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Re: Draft Action Plan for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico

To Whom it May concern:

The Iowa Environmental Council would like to offer the following comments on the Environmental Protection Agency's "Draft Action Plan for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico." The Council is a statewide alliance of 64 organizations and more than 700 individual members working with all Iowans to protect our natural environment. We seek a sustainable future through shaping public policy, research and education, coalition-building, and advocacy.

The growth of the hypoxic zone in the Gulf of Mexico is a serious national problem and the Iowa Environmental Council strongly supports the Task Force's efforts to create a basin-wide strategy to reduce the hypoxic area. While development of the strategy is a significant challenge due to the large geographic area, implementation of the action plan will be even more difficult and will require the cooperation of state, federal, and local partners throughout the basin.

One of the most controversial issues in the draft Action Plan is the establishment of a goal for reduction of the hypoxic zone. The draft plan outlines three options and asks for comments on the alternatives. In order for the action plan to be successful, we feel it is essential that the goal be measurable in order to allow assessment of progress toward meeting the goal. Both options 1A (20 - 40% reduction in the nitrogen loading to the Gulf) and 1B (reduce the 5 year running average area of the hypoxic zone to less than 5000 square kilometers) are measurable and would be preferable to 1C ("Within Basin" and "Quality of Life" goals) which are more difficult to measure.

It should be noted that all of these goals are important to success of the plan and are not incompatible. We suggest the Task Force look at ways of combining these goals into a goal statement that will include elements of all three.

Because of the significant role Iowa plays as one of the main source areas for the nutrients that are causing the hypoxic zone, Iowa will need to become a leader in the implementation of this Action Plan. In many ways Iowa is well positioned to take on this leadership role with many years of success in working with farmers to reduce fertilizer use. In fact, Iowa has already begun implementing many of the steps outlined in the Action Plan with the state's $11.2 million Clean Water Initiative passed during the 2000 legislative session.

The Iowa Environmental Council is a member of the Mississippi Riverwise Partnership (MRP), a coalition of organizations working to protect the river, its tributaries, and the Gulf of Mexico. The Council has endorsed the comments prepared by MRP and we refer you to these comments submitted separately for more detailed comments on the remainder of the plan.

The Council appreciates the opportunity to provide our comments on this Action Plan. If you have any questions or if I can be helpful in any way, please do not hesitate to call.

Mark O. Lambert, Executive Director

Susan Heathcote, Research Director
Iowa Environmental Council
711 East Locust St.
Des Moines, Iowa 50309
515/244-1194 (phone); 515/244-7856 (fax)

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