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Office of the Chancellor
P. O. Box 25203
Baton Rouge, Louisiana 70894-5203
(225) 388-4161; Fax: (225) 388-4143

September 11, 2000

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

Dear Task Force Members:

I have asked my faculty to review the proposed Hypoxia Action Plan. After our internal review, I am forwarding the following comments.

We are encouraged that there is language in the text to indicate that our concerns about the underestimation of the nitrogen contribution from urban sources has at last been considered. However, the numerical data included in the proposed Action Plan still attributes only 11% of the nitrate load to point sources. As noted at the St. Louis Task Force meeting, if Louisiana has 2,500 domestic sewage treatment plants with over 1,700 LPDES (NPDES) permits, we find it difficult to believe that the other 30 states have only the remaining 4,800 permits. This is an average of 160 per state, one tenth of that found in Louisiana. Please clarify. Further, it is our opinion that the assumption of the Nutrient Sources Committee that all municipal water treatment plants without nitrogen load discharge data are operating at the potential efficiency of secondary treatment, may not be accurate. Much more data analysis and clarification is needed.

The allocation of 24% of the nitrogen load to other unspecified nonpoint sources, which we assume includes both atmospheric deposition and urban stormwater runoff, also causes us some concern. Atmospheric deposition alone has been determined to contribute up to 30 % of the nitrogen in some watersheds along the U.S. East Coast. Additionally, the USGS study of runoff from residential areas in East Baton Rouge Parish, Louisiana indicates that both urban and suburban areas have high loads of nitrogen runoff. The loadings seem to be highest in areas where home sewage treatment is used (27 pounds/acre/year) followed by subdivisions with central sewage collection (23 pounds/acre/year). These loads exceed the nitrogen contained in surface runoff from agricultural fields.

We have concerns about the attribution of farm land and the proportion of this land that is reportedly using subsurface drainage. The numerical data are not contained in the Nutrient Sources Report; therefore, we must attempt to interpret the maps included in this report. In reviewing the maps of Louisiana, several glaring discrepancies appear. The amount of farmland represented in the eastern portion of the state is quite excessive (may be as much as three to five times overstated). This is followed by a massive misrepresentation of farmland implementing subsurface drainage systems. There is no tiled drained farmland in Louisiana! There are a few test plots but no commercial fields. This over statement may be leading to an excessive estimate of tile drained acreage included in the agricultural source category. This is significant because of the estimated nonpoint loadings from tile drained fields of up to 50 pounds of nitrogen per acre. This possible over-estimate could call into question the accuracy and completeness of the source data base outlined in the report.

Specific comments on management plan components are outlined below:

Long-term Goals:

  • Coastal Goal - We would encourage the adoption option 1.C–to pursue practical, cost-effective efforts by all states and tribes within the basin and all categories of sources to protect the ecological and fisheries resources of the northern Gulf of Mexico by reducing nutrient over-enrichment.
  • Within Basin Goal - We highly suggest that the "Within Basin Goal" include some reference to maintaining economic viability in rural communities and in the agricultural production sectors within the basin. We feel that the potential negative economic impacts associated with hypoxia plan implementation should be measured as well as the ecological impacts.
  • Quality of Life Goal - We support the voluntary, incentive-based approach to addressing hypoxia in the Gulf. This will lead to enhanced user group buy-in and increase the possibility of building partnerships within the Basin.

Comments on Implementation Actions:

  1. By Summer 2001 - We highly suggest that Land Grant institutions and key agricultural leaders be included as members of the sub-basin committees that will coordinate implementation of the Action Plan.
  2. By Fall 2001 - We highly suggest that Land Grant institutions be involved in the development of nutrient reduction strategies in each sub-basin with greatest contribution to Gulf hypoxia, including setting reduction targets in metric tons of nitrogen, establishing a baseline of existing efforts for nutrient management, identifying opportunities to restore flood plain wetlands along and adjacent to the Mississippi River, and detailing needs for additional assistance to meet goals and promote additional funding.
  3. By Fall 2001 - We would encourage that funding be provided to assist municipalities in reducing the loadings from both their point and nonpoint discharges. This may prove to be the most cost effective method of reducing nitrogen loads in the Mississippi.
  4. By Spring 2002 and #5 By Fall 2002. We endorse the increase in assistance and funding to landowners and businesses for voluntary implementation of BMPs.
  5. By Fall 2001 - We strongly encourage that the integrated Gulf of Mexico Hypoxia Research Strategy include research expertise from Land Grant institutions in addressing the serious uncertainties regarding the sources, effects (including the economic effects), and geochemical processes causing hypoxia in the Gulf.

Comments on Key Roles and Responsibilities:

  • Private Citizens and Businesses - Land Grant institutions' extension and outreach efforts will have to be significantly enhanced if farmers, landowners, and municipalities are to be provided with additional information about environmental problems, practical and cost-effective solutions, technical assistance, and the availability of financial assistance. This will require additional funding to appropriate institutions within the Basin.
  • State, Tribes, and Federal Agencies - We strongly support efforts to reduce the continued loss of coastal wetlands along Louisiana's coast. We feel that nutrient and sediment contributions to the near shore Gulf associated with the annual loss of 25-30 square miles per year are significant. River diversions and other related restoration projects that further the goals of restoring coastal wetlands, removing nitrogen, capturing sediments, and protecting near coastal water quality from excessive nutrient enrichment should be encouraged.

    Additionally, we request that the list of interest groups in this section include municipalities and municipal/local governments if we are to have towns and cities participate in the nitrogen reduction process. This group should also be included before additional actions are taken by Federal Agencies under the NPDES Program and the Storm Water section within the Clean Water Act.

    We also have some concerns about the enhanced wetlands and riparian zones that are proposed in the plan. While effective in removing sediment and other suspended solids, the data quantifying significant removal of dissolved nutrients (nitrogen and phosphorus) is inconclusive. It is our opinion that considerably more research needs to be done in this area to define the amount of removal that can be obtained by different plant species mixes, buffer widths and under different climatic/physical conditions. Compensation to landowners taking land out of production for buffer implementation will also need to offset current and long-term crop production losses.

    Land Grant institutions must also be engaged in developing and implementing research that will be required to reduce the uncertainties in the scientific assessment and improve the BMPs that may help in reducing nutrient losses from nonpoint and point sources.

  • Federal Agencies - Increased Land Grant institution involvement and funding will be required to achieve the goals outlined for federal agencies. The goals include state-targeted watershed-based outreach to increase steam-side buffers, increase participation and acres under CRP and WRP, increase acreage in conservation tillage, increase number of producers under voluntary nutrient management plans, and improve animal waste management practices. Outreach and education initiatives, like the Master Farmer Program, (currently being developed and implemented in Louisiana) will require increased funding commitments and multi-agency partnerships.

    Additionally, we highly encourage the consolidation of all related federal initiatives addressing water quality improvement on the ground. Reference to TMDL rules and the Coastal Nonpoint Source Program, administered by different federal agencies, is quite confusing and may lead to landowner/farmer frustration.

In closing, we would like to mention the following additional initiatives of importance that may lead to increased landowner/farmer participation and cooperation in the implementation of cost-effective BMPs throughout the Mississippi River Basin:

  • LMVI - Six states (Louisiana, Arkansas, Mississippi, Kentucky, Missouri, and Tennessee) have come together to form a Lower Mississippi Valley initiative based on seven agreed upon objectives. These include (1) increase public awareness of the importance of agriculture; (2) frame agricultural profitability - environmental stewardship linkage; (3) advocate a voluntary approach; (4) outline producer incentive programs required for success; (5) identify essential research, extension and technical assistance needs; (6) establish funding requirements; and (7) impact key conservation-related components of the 2002 Farm Bill. A LMVI draft plan of action should be completed by October 2000. We highly encourage that the Task Force evaluate the components of this plan and endorse/support the outlined actions that have achieved multi-state endorsement.
  • Increased research - We agree that the environmental responses to the hypoxia management actions in the basin are very speculative and will likely take decades. We therefore, strongly advise that extensive research be conducted to establish causes and solutions that will result in tangible results with minimal economic impact to agricultural producers. This uncertainty was made very clear when we saw the size of the Gulf hypoxic zone go from 8,000 square miles in the summer of 1999 down to 1,800 square miles in the summer of 2000. Even though we have collected extensive scientific data on Gulf hypoxia, these extremes (which occurred during two years of drought conditions) tell us that we have much to learn before definitive actions are taken.
  • Agricultural Industry Decline - With the most serious economic downturn in recent years now being experienced in the agricultural production sector, we must make sure that management actions do not inflict additional hardship on an already struggling sector of our natural economy. This point should not be taken lightly.
  • Basin Public Hearings - Because the actions being proposed may result in significant impacts on farmers, landowners, and municipalities, we highly suggest that public hearings be conducted throughout the Basin before the management plan is approved and implemented. The Extension Service could assist in planning and conducting such meetings.
  • Education & Research Enhancements - Lastly, we believe that additional education and research will be crucial to the implementation of a successful voluntary program in the Mississippi Basin. Increased funding for extensive Land Grant institution associated education (Extension Service) and research (Experiment Stations) throughout the Basin will be necessary to achieve the effort required in all associated states. We suggest that appropriate funding for these efforts be included in the hypoxia budget initiative listed in the plan.

Thank you for allowing us to submit comments. Please feel free to call if I can be of any additional assistance.

William B. Richardson, Chancellor
and Chalkley Family Endowed Chair

c: Congressional Delegation

Governor Mike Foster

Commissioner Bob Odom - LDAF

Secretary Dale Givens - LDEQ

Mr. Ronnie Anderson - LFBF

Dr. Leo Guedry

Dr. Jack Bagent

Dr. Larry Rogers

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