AUG-@2-1999 18:51 LCES ADMINISTRATION 225 388 4225 P06

Commissioner of Agriculture Bob Odom
Senator Mary Landrieu

Senator John Breaux

Congressman Bill Jefferson
Congressman David Vitter
Congressman Billy Teuzin
Congressman Chris John

Congressman John Cooksey
Congressman Jim McCrery

President of the Senate Randy Ewing
Speaker of the House Hunt Downer
Mr. Ronnie Anderson - LEBF President
Dr. Jack Bagent

Dr. Larry Rogers

TOTAL P.26


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Gulf of Mexico Hypoxia Working Group
August 2, 1999

major Gulf nutrient source. Additionally, restoration actions involving the enhanced diversions and
flow of nutrient/sediment rich River water will not only help restore land area and vegetation but
help reduce nutrient loads. The placement of River nutrients and sediments in degraded coastal
wetland areas would greatly benefit the marsh and may help reduce hypoxia as well.

‘The proposed remedies listed in the CENR report appear drastic for a problem that has not been fully
established. The transformation of 24 million acres of the Mississippi River Basin into

wetlands and/or riparian zones will remove 3.4% of the basin from agricultural production. Homes
and farm families will have to relocate, and their relocation will occupy more upland land areas. The
implementation of a mandatory 20% reduction in the use of nitrogen fertilizer may jeopardize the
financial survival of a great many of the corn and wheat farmers in the most productive farmland in
the U.S. and the world. The assertion that local commodity prices will rise to make up for the lost
yield simply denies any real understanding of how agricultural commodities are priced. Many other
factors must be considered (i.e., imports, foreign production adjustments, etc.) when world
commodity market price predictions are evaluated objectively.

Great nonpoint source runoff reducing advances have been and are being made in the MRB through
the voluntary implementation of Best Management Practices (BMPs). With proper farmer financial
incentives, there will no doubt be expanded BMP adoption nationwide. Successes include
widespread use of conservation tillage, nutrient management, animal waste management, and
integrated pest management (IPM). Additionally, water quality related research and extension efforts
within the LSU Agricultural Center have and will continue to expand. Secure funding for these
efforts, however, must be available.

In closing, we highly suggest that questions regarding the source of Mississippi River nutrients,
measurable fisheries impacts, and reasonable / effective management alternatives be addressed
before additional hypoxia-related policy actions are proposed, We must continue to work together
to reduce agricultural related nonpoint source runoff, however, mandatory policy actions should not
replace the cooperative, voluntary actions that are now being implemented by producers throughout
the MRB. Proposed actions should not devastate the most productive agricultural region in the
country.

Sincerely,
William B. Richardson, Chancellor
and Chalkley Family Endowed Chair

e Secretary of Agriculture Dan Glickman
Governor Mike Foster


AUG-22-1999 18:49 LCES ADMINISTRATION 225 368 425 — PP.

Louisiana State University

Fax: (228) 388-4143
Agricultural Center

August 2, 1999

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

1305 East-West Highway

Silver Spring, MD 20910

Re: Comments on Counci] on Environmental & Natural Resources (CENR) Hypoxia Work
Group Reports

1 would like to complement the various committees on their compilation of a vast amount of
information from a wide array of sources in a very short period of time. I believe that they have done
a credible job of data assemblage in the time frame allowed. However, as with any job of such
proportions, errors and omissions occur and misinterpretations creep in. On behalf of agriculture in
Louisiana and otherwise in the Mississippi River Basin, I must commenton some of our most critical
concems.

First of all the short period of time that has been made available to review this mass of information
and to respond was grossly inadequate, We were not informed that the reports were available until
the Hypoxia meeting in Memphis on June 30, 1999. Only one of the reports was available for
distribution at that meeting. Accessing them by Internet proved to be a laborious endeavor. I asked
our faculty in various areas to review and comment on the reports and they have done so, but all have
commented that the time period was too abbreviated for a thorough review. Actions to date indicate
that agriculture is being targeted. With this in mind, it would have been contributory to a balanced
interpretation of the data and its completeness if agriculture would have had the full 90 days to
prepare its comments. This not being the case, we are submitting the following abbreviated and
quickly constructed concems.

The existence of a large area of low oxygen concentration in the Gulf of Mexico to the west of the
mouth of the Mississippi during the summer and early fall cannot be disputed, and all scientists
should be concerned about its impacts on Gulf of Mexico fisheries. That this area is responsive to
the flow of the Mississippi and its contributions of sediment and nutrients and other factors not yet
fully understood is not in question. The historic significance of this occurrence, however, has not
been determined, nor has the true threats and/or benefits of Gulf nutrients been adequately evaluated.
The fact that Louisiana leads the nations in many categories of marine fisheries landings (i.¢.,


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Gulf of Mexico Hypoxia Working Group
August 2, 1999

shrimp, blue crabs, oysters, yellowfin tuna, menhaden) is no accident,-The tremendous northern Gulf
fisheries and wildlife productivity is heavily dependent on the Mississippi River nutrient laden
freshwater, and actions affecting this important natural function must be approached cautiously, The
Mississippi has always carried a load of rich sediment. The alluvial soils of Louisiana were built by
these deposits. Unquestionably, the channeling of the Mississippi for flood control has concentrated
the outflow into a few channels and may have concentrated the area of low oxygen. This same
channeling has contributed greatly to the loss of our coastal wetlands on which many of our estuarine
fisheries species depend for their growth and reproduction.

The panel evaluating Hypoxia-related fisheries impacts could not document any significant
Problems. The reported decline in the brown shrimp harvests may well be attributable to the loss
of nursery grounds from coastal erosion. In general, the harvest and catch per unit of time do not
appear to be negatively impacted for pelagic species in the Gulf. Oceans worldwide where hypoxia

"has been associated with fishery declines have also experienced problems with serious pollution and
long-term over fishing. Chesapeake Bay is an estuary without the openness of the Gulf and is not
comparable. The use of these areas to forecast doom for the Gulf is without scientific merit. The
panel correctly recommends further study before any conclusions can be reached on hypoxia-related
Gulf fisheries impacts.

‘The panel on nutrient source and flux concentrated almost exclusively on agriculture as the primary
nutrient loading source. Agriculture was poorly represented on the panels, and this may have
Fesulted in inadequate data collection and interpretation. Some of the soils in the upper-Midwest are
shallow overlaying glacial till and cannot be compared to deeper soils with intervening clay layers
farther south. The inclusion of rice fields and fields with ditches for draining surface runoff into the
same category with tiled fields is not sound, and runoff from rice fields cannot be compared to tile
drainage from Wisconsin corn fields. The rate of nitrogen Joss from cultivated fields in different
areas of the Mississippi drainage requires further study on a more localized basis. The nitrogen
content of the drainage from tiled fields is reflected in the water data although it is not clear what
percentage of the nitrogen gets into the streams from the field edge. It is also not clear what
percentage of the fields are fertilized in the fall or how many farmers apply “insurance” nitrogen.
Farm fertilizer, manure applications, soil mineralization and natural soil nutrient discharges are
inaportant sources of nitrogen in the waters of the Mississippi drainage, however, more research is
needed to actually quantify the true significance of these nutrient contributions.

Additionally, we believe that the contribution of other nitrogen sources has have not been adequately
appraised. The first of those is point source contribution from municipal waste water treatment plants
and home sewage treatment systems. According to the report on sources of nutrients, there are
11,500 municipal and industrial waste water treatment plants in the MRB. The discussion in the text


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Gulf of Mexico Hypoxia Working Group
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admits that the data base may not be complete, but proceeds to calculate as though it were.
‘This area certainly requires further study. The contribution of home septic systems, particularly in
times of floods or storm events has not been addressed.

‘The elevated nutrients in streams following storm events have been attributed to the flushing of
excess nitrogen stored in the soil. Unquestionably, this occurs, however, storm events of 3 or 4
inches create storm surges in sewer systems that most plants cannot handle, In these events it is
normal practice for plant operators to open bypass valves and discharge directly into the receiving
stream to protect the plant, A one and one-half inch rain recently created a 100 million gallon storm
surge at Baton Rouge, LA sewer plants. Floods also inundate sewer systems and plauts, especially
systems using oxidation ponds or wetlands as treatment systems, and wash the nutrient rich contents
into streams. As noted in the report, storm events bave become more common and this pattem
is expected to continue. Sewer-related nutrient contributions are not adequately addressed in the
report.

The nutrient contribution of storm water from urban areas was considered to be insignificant by the
panel. Urban areas constitute 0.6% of the basin or 4,757,295 acres. A 1998 USGS report of a 3-year
runoff water quality study conducted in Baton Rouge, LA, showed an average of 14.7 pounds per
acre per year of nitrogen in runoff from commercial, industrial and residential areas. The residential
area sampled released 21.6 pounds of nitrogen per acre per year. These residential rates could be
significant on a basin-wide basis if they are consistent across the area, Garden shop sales of fertilizer
were $8.3 billion in 1997 and $8.4 billion int998. At $20 for 50 pounds of fertilizer, this dollar
volume would equal 10,500,000 tons of fertilizer sold to homeowners nationwide. Using this
assumption, homeowner fertilizer applications equal approximately 44 of the amount by volume
applied commercially by farmers in the MRB; however, this volume is applied to only 0.6% of the
basin land area. The 21 pound per acre annual nitrogen contribution to storm water seems modest
when these estimated urban application rates are considered.

Additionally, there is considerable variance between an early estimate of atmospheric nitrogen
deposited in the basin by Dinnel (1995) who estimated atmospheric deposition at 174% of riverine
flux. The current report estimates this contribution at about 85% of the flux. No discussion of the
differences is included in the report.

Another concern relates to the possibility that a significant portion of the excessive shallow water
Gulf nutrients may be contributed by a quickly degrading coastal ecosystem. Louisiana is currently
losing 20-25 square miles of coastal wetlands per year. These fragile organic soils make up some
of the riches soils in America. It has been estimated that each square mile may contain'1.28 billion
pounds of organic matter and sediment per foot of depth. The potential impact of this nutrient
contribution does not seem to be adequately considered in the panel reports. A major
recommendation needing consideration is stepped up strategies that adequately address coastal
restoration in Louisiana. Any actions that reduce coastal land loss will also significantly reduce a