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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:

  1. We recommend adoption of "Coastal Goal" 1A, to reduce nitrogen discharge 20-40% by 2010 by curbing point sources, reducing nutrient runoff from agricultural operations, and by intercepting nutrients with restored riparian buffers and wetlands as it provides the most specific and measurable goals and provides for the greatest ancillary environmental benefits. However, we caution that while riparian buffer strips have proven to be effective at reducing nitrogen, phosphorus, and sediment loads in farm runoff, buffer strips have also proven to be ecological traps for nesting birds. We suggest consideration of restoring large tracts of native riparian buffers where feasible in prairie landscapes to avoid creating or exacerbating an ecological problem in the course of solving nutrient runoff problems.
  2. The Implementation Actions are ambitious, but achievable, especially if the implementation of this Action Plan embraces organizations and partnerships that are already working effectively on the landscape with private landowners and achieving nutrient reductions.
  3. The listing of Federal programs in the section "Funding the National Effort" appears to be reasonably complete. However, we caution against assuming that Congressional authorization and appropriation of these programs is secure. The Farm Bill is scheduled for reauthorization in 2001 and efforts are already underway to prepare for the deliberations that will occur in trying to maintain conservation programs for agricultural producers. Currently, both the Conservation Reserve (CRP) and Wetland Reserve Programs (WRP) are very near their enrollment caps of 36.4 million and 975 thousand acres, respectively. Ducks Unlimited has been very active in advocacy efforts to increase these caps so that these programs continue to provide a conservation option to landowners and broad based environmental benefits to our nation. Clearly, continued advocacy efforts are needed if these programs are to remain available and assist with reducing nitrogen and phosphorus loading into the Mississippi River and Gulf of Mexico.

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

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