Comments on Draft Action Plan for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico
September 11, 2000
Mississippi Riverwise Partnership
The Mississippi Riverwise Partnership, a coalition of organizations working to protect the health of the river, its tributaries, and the Gulf of Mexico, as well as promoting sustainable agriculture in the river basin, submits the following comments to the Mississippi River/Gulf of Mexico Watershed Nutrient Task Force.
We recognize that the creation of an action plan for the large geographic area of the Mississippi River Basin is a challenging task, and that the work of the Task Force has been made significantly harder by the large amount of misinformation and misunderstanding that has been generated around the issue of Gulf hypoxia.
The size and growth of the hypoxic zone in the northern Gulf of Mexico is a serious national problem, and deserves the dedication of national resources to implement solutions. While the elements of an effective Action Plan should be focused on the Congressionally-mandated goal of alleviating Gulf hypoxia, it is crucial to note that the actions necessary for reaching that goal are essentially the same ones needed to improve water quality upstream. Thus, an effective plan for reducing Gulf hypoxia can also deliver significant benefits for states along the upper river and its tributaries, and should be consistent with their own watershed assessments (carried out under the Clean Water Action Plan) and goals for safe drinking water and improved water quality. We believe that substantial reductions in nitrogen loading to the Gulf of Mexico can be achieved without imposing negative economic impacts on farmers and agriculture by utilizing the combination of actions identified in the CENR reports, including voluntary best management practices, restoration and protection of wetlands, and point source reductions.
Addressing Sources and Solutions
We also support the draft Plan's attempt to address all sources of nitrogen pollution in the basin, but urge that the Plan focus on directing resources where they are most needed and will have the greatest effect. As the Framework Approach section of the draft Action Plan notes, while there is no single solution to the problem, the optimal approach is to take advantage of the full range of possible actions to reduce nitrogen loads and increase nitrogen retention and denitrification, in a way that encourages adaptive management in a cost-effective manner. The CENR Reports (Mitsch, et.al) pointed out that actions such as implementation of best management and nitrogen reduction practices in agriculture, along with restoration of wetlands and planting of vegetative buffers, will have exponentially greater effects when undertaken together. They can also deliver multiple benefits of improved water quality, increased wildlife habitat, carbon sequestration, and nitrogen uptake.
The Task Force is attempting to take a cooperative, non-regulatory approach in the draft Action Plan. While we support this approach for addressing non-point sources of nutrient pollution, strong enforcement of existing regulatory standards is necessary for addressing point source discharges, including those from contaminated stormwater, municipal sewer systems, large animal feedlots, and wetland fills. We urge that the main priorities for the Action Plan be that it is comprehensive and effective. The Mississippi Riverwise Partnership has worked to elicit comments on the draft Action Plan from environmental, fishing, and agricultural interests, and supports stakeholder involvement throughout the basin as implementation of the plan moves forward.
Specific Comments on the draft Action Plan
The Task Force asked for comments on the following particular questions:1. Which of the "Coastal Goals" should be in the final Action Plan, and if not any of these, please suggest alternatives? Are the "Within Basin" and "Quality of Life" Goals appropriate, or how should they be modified?
Issues of Process
We have very serious concerns about the way in which the draft Action Plan presents this issue in the section on "Coastal Goals".
The first is a concern over process. The Task Force is asking for comments on the "Coastal Goal" options in a way that suggests voting. It should be obvious that an option which receives the greatest number of favorable comments is not necessarily the most effective or appropriate choice for reaching the goal set out in the Action Plan. Setting policy in this manner runs the risk of undermining the effectiveness of the entire effort.
Secondly, the three options listed under "Coastal Goals", while listed as separate choices, are clearly not incompatible. While the draft Action Plan gives no criteria for choosing between them, it also gives no reason why the actions needed to reach goals 1A or 1B are not consistent with the "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" of 1C.Goals 1A and/or 1B Are Preferable
Goal 1C alone is too vague and lacks a measurable standard for progress. Goals 1A and 1B are measurable and provide a context for assessment of progress in the five year evaluation period proposed by the draft Action Plan. Baseline data on the levels of nitrogen entering the Gulf from the Mississippi and Atchafalaya Rivers are available, and subsequent reductions in loading can be assessed through monitoring. The CENR Reports stated that nitrogen loading reductions of 20-40% into the Gulf are necessary to have a significant impact on the growth of the hypoxic zone. Option 1A doesn't make it clear whether the upper or lower limit of that reduction goal will be the target. Representatives of the Chesapeake Bay Program who spoke at the June 15 Task Force meeting described how states in that watershed agreed on a goal of 40% reduction of nutrient inputs. The state of Louisiana has taken the position that the Action Plan should achieve a minimum of 30% reduction of nitrate loading into the northern Gulf.
It seems, therefore, that achieving either the target of reducing annual discharges of nitrogen into the Gulf by 350,000 to 650,000 metric tons by the year 2010, as stated in option 1A, or that of reducing the 5-year running average areal extent of Gulf hypoxia to less than 5000 square kilometers, as stated in option 1B, will require at a minimum reducing average nitrogen loads to the Gulf by 30% from the 1980-96 average. The target goal should meet the threshold for effectiveness, yet also be one that states and stakeholders can understand. The range of actions available to meet that goal should be clearly identified, as should the measures by which progress will be gauged.
Similar efforts on a basin-wide scale, such as those for the Chesapeake Bay, have found that the setting of a numeric goal for reducing nitrogen pollution, even when part of a voluntary and non-binding agreement, is a critical benchmark for measuring progress or the lack of it. Specific numeric goals aimed at reducing hypoxia are properly focused on the Gulf of Mexico, and are necessary for gauging the success of the Action Plan. Without a numeric goal, effective programs could go unrecognized, and be at risk of defunding by policymakers.Opposition to Numeric Goal
We are well aware that some states and organizations have opposed adoption of any numeric goal, even one directed at the Gulf rather than upriver, though it is not clear whether this reflects an actual opposition to the specific numeric target or a general resistance on principle. Some parties have expressed the fear that failure to meet stated goals could result in regulatory actions aimed at nutrient reduction for non-point sources. We question this position, since the Task Force has, on the contrary, adopted an approach that attempts to direct resources to farmers and landowners for voluntary implementation of BMPs and nitrogen-reduction practices.
Some states have also expressed concerns that they will not "get credit" for runoff reduction efforts and programs already underway. This seems to reflect a misunderstanding of the Task Force's mission. It should be clear from the draft Action Plan that the effort to address the Gulf hypoxia problem is not a punitive program. Recognizing that nutrient-loading and runoff reduction programs already underway will have beneficial effects on the hypoxia problem is not inconsistent with agreement on a science-based target goal for reducing nitrogen loading to the Gulf, and certainly has no bearing on setting that target. The effects of programs already underway, including their effect on meeting the target goal, should be assessed quantitively and integrated into the development of strategies on a state and watershed level under the Action Plan.
The actions mentioned in Option 1A can clearly be applied to reaching a target goal of a 30% minimum reduction of nitrate loading to the northern Gulf. In addition to "intercepting and processing nutrients in riparian buffers and constructed or restored wetlands," protection of existing wetlands should be a high priority, as should addressing the impacts of air deposition from automobile exhaust and coal-fired power plants. The Draft Action Plan should also clarify the breadth of regulatory controls available to control direct discharges of nitrogen, including pre-treatment of industrial wastes, treatment of industrial and domestic wastes, and reduction of stormwater runoff.Within-Basin Goal
The Within-Basin Goal as stated is commendable, though perhaps vague enough to be open to interpretation. The Within-Basin Goal should be clear and measurable. Most importantly, the Action Plan must include a basis for quantitatively measuring the success of state and federal programs, including the Section 402 and 404 permitting programs, and voluntary programs such as WRP, CRP, and Section 319, in addressing nitrogen pollution problems.
The CENR Reports stated that restoration of 5 million acres of wetlands throughout the basin could achieve significant reductions in nitrogen, especially when coupled with on-farm practices aimed at reducing runoff and unnecessary fertilizer application.
2. Are the Implementation Actions listed and the dates associated with them appropriate?
The "guiding principle" of the Action Plan should reiterate that the actions necessary to alleviate Gulf hypoxia will also deliver benefits to watersheds upstream.
We strongly support the continuation of the Task Force for implementation of the Action Plan, and urge the participation of additional states, in particular Texas, whose resources are threatened by the spread of Gulf hypoxia. It is obvious that cooperation by all the states in the basin is necessary to make real progress on reducing Gulf hypoxia. As this process moves forward, however, it is imperative that the Task Force address some serious problems in its structure. Representatives of states on the Task Force should be appointed by their Governors, and should have a clear mandate and responsibility to speak for their entire state and its full range of constituents, rather than just one interest group.Short-Term Actions
i) Goal #1. Sub-basin Committees. Here, as with the other Short-Term Actions listed, there is no explanation for the time-frames given. It is not clear why formation of watershed sub-basin committees is delayed until the summer of 2001, since the Action Plan is to be finalized in fall of 2000. The formation of sub-basin committees
ii) provides an important opportunity for stakeholder participation at the sub-basin and watershed level. It is important, however, that the mission of the committees be clearly laid out in the final Action Plan, so that they can focus on local and regional opportunities for implementation of appropriate best management practices, wetland restoration, and point source discharge reduction, rather than hosting debates about the origins of Gulf hypoxia.
iii) Goal #2. The basins and sub-basins of concern have been identified by USGS in the CENR Integrated Assessment. The Task Force should establish a listing of priority basins and sub-basins by the spring of 2001. Development of strategies within these basins and sub-basins could then be developed and implementation begun by the fall of 2001. Again, preservation of existing wetlands should be an integral part of the strategy along with restoration of wetlands and riparian habitats.
iv) Goal #3. This goal as stated is somewhat nebulous. The Action Plan should include a quantitative goal for reduction of nutrients from point sources by a certain date. All NPDES permits for point source discharges in the Mississippi and Atchafalaya River Basins should be re-issued on time, and permits for all facilities discharging nutrients should include numeric effluent limitations for those nutrients consistent with the goal specified in coastal goal 1A.
v) Goals #4 and #5. Support by federal agencies for voluntary actions should involve quantitative improvements in water quality. Continuing investment by federal agencies in best management practices and wetland restoration should include adequate monitoring to establish the effectiveness of these actions in addressing nitrogen pollution. Increased assistance to preserve wetlands and streamside buffers should be included here, as well as controls on unregulated sources of air emissions of nitrogen.
vi) Goal #6. The proposed Gulf of Mexico Hypoxia Research Strategy needs to be integrated with that of the Gulf of Mexico Program. It is also unclear why the Action Plan delays this strategy until the fall of 2001. A comprehensive listing of research needs has been established through the CENR Integrated Assessment Process.
vii) Goal #9. The Action Plan gives no reason why the time-frame given for the Corps of Engineers to complete a "reconnaissance level assessment of potential nutrient reduction actions", i.e., by the fall of 2003, is justified. Such an assessment is already required by the National Environmental Policy Act and the Water Resources Development Act of 1986, and the Corps is capable of assessing actions that can be taken at present funding levels to modify projects and operations to reduce nitrogen pollution. The Corps must also commit to coordinated, comprehensive oversight of all of their programs and projects within the Mississippi River Basin, to ensure that gains in nitrogen reduction are not offset by projects or permitting practices that serve to increase nitrogen inputs.
3. Provide examples of any effective nutrient management State/Tribal program successes or challenges which can be highlighted in the final Action Plan.
The Barataria-Terrebonne National Estuary Program (www.btnep.org) is notable for developing a basin-wide Comprehensive Conservation and Management Plan, which won a national award and involved stakeholders from all sectors and interest groups. The Tensas River Basin Project undertaken by the Louisiana Department of Environmental Quality and collaborating agencies also involved a high degree of stakeholder participation (http://www.nonpoint.deq.state.la.us/ ws_tensas.html)
Iowa State University has initiated a number of innovative nitrogen reduction projects which should be linked up to the Task Force and incorporated into specific best management practice recommendations in the draft Action Plan. Their Agro-Oceanic Nutrient Flux Center site address is (http://www.public.iastate.edu/~turf2surf/homepage.html.) Tarleton State University in Texas has released the report on their Upper Maquoketa River Watershed Project in Iowa (http:// brahma.tarleton.edu/web/pub.IDC.)
Among private programs, Ducks Unlimited has undertaken extensive wetlands restoration and protection efforts in the basin and explicitly linked these to alleviating Gulf hypoxia (www.ducks.org/news/deadzone.org.) World Resources Institute is developing a nitrogen-trading model which has potential for application throughout the basin, described in their report Fertile Ground: Nutrient Trading's Potential to Cost-Effectively Improve Water Quality (http:// www.wri.org/water/nutrient.html#description.
The Mississippi River Basin Alliance has begun a new webpage devoted to successful runoff reduction efforts in the basin (www.mrba.org/runoffreduction/html), which includes links to websites describing federal, state, university, and private programs.
The Task Force should also coordinate with other regional conservation efforts in the basin, such as the Lower Mississippi River Conservation Committee (www.lmrcc.org.)
4. Are the listings of Federal programs in the section "Funding the National Effort" complete?
The Task Force should also integrate new legislation that provides additional resources as it is passed into law. One example is the pending Conservation and Restoration Act (CARA), authored by Senator Landrieu, which would provide increased funding for the Land and Water Conservation Fund, and for conservation/restoration work in the basin.Comments on Sections of the Draft Action Plan C) Key Roles and Responsibilities Private Citizens and Businesses
While we support the importance of educating homeowners and businesses, as well as farmers and ranchers, about the impacts of their activities on water quality problems such as Gulf hypoxia, we are concerned that the draft Action Plan convey that education and outreach programs are not sufficient in themselves. State and federal regulatory and non-regulatory water quality programs are critical to the success of efforts to address nitrogen pollution and Gulf hypoxia, and thus should receive priority treatment in the Action Plan. Private citizens and businesses can be encouraged to exceed minimal regulatory requirements with education and pollution prevention programs for reducing nutrient inputs to water bodies, but these efforts should be a supplement, not a substitute for enforcement of regulatory programs.States and Tribes.
The draft Action Plan notes that States and Tribes already have important water quality protection responsibilities under their own laws and under federal legislation. While the draft Action Plan does not impose any additional regulatory programs or requirements, it should explain clearly the role that rules such as TMDLs will play. The use of numeric water quality standards for nutrients, and the development and implementation of TMDLs should have a significant impact on reducing nutrients entering the Gulf. The Action Plan should also clarify that states should give priority to watersheds identified as impaired by nutrients or otherwise identified as significant sources of nitrogen in the TMDL development process. States should also act expeditiously to implement TMDLs for point sources through the NPDES program, and for non-point sources through available state programs.States, Tribes, and Federal Agencies
The restoration of coastal wetlands in the active Mississippi River delta and surrounding basins can play an important role in the reduction of nutrients entering the Gulf of Mexico. It should be made clear, however, that these actions are not a substitute for nutrient reductions upstream. Draft CENR Report 5 states that "there needs to be additional study to determine the actual discharge rates of diversions, the area of wetlands needed, the potential and actual nitrogen reduction, and the linkages between riverine input and offshore response." (p.78-79) Modeling and monitoring of the impacts of freshwater diversions and other restoration projects on nitrogen uptake and water quality should be incorporated into their development and coordinated with the Task Force. The Action Plan should also address issues of sediment transport throughout the basin as it relates to both coastal restoration and nutrients.
We support strengthening regulatory and non-regulatory measures to address nutrient pollution in municipal stormwater programs, municipal sewage treatment plants, and on-site sewage treatment systems. A report by the Natural Resources Defense Council, Stormwater Strategies, demonstrates that there are a variety of proven techniques for reducing nutrients in stormwater. Implementation of EPA's Phase II stormwater regulations over the next few years will provide a valuable opportunity to utilize these techniques, along with established approaches for reducing nutrients in sanitary waste systems, which will also provide significant benefits for reducing pathogen contamination of waters. States also have the responsibility to work towards adopting nutrient criteria into state water quality standards by 2003 as part of EPA's National Nutrient Strategy, and should integrate these efforts with strategies undertaken through the hypoxia Action Plan.
The Action Plan states that States, Tribes, and EPA will target Clean Water Act Section 319 funds to improve nitrogen management. Federal funds should also be targeted to clearly identified priority watersheds to obtain the greatest benefit in terms of nitrogen reduction. Coordination of state and federal nitrogen reduction/management programs is also critical. As one example, there are multiple efforts at pool management being undertaken by various agencies in the Upper Mississippi, but it is not clear that these efforts are being coordinated for maximum benefits.
We are concerned about the leadership role that the draft Action Plan assigns to EPA regarding monitoring standardization, data availability, and data coordination issues. The US Geological Survey (USGS) is a leader in monitoring and data, particularly in the Mississippi River Basin. The proposed Upper Mississippi River Basin Conservation Act, H.R. 4013 ("The Kind Bill) designated the USGS as the coordinating agency in charge of water quality monitoring for efforts to reduce polluted runoff in the upper river basin. If the Action Plan were implemented as currently written, and H.R. 4013 enacted, there would be significant potential for duplication of efforts and an additional need for coordination of EPA/USGS monitoring and data standard-ization, and the creation of information sharing systems. Finally, as a non-regulatory agency, USGS may be able to more effectively assume leadership of development of data collection, analysis, and distribution standards.
Monitoring and Assessment
We support the importance of documenting and monitoring land use changes to identify priority areas of nitrogen loss to streams. The draft Action Plan makes no mention of the growth of tile drainage systems in the Midwest over the last decade, which is directly impacting nitrogen loading in the Basin. Another issue which has been generating increased concern in the Tennessee River basin is the aerial spraying of fertilizers, which reflects the spread of highly managed monoculture pine plantations utilizing short rotation periods for harvest.
The development and implementation of a comprehensive monitoring and assessment strategy for the northern Gulf hypoxic region should be carried out by the relevant federal agencies and coastal states, and not just "the state of Louisiana."Federal Agencies
We fully support the draft Action Plan's acknowledgement that to successfully address hypoxia in the Gulf, programs such as the Environmental Quality Incentive Program (EQIP), the Conservation Reserve Program (CRP), the Wetlands Reserve Program (WRP), Agricultural Extension Education Programs, and Clean Water Act 319 resources, must be focused on targeted watersheds. The Action Plan needs to provide concrete guidance on how and where those actions will be targeted. It is not clear whether the "state-targeted watersheds" referred to in the draft Action Plan are the same watersheds designated by the CENR Integrated Assessment as significant contributors of nitrogen. The federal agencies should work together to focus on watersheds identified as priorities in terms of nitrogen pollution entering the Mississippi River, whether or not the states have targeted them as such. The number of acres in conservation tillage or under voluntary nutrient management plans are only partial measures of progress, and should be coupled with monitoring of nitrogen entering rivers and streams, as well as monitoring of groundwater pollution.
The statement that "EPA and NOAA will support targeted implementation of Louisiana's Coastal Nonpoint Pollution Program…" refers to agency obligations already present under existing law. It is unclear why Louisiana is singled out, and other coastal states are not included. The final statement referring to listing of impaired waters and TMDLs is also unclear. EPA is already obligated to approve prioritization and listing of impaired waters in accordance with Section 303(d) of the Clean Water Act, and to issue lists and develop TMDLs when state lists do not meet the requirements of the CWA. It would be more helpful to describe the method by which EPA intends to encourage prompt development of TMDLs in water bodies impaired by nutrients.
This section of the draft Action Plan needs to be strengthened to indicate that all of the identified tools provided by the Clean Water Act, Farm Bills, and Water Resources Development Act will be used to reduce nutrient pollution in the Mississippi River and Gulf of Mexico. As currently drafted, the Plan merely identifies existing tools without indicating that they should be aggressively utilized to achieve results. In addition, the NPDES program, while mentioned, is given much less emphasis than the voluntary programs that are catalogued, and the wetlands permitting program is not even named. While we support the use of incentives, education, and other approaches to increase participation in non-regulatory programs, the Action Plan should also encourage adequate funding for and enforcement of current regulatory programs that can reduce nutrient pollution.
For example, a stronger regulatory program is needed to control excess nutrients from concentrated animal feeding operations, which are continuing to increase in number as family farms are driven out of business. Feedlots in the Mississippi River Basin and its tributary watersheds regularly spill, dump, and leak manure, contributing to the nutrient loading that fuels Gulf hypoxia. The CENR Reports found that animal manure contributes 15% of the nitrogen entering the Gulf from the river system, yet feedlots are barely mentioned in the draft Action Plan. The Action Plan should indicated EPA's intention to close all of the regulatory loopholes that have allowed large animal feedlots to go unregulated, and should commit to effectively controlling the nutrient pollution that they are emitting into the surface water, ground water, and atmosphere. The relevant recommendations from the CENR reports, such as better management of livestock manure and limiting application of nitrogen fertilizer and manure to rates at which the nutrients can be utilized by crops, should be endorsed by the Action Plan and translated into concrete goals and the steps to achieve them.
Adaptive Management: Action, Monitoring, and Research
The draft Action Plan states that "[a] comprehensive program of planning, monitoring, interpretation, modeling, and research to facilitate improvement in scientific knowledge and adjustments in management practices should be coupled to the initial nutrient management strategies identified in this plan." This statement is somewhat vague. It is clear that comprehensive planning and monitoring of nutrient management strategies must occur in order for a baseline to be established and success of strategies determined. Additionally, the success of the Action Plan depends on the "coupling" of research and interpretation with the initial nutrient management strategies identified there, but there also needs to be a framework for how and when this will occur.
Funding the National Effort
We support a Clean Rivers/Clean Gulf budget initiative to restore the waters of the Mississippi /Atchafalaya River basins and reduce the hypoxic zone in the Gulf, but urge that the funds go towards effective strategies for reducing nitrogen pollution. We find the statement that "[t]his inititiave would provide flexible funding to support implementation of the most practical, appropriate, and economical mix of strategies" somewhat troubling. There must be an overall criterion of effectiveness, since the meaning of "practical" and "cost-effective" could be construed in ways that foreclose actions to address significant sources of nitrogen pollution. Consideration of efficiency is appropriate, but the foremost consideration must be that funded strategies effectively reduce nitrogen inputs and Gulf hypoxia.
We are also concerned with the draft Action Plan's emphasis on "large-scale, federally-funded navigation and flood control projects" as the Corps of Engineers' only significant contribution to the problem. While those large-scale projects are certainly significant, the Corps' wetlands permitting program must be included as part of any comprehensive effort to address nitrogen pollution. In parts of the Mississippi River Basin, more wetland acres are lost through permitting than are destroyed through the construction and operation of navigation and flood control projects. In addition, gains in wetlands restoration are often offset by permitted wetlands loss, with a corresponding loss of wetland sinks for nitrogen reduction.Mississippi-Gulf Omnibus Restoration Fund
The Action Plan must explain more fully the purpose, intent, and source for this fund. Will the Omnibus Fund compete for funding with existing restoration programs on the Mississippi River?
Will it become the major instrument for environmental funding in the Mississippi River Basin?
How would the Omnibus Fund relate to current efforts to fund the Environmental Management Program (EMP) in the Upper Mississippi River, the proposed lower Mississippi EMP, the Ohio River EMP, and proposed restoration efforts on the Missouri River? The Action Plan needs to address these issues, and make clear the contemplated source for funding.
Wetlands Restoration Fund
Again, additional funding for the Corps' wetlands permitting program must be included as well as additional funding for wetlands restoration. The Corps cannot justify additional restoration funding without first addressing their failure to request and obtain an adequate budget for implementing and enforcing the wetlands permitting program. As stated previously, in many areas of the Mississippi River Basin, gains in restored wetlands acres are exceeded by wetlands destruction associated with permitting under Section 404 of the Clean Water Act. Thus, restoration efforts that do nothing more than maintain the status quo are not sufficient to reduce Gulf hypoxia.
Absent from the list of Programmatic Indicators is any real indicator for reduction in nitrogen or nutrients associated with agriculture and non-point source pollution. As previously noted, acres placed in restoration and nutrient management programs do not necessarily translate to actual reductions in nitrogen pollution. An appropriate indicator would incorporate estimated and monitored reductions in nitrogen and phosphorous, to track the progress of programs aimed at those reductions.
We also have concerns about the indicator for wetlands, which makes no mention of protection of existing wetlands, a programmatic indicator of which should be included in the Action Plan.
An effective Action Plan for reducing hypoxia in the Gulf of Mexico represents an invaluable opportunity to address a serious national problem, and to improve the health of water bodies and the safety of drinking water throughout the Mississippi River basin. We urge the Task Force and its members not to forego this opportunity.
Gulf Restoration Network
Iowa Environmental Council
Michael Fields Institute
Mississippi River Basin Alliance
Natural Resources Defense Council
National Center for Appropriate Technology
Prairie Rivers Alliance
World Resources Institute
Center for Marine Conservation