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September 7, 2000

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

The undersigned agricultural organizations submit these comments regarding the U.S. Environmental Protection Agency's (EPA) Draft Action Plan for Reducing, Mitigating and Controlling Hypoxia in the Northern Gulf of Mexico.

We represent a vast array of agricultural interests, all of which have a vested and demonstrated concern about our environment. We have a long history of implementing conservation and other stewardship practices. We represent the majority of privately held land in the Mississippi River basin, and strongly believe that successful plans to reduce nutrient losses to the environment will be built on current practices and programs which are voluntary and incentive-based.

Hypoxia is the result of several natural and man-made factors working together. The scientific assessments that led to the draft action plan have focused only on addressing nitrogen while virtually ignoring other significant factors. An action plan based only on reducing nutrient loss is highly unlikely to have any significant impact on Gulf of Mexico hypoxia. We cannot expect that a series of actions that are designed to address only nitrogen, instead of all facets of a multi-part problem will ultimately do much to reduce hypoxia in the Gulf of Mexico.

The action plan lists three alternative coastal goals. The first is a numeric goal for reducing discharges of nitrogen to the Gulf via the Mississippi/Atchafalaya Rivers. A numeric goal is inappropriate for an action plan that relies on voluntary, incentive-based actions by millions of stakeholders in multiple jurisdictions. There is also wide dispute about the actual effect on the hypoxic zone that would result from such a goal. Nutrient loads to the river are a contributing factor to hypoxic conditions, not a directly correlated primary cause of hypoxic conditions.

The second alternative focuses on a reduction of the hypoxic zone itself - but then circles right back to the first alternative by saying the way to achieve this is through a 30 percent reduction in nitrogen loads. The dramatic reduction in the size of the zone this year is testament to the overwhelming impact of natural phenomenon in dictating the size and duration of hypoxia in the Gulf.

The third alternative is far more appropriate to a voluntary, incentive-based plan. However, it still seeks to draw a cause-effect relationship between upstream actions and downstream results. Farmers should be educated on the benefits of voluntary, incentive-based actions they can implement that will make them more profitable and reduce potential impact on local water quality. Farmers have an economic self-interest in reducing nutrient losses. Nutrient loss reductions are direct cost-savings for farmers. That's why farmers are continuing to use soil tests, fertilizer timing and placement methods, nutrient management plans and other BMP's to make maximum use of all nutrient sources. The widespread adoption of conservation tillage practices has helped reduce nutrient loss.

The "Within Basin Goal" is too broad, vague and singular in its focus. The real goal should be to continue to provide farmers the education and resources necessary so they can continue to be productive, while also considering the impact their actions have on the local watershed and ecosystems. Water quality goals also have to be seen within the context of other societal goals, particularly food production and food security. Both can be addressed simultaneously, but this action plan fails to achieve such balance.

The "Quality of Life" goal is the best statement of any needed goal. It is the only one that recognizes the important economic goals and the important role of the private sector in meeting the overall goals of the action plan.

The scientific assessment process has evolved from listing a single cause of hypoxia to now listing three factors: 1) excessive nutrients, primarily nitrogen; 2) physical changes in the basin, such as channelization and loss of natural wetlands and vegetation; and 3) stratification in the Gulf.

As this year's results showing a greatly diminished zone demonstrate, other factors which contribute to hypoxia can be managed. The discharge of the Mississippi and Atchafalaya Rivers is managed and controlled by federal law. Dr. Rabalais cites lower than average discharge as one reason for the reduced size of the zone this year. We believe the action plan can be much broader in suggesting to Congress possible actions that can be taken.

For example, a U.S.G.S. study, "Effect of Stream Channel Size on the Delivery of Nitrogen to the Gulf of Mexico," Nature, 403: 758-761, finds that nitrogen is naturally removed from small streams more quickly than from large rivers. The study concludes 'that the proximity of sources to large streams and rivers is an important determinant of nitrogen delivery to the estuary in the Mississippi basin, and possibly also in other large river basins.' In other words, nitrogen deposited directly into the Ohio River probably has a greater chance of reaching the Gulf of Mexico than does nitrogen originating from a field in Iowa that has to travel through miles of shallow ditches and streams before reaching a river. This information should be used to help focus future activities.

The Final Action Plan must include a more transparent and substantive discussion of the costs and benefits of the plan. Public Law 105-383 requires that "the plan shall also include the social and economic costs and benefits of the measures for reducing, mitigating, and controlling hypoxia. The draft outlines broad new spending programs and suggests additional spending on current programs, but fails to define the costs of the proposed action plan."

The Draft Action Plan makes no attempt to focus on in-the-field- activities to address nitrogen losses. The Plan calls for two years of establishing sub-committees and coordination among smaller watersheds and states in order to detail needs for additional assistance and develop promotional materials to request these funds. Instead of focusing on a top-down, leveraged takeover of local decision-making, the Final Action Plan should focus on apportioning the budget to those programs that are identified as keys to minimizing nitrogen losses to surface waters in the Basin. Further, the Final Action Plan should delineate what percentage of these funds will be expected to go to in-the-field technical assistance and infrastructure projects versus how much will be spent on other costs.

We in the agricultural community are committed to more efficient nutrient use. We continue to support voluntary, incentive based programs that help farmers adopt these types of practices. An action plan must be built on current voluntary programs that are successful and not propose the use of new regulatory requirements. We support additional funding for nutrient management, conservation buffers and other best management practices aimed at reducing nitrogen loss. We support additional funding for water quality monitoring and even for further scientific work on Gulf hypoxia. We do not believe strict numeric goals are appropriate for a voluntary, incentive-based approach. Voluntary programs that include farmers and scientists throughout the Mississippi River Basin will promote the cooperative effort necessary to address this issue.

Sincerely,

Agricultural Retailers Association
American Farm Bureau Federation
CF Industries
IMC Global
National Association of State Departments of Agriculture
National Cattlemen's Beef Association
National Corn Growers Association
National Cotton Council
National Milk Producers Federation
The Fertilizer Institute
USA Rice

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