOSITION, BULK ATMOSPHERIC DEPOSITION? A. TO BE EQUIVALENT? Q. YEAH. IS THAT THE SAME THING, IN YOUR MIND? A. WELL, YOU COULD -- IF YOU DID -- IF YOU LOOKED AT BULK DEPOSITION, I GUESS, BULK MEANING BOTH WET AND DRY--- Q. CORRECT. A. ---AND YOU ANALYZED IT CORRECTLY, YOU WOULD HAVE AN ESTIMATE OF THE TOTAL PHOSPHOROUS FALLING IN -- COMING INTO A SYSTEM, YEAH, IF THAT'S WHAT YOU'RE ASKING. Q. DO YOU HAVE ANY OTHER OPINIONS--- MR. BURGESS: OBJECT TO FORM. Q. ---THAT YOU -- SUCH AS THE ONE YOU GAVE ME REGARDING YOUR OVERALL VIEWS OF THE STATE OR THE HEALTH OF THE EVERGLADES? MR. BURGESS: OBJECT TO FORM. A. WELL, I THINK WE COVERED IT YESTERDAY. I MEAN THE ONLY OTHER THING WAS RELATED TO THE STA'S AND IMPLEMENTATION OF THE STA'S, THAT I CAN THINK OF. DR. RICHARDSON VOLUME III PAGE 1671 Q. DO YOU HAVE DIFFERENT OPINIONS OR OTHER OPINIONS BESIDES WHAT WE'VE TALKED ABOUT? DO YOU THINK THEY'RE NOT PROPERLY SIZED? A. I THINK I SAID YESTERDAY I THINK WE HAVE SOME EVIDENCE NOW THAT THEY'RE NOT PROPERLY SIZED. THERE MAY BE SOME TRANSFERABILITY ISSUES. Q. WHAT IS THE SIZE RIGHT NOW, AS YOU UNDERSTAND IT? A. I THINK THE BURNS AND McDONNELL REPORT TALKS ABOUT IT AS FORTY THOUSAND ACRES. Q. FORTY THOUSAND ACRES? OKAY. WHICH BURNS AND McDONNELL REPORT? A. THIS IS -- I THINK IT'S THE LAST ONE; IT'S FEBRUARY OR SOMETHING. Q. '94? A. I DON'T REMEMBER THE LAST DAY OF FEBRUARY. IT'S THE LAST--- Q. BUT, I MEAN, IT'S THIS YEAR, FEBRUARY? A. YES. Q. OKAY. AND YOU UNDERSTAND THAT'S WHAT'S BEING BUILT? I MEAN, THAT'S WHAT'S BEING PROPOSED TO BE BUILT--- A. I UNDERSTAND THAT'S--- Q. ---AS PART OF THIS SWIM PLAN? DR. RICHARDSON VOLUME III PAGE 1672 A. THAT'S WHAT I UNDERSTAND IS BEING PROPOSED. Q. AND YOU BELIEVE THAT THE FORTY THOUSAND ACRES IS NOT LARGE ENOUGH? MR. GREEN: OBJECT TO THE FORM. A. I BELIEVE THE STA'S AS OUTLINED AND DESIGNED, AND WHAT I'VE HEARD ABOUT AND WHAT I'VE HEARD DR. KADLEC TALK ABOUT AND THE EVIDENCE I HAVE, BASICALLY WILL HAVE -- UNDERSTANDING THE ECOLOGY OF THOSE PLANTS AS I DO -- WILL HAVE GRAVE DIFFICULTIES IN MEETING A PROPOSED FIFTY PARTS PER BILLION STANDARD UNDER THOSE LOADS THAT ARE PROPOSED. Q. OKAY. DO YOU KNOW HOW MUCH PHOSPHOROUS IS DESIGNED TO BE TREATED BY THE STA'S, WHAT LOAD? A. IT SEEMS TO BE AN EVER-MOVING TARGET. Q. OKAY. WHAT DO YOU UNDERSTAND IT TO BE? A. WELL, AT ONE TIME, I THOUGHT IT WAS TWO HUNDRED AND TWENTY TONS WITH ALL THE BYPASS WATER AND LAKE WATER AND SO FORTH; AND THEN I'M TOLD NOW IT'S LIKE MAYBE IN THE NEIGHBORHOOD OF A HUNDRED TONS. BUT IT REALLY WILL DEPEND UPON THE ADDITIONAL WATER THAT MAY ADDITIONALLY PASS THROUGH. SO, I THINK IT'S NOT REALLY TOTALLY CLEAR. AS I SAY, I READ THOSE AND LISTEN TO DOCUMENTS -- OR LISTEN TO PEOPLE TALK, AND IT VARIES FROM SOME NUMBER. I -- IT DOESN'T -- IT ISN'T DR. RICHARDSON VOLUME III PAGE 1673 REALLY CRITICAL. WHAT'S REALLY CRITICAL IS TO KNOW, AS FAR AS I'M CONCERNED, THE LOAD PER UNIT AREA THAT'S PROPOSED, AND SOME OF THE OTHER FEATURES WE TALKED ABOUT. AND I THINK WHAT'S MOST CRITICAL IS THE FACT THAT, AS A SCIENTIST, I WOULD LIKE TO SEE WHAT THE STATE PROPOSED TO DO, AND THAT IS TO TEST THE ENR PROJECT. Q. WHEN DID THE STATE PROPOSE TO DO THAT? A. I THOUGHT THEY PUT THAT IN THE SWIM PLAN; THAT'S MY RECOLLECTION. Q. YOU MEAN TO TEST THE ENR PROJECT BEFORE THE STA'S WERE BUILT? A. WELL, THEY HAD IT IN THERE, BUT I'M NOT SURE -- I CAN'T REMEMBER WHETHER THEY WERE GOING TO BUILD ALL THE STA'S. I BELIEVE THEY TALKED ABOUT JUST BUILDING IT IN CONJUNCTION WITH THE OTHER STA'S, WHICH I DON'T AGREE WITH. Q. DO YOU KNOW IF THE ENR PROJECT HAS BEEN BUILT? A. THE WALLS HAVE BEEN COMPLETED, AND I UNDERSTAND IT'S NOW BEING FLOODED OR HAS BEEN FLOODED. Q. SO, THAT WOULD SUGGEST TO YOU IT'S NOT BEING BUILT IN CONJUNCTION WITH THE STA'S? MR. BURGESS: OBJECT TO FORM. A. IT WAS PROPOSED TO BE THE FIRST ONE IN LINE. IT WAS PROPOSED AS A TEST SITE. BUT IT'S NOT, AS I DR. RICHARDSON VOLUME III PAGE 1674 UNDERSTAND IT, A FUNCTIONING TEST SITE TO THIS DATE. AS I UNDERSTAND IT, THE FEDERAL GOVERNMENT HAS -- EPA HAS BLOCKED ANY RELEASE OF WATERS, AND SO IT'S SITTING THERE AS A POND, NOT MUCH TESTING BEING DONE. Q. ARE YOU GOING TO BE EXPRESSING ANY OPINIONS ABOUT THAT SUBJECT, THE FEDERAL GOVERNMENT'S ROLE WITH REGARD TO THE ENR AND WHAT'S HAPPENING TO IT? MR. BURGESS: OBJECT TO FORM. A. I DON'T THINK THERE'S MUCH OF AN OPINION TO GIVE RELATED TO THAT EXCEPT SIMPLY THAT EPA -- I'M NOT GOING TO -- I'M NOT A POLICYMAKER; I'M NOT GOING TO BE CITING WHETHER THEY SHOULD OR SHOULD NOT BE GIVEN A DISCHARGE PERMIT. THAT'S REALLY NOT OF MY PURVIEW. Q. OKAY. IF YOU ASSUMED THAT THERE WERE GOING TO BE A HUNDRED TONS TO BE TREATED WITH THE STA'S, BASED ON YOUR STUDIES, ARE YOU ABLE TO ASSIGN AN ACREAGE? MR. GREEN: OBJECT TO THE FORM. A. WE WOULD BE ABLE TO, FROM THE FIELD STUDIES, GIVE AN ESTIMATION; AND ON THE LOAD BASIS, WE COULD GIVE SOME ESTIMATION. Q. AND HAVE YOU DONE THAT IN ANY OF YOUR PAPERS ANYWHERE? A. I BELIEVE WE GAVE SOME NUMBERS IN SEVERAL OF OUR MANUSCRIPTS THAT WERE PUBLISHED. DR. RICHARDSON VOLUME III PAGE 1675 Q. AND ISN'T IT A FACT THAT THE ACREAGE THAT YOU'VE GIVEN IS VERY CLOSE TO THE SAME ACREAGE THAT THE DISTRICT PROPOSES TO BUILD IN THE SWIM PLAN? MR. BURGESS: OBJECT TO THE FORM. A. ARE YOU REFERRING TO THE FORTY THOUSAND ACRES? Q. TO THE ACREAGE THAT -- IN THE SWIM PLAN. MR. GREEN: OBJECT TO THE FORM. A. WHAT'S THE ACREAGE IN THE SWIM PLAN? I'M NOT SURE IF I REMEMBER WHAT ACREAGE YOU'RE TALKING ABOUT. Q. WELL, THAT'S WHAT I'D LIKE TO KNOW, IF YOU KNOW THAT. DO YOU KNOW WHAT THE ACREAGE THAT THEY--- A. I THOUGHT THE ACREAGE THEY PROPOSED IN THE SWIM PLAN WAS LIKE TWENTY-SIX THOUSAND ACRES OR SOMETHING. Q. OKAY. ASSUMING IT'S TWENTY-SIX THOUSAND ACRES IN THE SWIM PLAN, IS IT A FACT, OR NOT, THAT YOUR PROPOSED ACREAGE BASED ON YOUR STUDIES FOR THE TREATMENT OF A HUNDRED TONS IS ABOUT THE SAME? A. I'D HAVE TO GO BACK AND LOOK AT THE NUMBERS. I DON'T REMEMBER EXACTLY. Q. WELL, HOW CAN YOU SAY, THEN, THAT THE ACREAGE IN THE SWIM PLAN IS WRONG? A. WELL, I DON'T BELIEVE THE SWIM PLAN TALKED ABOUT A HUNDRED TONS. I THOUGHT THE SWIM PLAN TALKED DR. RICHARDSON VOLUME III PAGE 1676 ABOUT A HUNDRED AND SEVENTY-FIVE TONS. I DON'T BELIEVE IT MENTIONED A HUNDRED TONS. BUT I'M SAYING FROM MY NUMBERS, YOU CAN CALCULATE. YOU TELL ME THE TONNAGE AND AT SOME POINT WE CAN SIT DOWN AND CALCULATE IT, BUT I DON'T HAVE THOSE NUMBERS IN MY HAND. BUT I UNDERSTAND IT WAS MUCH MORE. AS I SAID, IT WENT FROM TWO TWENTY, ONE SEVENTY-FIVE; YOU HEAR ALL SORTS OF NUMBERS. Q. OKAY. WELL, RIGHT NOW, DO YOU KNOW WHAT TONNAGE THE SWIM PLAN THAT'S BEING CHALLENGED IN THIS PROCEEDING IS DESIGNED TO TREAT? MR. GREEN: OBJECT TO THE FORM. A. I DON'T KNOW IF I CAN REMEMBER EXACTLY OR NOT. MY RECOLLECTION, IT WAS LIKE A HUNDRED AND SEVENTY-FIVE TONS, BUT I MIGHT NOT BE TOTALLY ACCURATE ON THAT. Q. AND DO YOU KNOW AT THIS POINT WHAT ACREAGE WAS PROPOSED IN THE SWIM PLAN THAT'S BEING CHALLENGED IN THIS PROCEEDING? A. REPEAT THAT, PLEASE. Q. DO YOU KNOW THE ACREAGE THAT IS PROPOSED FOR TREATMENT OF STA'S IN THE SWIM PLAN THAT'S BEING CHALLENGED? A. I THINK IT'S -- I THINK IT'S TWENTY-SIX THOUSAND ACRES. THAT'S MY RECOLLECTION, BUT I'D HAVE DR. RICHARDSON VOLUME III PAGE 1677 TO LOOK AT THE DOCUMENTS. AS I SAID, THESE NUMBERS HAVE BEEN CHANGING. Q. WELL, YOU'RE EXPRESSING AN OPINION THAT THE SIZING IS WRONG IN THE SWIM PLAN; IS THAT CORRECT? A. BASED ON OUR NUMBERS, YES. Q. OKAY. A. BUT, AS I SAID, IT REALLY DEPENDS ON SITTING DOWN WITH OUR MODEL AND OUR BASIC ESTIMATES AND DECIDING THIS COULD BE DONE. WE CAN PLAY -- YOU KNOW, WE CAN PLAY THE NUMBERS GAME, TRYING TO GUESS IF I CHANGE IT TO FORTY, WHAT IS THE INSTANT ANSWER. BUT THE ANSWER IS THE ANSWER. IT WILL BE WHATEVER OUR ESTIMATES SUGGEST THEY WILL BE. THEY WILL BE WITHIN CERTAIN BOUNDS. Q. ANY OTHER OPINIONS THAT YOU HAVE THAT HAVE COME TO YOUR MIND SINCE WE BROKE? A. WELL, LET ME LOOK AT MY ANNUAL REPORT, AND SEE -- TO MAKE SURE I HAVEN'T MISSED ANYTHING. Q. OKAY. HAVE YOU REVIEWED ANY REMOTE-SENSING DATA? A. I'VE LOOKED AT SOME REMOTE-SENSING DATA, YES. Q. WHEN? A. I'VE LOOKED AT SOME -- LET'S SEE. MR. BURGESS: DO YOU WANT HIM TO ANSWER DR. RICHARDSON VOLUME III PAGE 1678 THE QUESTION ABOUT ANY OTHER OPINIONS? HE SAID, "LET ME LOOK THROUGH MY ANNUAL REPORT," AND THEN YOU ASKED HIM--- MR. REID: NO, I THOUGHT HE MEANT HE WAS GOING TO BE LOOKING AT IT LATER TODAY. HE'S GOT IT IN FRONT OF HIM. WE'LL TALK ABOUT IT. I PLAN TO ASK THESE QUESTIONS ABOUT IT. MR. BURGESS: OKAY. HE'S--- MR. REID: HE CAN CERTAINLY -- DOES HE WANT TO TAKE A BREAK AND GO THROUGH IT AND SEE IF HE HAS OTHER OPINIONS? MR. BURGESS: NO, BUT I THINK THE ANSWER -- HE SAID, "LET ME TAKE A LOOK AT MY ANNUAL REPORT"--- MR. REID: WELL, I DIDN'T UNDERSTAND HE WAS ASKING TO TAKE A LOOK -- DID YOU WANT TO TAKE A BREAK AND READ YOUR ANNUAL REPORT RIGHT NOW, OR DID YOU JUST MEAN WHEN WE LOOK AT IT? WITNESS: I SAID -- NO, WHEN I TAKE -- IF YOU WANT ME TO. YOU ASKED FOR OTHER OPINIONS, AND I SAID I WOULD LIKE TO RELY ON MY ANNUAL REPORT TO MAKE SURE I HAVEN'T MISSED SOMETHING, AND THEN YOU WENT ON, SO--- DR. RICHARDSON VOLUME III PAGE 1679 MR. REID: ALL RIGHT. WELL, WE'LL TALK ABOUT YOUR ANNUAL REPORT. WITNESS: FINE. Q. (BY MR. REID) WHAT REMOTE-SENSING DATA HAVE YOU SEEN? A. ORIGIN -- WELL, I THINK -- WELL, I'VE SEEN SOME -- YOU MEAN ALL, WHATEVER I'VE SEEN, EVERYWHERE? Q. WELL, WHATEVER YOU HAD IN YOUR MIND WHEN YOU SAID YOU JUST LOOKED AT SOME. I ASKED YOU IF YOU HAD LOOKED AT ANY REMOTE-SENSING DATA; AND YOU SAID, YEAH, YOU JUST LOOKED AT SOME, AND I SAID WHAT--- Q. WELL--- A. ---SO, WHATEVER YOU WERE THINKING ABOUT. Q. I LOOKED AT SOME THAT WAS PROVIDED TO ME MONDAY, I GUESS, BY THE CO-OP. Q. WHOSE WORK WAS THAT? A. WELL, I COULDN'T REMEMBER THE NAME MONDAY, SO I SURELY CAN'T REMEMBER IT NOW. Q. YOU DON'T KNOW WHO DID THE REMOTE-SENSING OR WHERE IT CAME FROM? A. I KNOW WHERE IT CAME FROM. THE CO-OP COMMISSIONED THE STUDY, TO HAVE IT DONE, AND I HAD ACTUALLY MET WITH SOME OF THE CO-OP PEOPLE TO LOOK AT SOME OF THAT IN THIS PLAN. IT JUST -- I'M TERRIBLE AT DR. RICHARDSON VOLUME III PAGE 1680 NAMES -- IF YOU HAVEN'T FIGURED THIS OUT BY NOW, SO I JUST -- THE NAME ESCAPES ME AS TO WHO DID THIS WORK. BUT YOU WILL GET IT, AS I UNDERSTAND IT, AND YOU WILL HAVE THE NAME. Q. OKAY. AND WHAT WAS THE RESULT OF YOUR LOOKING AT THAT REMOTE-SENSING DATA? A. I ONLY HAD A VERY BRIEF TIME TO LOOK AT IT. WE COVERED THAT YESTERDAY. I SAID I LOOKED AT A FEW AREAS THAT I WAS FAMILIAR WITH, AND IT SEEMED TO REPRESENT WHAT I UNDERSTOOD TO BE OPEN WATER AREAS AND THE SAWGRASS AREAS AND SOME CATTAIL AREAS, BUT I HAVE NOT HAD A CHANCE TO STUDY THAT IN GREAT DETAIL. MR. REID: ARE WE GOING TO GET TO SEE THAT, BILL, OR IS THAT--- MR. GREEN: AS I SAID YESTERDAY, YOU'VE GOT IT. MR. REID: THE REMOTE SENSING? MR. GREEN: THAT'S MY UNDERSTANDING. IF YOU DON'T -- TODAY'S WEDNESDAY; YOU SHOULD HAVE IT. MR. REID: OKAY. Q. (BY MR. REID) ALL RIGHT. I TAKE IT, THEN, YOU HAVE NO OPINIONS THAT ARE BASED ON THE REMOTE-SENSING DATA THAT THE CO-OP HAD THAT YOU LOOKED DR. RICHARDSON VOLUME III PAGE 1681 AT MONDAY? A. OTHER THAN THAT I THOUGHT IT WAS REPRESENTATIVE OF THE AREAS THAT I KNEW, BUT I DIDN'T HAVE A CHANCE TO GO THROUGH IT IN GREAT DETAIL. Q. HAVE YOU LOOKED AT ANY OTHER REMOTE-SENSING DATA? A. ORIGINALLY I HAD LOOKED AT SOME LANDSAT DATA THAT WAS ANALYZED BY ERIM FIRM BACK IN '89, I GUESS IT WAS. AND I'VE LOOKED AT -- YEAH, THAT WOULD BE ONE OF THE MAJOR PIECES OF REMOTE-SENSING DATA. Q. AND HAVE YOU LOOKED AT THAT -- WHEN WAS THE LAST TIME YOU LOOKED AT THAT? A. I HAVEN'T LOOKED AT THAT DATA -- I MAY HAVE SHOWN THE SLIDE IN CLASS, BUT I HAVEN'T LOOKED AT THAT DATA, YOU KNOW, OTHER THAN JUST TO LOOK AT THE SLIDE, IN ANY DETAILS FOR A YEAR A TWO. Q. ARE ANY OF THE OPINIONS THAT YOU'RE GOING TO EXPRESS IN THIS CASE BASED ON ANYTHING IN THAT LANDSAT DATA? A. THEY GIVE ME SORT OF AN OVERVIEW OF THE CONDITIONS FROM THAT PERIOD. THERE WERE SOME TIME SEQUENCES FROM THAT, AND WHEN THAT'S MATCHED WITH SOME AERIAL SURVEYS THAT WERE DONE BY MIKE DENNIS AND CREW, THEY PROVIDE ME A BASIS TO LOOK AT THE AERIAL EXTENT OF DR. RICHARDSON VOLUME III PAGE 1682 VEGETATION, ESPECIALLY AS IT RELATES TO VARIOUS DENSITIES OF CATTAILS, SAWGRASS. Q. SO, SOMEBODY HAS TAKEN THE ERIM DATA, THE ANALYSIS OF ERIM, AND COMPARED THAT IN SOME WAY TO THE DENNIS AERIAL PHOTOGRAPHY? MR. GREEN: OBJECT TO FORM. A. NO, I DIDN'T SAY THAT. Q. ARE YOU GOING TO DO THAT? A. I SAID I WAS -- I HAD LOOKED AT THAT DATA AS A BASELINE AND THEN, FROM THAT, A MORE DETAILED -- THAT DATA FROM THE LANDSAT IS SORT OF A FIRST-CUT LOOK TO SEE, WHEN WE FIRST GOT INTO THIS STUDY, WHETHER OR NOT, IN FACT, CATTAILS WERE EXTENSIVE IN MONOCULTURE THROUGHOUT THESE AREAS. AND, SO, THAT FIRST CUT WAS SIMPLY TO TAKE AN ANALYSIS. IT GIVES YOU A -- IT DOESN'T PICK UP ALL THE CATTAILS, BUT IT GIVES YOU A PRETTY GOOD IDEA OF WHERE THE MONOCULTURES EXISTED AT THAT PERIOD. SO, THAT GIVES ME THE FIRST CUT, AND THEN THE SECOND CUT REALLY IS LOOKING AT MORE EXTENSIVELY THE -- THE LOW-ELEVATION SURVEYS THAT WERE DONE BY--- Q. BY DENNIS? A. BY DENNIS. MR. GREEN: COUNSELOR, LET ME INTERJECT DR. RICHARDSON VOLUME III PAGE 1683 FOR THE RECORD. I WAS WAITING FOR YOU TO FINISH THAT PIECE THERE. DUE TO THE FAULT OF NO ONE, I ASSUME, YOU KNOW, WE WEREN'T ABLE TO FINISH DR. JENSON. I ASSUME YOU'RE AWARE OF THAT. THERE WAS A PROBLEM THERE. WE HAD DELAYED ENTRY AND ACCESS INTO DIFFERENT AREAS THAT RELATE TO THE REMOTE-SENSING WORK. WE RESERVED THE RIGHT, BASICALLY, TO BRING TO PROFESSOR RICHARDSON'S ATTENTION THE COMPLETION OF OUR SATELLITE WORK, TO THE EXTENT IT HASN'T BEEN COMPLETED, WHEN IT'S COMPLETED; AND IT HASN'T BEEN COMPLETED YET. PARTS OF IT HAVE, PARTS WE'VE TALKED ABOUT--- MR. REID: IS THIS THE ERIM--- MR. GREEN: ---AND I THINK THAT MR. -- NO, IT'S NOT -- IT'S LAW ENVIRONMENTAL. MR. REID: WELL, THAT'S--- MR. GREEN: I KNOW, BUT I JUST--- MR. REID: OKAY. MR. GREEN: ---WHILE WE'RE ON THIS TOPIC. MR. REID: I SEE. OKAY. MR. GREEN: I BELIEVE THAT THE -- MR. DOWNING FROM LAW IS BEING DEPOSED DR. RICHARDSON VOLUME III PAGE 1684 TOMORROW AND, YOU KNOW, TO THE EXTENT THAT PROFESSOR RICHARDSON RELIES ON THAT AND, IF NECESSARY, ASKS HIM QUESTIONS ABOUT THAT, YOU KNOW, I DON'T -- I GUESS WE WOULD SAY WE'D MAKE HIM AVAILABLE FOR FURTHER QUESTIONS, BUT I JUST WANTED TO CLARIFY THAT--- MR. REID: OKAY. MR. GREEN: ---WE INTEND TO BRING THOSE TO HIS ATTENTION WHEN THEY'RE DONE. MR. REID: ALL RIGHT. LET'S WORK THROUGH IT, THEN. MR. GREEN: OKAY. Q. (BY MR. REID) THE ERIM ANALYSIS, ARE YOU -- YOU'VE NOT LOOKED AT THAT IN A NUMBER OF YEARS? A. NOT IN ANY DETAIL. THAT -- AS I SAID, THAT WAS A FIRST-CUT ANALYSIS TO SEE THE MAGNITUDE OF EXTENT OF MONOCULTURES OF CATTAIL. Q. OKAY. ARE YOU GOING TO BE RELYING ON THE ERIM ANALYSIS FOR YOUR OPINIONS IN THIS CASE? A. ONLY IN THE GENERAL SENSE. Q. OKAY. WHERE IS THE ERIM NOW? A. THAT'S ALL BEEN TURNED OVER TO YOU. Q. OKAY. BEFORE YOUR LAST DEPOSITION? ALL RIGHT. NOW, YOU MENTIONED THE DENNIS WORK. DR. RICHARDSON VOLUME III PAGE 1685 A. RIGHT. Q. HAVE YOU REVIEWED THE DENNIS WORK? A. I RECEIVED THAT FAIRLY RECENTLY, AND I HAVE LOOKED AT THAT AND LOOKED AT SOME OF THE ACREAGE FIGURES FOR BOTH -- THE VEGETATION. AND I HAVE LOOKED AT -- I BELIEVE THERE'S TWO SURVEYS, '91 AND '93, AND ALSO SOME MELALEUCA INFORMATION. Q. AND WAS THAT -- IS THAT IN YOUR FILES? A. YES, I BELIEVE IT WAS. Q. OKAY. AND WAS IT PRODUCED? A. I COULDN'T TELL YOU. Q. WELL, I DIDN'T SEE IT IN THE BOX THAT I GOT. A. THEN -- I PUT IT IN THE BOX, SO I CAN--- MR. BURGESS: WHAT IS IT? MR. REID: THE DENNIS -- ALL THE DENNIS -- THE MAPS AND THINGS THAT DENNIS DID. MR. BURGESS: THOSE HAVE ALL BEEN PRODUCED. MR. REID: OH, I KNOW THEY WERE IN DENNIS. BUT, I MEAN, IF THEY'RE IN HIS FILES, I'M ENTITLED TO GET THEM FROM HIM. MR. BURGESS: I THINK I PUT ON -- I THINK I PUT ON THE LIST OF DR. RICHARDSON VOLUME III PAGE 1686 PUBLICLY-AVAILABLE DATA AND DATA AND THE EXHIBITS PRODUCED IN OTHER DEPOSITIONS, THOSE BDA MAPS. MR. REID: I HAVEN'T SEEN THAT. IT APPARENTLY CAME IN AFTER WE STARTED UP HERE, OR AT LEAST AFTER WE LEFT FOR UP HERE. Q. (BY MR. REID) SO, TELL ME TO WHAT EXTENT OR HOW YOU'RE RELYING -- WHAT OPINIONS YOU HAVE BASED ON THE DENNIS DATA? A. WELL, THAT DATA GIVES ME A FAIRLY RECENT PICTURE OF THE EXTENT OF THE CATTAIL. MY MAJOR INTEREST WAS TO LOOK AT THE EXTENT OF CATTAIL AND OTHER SPECIES IN THE -- IN THE EVERGLADES, AND I'VE MET WITH MIKE DENNIS ON A COUPLE OF OCCASIONS, AND HE HAS PRESENTED SOME OF THE SUMMARIES OF THAT AND THEN FINALLY PRODUCED THE FIGURE; AND, FROM THAT, I LOOKED AT THE ACREAGE THAT WOULD BE IN SEVERAL CATEGORIES AND DETERMINED TO WHAT EXTENT THE CATTAIL MONOCULTURE WOULD EXIST AND WHERE IT EXISTED. Q. NOW, THE DENNIS -- THE '91 AND THE '93, THE TWO DIFFERENT MAPS, ISN'T IT A FACT THAT THE CATTAILS WERE MORE WIDELY DISTRIBUTED IN '93 THAN THEY WERE IN '91? A. NOT FOR THE MONOCULTURES. DR. RICHARDSON VOLUME III PAGE 1687 Q. NO, I MEAN CATTAILS IN GENERAL. A. I THINK DEPENDING ON -- I DON'T THINK THE CATEGORIES WERE -- THAT WAS A CONCERN OF MINE, IS THAT THE SURVEYS WERE DONE UNDER DIFFERENT SETS OF CATEGORIES, AND SO IT WAS HARD TO COMPARE WHEN YOU DON'T HAVE EXACTLY THE SAME PERCENTAGES, BUT THE -- I WASN'T VERY CONCERNED WITH THE -- WITH LIKE THE ONE PERCENT CATEGORY OF WHETHER OR NOT -- IN FACT, IT IS MY UNDERSTANDING FROM MIKE THAT, IN FACT, THE '93 SURVEY WAS -- WAS DONE ON A LITTLE MORE RIGOROUS BASIS THAN '91, AND SO WE WERE ABLE TO PICK UP IN THAT LOWER PERCENTAGE CATEGORY SOME MORE. THAT'S WHAT HE TOLD ME. Q. OKAY. BUT MY QUESTION IS, ISN'T IT A FACT THAT THE '93 MAP SHOWS A MUCH BROADER AREA OF CATTAIL THAN THE '91 MAP? MR. BURGESS: OBJECT TO THE FORM. A. NOT IN ALL CATEGORIES; I DON'T THINK THAT'S TRUE. I THINK IN THAT LOWER PERCENTAGE CATEGORY, THAT MAY BE TRUE. Q. I MEAN, IN ANY CATEGORY. A. I WOULD HAVE TO GO BACK AND LOOK AT THE ACREAGE FIGURES. I DON'T REMEMBER OFF THE TOP OF MY HEAD WHAT -- IT MAY BE, I JUST DON'T REMEMBER. Q. WELL, ARE YOU DRAWING ANY CONCLUSIONS FROM HIS DR. RICHARDSON VOLUME III PAGE 1688 WORK, OR DOES THAT JUST GIVE YOU A DEMONSTRATION, IF YOU WILL, OF SOMEBODY'S VIEWS OF WHAT'S HAPPENED TO CATTAILS? A. WELL, NO, I THINK IT'S -- I THINK IT'S A GOOD SURVEY. I THINK IT'S ONE OF THE MOST EXTENSIVE SURVEYS I'VE SEEN, AND I THINK IT'S REASONABLY -- REASONABLY ACCURATE, AND I THINK IT GIVES YOU -- LIKE I SAID, FOR MY PURPOSES, I WANTED TO KNOW WHERE THE CATTAIL MONOCULTURES WOULD BE, WHICH WOULD BE OF IMPORTANCE IN TERMS OF WHETHER THEY WERE EXPANDING OR NOT, AND IT GIVES ME AN IDEA OF WHERE THE CATTAIL EXTENTS ARE; SO, I THINK IT WILL BE USEFUL INFORMATION. I JUST DON'T HAPPEN TO REMEMBER THOSE NUMBERS OFF THE TOP OF MY HEAD. SO I WILL BE USING THAT, BASICALLY, AS A INDICATION. I'M GOING TO BE COMPARING IT TO SOME OF MY WCA-2A DATA, FOR EXAMPLE, AND LOOKING AT THAT -- THOSE PERCENTAGES. Q. YOU INDICATED THAT HE SAID THE SECOND MAP WAS -- THE TESTING WAS MORE RIGOROUS, OR THE METHODS WERE MORE RIGOROUS. HOW DO YOU UNDERSTAND THEY ARRIVED AT THOSE PERCENTAGES? A. I'M NOT SURE -- YOU MEAN THE CLASSES OF PERCENTAGES OR? Q. NO, THE PERCENTAGES; LIKE HOW DID THEY DR. RICHARDSON VOLUME III PAGE 1689 DETERMINE THAT A PARTICULAR AREA WAS LESS THAN ONE PERCENT CATTAILS OR TWO PERCENT TO FIVE PERCENT CATTAILS? YOU KNOW, THERE WERE DIFFERENT GRADATIONS ON THAT MAP. HOW DID THEY --DO YOU KNOW HOW THEY DETERMINED -- HOW THEY DID THEIR SAMPLING TO MAKE THOSE DETERMINATIONS? A. IT WAS MY UNDERSTANDING THAT THEY DID A LOT OF THIS FROM HELICOPTER SURVEYS WITH SOME -- WITH SOME GROUND-TRUTHING, AND THAT THEY BASICALLY USED A -- THEY HAD A STANDARD PROCEDURE THEY USED -- WHICH I DON'T REMEMBER FOR THE MOMENT WHAT IT WAS -- BUT, I MEAN IT WAS BASICALLY LOOKING IN CERTAIN DIRECTIONS OVER CERTAIN LINES. I THINK THEY LANDED AND ACTUALLY TOOK SOME ACTUAL SURVEYS. Q. OKAY. THEY EYE-BALLED IT? A. I WOULDN'T SAY THEY EYE-BALLED IT. I THINK IT'S A -- IT'S A REASONABLE SURVEY. Q. OKAY. BUT, I MEAN, THEY DID IT BY LOOKING AT IT, LOOKING AT THE AREA? A. YEAH, I THOUGHT -- BUT I ALSO THOUGHT THERE WAS SOME GROUND-TRUTHING THAT THEY HAD INVOLVED WITH THAT. Q. AND WHAT WAS MORE RIGOROUS ABOUT THE '93 MAP AS COMPARED TO THE '91 MAP? DR. RICHARDSON VOLUME III PAGE 1690 A. I THINK THEY MADE MORE CATEGORIES IN '93, I THINK. AS I SAID, I -- I'VE ONLY RECENTLY RECEIVED THAT, SO I HAVEN'T SPENT THE TIME THAT I PROBABLY WILL IN TERMS OF LOOKING AT THAT; BUT I WAS CONCERNED TO TRY TO DETERMINE THE TOTAL -- AS SORT OF THE LANDSCAPING, WHAT'S THE TOTAL ACREAGE OF THE LARGE CATTAIL AREAS. AND I THINK I GAVE YOU A FIGURE THIS MORNING ROUGHLY OF WHAT THAT -- THOSE WERE. Q. YOU MEAN THE SIX, SEVEN KILOMETERS SOUTH OF THE CANAL? A. NO, THE -- THE WHOLE AREAS; ALL THE AREAS. Q. BACK TO THE ORIGINAL QUESTION, UNDERSTANDING WHAT MR. GREEN SAID, AT THIS POINT, ARE YOU BASING ANY OF YOUR CONCLUSIONS ON ANY REMOTE-SENSING DATA? A. WELL, REMOTE-SENSING AND LOW-ANGLE ELEVATION DATA; AS MR. GREEN SAID, I PROBABLY WILL LOOK AT THIS OTHER DATA, AND THEN FROM THE--- Q. WHAT IS -- WHAT DO YOU MEAN "REMOTE-SENSING, LOW-ANGLE ELEVATION"? A. LOW ELEVATION? I GUESS IF YOU WANT TO CALL LOW-ELEVATION PHOTOGRAPHY REMOTE-SENSING, I GUESS YOU CAN PUT IT IN THAT--- Q. OH, YOU MEAN WHAT DENNIS DID? A. YES. DR. RICHARDSON VOLUME III PAGE 1691 Q. OH, OKAY. I UNDERSTAND YOU'RE GOING TO USE DENNIS' BUT ANY OTHER REMOTE SENSING? A. MR. GREEN -- I MAY SIMPLY--- Q. ASIDE FROM WHAT HE SAID HE MAY SHOW YOU. A. AND JUST USING AS A -- AS A BASELINE OR SOME BACKGROUND INFORMATION, I MAY RELY ON THE GENERAL CATEGORY, BUT NOT SPECIFIC ACREAGES AND SO FORTH. Q. ALL RIGHT. HAVE YOU READ DR. JENSON'S WORK? A. I'VE SEEN A COPY OF HIS REPORT; I HAVEN'T REALLY -- I'VE LOOKED THROUGH THE PICTURES. I HAVE NOT REALLY--- Q. DO YOU HAVE ANY OPINIONS OR COMMENTS ABOUT THAT WORK? A. NOT JUST FROM FLIPPING THROUGH IT. I HAVEN'T HAD A CHANCE. MR. REID: WHAT TIME IS IT? MR. GREEN: TWO FORTY-FIVE. MR. REID: LET'S TAKE A BREAK; WHAT DO YOU SAY? (THEREUPON, A BREAK WAS TAKEN FROM 2:45 P.M. TO 3:14 P.M.) MR. REID: DR. RICHARDSON, LET'S MARK YOUR DUKE WETLAND CENTER ANNUAL REPORT, WHICH IS DATED DECEMBER '92, REVISED APRIL 1993, AS DR. RICHARDSON VOLUME III PAGE 1692 EXHIBIT TWO. (THEREUPON, THE DOCUMENT REFERRED TO BELOW WAS MARKED AS DEPOSITION EXHIBIT NO. 2 - CURTIS J. RICHARDSON DEPOSITION - FOR IDENTIFICATION.) EXAMINATION BY MR. REID CONTINUES: Q. DO YOU HAVE A COPY? A. NO. RICK HAS MY COPY, BUT YOU TWO CAN SHARE THAT COPY. THESE COPIES ARE -- I DON'T KNOW HOW MANY WE SENT OUT. WE HAVE -- THAT'S THE PREVIOUS REPORT. Q. THAT'S THE PREVIOUS ONE? A. THAT'S THE PREVIOUS ONE. Q. OKAY. AM I SAFE IN ASSUMING THAT ANY OPINIONS THAT YOU WOULD GIVE IN THIS CASE WOULD BE BASED UPON DATA THAT'S CONTAINED IN THE -- IN THE PROJECTS DESCRIBED IN EXHIBIT TWO HERE? MR. GREEN: OBJECT TO THE FORM. A. ANY OPINIONS -- I WOULD HAVE OTHER DOCUMENTS BESIDES THIS. THERE ARE MORE RECENT PAPERS AND REPORTS AND OTHER THINGS THAT I WOULD RELY ON. BUT, CERTAINLY, AS IT RELATES TO THE EXPERIMENTS, A PORTION OF THE INFORMATION WILL COME FROM THIS DOCUMENT, AND OTHER RELATED DOCUMENTS AND PUBLICATIONS. Q. WELL, THE OTHER PUBLICATIONS WOULD STILL BE DR. RICHARDSON VOLUME III PAGE 1693 PRODUCED AS A RESULT OF THE WORK THAT WAS -- THAT'S REPORTED IN THIS EXHIBIT TWO; IS THAT CORRECT? MR. BURGESS: OBJECT TO FORM. A. THEY WOULD BE THE ESSENCE OF SOME OF THAT. BUT, I MEAN, AS I SAID, WE'VE ALREADY PUBLISHED SOME. YOU HAVE THEM THAT ARE ALREADY UPDATED VERSIONS OF VARIOUS CHAPTERS OF THIS, AND WE WOULD, OF COURSE, PUT THE MOST RECENT INFORMATION WE HAVE IN ANYTHING WE WOULD PRODUCE POST THIS VOLUME SINCE THIS VOLUME IS NOW--- Q. A YEAR OLD? A. IT'S A YEAR OLD. THE DATABASE FOR THIS WOULD HAVE STOPPED IN DECEMBER. THERE WAS NO NEW DATA ADDED TO THIS IN THE REVISED APRIL OF '93 VERSION. IT WAS SIMPLY TYPOS AND CORRECTIONS, AND THERE WAS NO NEW DATA ADDED. Q. NOW, ON PAGE ROMAN NUMERAL XXII, YOU--- A. ROMAN NUMERAL XXII. Q. ---YOU HAVE THREE QUESTIONS OR THREE AREAS IN WHICH YOU FOCUSED YOUR RESEARCH. A. THAT'S CORRECT. WHERE THE EXECUTIVE SUMMARY -- IS THAT WHAT--- Q. EXACTLY. SINCE THIS DOCUMENT WAS PRODUCED, HAVE THE AREAS OF RESEARCH CHANGED? DR. RICHARDSON VOLUME III PAGE 1694 A. IN GENERAL, THAT WOULD COVER THE RESEARCH THAT WAS FUNDED BY THE EPD. THE--- Q. I WANT TO SHOW YOU A QUARTERLY REPORT WHICH IS DATED JANUARY 1994. WE'LL MARK THIS AS EXHIBIT THREE. (THEREUPON, THE DOCUMENT REFERRED TO ABOVE WAS MARKED AS DEPOSITION EXHIBIT NO. 3 - CURTIS J. RICHARDSON DEPOSITION - FOR IDENTIFICATION.) Q. (BY MR. REID) HAVE YOU SEEN THAT BEFORE? MR. GREEN: COUNSEL, DO YOU HAVE COPIES OF THESE? MR. REID: NO, I JUST HAVE MY COPY. (THEREUPON, WITNESS REVIEWS DOCUMENT.) MR. REID: I THINK YOUR LAWYER FOUND IT. HE HAS THE JANUARY QUARTERLY REPORT? MR. BURGESS: NOVEMBER 1 TO JANUARY 31? MR. REID: IS THAT THE SAME ONE? MR. BURGESS: YES. MR. REID: OKAY. Q. (BY MR. REID) MY QUESTION IS, HAVE YOU SEEN EXHIBIT THREE BEFORE? A. I BELIEVE SO. IT LOOKS LIKE OUR QUARTERLY REPORT. DR. RICHARDSON VOLUME III PAGE 1695 Q. NOW, I HAVE ALSO SEEN SOME LETTERS THAT SEEM TO BE GOING OUT ON A MONTHLY BASIS OR SO, BUT I DON'T FIND A LETTER ANY LATER THAN THAT QUARTERLY REPORT. DO YOU KNOW IF THERE HAS BEEN A LETTER SINCE THAT QUARTERLY REPORT? A. ARE YOU REFERRING TO THE MONTHLY -- I THINK WHAT YOU'RE REFERRING TO IS THE MONTHLY REPORTS? Q. MONTHLY -- MONTHLY UPDATE, I THINK. A. MONTHLY UPDATES OR SOMETHING. Q. I'M SORRY; I TAKE THAT BACK. THERE'S A FEBRUARY '94. A. RIGHT. MR. REID: LET ME GET THIS MARKED AS EXHIBIT FOUR. (THEREUPON, THE DOCUMENT REFERRED TO ABOVE WAS MARKED AS DEPOSITION EXHIBIT NO. 4 - CURTIS RICHARDSON DEPOSITION - FOR IDENTIFICATION.) MR. BURGESS: DO YOU HAVE A BATES NUMBER ON THE BOTTOM OF THESE SO IT WOULD BE EASIER FOR ME? COURT REPORTER: 1309382. MR. REID: WHAT WAS THAT DATE, THE 14TH -- FEBRUARY 15. DR. RICHARDSON VOLUME III PAGE 1696 WITNESS: DO YOU JUST WANT ME TO IDENTIFY THIS? IS THAT WHAT--- MR. REID: YES, SIR. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. I RECOGNIZE THIS AS A -- I DIDN'T SIGN THIS PARTICULAR ONE, BUT IT'S -- IT'S OUR FEBRUARY REPORT. DO YOU WANT IT BACK? Q. NOW -- YEAH, I WANT ALL -- BOTH OF THEM. NOW, WITH THESE THREE EXHIBITS, WOULD THIS GIVE US THE MOST CURRENT INFORMATION AS FAR AS REPORTING THAT DUKE WETLAND CENTER DOES WITH REGARD TO THE EPD GRANT? A. IT WOULD GIVE YOU SUMMARIES OF SOME OF THIS INFORMATION, YES; BUT EACH -- EACH QUARTERLY REPORT, THESE ARE NOT VERBATIM, SO -- AND, SO, THERE ARE -- AS VARIOUS ASPECTS OR HIGHLIGHTS ARE COMPLETED -- IN THE PREVIOUS ONES, THERE MAY BE A HIGHLIGHT HERE AND THERE OF INFORMATION, SO -- MY POINT BEING THOSE ARE NOT VERBATIM. THE OBJECTIVES ARE THE SAME, BUT SOMEONE WOULD HAVE TO PERUSE THESE AND PIECE THESE TOGETHER TO COME UP WITH A COMPREHENSIVE PICTURE. MR. REID: ALL RIGHT. LET'S MARK EXHIBIT -- AS EXHIBIT 5, 6 AND 7 QUARTERLY REPORTS DATED MARCH '93, JULY '93 AND OCTOBER '93. DR. RICHARDSON VOLUME III PAGE 1697 (THEREUPON, THE DOCUMENTS REFERRED TO ABOVE WERE MARKED AS DEPOSITION EXHIBITS 5, 6 AND 7 - CURTIS RICHARDSON DEPOSITION - FOR IDENTIFICATION.) Q. (BY MR. REID) WOULD YOU LOOK AT ALL OF THESE, PLEASE, SIR? A. I'M DOING SO. Q. OKAY. (THEREUPON, WITNESS REVIEWS DOCUMENTS.) A. OKAY. THEY ARE QUARTERLY REPORTS THAT -- WITH THE DATES THAT ARE STAMPED ON THEM. Q. NOW, WITH THE ADDITION OF THESE DOCUMENTS, WOULD WE HAVE AN UP-TO-DATE VERSION OF THE GRANT WORK THAT YOU'VE DONE FOR THE EPD? MR. BURGESS: OBJECT TO FORM. A. YOU WOULD -- YOU WOULD HAVE A SUMMARY OF SOME OF THE -- OF THE PROGRESS OF THOSE KEY POINTS. YOU WOULD HAVE -- YOU WOULD HAVE TO INCLUDE THE MOST RECENT PUBLICATIONS, WHICH I PROVIDED YOU; YOU WOULD HAVE TO LOOK AT THE PAPERS THAT ARE IN PRESS, AND SOME PAPERS THAT WE PROVIDED YOU WITH SOME -- THERE ARE A FEW CHAPTERS THAT ARE, AT LEAST, IN THE DRAFT FORM FOR THE ANNUAL REPORT, AND WE PROVIDED THOSE FOR YOU, TOO. Q. YOU MEAN THE CURRENT -- THE ONE YOU'RE WORKING DR. RICHARDSON VOLUME III PAGE 1698 ON FOR THIS--- A. CORRECT. Q. ---NEXT YEAR? A. CORRECT. Q. THERE ARE DRAFT CHAPTERS, YOU SAY? A. YES. Q. DO YOU REMEMBER WHICH CHAPTERS WERE IN DRAFT, BECAUSE I DON'T REMEMBER SEEING ANYTHING IDENTIFIED AS PART OF AN ANNUAL REPORT? A. I DON'T -- I CAN'T SAY THAT THEY WERE IDENTIFIED AS AN ANNUAL REPORT, BUT I'M SAYING THAT THEY'RE -- EACH INVESTIGATOR -- THE WAY IN WHICH I WORK -- IS ASKED TO START TO COMPILE WHEN THEY CAN DO SO, FROM THE DATA THEY HAVE, TO PULL TOGETHER THEIR MOST RECENT DATA AND DRAFT A CHAPTER; AND I HAVE A FEW OF THOSE THAT HAVE BEEN PROVIDED. Q. WILL YOU KNOW AS WE GO THROUGH THIS WHICH ONES YOU HAVE? A. SURELY. Q. OKAY. CAN YOU JUST TELL ME RIGHT NOW LOOKING DOWN THE CHAPTER LIST WHICH ONES HAVE BEEN PREPARED IN DRAFT? A. WHICH CHAPTER LIST DO YOU MEAN? Q. IN THE ANNUAL REPORT. A. THERE WOULD BE SOME DIFFERENT CHAPTERS. I DR. RICHARDSON VOLUME III PAGE 1699 MEAN, WE DON'T FOLLOW EVERY YEAR THE EXACT SAME CHAPTERS. Q. OKAY. A. THERE WOULD BE -- THERE WILL BE CHAPTERS UNDER THE GENERAL TOPICS. IN OTHER WORDS, THERE WILL BE SOME CHAPTERS UNDER "DOSING," AND THERE WOULD BE SOME CHAPTERS UNDER "GRADIENT," AND THERE WOULD BE SOME CHAPTERS UNDER "VARIOUS EXPERIMENTS." Q. NOW, AS FAR AS PUBLICATIONS, THOSE ARE LISTED, ARE THEY NOT, IN THESE QUARTERLY UPDATES? ANY PUBLICATIONS THAT HAVE OCCURRED? A. I BELIEVE THEY ARE. Q. OKAY. SO, THAT'S HOW I COULD FIND OUT WHAT PUBLICATIONS SHOULD BE READ? A. YES. Q. HOW WOULD I KNOW ABOUT PUBLICATIONS IN PROCESS? A. WELL, AS I SAID, WE HAVE -- SOME OF THE CHAPTERS THAT WE -- SOME OF THE CHAPTERS -- ALMOST ALL THE CHAPTERS -- AND I'M NOT SAYING ALL OF THEM, BUT SOME OF THE CHAPTERS IN THE ANNUAL REPORTS HAVE -- IF YOU LOOK AT THEM CAREFULLY, YOU SEE THAT -- WHAT THE FINAL MANUSCRIPT SAID HAVE BEEN ACCEPTED AND SO FORTH. THAT'S WHAT THEY TURN OUT TO BE. IN OTHER WORDS, WE DR. RICHARDSON VOLUME III PAGE 1700 WRITE A CHAPTER, AND IF THE DATA ARE SUFFICIENT, WE WOULD THEN MAKE THAT INTO A MANUSCRIPT FORM--- Q. OKAY. A. ---AND I BELIEVE THERE ARE REFERENCES IN SEVERAL PLACES THAT SAY "MANUSCRIPT IN PREPARATION" OR "MANUSCRIPT IN REVIEW" AND SO FORTH. Q. IN THE CASE -- THE SWIM CHALLENGE PROCEEDING, DO YOU INTEND TO TESTIFY WITH REGARD TO THE LONG-TERM EFFECTS OF INCREASED NUTRIENTS AND WATER INPUTS ON THE NATIVE PLANT AND ANIMAL COMMUNITIES IN THE WCA'S? MR. BURGESS: ARE YOU READING FROM AN EXHIBIT, COUNSEL? MR. REID: YES. MR. BURGESS: WHICH EXHIBIT? MR. REID: IT'S IN ALL OF THEM. MR. BURGESS: AND CAN YOU REFER THE WITNESS? MR. REID: WELL, I DID PREVIOUSLY. A. YES, I'LL HAVE AN OPINION ON THAT. Q. (BY MR. REID) WILL YOU ALSO HAVE AN OPINION AS TO WHAT IS THE LONG-TERM NUTRIENT STORAGE CAPACITY OF THE WCA'S? A. I WOULD HAVE AN OPINION ON THAT. Q. AND WILL YOU HAVE AN OPINION REGARDING HOW CAN DR. RICHARDSON VOLUME III PAGE 1701 WATER MANAGEMENT IN THE WCA'S BE IMPROVED TO MAINTAIN NATURAL COMMUNITIES? A. AND I'LL HAVE AN OPINION ON THAT. Q. NOW, DO YOU HAVE FINAL OPINIONS WITH REGARD TO EACH OF THOSE THREE AREAS AS YOU SIT HERE TODAY? A. I THINK WE WENT THROUGH THAT FOR THE LAST DAY AND A HALF. Q. I UNDERSTAND. MY QUESTION IS, DO YOU HAVE FINAL OPINIONS ON THESE THREE DELINEATED OPINIONS? A. I WILL HAVE -- I HAVE OPINIONS THAT, YEAH -- NOW, THEY MAY BE SLIGHTLY MODIFIED, BUT I HAVE PULLED TOGETHER MOST OF THE INFORMATION THAT I WOULD NEED TO HAVE SOME OPINIONS. Q. AND WOULD THE BASIS FOR THESE OPINIONS BE THE RESEARCH PROJECTS THAT HAVE BEEN UNDERTAKEN AS PART OF THIS GRANT, THE DATA THAT CAME FROM THOSE? A. TO A LARGE DEGREE, BUT THERE WOULD BE OTHER DATA THAT I WOULD BRING IN -- SOME DISTRICT DATA, SOME OTHER PUBLISHED DATA, SOME SUPPORTING SCIENTISTS DATA. Q. OKAY. LET'S LOOK AT PAGE TWENTY-THREE, ROMAN NUMERAL XXIII. AT THE TOP, IT'S BEGINNING OF THE DISCUSSION OF GENERAL OBJECTIVE ONE, WHICH HAS TO DO WITH THE FIRST OF THE THREE OPINION AREAS THAT WE JUST TALKED ABOUT. DO YOU SEE THAT? DR. RICHARDSON VOLUME III PAGE 1702 A. GENERAL OBJECTIVE ONE? Q. YES, SIR. A. OKAY. Q. OKAY. NOW, THE FIRST THING THAT'S MENTIONED IS A FERTILIZER STUDY--- A. CORRECT. Q. ---IS THAT THE FIRST -- IS THAT THE SAME FERTILIZER STUDY THAT WE TALKED ABOUT THIS MORNING? A. THAT'S CORRECT. Q. AND HAS THAT STUDY BEEN COMPLETED TO THE POINT THAT YOU'RE COMFORTABLE MAKING FINAL OPINIONS OR CONCLUSIONS? MR. GREEN: OBJECT TO THE FORM. ASKED AND ANSWERED. A. WHEN WE WENT THROUGH THAT THIS MORNING, I SAID WE HAD DATA SUMMARIZED UP TO, I THINK, YOU KNOW, THE THIRD YEAR; AND FROM THAT, I CAN MAKE SOME INFERENCES AND HAVE FINAL OPINIONS, WHICH I GAVE YOU EARLIER, AS TO WHAT IT SHOWS AT THAT PARTICULAR POINT IN TIME. Q. OKAY. I'D LIKE TO LOOK AT THESE -- STRIKE THAT. ON PAGE XXIII AND THEREAFTER, THERE ARE A NUMBER OF ITEMS LISTED, NUMBERS ONE, TWO, THREE AND SO FORTH. DO YOU SEE THOSE? A. UH-HUH (YES). DR. RICHARDSON VOLUME III PAGE 1703 Q. ARE THESE CONCLUSIONS THAT HAVE BEEN DRAWN BY SOMEONE WORKING ON THIS PROJECT BASED ON THE FERTILIZER STUDY LISTED AT THE TOP? A. THIS IS -- THIS IS A SUMMARY PULLED TOGETHER BY DR. CRAFT AND MYSELF. Q. OKAY. ARE YOU COMFORTABLE WITH THE OPINIONS THAT ARE EXPRESSED NUMBERED ONE THROUGH TWELVE? MR. BURGESS: TAKE YOUR TIME AND READ THEM IF YOU NEED TO, CURT. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. AFTER READING THESE, I THINK, IN GENERAL, THEY SUMMARIZE AND GIVE AN OVERVIEW OF SOME OF THE KEY POINTS, WITH THE POSSIBILITY OF NUMBER SEVEN, WHICH I'M NOT SURE IT'S CLEARLY STATED AS TO WHAT THE NUMBER OF SPECIES ARE. I'D HAVE TO LOOK BACK AT THE DATA. I THINK THEY'RE REFERRING -- I'M NOT SURE, I'D HAVE TO GO BACK -- AND, AFTER REVIEWING THAT, I WOULD ADD THE NAME OF DR. JAN VYMAZAL, WHO DID THE PERIPHYTON WORK ON THIS COMPONENT. THIS IS A -- UNDER THIS CATEGORY, THIS IS A SUMMARY, REALLY, OF -- I HAVE TO GO BACK AND CHECK. YEAH, IT SAYS DR. CRAFT, DR. RICHARDSON, DR. VYMAZAL. THERE WERE THREE OF US WHO WERE PRIMARILY WORKING ON THAT PART OF THE FERTILIZER STUDY AND MAYBE A STUDENT; DR. RICHARDSON VOLUME III PAGE 1704 BUT UP TO THAT TIME PERIOD, THAT WAS A REPRESENTATION, AND THIS -- THOSE POINTS WOULD BE SORT OF A GENERAL OVERVIEW OF SOME OF THE STUFF. Q. ALL RIGHT. NOW, WE TALKED ABOUT THE FERTILIZER STUDY THIS MORNING; BUT, AT THAT TIME, I DIDN'T ASK YOU TO DESCRIBE THE METHODOLOGY. COULD YOU DO THAT FOR ME NOW, PLEASE? A. WHAT DO YOU MEAN BY THE METHODOLOGY? Q. WHERE IT WAS DONE AND HOW IT WAS SET UP. A. IT'S OUTLINED PRETTY -- IN PRETTY MUCH DETAIL IN, I THINK -- IT WOULD BE THIS REPORT AND THIS REPORT (WITNESS MOTIONING), BUT I WILL GIVE YOU A THUMB-NAIL SKETCH OF IT--- MR. BURGESS: JUST FOR THE RECORD, THE WITNESS IS REFERRING TO EXHIBIT TWO, DECEMBER '92 ANNUAL REPORT REVISED IN '93, APRIL OF '93? MR. REID: AND ITS PREDECESSOR. WITNESS: AND THE PREDECESSOR TO THAT. MR. REID: OKAY. A. ---ESSENTIALLY, THE PLOTS WERE SET UP. THERE WERE TWENTY-SEVEN PLOTS PER SITE. THERE WERE THREE SITES IN WATER CONSERVATION AREA 2B. ONE WAS A PURE MONOCULTURE OF SAWGRASS, REASONABLY HEALTHY STAND. THE DR. RICHARDSON VOLUME III PAGE 1705 SECOND SITE WAS A MIXED SITE WITH ABOUT FIVE PERCENT, MAYBE A LITTLE BIT LESS IN PLACES, OF CATTAIL AND SAWGRASS. Q. FIVE PERCENT WAS CATTAIL AND THE REST WAS SAWGRASS? A. IN THE PLOTS THAT WERE SELECTED. Q. IN THE SECOND PLOT, OKAY. A. THE SECOND AND THE MIXED SITE. THE THIRD ONE WAS A SLOUGH COMMUNITY. THESE ARE ALL ALONG THE DIKE -- SOUTH OF THE DIKE OF WC -- IT SEPARATES WCA-2A FROM WCA-2B. THE PLOTS WERE ESTABLISHED ON A RANDOM BASIS WITH UNWALLED CONTROLS. CONTROLS YOU REPLICATED THREE TIMES. LOW NITROGEN, LOW PHOSPHOROUS, HIGH NITROGEN -- WE DOUBLE-CHECKED THAT -- AND HIGH PHOSPHOROUS. Q. IT'S A LITTLE CONFUSING THE WAY YOU'RE SAYING THAT. A. WELL, I'M GOING TO TRY TO CLARIFY IT FOR YOU IN A SECOND. Q. OKAY. YOU HAD NINE PLOTS WITHIN EACH SITE? NO, I'M SORRY. YOU HAD TWENTY-SEVEN PLOTS WITHIN EACH OF THE THREE SITES? A. RIGHT. I'M GOING TO GO THROUGH THIS SO YOU CAN -- SO YOU CAN FOLLOW A LITTLE MORE CAREFULLY. JUST DR. RICHARDSON VOLUME III PAGE 1706 GIVE ME A MOMENT HERE. (THEREUPON, WITNESS REVIEWS DOCUMENT.) A. IF YOU'LL TURN TO PAGE FOURTEEN -- SINCE IT WILL BE AN EASY WAY TO DO THIS -- IF YOU TURN TO PAGE FOURTEEN IN THE--- MR. BURGESS: EXHIBIT TWO. A. ---EXHIBIT TWO, YOU WILL SEE WCA-2B. YOU WILL SEE THERE ARE THREE CIRCLES THAT ARE RELATED TO -- IT SAYS "SAWGRASS," "SAWGRASS-CATTAIL MIXTURE" AND "SLOUGH." THOSE ARE THE LOCATIONS OF THE SITES. Q. OKAY. A. IF YOU TURN TO TABLE 1-1 AND LOOK, ALSO, ON THE PRECEDING PAPER -- PAGE, BUT WE'LL GO THROUGH THAT IN A MOMENT -- SEVEN FERTILIZER TREATMENTS; LOW, MEDIUM AND HIGH PHOSPHOROUS; MEDIUM AND HIGH NITROGEN; AND MEDIUM AND HIGH N+P. YOU CAN SEE THE RATES -- THE RATA THERE. THERE WERE TWO CONTROLS, ONE WITHOUT SIDES, ONE WITH SIDES. LOOK AT THE WALLED EFFECT. AND THEN YOU CAN SEE THERE WERE SERIES OF PLOTS THAT HAD NO NITROGEN, SERIES OF PLOTS THAT HAD NO PHOSPHOROUS, SERIES OF PLOTS THAT HAD NOTHING ADDED TO THEM, AND THEN A COMBINATION OF PLOTS THAT HAD BOTH NITROGEN AND -- MEDIUM NITROGEN PLUS PHOSPHOROUS AND HIGH NITROGEN PLUS PHOSPHOROUS, SO THOSE, IF YOU GO THROUGH DR. RICHARDSON VOLUME III PAGE 1707 THE COMBINATIONS, WILL END UP RESULTING IN ROUGHLY THE TOTAL NUMBER OF PLOTS. Q. OKAY. A. TWENTY-SEVEN TWO-BY-TWO METER PLOTS, NINE TREATMENTS, THREE REPLICATES. Q. WHAT WAS THE BACKGROUND-SOIL LEVEL AS FAR AS PHOSPHOROUS GOES--- MR. GREEN: ASKED AND ANSWERED. Q. ---IN THIS SITE? A. YEAH, I THOUGHT -- I THOUGHT WE DISCUSSED IT. I'M DOING IT FROM -- FROM MEMORY NOW, BUT WE--- Q. I DON'T THINK SO. I THINK WE TALKED ABOUT THE DOSING STUDY, BUT I DON'T REMEMBER THE FERTILIZER STUDY. A. WELL, REGARDLESS OF THAT, I'M PRETTY SURE WE DID. BUT, IN ANY CASE, THE BACKGROUND LEVEL OF THESE SITES -- THE BEST OF MY RECOLLECTION -- I DON'T REMEMBER THE EXACT NUMBER -- BUT I THINK THEY'RE IN THE FIVE HUNDRED RANGE, SIX HUNDRED RANGE, SOMEWHERE IN THERE. Q. IN THE SOIL? A. IN THE SOIL, MICROGRAMS PER GRAM. Q. AND HOW MUCH IN THE WATER? A. THE WATER COLUMNS WHICH WE CHECKED INITIALLY DR. RICHARDSON VOLUME III PAGE 1708 WERE IN THE TEN TO TWENTY RANGE -- SOMETIMES LOWER, SOMETIMES HIGHER, SOMEWHERE IN THERE, THAT WERE CONSIDERED. Q. PARTS PER BILLION? A. PARTS PER BILLION, TOTAL PHOSPHOROUS. Q. WHAT WAS THE HYDROLOGY OF THE AREA LIKE? A. IF YOU TURN TO PAGE FIFTEEN, THIS GIVES YOU DATA UP THROUGH '92, WHICH IS SOMEWHAT REPRESENTATIVE. YOU CAN SEE THE WATER LEVEL CENTIMETERS ABOVE THE SOIL SURFACE. THESE ARE MONTHLY MEANS. YOU CAN SEE WHERE THE BLACK SQUARES THAT, ESSENTIALLY, WE RUN FIVE TO ROUGHLY TEN CENTIMETERS ABOVE THE SOIL SURFACE FOR THE SAWGRASS SITE. THERE IS SOME SEASONAL PATTERN, BUT IT'S GENERALLY -- THERE'S A PERIOD, I THINK ONCE IN THERE, YOU CAN SEE IT DROP, BASICALLY, TO SURFACE. IF YOU LOOK AT THE SLOUGH SITE, YOU CAN SEE THERE IS A BIT MORE OSCILLATION, WHICH IS THE DIAMONDS. AND YOU CAN SEE THAT, IN FACT, WE RUN FOR A PERIOD OF TIME AROUND TWENTY CENTIMETERS, AND THEN IT GOES UP INTO THE THIRTY-CENTIMETER RANGE, THEN BACK DOWN INTO THE TWENTY TO TWENTY-FIVE CENTIMETER RANGE. THE MIXED SITE FOR A PERIOD OF TIME IS ALSO MATCHED WITH THE SAWGRASS SITE, AND THEN IT OSCILLATES AND WE ESSENTIALLY GO ABOVE THIRTY, BELOW, ABOVE. IT DR. RICHARDSON VOLUME III PAGE 1709 HAS MORE -- THIS IS THE ONE THAT'S CLOSEST TO THE S1/46 GATE; AND, SO, AS THE DISTRICT OPENS AND CLOSES THAT GATE, THE WATER LEVELS IN THERE HAVE CHANGED. THEY CHANGE QUIT