December 16, 1999

Mr. Donald Pryor

Gulf of Mexico Hypoxia Working Group
National Oceanic and Atmospheric Administration
National Center for Coastal Ocean Science

Room 9127 _

1305 East-West Highway

Silver Spring, MD 20910

Re: COMMENTS ON THE INTEGRATED ASSESSMENT ON
THE CAUSES AND CONSEQUENCES OF HYPOXIA IN THE
GULF OF MEXICO

Dear Mr. Pryor:

The Natural Resources Defense Council is a national, non-profit organization of
scientists, lawyers and environmental specialists dedicated to protecting public health and
the environment. Founded in 1970, NRDC has more than 400,000 members nationwide,
served from offices in New York, Washington, Los Angeles and San Francisco. NRDC
appreciates the opportunity to comment on the Integrated Assessment on the Causes and
Consequences of Hypoxia in the Gulf of Mexico.

In general, NRDC endorses the comments of the Gulf Restoration Network, which
discuss the array of issues covered by the Integrated Assessment, and we wish to restate
the point in those comments that "the Assessment makes important initial findings
regarding the relationship between nitrogen and the Dead Zone, sources of nitrogen
entering the Mississippi River Basin, and potential strategies for reducing the level of
nitrogen reaching the Gulf.” The comments below are intended to discuss one aspect of
the Integrated Assessment—its focus on pollution from livestock operations.

Concentrated Animal Feeding Operations (CAFOs) can contribute to nutrient pollution
through their emissions of ammonia and the often excessive and concentrated application
of manure onto the land. Additionally, CAFOs often utilize enormous lagoons to store
their waste and these lagoons often break or spill into surface waters, or leach into ground
and surface waters. Pollution problems are compounded since these operations tend to

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congregate around processing plants, with the result that more waste is generated in
certain counties and regions than can be taken up by the crops.

To its credit, the Integrated Assessment recommends that manure be more carefully
applied and be better managed when it is stored. In fact, the Integrated Assessment notes
that improved management of feedlot runoff is one of the three changes in agricultural
management practices that could have the greatest estimated potential to reduce nitrogen
sources to streams and rivers

However, unlike the Draft Hypoxia Assessment Reports, the Integrated Assessment
appears to ignore altogether the increased concentration in the livestock sector and the
potential for CAFOs to pollute. Nor is there any interest in learning more about the
problem — the recommendation in Draft Assessment Report Topic 4 that "there is a great
need for research on the impacts of large scale confined animal feeding operations and for
studies on ways to minimize these impacts" (Draft Assessment Report Topic 4, p. 72)
was not included in the Integrated Assessment, Finally, Table 2.1 leads the reader to the
conclusion that the problem of animal manure is not significant (15% of the total N flux
to the Gulf), but fails to add the footnote that was included in Table 6.4 of Draft
Assessment Report 3 — that the 15% is a very uncertain number. The lack of certainty
about the contribution from CAFOs to the Gulf of Mexico was also noted by Dr. Otto
Doering in his presentation on Draft Assessment Report Topic 6. Mr. Doering asserted
that the threat of nutrient pollution was more significant than the calculations of manure
Suggest. He further indicated that this was duc to the concentrated industrial manner in
Support in recent publications. See Carey, ct al. "The Role of the Misissippi River in the
Gulf of Mexico Hypoxia," p. 27 (Environmental Institute Report 70, May 1999); Clean
Waser Network and the Netural Resources Defense Cowncil, Americas Animal Factories:
Prevent Polh 0 estock Waste (Washington, D.C.,

Much like the Draft Assessment reports, the Integrated Assessment ignores contributions
to water quality impairment from CAFOs besides manure applications onto the land.
These contributors include manure that is leached by CAFO lagoons into groundwater
that connects with surface water, and lagoon failures. In a recent analysis of factory farm
pollution in 1999 alone:

© Spills and dumping of manure and other waste products occurred over 100 times
at factory farms in the ten surveyed states, including: Arkansas, Illinois, lowa,
North Carolina, Ohio, Minnesota, Missouri, Oklahoma, Wisconsin, and Virginia.

© More than four and a half million gallons of manure were spilled or leaked into
amount spilled is often unknown.

© Public health and wildlife were threatened by pollution of our rivers, lakes, and
coastal waters.



Nowesk sod Gp Emch Wales Lengueet Auntan (Cette Dae December 1999)

help to reduce pollution from CAFOs, include banning open air lagoons and other liquid
manure systems to address lagoon breaks, spills and leaching; supporting sustainable _
livestock systems -- that do not concentrate and dispose of the waste in liquid form; and
requiring water quality monitoring and reporting by CAFOs to measure pollution
contributions and ensure compliance with pollution controls.

In conclusion, while the Integrated Assessment makes some strong and helpful policy

points in a number of areas, the document needs to a better job of assessing the impact of
and making recommendations to reduce the pollution from CAFOs.

‘Senior Resource Specialist