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September 11, 2000

Dear Sirs:

On behalf of the New Mexico Cattle Growers Association (NMCGA) and its membership, I am writing to express my concerns with the above-specified document. We are concerned with the use of water-quality standards and Total Maximum Daily Loads (TMDLs) to make decisions affecting the Gulf of Mexico. We feel that the document did not adequately address the adverse economic and social impacts the document will have on farms and cities in the area. The Action Plan did not discuss the social and economic impacts as required by statute, and as such, should not be implemented until those issues are addressed.

The NMCGA is very concerned about the adequacy of the science used as a basis for the Action Plan. The federal agencies are unwilling to reconsider the assumptions underlying their analyses or re-evaluate their conclusions and appear to be committed to implementing an Action Plan which could have significant environmental and economic impacts on affected areas.

We are also very concerned about the level of local input into the plan. How can this be considered a volunteer program if the key players, the states and tribes, are not being asked if they wish to volunteer? Implementation of this Action Plan could have serious impacts on agriculture in the affected areas, adversely affecting their operations, which leads to an adverse impact to rural economies and families. Those who will be affected need to be involved in the development of any plan.

Because of the potential impacts on agriculture and the cities of the basin, the costs to state and tribal governments and the use of water quality standards to achieve USEPA goals, the USEPA should comply with the clear intent of Congress and submit the final Action Plan to the governors of the 31 states for their input and approval.

The NMCGA has numerous, specific concerns about the technical information contained in the document, as well as the burden that will be placed on states in complying with this action. Most importantly, the document fails to meet the basic requirements called for by the National Environmental Policy Act (NEPA) by failing to consider the economic impacts to the affected areas. Implementation should be held back until this analysis is conducted and worked into the Action Plan.

Thank you in advance for your consideration,

Caren Cowan
Executive Secretary

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