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September 11, 2000

Mississippi River/Gulf of Mexico Action Plan (4503F)
C/O U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460

RE: Comments on the Draft Action Plan of Action for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico

On behalf of the members of the Agricultural Retailers Association (ARA), I would like to offer the following comments regarding the proposed hypoxia action plan. ARA represents over 700 companies operating out of more than 6,000 locations providing farms and other customers plant nutrients, crop protectants, seed and other supplies. ARA members also provide agronomic, environmental and technical services to ensure proper management of crop inputs.

ARA has placed a high priority on the growing concerns raised by federal agencies that agricultural practices and methods used to produce America's food and fiber are suspect and have become the central discussion of enforcing mandatory state and federal water quality programs. In 1999, ARA developed a Nutrient Management and Hypoxia Task Force White Paper that made several recommendations, including the promotion of formal nutrient management planning and increased adoption of existing best management practices. In addition, the task force recommended that providing retailers with the tools to communicate with growers is an integral component to the adoption rate of these practices.

In addition, ARA recently established an ad hoc task force to develop a farmer-retailer nutrient management education program. The program would provide both an economic and environmental perspective. It should also focus on assisting retailers to encourage producers in the adoption of nutrient BMPs and help overcome producers' fears and how to manage the risks of using BMPs.

Finally, ARA is participating in a cooperative research proposal to the U.S. Department of Agriculture-Agricultural Research Service to establish a consortium with a goal of developing and implementing nitrogen practices that would increase profit and efficiency of nitrogen use and reduce environmental contamination. The proposal is unique in that will link retailers and producers with the education and research community to participate in the evaluation of land management practices and technologies that will increase adoption by maximizing crop yields and nitrogen efficiency and reducing offsite movement.

American agriculture continues to be strongly committed to address water quality challenges by minimizing runoff in the Gulf and other water bodies. Agriculture has made substantial investments and made significant efforts in protecting the environment through voluntary, incentive-based programs. ARA welcomes the emphasis of the Draft Action Plan on incentive-based, voluntary efforts to reduce nonpoint sources of nitrogen.

Long-Term Goals

The Draft Action Plan proposes three options for the Coastal Goal: 1) quantitative reduction of annual discharges of nitrogen into the Gulf from the Mississippi/Atchafalya Rivers by 350,000-650,000 metric tons; 2) quantitative reduction of Gulf of Mexico hypoxia zone to less than 5,000 square kilometers by reducing average nitrogen loads by 30 percent; and 3) an integrated approach to pursue practical, cost-effective efforts by all states and tribes with the Mississippi/Atchafalya Basin and all categories of sources to reduce nutrient over-enrichment.

It is highly questionable whether the integrated assessment provides credible scientific evidence to support nutrient use reduction mandates. More importantly, the plan provides no substantive evidence as to whether these goals (in either option 1 or 3) are in fact realistic or achievable in the time frame proposed by the plan.

Second, quantitative goals are incompatible with existing agricultural stewardship and voluntary assistance programs. It is common knowledge that it can take several years before water quality improvements can be measured. In addition, numeric goals for reducing nitrogen losses will be interpreted to enforcing reductions in the use of nitrogen for agricultural crops. Restricting inputs will not result in a reduction in nitrogen loss. Rather, nutrient management planning encompassing soil testing, timing and method of application; the use of conservation buffers, crop rotation, conservation tillage and weather conditions will all play a key role in effective utilization of nitrogen.

The third qualitative option (1.C.) is much more preferable and appropriate to accommodate a voluntary, incentive-based focus for agriculture. A way to measure success in this option could involve the number of miles of conservation buffers in place, acres in conservation tillage or adoption rate of best management practices.

The Within Basin Goal calls for restoration and protection of waters which could imply a quantitative objective and the establishment of some predetermined baseline to "restore" waters. It is overly broad and should be revised to be compatible with the qualitative Coastal Goal (1.C.).

The Quality of Life Goal endorses the voluntary, incentive-based approach and recognizes the important role agriculture plays in private sector land management. It also acknowledges that agricultural producers have an environmental and economic self-interest in reducing nitrogen losses increasing the effective utilization of plant nutrients.

Implementation Actions

We would applaud the initial action (#2, By Fall 2001) to establish a baseline of existing efforts for nutrient management. It is imperative that the Draft Action Plan assess the impact of past and current achievements the agricultural sector has made through stewardship and voluntary assistance programs. It is impossible to determine what strategies should be put in place without determining the cumulative impacts of past and current conservation and stewardship efforts.

Moreover, there should be a complete assessment of the current and proposed public and private research on nutrient management efforts in the Mississippi/Atchafalya River Basin before expending resources on implementing new programs or redirecting current efforts. The consortium research ARA referenced earlier is a good example of nutrient management research that could be integral to implementation of the Draft Action Plan.

However, the second short term action calls for setting reduction targets in metric tons of nitrogen, which is inconsistment with the Option 1.C. Coastal Goal. Again, it would be more prudent to establish best management practice implementation goals.

The second action also calls for detailing needs for additional assistance to meet goals and promote additional funding. It should be made clear that new appropriated funds for increased technical and financial assistance are needed not just redirecting funds which are woefully inadequate. The Draft Action Plan should provide cost estimates not only for existing but for new spending programs. As the plan implies, the success of follow-up actions (#3, #4, #5) is dependent on accurately determining the magnitude of funds needed to effectively implement the planned activities through 2005 and beyond.

Conclusion

To be successful, the Draft Action Plan must continue to fully endorse the voluntary, incentive-based approach for agriculture to effectively participate in the agency's efforts to reduce, mitigate and control Hypoxia. What is needed are additional resources better targeted to impaired watersheds and directed at on-the-ground activities and practices that will result in further site-specific water quality improvements. Additional funding is needed for technical assistance, financial incentives for farmers and assistance in the development of nutrient management plans. Research funding that focuses on nitrogen utilization, efficiency, and loss reduction technology in impaired watersheds is critical to achieving long-term solutions for reducing nutrient loss. Agricultural research, improved water quality monitoring, technical assistance and conservation initiatives are keys to improving water quality while assuring an abundance of affordable agricultural goods.

Sincerely,
Floyd D. Gaibler
Vice President, Governmental Affairs

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