8 September 2000
Mississippi River/Gulf of Mexico Action Plan (4503F)
c/o U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC 20460
Dear Sir or Madam:
Thank you for the opportunity to comment on the Draft Action Plan for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico. Rarely, has our country faced an environmental problem of such geographic expanse with such a diffuse cause. Ducks Unlimited finds the action plan accurately targeted, reasonably specific, and generally well done. We agree with the conclusion that coordinated private and government efforts to improve farming techniques and restore wetlands and riparian buffers are critical to reducing losses of nutrients into the Mississippi River watershed and ultimately the Gulf of Mexico. We also applaud the adaptive management approach that is suggested and recommend the development of strategic GIS models to assist in targeting restoration projects at the landscape level.
The critical role that private conservation organizations and private landowners play in implementing large-scale landscape changes is not well documented or described. Indeed, since 1984 Ducks Unlimited has protected, restored, or enhanced 1,022,771 acres of wetland and associated upland habitats throughout the Mississippi River Basin and has provided on site technical assistance to private landowners to help make their agricultural practices more environmentally friendly on another 1,486,441 acres. Within the key nitrogen source areas of Iowa, Illinois, Indiana, southern Minnesota, and Ohio, we have protected, restored, or enhanced 207,199 acres and provided technical assistance to private landowners on another 24,031. Other private conservation organizations such as The Nature Conservancy, the Rocky Mountain Elk Foundation, Pheasants Forever, and the National Wild Turkey Federation also are very active in the Mississippi River Basin, and their efforts have helped conserv hundreds of thousands of acres of additional habitat. These accomplishments are the result of working in partnership with many public agencies and private organizations and nurturing relationships with private landowners to find winning solutions for both the environment and agricultural production. Given the success of these efforts we recommend that you add Private Conservation Organizations under the list of Key Roles and Responsibilities with the following suggested text:
"Private Conservation Organizations have an interest in clean water and healthy wetlands and associated uplands that sustain fish and wildlife populations, biodiversity, and recreational opportunities. These organizations have professional staffs that have developed strong relationships with private landowners that allow efficient and effective delivery of habitat conservation projects. Partnerships with private organizations also allow for increased congressional support and allow government programs to better leverage funds and expertise."
In the prairies of the Great Plains and Midwest our programs target the protection and restoration of native grasslands to enhance nesting success of waterfowl and other prairie nesting birds. Research on these restored grassland habitats has shown a nitrate reduction in runoff of 98% compared to adjacent croplands. In the Lower Mississippi Alluvial Valley, efforts of the Partners for Fish and Wildlife Program provide winter flooding of harvested rice fields to provide foraging and resting habitat for waterfowl and many other wetland birds. Research on this practice has shown a 97% reduction in sediment loss and a 96% reduction in nitrate runoff compared to traditional tilled and drained fields. These efforts are already contributing to reducing nutrient loading in the Mississippi River Basin and opportunities for expansion of these efforts to further improve water quality are enormous.
In regards to the specific questions posed in review of this draft plan we offer the following recommendations:
Thank you again for the opportunity to comment on this Action Plan and provide suggestions for its successful implementation. We look forward to continuing our work with public agencies and to establishing new partnerships to enhance efforts to reduce hypoxia and provide many more environmental benefits to our nation's lands and waters.
Stephen E. Adair, Ph.D.
Director of Conservation Programs