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September 8, 2000

National Association of Conservation Districts
509 Capitol Court, NE
Washington, DC 20002

RE: Notice of Availability and Request for Comment on Draft Plan of Action for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico

Dear Sir or Madam:

The National Association of Conservation Districts (NACD) is pleased to submit comments regarding the above-referenced action plan. NACD is a nongovernment 501(c)(3) organization that represents the nation's 3,000 conservation districts and more than 16,000 men and women who serve on their governing boards. Established under state law, conservation districts are local units of state government charged with carrying out programs for the protection and management of natural resources at the local level. Conservation districts work with nearly two-and-half million cooperating landowners and operators each year and provide assistance in managing and protecting nearly 70 percent of the private land in the contiguous United States. As such, we have a direct interest in the proposed action plan to address hypoxia in the Gulf of Mexico.

In general, we view the draft action plan as being a top-down, federally driven program that ignores the time-proven and successful locally led approach to natural resources management that conservation districts pioneered more than 60 years ago. The draft fails to recognize the success we have achieved in working with landowners and operators on a voluntary basis to address environmental concerns locally. Protection of natural resources begins at the local level, with local citizens working to find solutions that work for both the environment and the people.

Conservation districts work with a vast array of private landowner interests, all of which have a vested and demonstrated concern about protecting our environment. We have a long and successful history of implementing conservation practices and strongly believe that successful plans to reduce nutrient losses to the environment will be built on current practices and programs that are locally led, voluntary and incentive-based.

We view the draft action plan as being narrowly focused, selectively interpreting the various scientific reports it references to support what are apparently predetermined conclusions. For example, the US Geological Survey's (USGS) Flux and Sources of Nutrients Report, which is referenced in the draft plan, relies on a database that does not include urbanized areas. By emphasizing rural - that is, agricultural - areas, it creates a bias toward attributing nutrient problems primarily to agriculture. Further, it is our understanding that USGS rejected offers from several states in the basin to supplement its data and provide for a more accurate report.

Another major shortcoming in the draft is its failure to recognize ongoing conservation initiatives at the state and local level. Every state in the Mississippi River Basin (MRB) administers nonpoint source pollution control programs, yet none of these activities is acknowledged in the analysis or the draft action plan. During the course of the assessment, both Illinois and Iowa offered detailed descriptions of their programs to establish a comprehensive analysis of what actions may be needed. None of their information was referenced, or even acknowledged in the draft action plan.

The draft action plan makes repeated references to targeting federal programs such as the Environmental Quality Incentives Program, the Conservation Reserve Program, the Wetlands Reserve Program, Clean Water Act Section 319 and Section 6217 of the Coastal Zone Act Reauthorization Amendments of 1990. However, it makes no proposal to increase funding for these programs, which are already oversubscribed. Costs remain both undefined and uncommitted from the federal government. Targeting existing resources to this initiative will only draw much-needed assistance from other areas of the nation.

In our view, the best way to address the hypoxia issue in the Gulf of Mexico is to increase our commitment to providing technical, financial and educational assistance to private landowners and operators in the MRB. Moreover, to be successful any effort to deal with hypoxia concerns in the Gulf - or anywhere else - must rely on a close, cooperative partnership with state and local governments and the private landowners and operators they work with.

We appreciate the opportunity to provide our comments on the draft action plan.

Larry C. Smith, Chair
NACD Water Resources Committee

copy: NACD Board of Directors

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