FROM 1!DNR ADMINISTRATION 626 266 ese3

wae

1999,@6-e2 14137 9 4084 F.@8/065

Reducing nutrient loads, especially nitrate-nitrogen, to surface water, groundwater, and
the Gulf of Mexico.

14. We support the stated need for linkage of the water quality model with the hydrodynamic
model of Gulf of Mexico circulation, expansion of the model spatial domain, and refinement
of horizontal and vertical spatial resolution in the model, along with expanding the water
quality model itself to include a sediment diagenesis submodel, multiple phytoplankton
groups and silica as a potential limiting nutrient. In addition, the models should consider the
relative amounts of inorganic nitrate to organic nitrogen found in the water.

15. We support the stated need for additional study to determine the advantages or disadvantages
of large scale diversions of the Mississippi River into the coastal zone.

16. The remedial options should be considered options only and not proposed solutions.

17. Itis critical that the next phase of the planning effort define the management target for the
Gulf so that altemative management approaches can be modeled against that target. The
variables in the gulf could include horizontal and vertical extent of hypoxie, duration severity
of conditions or combinations of these four measures of effect. . .

o Evaluation of ‘economic costs and bencfits of methods for redueing nutrient loadgto the
.- Gulf of Mexico es :
, 18, The economic value of the Gulf fishery and the value of the basin. agriculture need.to be
assessed more completely. - ak

19. The analysis should include the (long-term) reductions in atmospheric sources of nitrogen

‘ that would result from transition to the “fuel-cell” technology for power generation and

automobiles, and the affect that this would have on air deposition rates of nitrogen.

20. The analysis should identify the number of years in which a significant (20 percent) reduction
in nitrogen loadings would be achieved, given the current rate of nitrogen level reductions
and the current degree to which conservation plans and practices are being adopted by

21. The analysis should address the costs of restoring wetlands for flood storage purposes, as
well as potential nitrogen reduction purposes. .

WIDNR and DATCP Technical Concerns Regarding The Gulf Of Mexico Hypoxia Assessment

3.


FROM IDNR ADMINISTRATION eee 266 6s83 1998,@6-a2. 14137 #084 P
Ld 24705

introduction of extensive lock and dam systems in the 1950s, significantly reducing the
coarse fraction. .

8, Additional research and computer modeling needs to be done to characterize the quantity and
quality of flood flows “before” and “after” the construction of locks and dams, and extensive
reductions in the riparian in the Mississippi River basin. These models should also consider
the influence of the inter-coastal wetland areas in moderating flood flows, along with the
“before” and “after” impact of off-shore oil extraction on inter-coastal wetland areas, In
particular, this research should identify the effect of the available flood storage capacity and
areal extensiveness of wetlands on the ratio of organic and inorganic nitrogen, the ratio of
colloidal, fine, medium, and coarse sediments, and the extent and duration of flood levels of
fresh water delivered to the Gulf of Mexico. :

9, Identification of nitrogen as the major causative factor with hypoxic conditions in the guifis
not clearly correlated with the trend data that is illustrated in the reports. Further, nitrate flux
is characterized as steadily increasing since the 1950's to a level that is three-times greater.

A more accurate depiction is that nitrate levels peaked in the early 1980s and have been
steadily declining, with the exception of the 1993 flood year. While reducing nitrogen
- Joading should have positive impacts from the perspective of either or both local and regional
- water quality-conditions, additional modeling work could improve the understanding of thes:
__ relationship of nitration flux in tandem with fresh water flux to the problemsof hypoxia inthe
_ Gulf of Mexico. .. “ye oo
“JO; The relationship ind relative impacts of nitrogen, phosphorus and silitd loids'in terms offs:
enriching the Gulf productivity versus inducing hypoxic conditions needs tobe better
understood. In particular, additional work needs to be done to identify how the reduction in
volume and change in composition of the size fraction of the suspended sediments influence
the bottom morphology and benthic habitat of the Gulf of Mexico, and the relationship this
may have on conditions contributing to hypoxia formation. .

Effects of reducing nutrient loads to surface waters within the Mississippi River Basin and
the Gulf of Mexico.

11. More work needs to be done in evaluating the Gulf system response to nutrient reductions
both in terms of load reductions levels and time of response.

12, The analyses did not include the results of nonpoint source program implementation ranging
from BMPs to wetland reserve or restoration acreage.

13. The importance of the coastal wetlands to the gulf fishery and the relationship to solids,
nutrient, and sediment loading in the basin needs to be better understood through data
collection and modeling.

WI DNR and DATCP Technical Concerns Regarding The Gulf Of Mexico Hypoxia Assessment

2.


FROM #DNR ROMINISTRATION GCE 265 Sse3 1999,96-a2 14:35 #064 P.21/25

State of Wisconsin
re.

Department of Agriculture, Trade and Consumer Protection

Department of Natural Resources
; gf
aeFaxNote 7671 Py Pad SS
August 2, 1999 rey - i.
: fe OK, al
Gulf of Mexico Hypoxia Working Group Pre #3 of -7/3- Rob: Sh
National Centers for Coastal Ocean Science Fax#
WS 13446 SSMC4 ,
1305 East-West Highway :

Silver Spring, MD 20910
“Subject: Gulf of Mexico Hypoxia Assessment
Dear Members of the Hypoxia Working Group:

We are writing to express our comments in response to the May 4, 1999 notice in the Federal
Register of technical reports regarding hypoxia in the Gulf of Mexico. Wisconsin is very
concerned about the findings of these scientists that this oxygen depletion condition exists in.
the Gulf of Mexico and is apparently getting worse. We support the need to learn more about
this predicament and to take appropriate steps. The work that has been put into these reports is
very helpful in better understanding the dimensions of the hypoxia and possible causes. ©

It is our understanding that these reports were intended to be a first step in developing a
common understanding of the problems in the Gulf. The reports were to include the sources of
those problems from throughout the drainage basin, the possibility for improvements or
restoration and the suggested actions that could have positive impacts on the Gulf situation.
We believe that the approach of engaging the scientific community at the outset has been an
effective means to collect the best science and through a public review and analysis process
identify areas of agreement as well as areas where data gaps or valid technical disagreements

{ . exist. We acknowledge the hard work that many dedicated individuals performed in producing

. the assessment reports. However, our staff identified some specific technical concerns that still
need to be addressed. We have attached this list of technical concerns for your consideration
in developing the upcoming integrated report. :

We are now at a point in the overall process where it is critical to fully involve state
representatives. The next stages, the integration report, and the action plan, will go beyond
science and data and begin to incorporate legal, political, and social aspects into the planning
‘ _ process. Only with state representation can you obtain the necessary expertise to develop ©
| meaningful and effective management programs in a basin as large and diverse as this basin.


FROM 1DNR ADMINISTRATION 6s 268 6se3

Wisconsin Comments on the Gulf of Mexico Hypoxia Assessment
August 2, 1999
Page 2

From the same perspective, the absence of state involvement in the preparation of these reports
has resulted in reports which did not utilize the full data sets which exist (because of reliance
of published reports) or the most recent information regarding agriculoure practices. There is
also 2 lack of consideration of the implementation of federally subsidized conservation reserve
program or wetland reserve projects or in states like Wisconsin with large state nonpoint
management programs, implementation of best management practices in the target areas.

‘These limitations in the technical reparts again mandate the full involvement of state
representatives to most accurately reflect the current state conditions.

‘The State of Wisconsin is recognized as a leader in preserving the quality of our environment.
We have a long history of blending both regulation and cooperation into effective management
strategies that allow us to take advantage of the energy and creativity of the citizens of this
state-whether they live in the cities or the rural areas. Our approaches have also allowed
looking at issues comprehensively to ensure that environmental investments can return multiple
benefits. ‘Therefore, we were pleased to note that the report dealing with the reduction in
nutrient loads suggested a combination of sectors and actions. Differences among the states
will mandate diverse management expectations if we are to be effective in not only protecting
an important national resource like the Gulf, but also the resources and livelihoods of all the
citizens in the basin.

We believe it is critical that the assessment that will summarize the findings in these reports
focus strictly on the science of the problem and pot contain recommended solutions, which is
the policy that should follow the technical work, Following the public review and completion
of the assessment, the preparation of an action plan should be a joint effort with the states.
This partnership is essential to successfully manage an ecosystem of this scale.

We are commited to participating in the development of the assessment and the action plan.
‘Thank you for an oppormmity to comment and we look forward to a fuller involvement.

Sincerely, : .
George E. Meyer, Secretary Ben Brancel, Secretary
‘Wisconsin Department of Natural Resources Wisconsin Department of Agriculture, Trade

and Consumer Protection

ce Caro] Browner, EPA
Francis X. Lyons, EPA, Region 5
NOAA Coastal Ocean Program

1999,08-02 14136 #084 F.22/05


FROM 1 DNR ADMINISTRATION 628 266 6983

1999,@5-02 141360 #084 P.23/065

TECHNICAL CONCERNS FROM THE STATE OF WISCONSIN
DEPARTMENT OF NATURAL RESOURCES AND
DEPARTMENT OF AGRICULTURE, TRADE & CONSUMER PROTECTION
REGARDING THE GULF OF MEXICO HYPOXIA ASSESSMENT
August 2, 1999

Characterization of Hypoxia

1

Additional work needs to be done to show the areal extent of hypoxia prior to, and at 50- or
100-year intervals since European settlement. This information needs to be presented in a
map form that may be compared against the maps of hypoxia shown in the assessment for the
years 1992-1995. More reccut maps showing the areal extent of hypoxia in the years since
1995 should also be made available.

Ecological and economic consequences of hypoxia

2.

. ecological and economic effects of hypoxia in the northem Gulf of Mexico.”

We support the recommendations in section 5.3 of the Report for Topic #2: “A
comprehensive-research plan is needed as a focus for efforts directed at assessing both - .

More work neéds to be done to determine in-stream loss of nitrogen, such as denitrification
or burial in reservoirs or in flood plains, to understand the degree to which nitrogen deposited
in the upper reached of the Mississippi River Basin are actually delivered to the Gulf of:
Mexico. . .
Impacts on the fishery and the economic implications are based on examples from oth
locations and miay not be representative of actual Gulf responses. .

Flux and sources of nutrients in the Mississippi-Atchafalay River Basin

5.

‘We believe you have not taken full advantage of analyzing available state water quality data.
For example, sub-basin loadings exist and are available for many tributaries in the basin.
‘These data should be collected, compiled, and added to the data sets that were used to
identify the significant nutrient source tributaries.

Additional work needs to be done to identify and include estimates of nitrogen contributions
to the atmosphere from municipal and industrial facilities and motor vehicles. Prior
published research indicates total air deposition of nitrates may be equal to 174 percent of the
average total amval flux of nitrate to the Mississippi River Basin, and that air deposition may
account for up to 23 percent of the total nitrogen load (this assessment indicates that the
relative contribution is 10 percent).

Additional work needs to be done to identify nutrient, sediment, and water flux to the Gulf of
Mexico prior to 1950. For example, published data from U.S.GS indicates sediment
delivery was approximately double in the 1700s, compared to delivery rates today.
Composition of the particle size of the delivered sediment radically changed after the