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September 11, 2000

Mississippi River/Gulf of Mexico Action Plan (4503F)
c/o U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, DC 20460

The Louisiana Mid-Continent Oil and Gas Association appreciates the opportunity to comment on the Draft Plan of Action for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico which appeared in the July 11, 2000 Federal Register (65 FR 42690). Mid-Continent is an industry trade association representing individuals and companies who together produce, transport, refine and market over 90% of the crude oil and natural gas in Louisiana. Mid-Continent represents all of the Louisiana refineries located along the Mississippi and Atchafalaya Rivers that may be impacted by the recommendations in the draft plan.

Mid-Continent supports the voluntary efforts to mitigate/control the formation of hypoxia along the northern Gulf of Mexico. Mid-Continent not only represents industry activities in this area, but many of our member company employees live near the Gulf of Mexico coastline and benefit from the recreational opportunities that a healthy Gulf provides.

It is Mid-Continent's understanding that the proposed plan is a guide for individual states to follow and not necessarily a legally binding requirement. In this spirit, Mid-Continent offers the following comment.

Implementation Action Item #3 appears to require states to "identify point source discharges of nutrients and undertake steps to reduce these loadings." Mid-Continent interprets this recommendation to require states to automatically impose reductions on large point sources regardless of historical reductions, technology availability and overall contribution to nutrient loading in the river. For example, refineries installed wastewater treatment plants in the 1970s and 1980s to greatly reduce the amount of ammonia discharged to the river. As a result of this technology, the amount of nitrates discharged increased. While the nitrate discharge amounts seem large, there is little that can be practically done to reduce these totals since they are a direct result of the control of another nutrient (ammonia).

For these reasons, Mid-Continent recommends this Action Item be revised to read as follows:

"#3 By Fall, 2001 Clean Water Act permitting authorities within the Mississippi and Atchafalaya River Basin will 1) identify point source discharges with significant discharges of nutrients, 2) review the history of nutrient reductions from these discharges, 3) review the technological feasibility of further reducing nutrient discharges from these sources, and 4) determine whether further reductions of nutrient loadings from the discharges are warranted. If action is warranted, the permitting authorities will undertake steps to reduce these loadings, consistent with Action Item 2 above."

Once again, Mid-Continent appreciates the opportunity to submit these comments.

Very truly yours,

Richard T. Metcalf
Health, Safety and Environmental Affairs Coordinator
Louisiana Mid-Continent Oil and Gas Association
801 North Boulevard - Suite 201
Baton Rouge, Louisiana 70802
(225) 387-3205 phone; (225) 344-5502 fax
Metcalf@lmoga.com E-mail

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