caused by “harmful algal blooms” was “harmful or fatal” to fish and shellfish, and
responsible, in part, for $1 trillion in economic harms. Instead of sponsoring an
honest, open-minded inquiry, Congress mandated a witch hunt, an assessment
with a preconceived conclusion to guide the president in developing a plan “for
reducing, mitigating, and controlling hypoxia in the northern Gulf of Mexico.” And
he must do it by March of next year.

The outcome of the assessment process is hardly to be wondered at; it was, in
fact, premeditated and predetermined—tong before the work group was
organized or its inquiry begun.

As early as 1992, Purdue University professor Stephen B. Lovejoy, in a report to
the U.S. EPA Gulf of Mexico Program, plainly acknowledged the lack of any
credible water quality data for the Mississippi basin, “Measurements of actual
concentrations of pollutants and flows [are] nonexistent, both temporally and
spatially,” he concedes (“Sources and Quantities of Nutrients Entering the Gulf of
Mexico...” EPA 800-R-92-002, p. 48). Neither does Dr. Lovejoy offer any
scientific justification for the conclusion (already firm in 1992) that nutrient
reductions are necessary to the health of the environment. Rather, the effort to
reduce nutrient loading in the Mississippi, according to Lovejoy, is driven by
“social forces suggesting that agricultural practices should be less
environmentally degrading” (p. 3) Clearly, “social forces,” means public opinion—
in this case, the opinion of a public that has been prejudiced by the continual
repetition and broad circulation through the media of the a priori, unscientific
judgements of government agencies, environmental groups, and university
researchers whose speculations are now discredited by their own study.

{t is no secret that public opinion drives policy. But it is a national scandal when
those describing themselves and presenting themselves to legislators and the
public as “scientists” abandon their ethical responsibilities to scientific method by
subscribing to and recommending policy that is inconsistent with their own
findings of fact. This is corrupt practice unworthy of “seekers after truth,” and
deserves to be publicly condemned.

The Stakes Are High

The Fisheries

According to Louisiana marine fisheries officials, “the harvest of the commercial
and recreational marine fishery resources of Louisiana is valued at over one-half
billion dollars annually, and generates over 1.2 billion dollars in economic activity
in the state of Louisiana.” In 1994, at the height of hypoxia’s historic expansion to
7,000 square miles, when hypoxia’s impacts should have been most devastating,
fisheries landings off the Louisiana coast surpassed 1.7 trillion pounds, and were
worth nearly $340 million to the working fishermen of the region—the largest,
most valuable catch in nearly a decade.


from all of the United States, South America, Europe, Asia, and a good part of
Africa. Where would wildlife and wilderness survive?

Clearly, tripling the world’s food supply without both concentrating production and
increasing yields on the world’s best existing farmland would mean the collapse
of the global environment. The rain forests—already being destroyed at appalling
rates for low-yield, unsustainable, slash-and-burn agriculture—would be gone:
Researchers have found more wild species in five square miles of rain forest
than on the entire North American continent. Losses to biodiversity, wildlife
habitat, and to species would, therefore, be calamitous.

Providing adequate nutrition and clothing for the people of the 21°' century while
protecting the environment, will be an extreme test of humanity's creativity and
resourcefulness. It will require heroic achievements in agronomy, an
unprecedented opening of world markets to farm products, and development of
still safer and more reliable technologies for storing, transporting, and distributing
food. It is to these efforts that we must devote our resources, energy, and
ingenuity.

In this enterprise, if we do not optimize our use of the world’s prime farmland—
the Mississippi River Valley, the Argentine Pampas, the Paris Basin of France,
and the Upper Euphrates Valley of Turkey—we invite human and environmental
disaster.

As custodians of these prime farmlands, we have, in fact, a global responsibility
to raise their yields as high as we safely and sustainably can. If even five million
acres in the Mississippi River Valley are intentionally taken out of production and
millions of other acres are forced into lower-yield regimens, as the Work Group
incredibly proposes, we will have taken a fateful first step down the road to
environmental catastrophe.

To take such action, without justification, simply to appease an unreasoning, ill-
advised, and scientifically unsupportable prejudice against high-yield agriculture,
would be criminal—an assault against Earth’s most imperiled ecosystems and
against the children of the new millennium’s emergent nations.

Every senseless, unwarranted, and unjustified limitation that the environmental
movement succeeds in placing on American agriculture further increases the
likelihood of global environmental devastation. Is this, truly, what EPA, NOAA,
CENR, the Gulf of Mexico Hypoxia Work Group, the Congress and the President
really want?

Let us hope not. But unless the President is prepared to act on his task force's
finding that there are no "detrimental ecological and economic impacts," and
ignore their ludicrous recommendation to sabotage Midwest agriculture, that is
what they—and we—are going to get.


is being foisted on the public—and that is allowed to go uncorrected by EPA,
NOAA, and CENR, by Dr. Nancy Rabalais and the Sierra Club—is that hypoxia is
a steadily worsening condition, and that—if not mitigated—it will eventually bring
ruin to the ecosystem. This is an unscientific, pernicious untruth and a discredit to
the community that fosters it.

Not content with the inanity of their prediction of future doom, however, the Topic
2 Task Group, proposes one of the most egregiously irresponsible comparisons
ever to insult an intelligence. They suggest that the Gulf of Mexico could become
another Black Sea—severely impacted by hypoxia.

Compared to the Gulf of Mexico, the Black Sea is a stagnant pond. It has less
than one-third the area, one-fifth the volume, and, for all practical purposes, is
landlocked. Its only outlet is an opening 800 yards wide in the Bosporus. By
contrast, the Gulfs mouth stretches 450 miles from the Yucatan to the Florida
peninsula. Currents in the Black Sea are so weak that more water actually flows
in through the Bosporus than escapes.

Hypoxia has been a known and well understood phenomenon in the Black Sea
for many years, and it has nothing to do with agriculture. According to Russian
oceanographers Luch Fomin and Viadimir Goncharov, the Black Sea’s “lower
levels are, to all intents and purposes, almost ‘dead’—not as a result of modern
pollution but because of [natural] continued weak ventilation of the deep layers.”

Then Task Group 2 proposes the even more bizarre and preposterous
comparison of the Gulf to the Kattegat. The Kattegat is a strait not a gulf or a sea;
it is a narrow, elongated channel that connects the North Sea and the Baltic, with
good bits of Denmark blocking the flow of water between them. The Gulf of
Mexico has a surface area of 1.5 million square miles, the Kattegat less than ten
thousand square miles. The Gulf’s mean depth is more than 4,500 feet. The
Kattegat’s is 84 feet.

The Process Is Corrupt

In inviting public comment on this report, EPA does not state that the purpose of
the report and of soliciting comment is to determine whether nutrient reductions
are at all necessary or appropriate. Rather, it is to assist the CENR Gulf of
Mexico Working Group to “provide ecological and economic analysis of various
options for reducing nutrient loads carried by the Mississippi River to the Gulf of
Mexico.”

Again, this is not surprising. The public law calling for the hypoxia assessment
was passed by a complacent Congress that accepted inaccurate findings from a
Senate Commerce Committee that allowed itself, also, to be deceived by the a
priori speculations of “scientists’—individuals with doctoral degrees in scientific
fields— who allowed prejudice to preempt science in their approach to this issue.
In the 1998 Coast Guard Authorization Act, Congress unfortunately did not order
an assessment that would first discover the facts, and, then, determine what, if
any, remedial action was necessary. No. It incorrectly assumed that hypoxia,


“Louisiana's fisheries, and to a large extent those of the northern Gulf of Mexico,”
the state’s fisheries officials reported at an EPA hypoxia conference in 1995,
“depend on the Mississippi River for their existence. The sediments and nutrients
carried by the river built the Louisiana coastal marshes. Today, as a result of
leveeing [sic] the river, nutrients and sediments that once built and maintained
Louisiana's coastal. marshes are being deposited off the Continental Shelf in the
abyssal depths of the Gulf of Mexico. Decreasing the nutrient levels in the
Mississippi River may serve to lessen the severity of hypoxia in coastal waters,
but also may impact the food web of the northern Gulf and decrease fisheries
production,” they warned.

If hypoxia were, in fact, a demonstrated detriment to the Gulf environment or
fisheries, then lessening its severity would clearly be appropriate and desirable.
Alabama researchers also report, however, that hypoxic events in Mobile Bay
have been documented “since the mid-1800s,” and, "despite the frequency of
these events [hypoxic conditions exist approximately 50 percent of the time],
fisheries landings in Mobile Bay remain high and researchers are now.
addressing the question of whether such events (that may help maintain highly
productive “pioneer” communities) may have a beneficial effect on secondary
production in the ecosystem.” In other words, Alabama officials are assessing the
beneficial impacts of hypoxia.

Donald Boesch, an expert on hypoxia at the University of Maryland and a leading
researcher involved with the Chesapeake Bay Program, without apparent
embarrassment, openly acknowledged at the 1995 EPA conference that there
has never been a scientific effort to answer even the most fundamental questions
regarding hypoxia. There has been no attempt to determine whether or not
hypoxia in the Gulf, or the Chesapeake Bay for that matter, is a natural or
anthropogenic phenomenon, whether it is getting worse or better, or to establish
any connection between the phenomenon and long term ecosystem response.

Boesch even noted that there is no evidence whatever that hypoxia has ever
adversely affected Chesapeake Bay fisheries.

There is, then, no scientifically credible rationale to support a belief that hypoxia
will ever harm, let alone ruin, the Gulf or its fisheries. If anything, the arbitrary
reduction of nutrients upon which the fisheries are dependent, will decrease
production in high-flow years, and cause potentially catastrophic reductions
during persistent dry periods. The self-defeating regulation of Midwest agriculture
now being proposed so irresponsibly by the Work Group is more likely to starve
the fisheries, in fact, than to provide any conceivable benefit.

American Agriculture

If the administration persists in this idiotic plan to mitigate what does not require
mitigation, the costs will be immense, not only to the fisheries, but to American
agriculture, to the national GDP, and to the balance of trade. It will seriously harm


Vi A project of Hudson Institute

Food Issues

July 29, 1999

Gulf of Mexico Hypoxia Working Group

National Centers for Coastal Ocean Science
WS 13446

1305 East-West Highway

Silver Spring, MD 20901

Dr. Rick Halpern requested that I send the enclosed comments. This is a corrected
version and is intended to replace the copy that was previous mailed.

If you should have any questions, please feel free to contact us.
Sincerely,

ev Clic

Alice Killian
Administrative Assistant

P.O. Box 202
Churchville, VA 24421
540-337-6354 @ 800-876-8011 @ FAX 540-337-8593 @ www hudson.org/cgfi @ cgfi@rica.net

Dennis Avery

Alex Avery
‘Research Director

Deve Juday
Adjunct Fellow

Richard Halpern, Ph.D
Adjunct Fellow


our potential as the greatest supplier of food and fiber to a world that will need
them, if our wildlife and our richest and most diverse ecosystems are to survive
beyond the first half of the twenty-first century.

Initially, our annual domestic economic losses will be measured in the hundreds
of billions of dollars. Before long, our losses will be reckoned in the trillions.
Agriculture is the largest single contributor to gross domestic product, worth
approximately $3.4 trillion a year to the economy. The value of Mississippi Valley
agriculture is approximately $1.7 trillion to $2.0 trillion a year. If the retirement of
5 million acres and mandated yield reductions result in an overall decline in
production of 15%, value lost will exceed $250 billion a year. Moreover,
agricultural exports, the single most important factor in sustaining our balance of
trade, will certainly experience further significant decline.

In the final analysis of the Work Group's scenario, everybody loses. As Dr.
Doering’s group 6 observes in crisp, sanitized jargon “costs are imposed on
some who are constrained to abandon profitable production in order to meet
nitrogen loss goals.” What this means in plain English is that the smaller, less-
efficient, less-resitient family farm will go out of business. At the other extreme of
the scale, according to the work group “the primary concern of the agribusiness
industry is loss of sales in an expanding free market environment where market
share is voluntarily constrained to meet environmental objectives.” What this
means is that production we give up in order to achieve entirely non-existent
environmental and economic benefits will be replaced by production in other
parts of the world—places without the environmental scruples we can afford,
without the technology to use fertilizers and pesticides with minimal risk to
consumers and the environment.

Dr. Doering and his colleagues are right. American farmers, agricultural
suppliers, equipment manufactures, food processors, transportation companies
may suffer significant financial losses, consumer prices in the United States will
probably rise. But what Doering et a/ don’t say—because they are apparently
oblivious—is that losses to the American economy will pale in comparison to the
price that will be paid by world wildlife and the world’s environment.

The Environment

If the world’s population peaks at 8.5 billion sometime toward the middie of the
next century, as most forecasters predict, and demand for high quality protein,
fruits, vegetables, and cotton in the developing world keeps pace with increasing
levels of affluence, we will need to increase world agricultural output threefold. At
current levels of production, with high yield cropping and intensive livestock
husbandry, we are using 6 million square miles of the earth’s available surface
for agriculture. Without the benefit of today’s high-yield farming, we would have
to plow another 15 million square miles of wildlands just to meet current demand.
Without high-yield agriculture, we would have to clear the remaining wildlands


A project of Hudson Institute

Dennis Avery

Alex Avery

Research Director

Dave Juday
Adjunct Fellow

Richard Halpem, Ph.D

Comment on the Reports of the Hypoxia Task Groups to the
Committee On Environment and Natural Resources and the
Gulf of Mexico Hypoxia Work Group

Submitted on behalf of the Center For Global Food Issues
By Richard A. Halpern, Ph.D., Adjunct Fellow

The Great Disconnect

The Hypoxia Work Group's report to the National Science and Technology
Council's Committee on Environment and Natural Resources (CENR), assessing
“the causes and consequences of hypoxia in the Gulf of Mexico” finds that:

1. There are no discernable, measurable, or documentable “detrimental
ecological and economic effects” to the Gulf environment or its
fisheries from hypoxia.(Topic 2, p. 52);

2. Such ecosystem disturbances in the shallow continental shelf as can
be documented are as likely to be the result of trawling or “other
sources of stress.” (Topic 2, p. 50);

3. Even during the recent unprecedented extremes in hypoxic conditions
(1993-97), Louisiana's coastal fisheries flourished, maintaining “energy
flow to productive fisheries (crabs and shrimps) that depend on the
bottom” (Topic 2, p.9)

In short, this exhaustively researched and peer reviewed investigation has
concluded-—without qualification—that there is, at present, no reason to believe
that hypoxia has ever posed or now poses an environmental or economic threat
to the Gulf or its fisheries.

Nevertheless, and notwithstanding its own findings, the Work Group
recommends that five million acres of the world’s most productive farmland be

P.O. Box 202
Churchville, VA 24421
540-337-6354 @ 800-876-8011 @ FAX 540-337-8593 @ www.hudson.org/cgfi @ cgfi@rica.net

Adfunct Fellow


taken out of production, and that yields throughout the Mississippi River Valley
watershed be reduced, forcing smaller farmers out of business, through a
mandated 20 percent reduction in nitrogen inputs. (Topic 6, p. viii).

The disconnect between the work group's findings and its recommendation is so
complete and so manifest, that in order to justify the implementation of CENR’s
agenda to reduce agricultural production in the Mississippi River Valley, Task
Group 6 is compelled to argue seriously and publicly that the failure to discover
any economic benefit or scientific rationale for reducing nitrogen in the
Mississippi need not be an obstacle to the CENR plan.

The group, led by Purdue agricultural economist Otto Doering, concludes that the
CENR agenda can go forward because, after all, “important public decisions are
seldom made on the basis of strict benefit/cost analysis, especially when
complete benefits cannot be estimated.” The intellectual and scientific bankruptcy
of this line of reasoning is staggering. Even so, in the case of the Gulf, we are
dealing not with a failure to estimate “complete benefits” of proposed reductions
in nitrogen, but a complete and utter failure to discover any benefit at all.

In fact, all indications are that reducing nitrogen inputs from Mississippi Valley
agriculture will harm the Gulf fisheries, disastrously restrict American agriculture,
and endanger the world’s most threatened environments without any measurable
or sustained benefit to anyone or anything.

The Black Sea and Other Red Herrings

Having failed utterly to find a present risk to the Gulf, the Topic 2 task group, led
by Virginia Institute of Marine Science’s Robert Diaz and Andrew Solow of
Woods Hole Oceanographic Institution, have hit on a rationale for the assault on _
agriculture that may give marine science itself a bad name.

“Currently, there are no hypoxia effects on fisheries,” they concede, but, they
warn, conditions could worsen. “In the face of worsening hypoxic conditions, at
some point fisheries and other species will decline, perhaps precipitously,” they
hypothesize. But, Diaz, Solow and company know perfectly well that there are no
“worsening hypoxic conditions” in the Gulf. The hypoxic zone’s sudden
expansion to 7,000 square miles could only have resulted from the Great Flood
of 1993—a 500-year event, the “most devastating flood in modern United States
history,” according to the USGS. If this cataclysmic expansion of the hypoxic
zone produced no discernible negative impacts, hypoxia can never pose a
serious threat to the Gulf without changes in the Mississippi Valley of an order
than can be hardly imagined.

We can expect a 7,000-square-mile hypoxic zone once every 500 years. For the
fisherman who enjoyed enhanced catches during the mid-90s, that may come as
bad news.

By the summer of 1998, the hypoxic area had already receded to 4,800 square
miles, as the aftermath of the Great Flood waned. The impression, therefore, that