Noah S. Root :
y-- §001 S. Hickory Ave. #127 Noahroot@aol.com
__ Broken Arrow, Oklahoma 74011___ (918) 451-597.

EcoLaw Institute Inc.
Reséarch

July 26, 1999

Gulf of Mexico Hypoxia Working Group
National Center for Coastal Ocean Science
WS 13446 55MC4

1305 East-West Highway

“Silver Spring, MD 20910

RE: A Public-Comment on the Hypoxia Assessment Reports
Dear Working Group:

I. appreciate your-work on the reports but was there a news
release? There seems to be not much public awareness of the
"dead zone" problem and proposed solutions. I notice that
the agribusiness news apparently has not mentioned these
public reports. Scientific communication with the public is
essential as the science itself, I accidentally found out
about the reports at: the NOAA and EPA web sites.

Some states are still attempting to drain wetlands for crops
even as wetland restoration is proposed in the reports.
Public awareness is the beginning of enforcement of
watershed solutions. Denial is still-an option of a social-
political system that has not coped with the prospect of
more ozone depletion and a runaway greenhouse effect.
Climate change is likely to enhance the Gulf hypoxia ~
problem.

To add the cost of pollution mitigation to a product
(including public education) is. uncommon common sense. ~~.
There is a hidden cost in the price of cheap food. The
largest share of the polluting nutrients is the combination
of growing cheap grain to feed large numbers of confined
meat animals producing concentrated manure that also
produces water pollution. Why is this legal?

None of the reports mentioned the expansion of organic
production. It doesn't use genetic engineering,
antibiotics, hormones or synthetic nitrogen fertilizer.

’ There is a May, 1999 report on the web by Rick Welch at the
Henry A. Wallace Institute for Alternative Agriculture:. THE
ECONOMICS OF ORGANIC GRAIN AND SOYBEAN PRODUTION IN THE
MIDWESTERN UNITED STATES, >http://www.hawiaa.org/pspr13,htm<


From page 58 of the Topic 6 report, EVALUATION OF ECONOMIC
COSTS .-AND BENEFITS OF METHODS FOR REDUCING NUTRIENT LOADS -TO
THE GULF ‘OF MEXICO: "Livestock producers would bear more
costly feed grain input costs as prices increase under
nitrogen loss resrictions. Consumers of basic: commodities, ©
and the finished food and fiber products derived from them,
would suffer some loss from price increases caused by
production changes and acreage restored to wetlands."

It may be somewhat misleading to refer to animal manure as a
nutrient when it can contain heavy metals, pesticides,
antibiotics and other additives. Years ago it was noticed
when cattle were.first fed antibiotics, the cow patties took
longer to biodegrade. The problem with exporting cheap meat
and grain is the pollution costs stay here for a long time
as we are learning. :

. Cleaning up the dead zones may be helped by a DIET FOR A NEW
AMERICA as the book title by John Robbins suggested.

Tulsa's water supply is downstream from many polluting hog
er chicken confined animal feeding operations(CAFO's). The
city is paying the cost of cheap meat by a treatment for
excessive phosphorus and nitrogen producing algae in the
water supply lake. Arsenic was found to be a formula ~
ingredient in poultry feed that also ends up in the water.
and land. : . .

. Will legal action to clean up the Gulf hypoxia zone also
help urban water supply problems? This should be part of
any solution presented to Congress. We all live downstream.

Sincerely,
Nook S$, Revt
Noah S. Root

Researcher
EcoLaw Institute Inc.