National Corn

Growers Association
Washington Office

122 C St. NW, Suite 510
Washington, DC 20001-2109
202/628-7001 FAX 202/628-1933

December 20, 1999

Gulf of Mexico Hypoxia Working Group
National Oceanic and Atmospheric Administration
National Centers for Coastal Ocean Science
Room 9127

11305 East-West Highway

Silver Spring, MD 20910

RE: Comments on the Integrated Assessment of Hypoxia in the Northem Gulf of
Mexico

Tam pleased to submit these comments on the Integrated Assessment of Hypoxia
in the Northern Gulf of Mexico on behalf of the National Com Growers Association
(NCGA). NCGA is a federation of 25 state associations and 19 checkoff boards
Tepresenting 29,900 grower members across the Corn Belt. On average, 78 million acres
are planted to corn in 48 states across the United States annually, representing
approximately 30% of the total row crop acreage harvested in this country. Corn has a
variety of end uses, including animal feed, as well as industrial uses such as corn
sweetener, comstarch, fuel ethanol and beverage alcohol.

Com growers have always realized the importance of wise use of natural
resources. Toward that end, NCGA has sponsored stewardship programs devoted to
conservation of soil and water resources. The Conservation Buffer Initiative, for
example, promotes the planting of buffer Strips to conserve soil and water resources while
Protecting crops, reducing wind erosion, and creating habitat for wildlife. This Program,
which began in 1997, is important in that it marks the first cooperative agreement
between USDA and a national commodity group designed to reach growers at the
grassroots level. NCGA also encourages stewardship through various watershed
Programs, promotion of best management practices, and research into making the com
plant itself more environmentally friendly. Fundamentally, corn growers believe that
environmental results can be achieved more effectively through stewardship and
voluntary programs than through additional regulation.

NCGA is supportive of voluntary incentive-based programs to improve water
quality and maintain productivity of our land. One of NCGA’s primary goals is to be
good stewards of our land. With this philosophy in mind, it is vital that hypoxia



NCGA Hypoxia Comments
December 20, 1999
Page 2 of 3

discussions not pit the interests of fisheries and shrimpers against farmers. NCGA urges
that primary consideration be given to voluntary efforts. Voluntary programs, providing
technical assistance and resources to growers is the most effective way to clevate
adoption of conservation practices. Understanding must be given to a grower’s financial
Situation and the ability or restraints on altering farming practices,

Throughout the Integrated Assessment, various scenarios for alteration in land
management will have a significant impact on growers, Any change in practices, be it
nitrogen application, wetland restoration, alteration of tiles, and /or alteration of cropping

put American agricultural products at a significant disadvantage in world markets.
NCGA monitors our competitor’s agricultural production closely, and is concerned that
significant changes in farming practices may shift our domestic and foreign markets in
favor of our competitors.

The Integrated Assessment does note information provided by the Fertilizer
Institute regarding nitrogen application, but NCGA would like to stress that changes in
agriculture are taking place tapidly. NCGA is involved in research to make the corn
plant more environmentally friendly, through innovations such as: the identification of
genes to make the plant more digestible for livestock thereby producing less waste;
making the plant more drought resistant; making the plant resistant to disease; and
improving nutritional value. Also corn yields have increased over the last 60 years due to
ongoing research and improving genetics. Through this important research, growers can
produce higher yields using less inputs and reducing stress on the environment.

While most water quality programs are interrelated, NCGA feels that the charge
of this task force was to evaluate hypoxia, and not speculate about the TMDL process.

It is vital that the recommendations based on this Integrated Assessment fully
account for the impact on US agricultural Production. Growers have a long and



NCGA Hypoxia Comments
December 20, 1999
Page 3 of 3

Any future recommendations must also factor in this time for results and be cautious of
oOverburdening growers with Tequirements because immediate results are not apparent.
Finally, the significant lack of direct data regarding conservation practices and specific
water quality improvements must be considered Prior to touting a specific numeric
criterion for water quality improvement.

The issues contained in this document have potentially significant impacts on the
livelihood of grower throughout the United States and we urge the members to take these
impacts into full consideration. NCGA would be pleased to participate in any discussion
on this matter with EPA, NOAA or other Task Force members.

Sincerely,

Syr~ D fenae—

Lynn O. Jensen
President