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Comments from the Louisiana Department of Environmental Quality

(1) In both Long Term Goals 1.A. and 1.B, we have used the time period 1980-1996 to base our percent nitrogen loading reductions on. I had suggested to Don Scavia and do also here that maybe we should consider using just 1980-1992 which would preclude the use of the 1993 nitrogen loading data which clearly was a once in a century or more event and far exceeds the nitrogen loading records from the previous years. This also considers that a lot of the nitrogen loading coming down that year was from inundated sources that no NPDES permit, BMP or management plan could have prevented.

(2) In 1.B we are still using, "The best current science...". I prefer the comment from Wayne that we use "Current studies indicate..." instead.

(3) In the Indicators of Success/Progess Section, Environmental Indicators last bullet in the back of the Plan (last page), we say "...characteristic of non-hypoxic conditions...". Because we are not talking of returning the conditions in the Gulf to completely "non-hypoxic" conditions, I suggest we say "...characteristic of more normal or natural hypoxic conditions...". This is more in line with our 10 year goal to reduce hypoxia to 5,000 sqK. Totally non-hypoxic conditions at all times and locations in the Gulf may not be realistic or necessary to maintain productive fisheries in the Gulf. We can still measure and expect to see a return to a more normal diversity and abundance and normal migratory patterns of key species with a reduction to 5,000 sqK hypoxic conditions.

(4) In the Program Indicators subsection 5th bullet, we are proposing to use the "states with fully approved Coastal Nonpoint Source Pollution Control Programs". For the watershed, I think that Louisiana and Mississippi are the only coastal states unless we are going to count Texas, Alabama and Florida as other Gulf States. Overall state nonpoint source activities outside the coastal zone in inland rural watersheds such as the Tensas in Louisiana and Yazoo in Mississippi will have more impact on hypoxia than true "coastal" watersheds. All Gulf states will eventually get approved coastal nonpoint programs but I don't think it helps us here as a programmatic indicator and would prefer to see it deleted. I think it will be adequately covered by the continued operation and maintenance of the overall state nonpoint source programs. Currently Louisiana is finishing an update of our statewide NPS program as are all states in the watershed. I would be more useful to know that all states in the watershed have approved updated statewide nonpoint source programs.

Dugan Sabins
Louisiana Department of Environmental Quality
Water Quality Management Division
7290 Bluebonnet Blvd.
Baton Rouge, LA 70884-2263
Phone: (225) 765-0359; Fax: (225) 765-0635

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