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Comments by the American Sugar Cane League on draft action plan for Gulf Hypoxia:

The American Sugarcane League is a trade association representing the Louisiana sugarcane growers and raw sugar cane processors. The Louisiana sugarcane industry is located in 25 south and south-central Louisiana parishes. Much of the sugarcane crop is grown along bayous and rivers that were once tributaries of the Mississippi river. The members of the Louisiana sugarcane industry are keenly aware of the benefits of this state's abundant natural resources and the importance of preserving them. The sugarcane industry owes its very existence to the land formed from the rich delta deposits of the Mississippi river. As an agricultural enterprise, it is rather ironic that we must now take issue with a system that for many thousands of years has enriched and formed the South Louisiana landscape. Now that man has channeled the river and altered the system (albeit for the greater common good) it is important to recognize that a proper balance must be restored for long term benefits to be realized.

Since sugarcane fields do not drain into the Mississippi river, and the Louisiana sugarcane industry has not been identified as a major contributor to the Gulf Hypoxia problem, it is difficult to comment on some of the issues brought forward. But, as a part of the agricultural community, it is wise to remain vigilant and informed of the latest science dealing with this issue. Nutrient over-enrichment has been cited as the major contributor to the Gulf of Mexico "dead zone". Since a large portion of the nutrients appear to be from non-point sources, this is a major part of identifying a solution. It is important to encourage further work to identify all sources of nutrient overloading and inform everyone discharging into the river system of the latest data. It is equally important for all stakeholders to be in agreement with the action plan for it to work.

The concept of implementing a cooperative, non regulatory action plan to address the Gulf Hypoxia problem is good. The agricultural community would be best served by this approach instead of being faced with mandatory regulations that would be difficult to implement and manage. One must question what the impact of the proposed TMDL regulations will be. How much overlap will there be? In reality there are many more questions than this. One can easily be confused with the many proposed regulations that could potentially affect them.

Commenting on the coastal goals, it seems as though the coastal goal 1.C is certainly less restrictive than 1.A or 1.B and appears to be the most practical at this point. The importance of adopting a practical, workable plan is critical for implementation. One could ask if the coastal goal should be more precise, but since there is still some uncertainty as to whether nitrogen alone is the major culprit, this goal allows for the greatest flexibility. It is uncertain whether the reduction of nutrients is expected to be in the 20%, 30%, or 40% range like 1.A and 1.B. Additional information on the role that phosphorus or other nutrients contribute to the problem may likewise need to be addressed.

Commenting on key roles and responsibilities: Private Citizens and Businesses: Education is a key component for successful implementation of any project. Adequate funding is needed for "real world" demonstrations of pollution prevention measures, BMPs and other publicly visible educational tools. The Cooperative Extension Service has successfully used this technique to encourage the use of recommended agricultural practices. Demonstrations may likewise encourage private citizens to realize the importance of their actions. Additional funding may also be needed to validate current BMPs for long-term impact and effectiveness. Incorporating the idea of incentives to allow landowners and producers to establish buffer strips, use cover crops or refine the use of variable rate technology or other measures to reduce nutrient loads may likewise have merit.

One more area of concern is funding levels to complete the outlined actions within the suggested time frame. Is the present level of funding adequate? If it is, then the chances of new projects getting enough funding is good. It seems as though present projects are underfunded. If this is true, how can this issue attract more attention and become a higher priority? If additional inputs or practices are necessary for Landowners; in particular agricultural producers to minimize nutrient runoff, will the compensation be adequate?

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