2B NATIONAL CATTLEMEN’S BEEF ASSOCIATION

100 YEARS 1301 Pennsyvania Ave,, NW, Sutte #300 * Washington, DC 20004 * 202-347-0228 » Fax 202-638-0607
USA

August 12, 1999

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

1305 East-West Highway

Silver Spring, MD 20910

RE: Comments on Scientific Reports For An Assessment on the Issue of Hypoxia

The National Cattlemen’s Beef Association is pleased to comment on the six
topical scientific reports requested by the National Science and Technology Council's
Committee on Environment and Natural Resources (CENR) for an assessment on the
causes and consequences of hypoxia in the Gulf of Mexico. NCBA represents the many
cattle feeders and family ranchers, all of who have a stake in protecting the environment.

Initiated in 1898, NCBA is the marketing organization and trade association for
America’s one million cattle farmers and ranchers. With offices in Denver, Chicago and
Washington, D.C., NCBA is a consumer-focused, producer-directed organization
representing the largest segment of the nation’s food and fiber industry. As
representatives of family farmers and ranchers with a vested interest in protecting the
environment, we are pleased to provide the following comments.

The cattlemen are strongly committed to addressing water quality challenges
today and in the future through sound science based management practices. Programs
initiated in the 1985 Farm Bill and its successors that provide technical and financial
assistance to facilitate implementation of best management practices (BMPs) have
resulted in environmental and water quality improvements.

Many cattle producers are currently participating in state and federal regulatory
programs that address many of the potential water quality issues discussed in these
reports. Others not required to be permitted under The Clean Water Act are participating
in nutrient planning, habitat conservation and conservation programs to better the
environment and water quality.

NCBA always encourages our members to only participate in programs based on
sound science that are proven to protect the environment through actual on the ground
monitoring and analysis. We do not support one-size-fits all regulatory programs for
environmental protection.

AMERICA’S CATTLE INDUSTRY

Denver Washington, D.C. Chicago


These documents look at land use and make a direct correlation to nitrogen
loading based on modeling and not actual water samples. Land use in the Mississippi
watershed cannot be directly linked to all nitrogen loadings. Thus, we disagree with the
conclusion and approach taken that a set percentage reduction in nitrogen use will
accomplish the goal of reducing hypoxia. This is exactly the type of one-size-fits all
approach that is forced down upon states that we discourage.

Farmers and ranchers want a voluntary, cooperative effort to ensure that the
actions we take will result in protecting the environment. Farmers have not only an
obligation to protect the environment because they will pass this land on to future
generations but also an economic self-interest to maximize production by getting the
most production our of the least amount of output. Thus, the assumptions that producers
are over applying nutrients would be counterproductive.

NCBA supports science based programs that help America’s cattlemen build upon
the ongoing progress in improving water quality. Thank you for this opportunity to
comment and we hope you take our comments into consideration.

Sincerely,

Bu ba

Brice Lee

Chairman

Property Rights and Environmental Management Committee
National Cattlemen’s Beef Association