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September 6, 2000

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

Dear Members of the Work Group:

The State of Missouri welcomes the opportunity to participate in the drafting of this Action Plan and expresses its appreciation for the efforts of those who have worked to prepare this draft. Missouri supports the overall goals of the Draft Action Plan and looks forward to working with the federal agencies and the other states in the Basin to reduce hypoxia in the Gulf of Mexico while improving local water quality.

We offer the following specific comments that are keyed to the Draft Action Plan.

Long-Term Goals

We suggest that option 1.B be edited to read "to reduce the 5-year running average areal extent of Gulf of Mexico hypoxia to less that 5000 square kilometers by the year 2010. Identification of specific actions within the basin, to achieve the necessary nutrient load reduction, should be developed through the implementation actions outlined in this Action Plan." Such a goal is quantitative and focuses on the problem that we are addressing in the Gulf of Mexico without including additional criteria that may or may not be appropriate.

We also suggest that an explicit research goal be added to the list in recognition of the need for research as an element of the adaptive management approach noted in the text. Research Goal - "to increase our knowledge of the Mississippi/Atchafalaya River and Gulf of Mexico systems in order to improve our understanding of the hypoxia phenomenon, its causes and the most effective steps to mitigate the water quality impacts of human activities."

Implementation Actions

General The timelines presented in the Action Plan are extremely ambitious. Many states are currently heavily committed to actions related to the 2000 Impaired Streams (303d) list and the implementation of Total Maximum Daily Loads for those watersheds. While some of the actions proposed for 2001 compliment these efforts, we suggest extending the timeline in order to make reaching the deadlines more realistic.

#1 The Missouri and Upper and Lower Mississippi River watersheds already have committees in place. This action appears to duplicate the coordination efforts of those groups and to recommend a great increase in the number of interstate committees. States have been responsible for implementing national guidelines for years; adding more groups and more meetings for sub-watersheds will simply divert resources from mitigating the problems.

In addition, money has flowed historically through the states for water quality programs. Unless some compelling reason to change this approach is offered, state agencies should continue to be the judge of what is working best in their states. Please note that we do support #8 in this section because that offers a consistency critical to assessing the entire basin.

#2 Edit to read: "along and adjacent to the Mississippi River, its tributaries and distributaries,".

#7 The proposed monitoring efforts are a critical component of this effort. Coordination and standardization will be necessary to ensure consistency in results and analyses throughout the basin. We suggest that the EPA and USGS meet with the state agencies involved in water quality monitoring to agree on protocols for this effort. This need not delay the implementation of enhanced monitoring, but is important to ensure that results of monitoring are comparable across the basin. A coherent monitoring program is also necessary to determine which approaches are most successful.

#10 Change "Task Force will determine" to "Task Force will recommend". Implementation will occur at a local level to be most suitable to the specific sources and conditions.

Key Roles and Responsibilities

States and Tribes

#2 Prioritization depends on numerous factors related to the severity of the impact, whether the affected stream is a drinking water source, and numerous local factors. The TMDL process may not match the requirements of this plan. A stream may not be impaired by nitrogen, yet still be a significant contributor to hypoxia or a stream may actually be listed as impaired by another pollutant with nutrients only peripherally addressed through the TMDL process. Finally, water quality impairments that threaten human health human health are always our first priority.

#3 Minimum national standards should be developed and the EPA should be a full partner in developing state standards. Without federal guidance we risk an uneven playing field that will undermine the broad, cooperative approach necessary to address hypoxia. Compare this entry with the last item under "States, Tribes and Federal Agencies" in which the federal role is expressly included.

#5 (new) We propose that each state develop an EPA-approved non-point source management plan. If non-point sources are critical sources of nutrients, these plans should play an important role in directing state responses. The development of such plans is an important step in the assessment of current conditions and the implementation of the required changes.

States, Tribes, and Federal Agencies

#3 Use of 319 monies has always been left to the discretion of the States and Tribes and it should remain so. If this problem is a high priority, then resources should be identified to solve hypoxia without diverting funds from a successful program that has been used to address a broad range of water quality issues. In addition, this statement is overly broad and suggests that other potential uses of 319 funds must be a lower priority than the purposes listed.

Framework and Approach for Reducing Hypoxia…

#1 Add "point source". Given the uncertainties about wastewater inputs after the last St. Louis Task Force meeting, point source reductions may be significant.

Agricultural Nutrient Efficiency Fund

Add : "Significant funding resources must be identified for implementing the incentive-based parts of this Action Plan. Specifically, NRCS funding for Nutrient Management Plan development is critical to achieving agricultural non-point source reductions." Funding restrictions at NRCS are slowing the implementation of Best Management Practices and Comprehensive Nutrient Management Plans and will limit the gains envisioned in this plan unless funding is forthcoming. Once again, this effort will overlap with TMDL analyses and implementation plans.

Mississippi River/Gulf of Mexico Action Plan

Failure to garner support for NRCS efforts will greatly diminish the effectiveness of the proposed Plan and lengthen the time periods required to achieve the desired nutrient reductions.

Thank you for the opportunity to contribute to the preparation of this plan.


Stephen Mahfood

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