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September 8, 2000

Dear Sir/Madam:

The Illinois Beef Association is a statewide voluntary membership organization representing all aspects of the beef industry throughout the state. We share many of the concerns others throughout Illinois and the Region have with the Draft Mississippi River/Gulf of Mexico Action Plan (herein "Plan"), published in the Federal Register on July 11, 2000.

We support Illinois Governor Ryan's objection to "Plan's" provision for numeric standard lowering of plant nutrient application (to farmland) as a means to reduce the Gulf's Hypoxia problem. IBA believes the "Integrated Assessment's" failure to establish a scientific basis or demonstrate a direct amount of improvement in Gulf quality to a measured reduction in plant nutrient application is sufficient justification for our objection.

In addition, the beef industry is concerned that the mandate of the Act - P.L. 105-383 is ignored. Section 604(b) requires that the President, in conjunction with the chief executive officers of the states, submit a plan for reducing, mitigating, and controlling hypoxia in the northern Gulf of Mexico. We are not aware of any "Plan" endorsement by "chief executive officers of the states." As pointed out above we know of at least one objection.

Further in the Section cited it says, "the plan shall also include social and economic costs and benefits... " We believe there will be significant social and economic costs from displaced producers, lost productive acreage base and lower production levels should this "Plan" be implemented. These costs have been totally ignored. More importantly we believe this "rush to judgment Plan" damages beyond repair much of the social fabric of the region.

We are familiar with the research of noted expert Derek Winstanley, Chief, Illinois State Water Survey and agree with his conclusion that the science does not establish the need for adopting a "Plan" to deal with either an emergency or crisis, which EPA clearly implies. At a recently concluded meeting in Illinois scientists, when discussing research needs, point out again that the "nitrogen cycle" needs further research to meet today's needs. Some were also quick to add that postulated link of Gulf hypoxia to nutrient use in Illinois might not be defensible.

The "Integrated Assessment" also outlines numerous research needs and categorizes them as either "immediate or long-term priority." IBA strongly believes results from those "immediate research priorities" should begin to "flow" to enhance the basis on which any adopted "Plan" rests.

At first glance it would appear that, while the government is here to help, its operating premise is, "We don't need more research since our mind is already made-up." We believe the premise should be; "Let's do further research to see what might be revealed and how we can solve the problem in a cost efficient manner" With no clear revelation in either the "Plan or "Integrated Assessment" of what resources might be available to states, we would strongly encourage research funding be the federal government's first priority and delay any "Plan" implementation until the problem is better understood

The draft "Plan" has been difficult to review because the discussion seems inconsistent. As an example, there is discussion about the "adaptive management framework and voluntary, incentive-based efforts" which then shifts to "a basin wide context for continued pursuit of.... regulatory controls for point sources," nutrient criteria and standards, TMDLs, NPDES permits.... There can be no doubt that the language shift mandates nutrient management goals or standards are driven by the Gulf of Mexico objectives. IBA would simply ask: "What happens to local priority needs?"

The "Plan" also throws into the No. 2 short-term actions a point about "...restore flood plain wetlands (including restoration of river inflows)...."It appears that this is an "after thought" and the Action Plan for addressing Gulf hypoxia is the shell within which to insert every other environmental goal, such as restoring wildlife habitat which is not related to the stated goal of the "Plan." Beef producers are concerned that this goal may negatively impact them in two ways: first the loss of prime farmland for row crop production and second increasing unmanaged and uncontrolled wildlife populations that carry diseases transmittable to our domestic herd.

Thank you for the opportunity to review and comment on this proposal.

Maralee M. Johnson
Executive Vice President

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