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COMMENTS ON

DRAFT PLAN OF ACTION FOR REDUCING, MITIGATIN AND CONTROLLING HYPOXIA IN THE NORTHERN GULF OF MEXICO

I commend the EPA and the Task Force for the effort in getting this Draft Plan developed and out for public review. The following comments are offered for your consideration.

General Comments

  1. The plan is quite comprehensive in addressing issues that need attention. That is good.
  2. The plan is much too weak in the accountability of who must do what by when to achieve the stated goals. Without much greater accountability, the plan will be nothing more than a paper exercise and the needed controls will be put off for a long time at the expense of the Gulf of Mexico.
  3. The use of the Adaptive Management approach is good. But it needs much more accountability built into it.

Specific Comments

  1. Section: Long-Term Goals. The document says the goals are "three-fold". However, only one goal is actually listed-"Coastal Goal". In the copy of the document on the EPA web site the other two goals were not listed. That is a problem for the reviewer!
  2. Three options are presented for the coastal goal. I strongly endorse proposed goal 1A. The reasons for this are explained below.
    • Proposed Goal 1A: This goal sets a measurable goal of the cause of the problem-nutrients. It is impossible to determine when a goal is met unless there is a way to measure progress and success. This proposed goal focuses on nutrients, which it should, and sets a quantitative measure which it should. Using the Adaptive Management approach, the Task Force can then assess progress or lack there of and adjust the control programs as needed. KEEP THIS GOAL!
    • The entire Action Plan is a bold step forward to address the hypoxia problem. The shear immensity of the undertaking to control nutrients over a major portion of the US is an ambitious undertaking. USEPA and the Task Force are to be commended for doing this Action Plan. Now is the time to be bold if the Action Plan is to ever get off the ground. Therefore, a clear, achievable goal needs to be stated, adopted and then actions undertaken to achieve it. If a wishy-washy goal is chosen, the Action Plan will have no credibility!
    • Proposed Goal 1B: At best this is a surrogate measure of the problem. It focus on the effect, not the cause. This goal lacks the needed way to get to the accountability of controlling the sources of the problem-nutrients. This is a vague, wishy-washy, and an almost worthless goal. It will allow people to duck responsibility to undertake needed corrective actions to reduce the hypoxia.
    • Proposed Goal 1C: This goal is absolutely worthless if the Task Force really is serious about achieving a fix to the hypoxia problem! This proposed goal is vague, not measurable, and, if adopted, will certainly mean that the Task Force report will go on a shelf to be ignored because no one is accountable for anything. Words like "pursue practical, cost effect efforts" or "reducing nutrient over-enrichment" are meaningless. There is a total lack of accountability or sense of responsibility portrayed! Drop this goal!
  3. The short term actions and time-frames are excellent and should be retained (as modified by the comments that follow)! They clearly delineate who must do what by when which is needed to address the hypoxia problem!
  4. Short term action number 3 needs to be modified. Words like "significant discharges of nutrients" are vague. It begs the question, "significant" compared to what? As written, this action step could be interpreted that all point sources must reduce their loadings of nitrogen starting now. This fuels the ongoing debate that the point sources always get regulated or over-regulated while the non point sources get by with voluntary actions at their own pace. This action step, unless modified, will result in the point sources fighting this strategy versus supporting it. That would be an undesirable outcome of the choice of words used.
  5. Short term action number 2 discusses developing strategies for nutrient reductions in sub-basins with the greatest contribution of nutrients. It is recommended that the final Action Plan stress that theme as the main approach. If it is really necessary to single out point sources, do it in a less painful and anger-producing fashion. Consider something like the following: #3. By Fall, 2001, acting upon what is learned from the sub-basin assessments in action 2, States and Tribes within the Mississippi and Atchafalaya River Basin will use whatever authorities they have to address the largest sources of nutrients in those sub-basins and undertake steps to reduce those loadings as soon as is possible consistent with the quantitative goals established.
  6. The "Key Roles and Responsibilities" discussion is good. By necessity this has to be a bit general. Under the second dot point under "States and Tribes" it is recommended that this be modified to say, "…(TMDLs) for nutrients for those waters…..". I am sure you meant to specify nutrient TMDLs versus all TMDLs.

These comments are submitted by Dale S. Bryson. Telephone: 630-305-7933 or E-mail: cleanwater@sprynet.com.

E-mail: ebbeyer@aol.com

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