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lowsa Farm Bureau Federation
5400 University Avenue, West Des Moines, lowa 50266-5997 / (515) 225-5400

July 28, 1999

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

1305 East-West Highway

Silver Springs, MD 20910

RE: White House Committee on Environment and Natural Resources Hypoxia Assessment

Thank you for the opportunity to comment on your recent hypoxia assessment. Nutrient
management is an extremely important issue for Iowans, particularly Iowa farmers. In fact,
agribusiness, commodity groups and the Iowa Farm Bureau Federation recently reconvened the
Towa Nutrient Management Task Force to examine a number of nutrient management issues,
including hypoxia. This group will examine progress on particular nutrient management issues
since the task force issued a report and recommendations nine years ago. The task force will also
make recommendations for future nutrient’ management strategies that the individual
organizations will work to implement.

With this in mind, our first comment is that the local level is the appropriate place to discuss
nutrient management strategies and policies. While the Committee on Environment and Natural
Resources (CENR) hypoxia assessment provides a great deal of information and data to be
considered and specific recommendations on strategies and polices to deal with the issue, the
discussion about the applicability of these recommendations should first begin at the state and
local watershed level.

In order to have the appropriate time to at least begin this discussion, the comment period should
be extended for at least another 60 days. The comment period that has been provided is
inadequate given the complexity of this important issue and the potential impact on the
agricultural economy. We request that you extend the comment period for another 60 days to
allow for adequate time for industry review of the assessment.

In addition, preliminary review of the six reports, and the scientific literature, lead us to reject the
hypothesis that hypoxia in the northem Gulf of Mexico has accelerated in the last 50 years due to
a doubling or tripling in the fluxes of nitrogen and phosphorous from the Mississippi River Basin
(MRB), primarily from the use of inorganic fertilizer. By using the holistic methodology
identified by the CENR in its own report on "Setting a New Course for Coastal Ocean Science,"
we find that the fluxes of nitrogen and phosphorous from the MRB to the northern Gulf and the

The Voice of Agriculture


Towa Nutrient Management Task Force
Hypoxia Assessment Comment Letter
Page 2

rate of primary productivity in the northem Gulf has declined over the past 50 years, even though
the use of nitrogen and phosphorous fertilizer has increased.

Also, the reports lack a credible, scientific, conceptual framework for addressing the causes and
remedies of hypoxia. The assessment is narrowly focused on dissolved nutrients and, even prior
to the assessment, the solution to the problem had been defined as a reduction in

the load of dissolved nutrients carried by the Mississippi River. The structure and scope of the
assessment is even inconsistent with the methodology identified by CENR in its own report.
This report, developed by consensus among federal science agencies, the university community,
and natural resource managers, recommends a comprehensive, integrated, systems approach to
address the complexities associated with the degradation of coastal ocean quality. This approach
includes recognizing the heterogeneous and highly dynamic nature of coastal ecosystems and the
need to address in a thorough manner freshwater, suspended solids, sediments, terrestrial organic
matter, the loss of wetlands, pollution, and land-use changes, as well as dissolved nutrients. In
addition, the assessment does not address the probable negative impacts on the rich commercial
and sports fisheries in the northem Gulf of a reduction in nutrient loads.

A more thorough analysis of the recommendations must also be completed. Recommendations
such as the use of treatment wetlands, while based on some preliminary work by Dr. William
Crumpton at Iowa State University, and others, deserves continued discussion. The use of
constructed or restored treatment wetlands on a large scale has not been demonstrated, nor
adequately evaluated in terms of the policy’s impact on private property ownership, it’s impact
on state resources, and coordination with federal conservation programs.

In particular, recommendations for fertilizer restrictions and/or taxes are not justified or
supported by fact. There is no cause and effect relationship demonstrated by the assessment, or
any other known science, between a 20 percent mandated cut in agricultural nutrient loadings
and any improvement in the short run in water quality. These kinds of recommendations have
serious economic consequences for farmers and their communities. They must be fully
evaluated, especially when economic conditions are already very serious for farmers.

The National Soil Tilth Laboratory in Ames says there may be a correlation between hydrology
in the watershed and total nutrient loadings. However, given the complex relationship between
watershed hydrology, established drainage systems and productive soils in Iowa, any policy
choices must be fully discussed and considered by watershed residents and scientists before
federal conclusions are reached.

We do support continued opportunities for voluntary education and demonstration of best
management practices that protect water quality. Iowa farmers have made great strides in soil
conservation and efficient use of nutrients. With continued use of voluntary programs using best
management practices and cost-share assistance, Iowa farmers will make even more progress.
Progress to date includes the following highlights:

© Com researchers continue to produce hybrids that increased yield and increased their ability
to use nitrogen fertilizer. In fact, the number of pounds of nitrogen fertilizer applied to grow


Towa Nutrient Management Task Force
Hypoxia Assessment Comment Letter
Page 3

a bushel of corn has declined 22 percent from a high of 1.31 pounds N/bushel produced in
1984, down to 1.02 pounds N/bushel in 1998.

¢ Towa has established an estimated 150,000 acres of conservation buffers of grass and trees.
These buffers help improve water quality in our lakes and streams. Iowa has more farmers
with continuous CRP than any other state, with one of every 10 landowners participating.

e By 1992, Iowa farmers had applied conservation practices to save 100 million more tons of
topsoil than in 1982 ~ enough to fill a convoy of dump trucks 105 feet wide, parked bumper
to bumper from Council Bluffs to Davenport.

This success is a direct result of “the Iowa model” for conservation programs, using voluntary
education, information and demonstration. The Conservation Districts of Iowa, Iowa
Department of Agriculture and Land Stewardship, Natural Resources Conservation Service, the
DNR, ISU Extension, and commodity, farm and agribusiness groups and others are committed to
the Iowa model.

In summary, this assessment provides a starting point for continued discussion. However, given
the complexity of the issue and the unknown effects of the various policy choices, extreme care
must be taken to allow adequate time for consideration and further research. Premature
decisions may have serious irreversible consequences for watershed residents. We are opposed
to any decisions based on inadequate information available and time for consideration at this
time. :

Sincerely,

fey Bands

Roy Bardole, Chairman

The Iowa Nutrient Management Task Force
Agribusiness Association of Iowa
Iowa Cattlemen’s Association
Iowa Corn Growers Association
Towa Dairy Products Association
Towa Farm Bureau Federation
Towa Pork Producers Association
Towa Poultry Association

Iowa Soybean Association

Towa Turkey Federation