nonpoint sources will be on farmers. As the agency with the authority and expertise in
the area of agriculture, and the local structure to carry out activities directly with
farmers, USDA should take the lead.

Farmers and other agricultural interests are concerned how this CENR process fits in with
the other water quality related activities and rulemakings of the federal government. The
Clean Water Action Plan is resulting in a wide variety of rulemaking proposals. How
does the CENR process relate to those other efforts? The time, effort and expense that
farmers are undergoing to implement Best Management Practices to improve water
quality must be acknowledged by the CENR approach.

Nitrogen provides an essential nutrient needed by aquatic ecosystems to grow, thrive, and
expand in the Gulf of Mexico. Further research is needed to examine the proportional
influence of physical, chemical, biological and meteorological conditions on Gulf of
Mexico hypoxia, and nitrogen’s role in this natural cycle.

USDA has a proven track record of working with American farmers in implementing
voluntary, incentive based programs that conserve natural resources while providing the
world with an abundant, reliable, and affordable supply of agricultural products. Farmers’
demand for conservation cost share and technical assistance exceeds USDA’s current
funding supply. In developing a “Win-Win” strategy to combat Gulf hypoxia, federal
agencies must institute programs that capitalize on existing federal and state initiatives
and that provide farmers with adequate cost-share and technical assistance resources.

As federal agencies work towards an Integrated Assessment, it is paramount that we
cohesively identify data gaps and areas for additional research:

¢ Nitrogen is an essential nutrient for plant growth and reproduction that, in some
cases, contributes to algal growth in water. USDA is committed to providing farmers
with the technical assistance and cost-share resources needed to reduce nitrogen’s
impact on water quality.

e However, hypoxic episodes are a natural phenomenon caused by a variety of factors,
including physical, chemical, biological and meteorological conditions, Specifically,
the roles of increased rainfall patterns in the entire Mississippi River Basin, increased
organic carbon loading, and increased flow in the Mississippi River are not yet fully
understood. Future research should more closely examine the proportional influence
each exerts in causing hypoxia, as well as meteorological patterns and current in the
Gulf.

e Channelization, river levees, and drained wetlands result in floodwaters that spend
significantly less time in flood plains and reduce the opportunity for natural nitrogen
removal.

e “A comprehensive research plan is needed as a focus for efforts directed at assessing
both ecological and economic effects of hypoxia in the Gulf. This plan must include
elements for both directing new research and also synthesis of existing data.” {CENR
Report 2, p 10}


ATTACHMENT

It is critical that adequate federal resources be allocated to address water quality
challenges. Over $100 billion has been spent in the past 26 years to deal with urban point
sources of water pollution. With the increasing emphasis on nonpoint sources, available
resources should shift as well. If the new priority is nonpoint source runoff, a portion of
the State Revolving Loan Fund should be made available to rural areas and additional
funding should be allocated to improving water quality monitoring, technical assistance
and cost-share programs rather than new federal regulatory programs.

The Environmental Quality Incentives Program (EQIP), and the buffer component of the
Conservation Reserve Program (CRP) all are farmer-supported, voluntary programs with
important water quality benefits that must be fully funded to meet growing needs.
Additional research and pilot projects are needed to determine how farmers can most
effectively use wetlands as a tool to reduce nutrient loss to waters. Additional funding is
also needed for state directed technical assistance, financial incentives for farmers and
assistance in the development of nutrient management plans. Research funding that

~ focuses on nitrogen utilization, efficiency and loss reduction technology in impaired
watersheds is critical to achieving long term solutions for reducing nutrient loss.

The Natural Resources Conservation Service (NRCS) must be funded to support its
primary mission of being the lead agency in the federal system that works with and
assists farmers to improve water quality.

The CENR reports focused on nutrients from agriculture as the cause of hypoxia and
predictably offered nutrient-based solutions, including reduced nitrogen use and creation
of wetlands. The reports find no economic damage to the commercial fishery from
hypoxia, no threat to human health and do not examine important factors about the
complexity of the Mississippi River system, yet suggest fixing one of the alleged causes
by measures that reduce agriculture. The recommendation to limit fertilizer use to lower
the amount of nutrients entering the Mississippi River will impact farm productivity and
the livelihood of agriculture in the affected area. Creating and restoring 24 million acres
of wetlands (as advocated in the CENR Topic 5 report in the six states identified as
contributing the most nitrate to the Mississippi River will reduce corn and soybean acres
by 29 percent. The resulting reduction in crop output would be equivalent to all the corn
exports from the United States in 1997 and one-half of the soybean exports.

Up to this point the CENR process has not been open to outside sources of information in
the development of the six scientific assessments. Any further development of this issue
and actions undertaken should take into active consideration the views and submissions
of those affected, as directed by the language in Public Law 105-383, the Harmful Algal
Blooms and Hypoxia Research and Control Act of 1998. The preparation of the
Integrated Assessment and Action Plan should be led by the U.S. Department of
Agriculture. In the Mississippi River basin the greatest impact of any actions to deal with


e As these reports are integrated into an Action Plan to reduce the hypoxic zone in the
Gulf of Mexico, federal agencies, scientific researchers and other stakeholders must
reach consensus on a scientifically-based, cost-effective strategy that includes
realistic goals, measures of success, and implementation timelines.

American farmers have a long-standing tradition of conserving natural resources while
providing the world with an abundant, reliable, and affordable supply of food, natural
fiber, horticultural, and other agricultural products. Farmers, ranchers, and their families
can be counted upon to continue to work with the federal government in implementing
voluntary, incentive-based partnerships and programs.

e Farmers have an economic self-interest in maximizing the efficiency of nitrogen use.
Farming, like any business, depends on maximizing production while controlling
costly inputs, including fertilizer. In fact, since the late 1970s, grain and com yields
on American farms have increased, while nitrogen fertilizer application rates have
Temained constant.

¢ Nutrient management plans and precision agriculture techniques—such as no-till
planting, soil testing, and buffer strips—have resulted in significant improvements to
watersheds and terrestrial ecosystems. Use of these techniques has resulted in:
increased production efficiency; improved product quality; more efficient use of
inputs; energy conservation; as well as soil and groundwater protection.

© NRCS provides conservation technical assistance (CTA) to improve and conserve
natural resources. This assistance is based on voluntary, local landowner cooperation.
It develops the standards and practical field guidance used by USDA and many other
federal, state and local programs. In addition, it helps producers determine the needs
of their operations, the practices that can address these needs, and the best way to see
those practices implemented.

¢ The Environmental Quality Incentives Program (EQIP) assists row crop and livestock
producers with the direct costs of adopting conservation practices while keeping land
in production. It is essential to helping producers meet ongoing and numerous
federal, state and local water quality and other program challenges. Producers’
demand for EQIP assistance far outstrips the current funding levels. In 1998, USDA
received almost 55,000 applications for EQIP assistance, representing almost $490
million in need. USDA was able to fund only approximately 20,000 of these
applications and provide only $154 million in assistance.

© The 18" sign-up period for the Conservation Reserve Program produced 90,306
offers totaling 7.1 million acres. Enrolled acreage includes 3.2 million acres of highly
erodible land, almost 2.8 million acres of land located within conservation priority
areas, over 450 thousand acres of wetlands and protective upland areas, and 217
thousand acres to be restored to rare and declining habitats.

«© The Wetlands Reserve Program provides cost-share resources to farmers to assist
them in removing farmed acreage that was drained wetlands out of production on a
permanent or long-term basis. Over 774,000 acres were enrolled in this program as of
May 1999.


AMERICAN SOCIETY OF AGRONOMY
CROP SCIENCE SOCIETY OF
SOIL SCIENCE SOCIETY OF AMERICA”

677 South Segoe Road * Madison WI 53711 * Fax (608) 273-2021
ASA (608) 273-8080 * CSSA (608) 273-8086 +» SSSA (608) 273-8095

11 August 1999

Hypoxia Working Group
Attn. John Field
NCCOS/NOS/NOAA
WS 13446 SSMC4

1305 East-West Highway
Silver Spring, MD 20910

Dear Dr. Field:
The American Society of Agronomy, the Crop Science Society of America and the Soil Science
Society of America endorse the letter and attachment regarding the hypoxia assessment reports,

contained in your 9 August 1999 email and are willing to be signatories to the letter.

Sincerely,
g. Vichatider TOD
John J Nicholaides III

Executive Vice President

cc: ASA, CSSA, SSSA Executive Committees


Risk mitigation programs, as opposed to application restrictions, are the keys for the
long-term success of any “Win-Win” strategy. In developing a strategy, Agencies must
institute programs that capitalize on existing federal and state initiatives and that continue
to provide farmers with cost-share and technical assistance programs.

¢ USDA conservation programs will continue to provide technical assistance to farmers
to plan and apply conservation treatments to control erosion and improve the quantity
and quality of soil resources. In addition, these conservation treatments will continue
to improve water resources, enhance fish and wildlife habitat, and enhance woodland,
pasture and range conditions.

¢ Restored and reconstructed ecosystems provide significant benefits over fertilizer
application restrictions. Riparian buffer strips, wetlands, and reforested acreage filter
runoff and remove sediments and nutrients. Additionally, these areas provide habitat
for countless species of plants and animals. Fertilizer restrictions may ensure that
nutrient loads to the Mississippi River do not increase, but will do nothing to stop
mnoff of existing nutrients from soil.

¢ Any Action Plan developed should rely heavily on existing conservation programs,
including CRP, EQIP, WRP and CTA. Currently, these programs do not havé the
funding or manpower necessary to meet farmer demand. These initiatives should be
funded at appropriate levels and acreage caps to assist in the creation of restored
ecosystems that naturally filter nutrient loads before reaching the Mississippi River.


August 10, 1999

Gulf of Mexico Hypoxia Working Group
National Centers for Coastal Ocean Science
WS 13446 SSMC4

1305 East-West Highway

Silver Spring, MD 20910

The undersigned organizations submit the following letter and attachment regarding the
six topical scientific reports requested by the National Science and Technology Council’s
Committee on Environment and Natural Resources (CENR) for an assessment on the
causes and consequences of hypoxia in the Gulf of Mexico are is submitted by the
undersigned organizations.

American agriculture is strongly committed to addressing water quality challenges by
minimizing runoff from the more than 950 million acres of land under the stewardship
care of nearly 2 million farmers and ranchers. Farmers today are producing more crops
with less fertilizer, meaning they are more efficient at nitrogen application, utilization,
and reducing nitrogen loss from their cropland. Programs initiated in the 1985 farm bill
and its successors that provide technical and financial assistance to facilitate
implementation of best management practices (BMPs) have resulted in environmental
and water quality improvements. Emphasizing and fully supporting current efforts to
improve nutrient management through improved farm practices will benefit water quality
much more than mandating farmers to comply with a use reduction strategy.

Water quality challenges are based on a variety of concerns. What is needed are
additional resources better targeted to impaired watersheds and directed at on-the-ground
activities and practices that will result in further site-specific water quality improvements.
Agricultural research, improved water quality monitoring, technical assistance and
conservation initiatives are keys to improving water quality while assuring an abundance
of affordable agricultural goods. The current economic crisis facing U.S. agriculture
makes financial assistance crucial in order for farmers to afford to institute on-farm
practices to improve water quality.

The CENR reports ignore many crucial issues affecting the Gulf of Mexico, including the
increased efficiency of fertilizer use by farmers and the impact of changes in the flow of
the Mississippi River. Diverting the equivalent of the flow of the Ohio River from the
Mississippi River into the shallow Atchafalaya Bay has significant consequences.
Rainfall has increased in the Mississippi River basin in recent decades, and engineering
changes for flood contro! have added to the flow. Simply mandating a fertilizer use
reduction strategy as recommended will be costly to individual farmers, and does not
address the issue of improving water quality.

The better approach is to acknowledge and work to understand the complexities of the
hypoxia issue while still benefiting from continued water quality progress through
existing programs. Voluntary, cooperative, incentive based programs to improve water


quality will yield real gains for the Mississippi River and the Mississippi River Basin
without increasing economic hardship to farmers. Programs that work with farmers
through cost sharing and technical assistance for nutrient management are workable
solutions to improving water quality. Supporting these programs through full funding is
the most economically viable method of reducing nutrient loss in the Mississippi River
Basin.

In conclusion, we support workable programs and resource allocations that help
American agriculture continue to build upon ongoing progress in improving water quality
by reducing runoff of nutrients from farming. We urge that the Department of
Agriculture be assigned the lead role in completing the CENR process and we look
forward to the opportunity for increased participation and input by the agricultural
community.

Sincerely,

AGRIBANK, FCB
AGRICULTURAL RETAILERS ASSOCIATION
AMERICAN FARM BUREAU FEDERATION
AMERICAN SOYBEAN ASSOCIATION
THE FERTILIZER INSTITUTE
NATIONAL ASSOCIATION OF STATE DEPARTMENTS OF AGRICULTURE
NATIONAL CATTLEMEN’S BEEF ASSOCIATION
NATIONAL CONSERVATION BUFFER COUNCIL
NATIONAL CORN GROWERS ASSOCIATION
NATIONAL COUNCIL OF FARMER COOPERATIVES
NATIONAL MILK PRODUCERS FEDERATION

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