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September 12, 2000

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

Re: Comments on Draft Action Plan to Reduce Hypoxia in the Northern Gulf of Mexico

Dear Task Force:

We appreciate the opportunity to comment on your draft plan before you put it into final form. We agree that this is an important and complex issue, and the State of Wyoming, as a headwater state of the Mississippi may be requested to play some role in solutions developed by the multi-agencies involved in this action plan. Therefore, our input is important.

It appears to us that this proposal is fundamentally flawed in the following ways:

  1. There does not appear to be a clear understanding of how and where responsibility should be allocated within the Basin States to gain the most effective and efficient results. This admission is clearly recognized under the "Adaptive Management: Action, Monitoring and Research" section of the document. We should learn from the recent criticism of federal and state actions. We should not act upon presumptions or flawed statistics. The first Implementation Action should consist of collection of data from all basin states, analysis of this data, profiling the problem throughout the basin and then deciding if we have sufficient data to make good choices or do we need additional monitoring? This will be a more preferable approach that the shot-gun approach that seems to be suggested in the "Implementation Actions" of the document. Our suggestion is that the "Adaptive Management" section of the document should be where the Task Force starts this endeavor. If not, then the first action item of the Implementation Plan should consist of a disclosure of the baseline analytical work that has been done to define the extent and sources of the nutrient loading and how action plans can be effectively assigned throughout the basin.

  2. If EPA and the Task Force are going to expect the states to extend their current efforts and workload and become involved in this greater mission, they should be involved at the onset and have the opportunity to buy into a strategic approach. Different parts of the plan make reference to the states that border the Mississippi River and other parts appear to apply to the entire 31 states in the Basin. As a tributary state, it was difficult to assess what the impact of this Action Plan would be on Wyoming. Once again, this plan envisions that the Task Force and Agency will adopt a strategic plan and expect these governmental entities to buy in. Again, we would suggest that you bring the concept of the "Adaptive Management" action plan to the front of the document and your strategic approach to accomplishing this mission.

  3. Finally, this plan envisions that states will participate without additional resources and funding. This assumption is also flawed. Currently, state resources are stretched to the limit to meet TMDL, AFO/CAFO, CWAP, and new water quality standards requirements. This strategy must come with a proposal to add resources for those states that will play the largest role in reduction of nutrient levels.

We appreciate the opportunity to comment. Please feel welcome to contact us if you have any questions.

Sincerely,

Gary Beach
Administrator
Water Quality Division
Sue Lowry
Director of Policy
State Engineer's Office

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