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September 11, 2000

Mr. Chuck Fox
U.S. Environmental Protection Agency
Gulf of Mexico Hypoxia/Mississippi River Watershed
Nutrient Task Force

Dear Mr. Fox,

I am submitting comments on the Draft Action Plan for Reducing Gulf of Mexico Hypoxia on behalf of the Dogwood Alliance, a coalition of 61 organizations dedicated to protecting the native forests and other natural systems of the southeast. While the Draft Action Plan rightly focuses on agricultural runoff and municipal water systems as key sources of nitrogen input into the Mississippi River basin, we are concerned that there are other significant sources of nitrogen that have not received adequate attention from the Task Force.

The Dogwood Alliance is extremely concerned about the growing impacts of industrial forestry on landscape and watersheds. These impacts include the spread of high capacity wood chipping mills, an increase in intensive clearcutting, and the resulting loss of native ecosystems through conversion to heavily managed monoculture plantations. These activities can have significant effects on water quality, such as erosion of sediment and liberation of nitrogen in the breakdown of soil, which have not been adequately addressed in many states’ TMDL programs. However, an additional impact of industrial forestry practices on water quality, and on nitrogen loading in particular, comes from the aerial spraying of fertilizers. This spraying is done primarily in the highly managed stands of monoculture pines that are designed for short rotation cycles, and thus demand high growth rates and compensation for soil depletion. Whereas in agricultural application nitrogen-based fertilizers are usually worked into the soil, aerial spraying deposits large amounts of material on plants and other surfaces as well as the soil, which is then easily washed into water bodies when it rains.

Our systematic aerial and field surveys show that there is a striking increase in native forests being converted to intensively managed pine with an increase in the aerial application of in the Tennessee River Basin, which is of course part of the Mississippi River Basin. To further quantify changes, we have contracted with the University of Tennessee Geography Department to conduct a GIS and satellite imagery to quantify the changes in forest type and the increase in pine plantations in 36 counties of the Cumberland Plateau over a 20 year period. In addition, we have requested the Tennessee Wildlife Resource Agency (TWRA) begin an assessment of aquatic wildlife impacts associated with the heavy applications of fertilizer in streams that transect pine plantations.

We also know, however, that intensive industrial forestry is being carried out throughout the Mississippi River Valley. Some indicators of this are the spread of wood chipping mills in all the states along the river from Missouri south, and the export of wood chips from the ports of New Orleans, Port Arthur, and Lake Charles. There is also every reason to expect that the spread of monoculture pine plantations in these states will result in an increase in the use of aerial spraying of fertilizers.

The need to assess the impacts of aerial spraying of fertilizers and other forestry activities relative to Gulf hypoxia falls under the "Key Roles and Responsibilities" delineated in the Draft Action Plan, p.8: "In cooperation with federal agencies, States will document and monitor land use changes to identify priority areas of likely nitrogen loss to streams. States will work with the USDA to complete soil maps for all agricultural areas in the basin and evaluate in more detail the soil nutrient loading and cycling in critical areas."

We urge the Task Force to include industrial forestry practices, such as aerial spraying of fertilizer, in the list of activities that contribute to nitrogen loading into the river system, and subsequently the Gulf of Mexico, and to address the impacts of these practices in the Action Plan for Reduction of Gulf hypoxia.

Cielo Sand
Dogwood Alliance
Director of ForestWatch Program
PO Box 7645
Asheville, NC

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