"Keeney and DeLuca (1993) examined nitrate concentrations in the Des Moines
River in 1945, 1955, 1976, and from 1980 through 1990 and found the average
nitrate-nitrogen concentration to have changed little in the last 45 years (5.0 mg-
NAL in 1945 to 5.6 mg-N/L in 1980-90). They concluded that intensive agricultural
practices that enhance mineralization of soil nitrogen coupled with subsurface
artificial drainage are the major contributors of nitrate-nitrogen to streams and
rivers of the Midwest."

Report 5, Section 1.3.1, Pg. 5

The authors have glossed over the evidence that supports the scientific
conclusion that mineralization of soil nitrogen is the major contributor of nitrate-
nitrogen to the Mississippi River Basin and have instead focused only on fertilizer
nitrogen. Mineralization of soil nitrogen is a natural process that provides
beneficial nitrogen for crop production. Soil organic matter content, water holding
capacity and crop production capacity are degraded if mineralized soil nitrogen is
not replaced in the soil. Elsewhere in these reports the authors have asserted
that nitrate-nitrogen concentrations have been steadily rising in the Mississippi
River. The above quotation appears to contradict this assertion.

"Goolsby et al. (1999) found 2.7 million metric tons per year of nitrogen being
discharged into the Mississippi River Basin, about 40% of the total fertilizer use
in the basin (Table 1.1)."

Report 5, Section 1.3.2, Pg. 7

“Point source discharges of nitrogen are estimated to add 0.27 million metric
tons/yr of nitrogen to the streams and rivers of the Mississippi River Basin, about
1.5% of the total loading generally coming from agricultural lands (fertilizer use,
mineralizing soil, and legume N-fixation) (Goolsby

et al., 1999; Table 1.1)."

Report 5, Section 1.3.4, Pg. 7

The above statements are very misleading, the manure nitrogen mentioned
above was not "discharged" but rather was managed as a nutrient source for
crop production through methods such as land application, composting and other
methods. The use of the word "discharge" puts an unnecessary negative
connotation on the activity. The second quote further misleads the public by
attempting to downplay the amount of nitrogen discharged to the rivers and
streams of the Mississippi River Basin, describing it as "1.5% of the total loading
generally coming from agricultural lands." This would better be described as
17% of the nitrogen that is ultimately discharged to the Gulf of Mexico. It is
incorrect to state that it is 1.5% of the nutrients "coming from" agricultural lands.

“Long-term changes in annual precipitation due to climate shifts could have a
major effect on nitrate loading to the Gulf of Mexico from the Mississippi River


References

Sharpley, A.N., T.C. Daniel, J.T. Sims, and D.H. Pote, 1996. Determining
environmentally sound soil phosphorus levels. J. Soil Water Conserv. 51: 160-166.


" Without focusing on these critical source areas, broadly applied remedial
measures are likely to be an inefficient and expensive approach fo reducing P
exports to surface waters.

"A significant difference between strategies for N and P is that N losses can
occur from any location in the watershed, while areas prone to surface runoff
contribute most to P losses. Hence, remedial strategies for N can be applied to
the whole watershed. The most effective P strategy, however, would be to
prevent excessive buildup of P across the whole watershed and reduce surface
runoff from critical areas that have a high potential for exporting P to surface
waters.”

Report 4, Section 3.2.1.3 Page 23

In the space of one paragraph, application of the management strategy of
“preventing the development of excessively high levels of soil available P" in all
soils in the watershed is changed from an "inefficient and expensive approach",
to the "most effective" P strategy. | believe this is a mistake and this statement
would make more sense if the last statement read: "The most effective P
strategy, however, would be to prevent excessive buildup of P and to reduce
surface runoff from critical areas that have a high potential for exporting P to
surface water."

"In addition to control and treatment of runoff and erosion and proper
management of fertilizers and manure, changes in animal feed may provide
Significant reductions in P losses to surface waters. The P content of animal feed
can be matched to dietary intake requirements, thereby reducing P
concentrations in animal manure (Daniel et al. 1998). An alternative strategy is to
add the enzyme phytase fo animal feed to increase the retention efficiency of
feed phosphorus by animals (Daniel et al. 1998). Finally, com used for animal
feed can be altered genetically to produce low levels of phytic acid phosphorus
(Ertl et al. 1998), thereby reducing excretion of P."

Report 4, Section 3.2.1.3 page 23

Stating that changes in animal feed may provide significant reductions in P
losses to surface waters is not correct. To make this assertion you have to
accept as fact that significant quantities of animal manure are discharged directly
into surface waters. This is not the case. Reducing P concentrations of animal
manure is advantageous because it reduces the amount of land area over which
the manure would need to be applied if it was applied at a phosphorus
agronomic rate. It is a tool which may help farmers to reduce the cost of
compliance with regulatory restrictions on the amount of phosphorus that may be
applied to the soil. It is a stretch of logic to assert that it would provide significant
reductions in P losses to surface waters, especially since the soil concentration
of P is not even significantly related to P losses to surface water.


Basin. Increased amounts of annual precipitation would likely lead to greater
surface runoff and subsurface drainage of water containing nitrates."

Report 5, Section 3.1.1.5 , Pg.18

I can find no scientific justification for the above assertion. Increased annual
precipitation is likely to have a large number of environmental effects within the
Mississippi River Basin, including a decrease in the likelihood of drought years,
an increase in denitrification, and increased crop yields, and yes increased runoff
and subsurface drainage of water. It is as likely , if not more likely, that
increased precipitation would decrease the nitrate loadings to the Gulf of Mexico
from the Mississippi River Basin. If we are willing to accept as scientific fact that
there is a trend toward increased precipitation of between 10% over 90 years, or
3% a decade, both of which the author claims are correct, then the effects of this
increased rainfall should be accounted for in any plan for the Mississippi River
Basin.

Conclusion

In general, there are too many things that are either identified as unknown, and
likely others that have not been identified that lead a person to conclude that the
development of a remediation plan for the hypoxia in the Gulf of Mexico is
premature. It is evident from the topic papers that not only are we unsure about
the need to remediate, it is quite possible that any remediation would have
negative economic effects on the Gulf of Mexico fisheries. It is irresponsible to
spend billions of dollars in additional environmental controls in one region of the
U.S. with the potential effect of hurting another region.

The document fails to relate the amount of food produced in the Mississippi River
Basin to the increased use of nutrients. Nor does it identify the amount of
nitrogen that is removed from the Mississippi River Basin annually in the form of
feed for animals and food for humans. The documents are written as if there is a
one way flow of these nutrients into this ecosystem and the only removal is
downstream into the Gulf of Mexico. The proposed plan will hobble the most
productive food producing region of the world, only to remove nutrients and
productivity from the Guif of Mexico fisheries.

We are concerned about the great potential for negative consequences of going
forward with the proposed planned activities contained within these integrated
assessment documents. We are also very concerned with much of the language
and the way this "scientific” document is written. These documents are written
more from the viewpoint of building a case against nitrogen fertilizer use in
modem high-yield crop production rather than as a scientific assessment of the
situation. They even go so far as to admit that the costs far outweigh the
potential benefits, but cost/benefit analysis is rarely used in public policy
decisions.


August 2, 1999

John Field

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

1305 East-West Highway,

Sitver Spring, MD 20910

Facsimile: (301) 713-4270

Dear John Field,

Subject: Gulf of Mexico Hypoxia Working Group

BIO GRO
A WASTE MANAGEMENT COMPANY

Midwest Region
4343 Infirmary Road
Miamisburg, OH 45342
(937) 384-0659

(937) 384-0674 Fax

Enclosed please find our comments on the Gulf of Mexico Hypoxia Reports to the Committee on
Environment and Natural Resources. Please contact me at (937)384-0659 if you have any questions

or concems.

Sincerely,

YZ

Bruce MacLeod
Technical Services Manager

Enclosures (2)
cc: Jeffrey Faust, Pamela Gratton

A Division of Wheelabrator Water Technologies, Inc.



It is obvious from these documents that the plan to reduce the efficiency of
Midwest agriculture through cutting back nitrogen fertilizer and taking acreage
out of production would be both arbitrary and without scientific justification.
Regulations need to be based on sound science.

We also add that, in addition to our comments, we concur with the comments
submitted by Richard A. Halpern on behalf of the Hudson Institute Center For so
Global Food Issues (copy attached).

Please contact me at (937) 384-0659 if you have any questions or would like
further information.


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

Wheelabrator Water Technologies Inc., Bio Gro Division

Wheelabrator Water Technologies Inc., Bio Gro Division is the largest biosolids
management firm in the Midwest United States, as well as North America. The company
currently has over 200 biosolids management projects nationwide. Bio Gro is involved in
both the treatment of wastewater solids and distribution and marketing and land
application of the treated solids (biosolids) on farmland.

Bio Gro is disappointed in the direction that the assessment has taken. The reports started
from the foregone conclusion that nutrient reductions are necessary in the Mississippi
River. A more appropriate starting point would be to first identify if there is a problem
and then look for potential solutions to the problem. The reports are written to defend a
course of action when there is no scientific basis for that course of action. Such
statements as, “Lack of identified hypoxic effects in available fisheries and fish
population data does not imply that effects would not occur should conditions worsen."
Report 2, Section 5.1 Pg 51. This quotation is one of the numerous examples of
language throughout this report used to justify a massive and costly ratcheting down of
nitrogen fertilizer usage in the Cornbelt based completely on speculation. This statement
is particularly misleading when you consider that the conditions would have to be worse
than "the most devastating flood in modern U.S. history" according to the USGS. Taking
any mitigating action based on this unrealistic hypothetical situation is irresponsible.

Specific Comments on the Reports

"The lack of obvious detrimental ecological and economic effects does not
preclude the possibility of ecological and economic disaster in the future."
Topic 2, Section 5.1 , Pg. 52

Nor does it predict it.

“Consideration of how hypoxia and other stressors interact with all aspects of the
Gulf ecosystem is essential prior to planning any restoration efforts."
Topic 2, Section 5.3, Pg. 54

We agree with the above statement, unfortunately the restoration plan was
tequired before the process began. The work group has developed a plan before
steps essential to the development of the plan were completed.


“No satisfactory framework currently exists to predict the quantitative effects of
changes in stream nutrient concentrations on either fish yield or fish species
composition, and thus no quantitative statements can be made about the
potential effects of nutrient loading restriction on fisheries throughout the MRB.
Attempts should be made to develop such models."

Report 4, Section 4.1.3 Pg. 74

“Moreover, projected changes in nutrient inputs to MRB rivers from improved
land management practices and additional controls on point sources are not
likely to have dramatic effects on trophic state conditions in the rivers; i.e. they
likely will remain moderately productive systems. On this basis, it seems unlikely
that sport fisheries would be affected negatively. Any declines that may occur in
total biomass production likely would be compensated for by improvements in
habitat and other changes that would promote the development of game fish
populations over rough fish populations."

. Report 4, Section 3.2.4 pg. 59-60

The authors, while readily admitting that they do not have the framework
available to make quantitative predictions about the fish yield or fish species
composition, are quite willing to speculative about what would likely happen in
the Mississippi River Basin. To exacerbate this, the same speculative results
are included as a positive ecological effect without the qualifying statements. It is
clearly a very biased opinion to state that this is a positive and a negative, but
likely not a negative.

"When available P levels at the soil surface exceed threshold levels at which
there is no further response by the crop (Sharpley et al. 1994), the potential for P
losses to surface waters increases. The critical threshold varies by state and crop
but generally ranges from 25 to100 mg P/g for the Bray-1 soil extraction and
from 35 to 120 mg P/kg for the Mehlich-1 extraction (Sharpley et al. 1994).”
Topic 3.2.1.3 Page 21

The writer is over simplifying this document and this creates a misunderstanding
of the issue of soil phosphorus levels. The "critical threshold" that the author is
talking about is the agronomic critical value for soil test P, or the P soil test value
above which the addition of phosphorus fertilizer does not economically increase
crop yields. It is being presented as an environmental threshold for preventing P
losses to surface waters. In fact, the soil test P content of surface soils is a very
poor indicator of P loss to surface soils because the volume of runoff, as affected
by climatic, edaphic and agronomic factors plays a larger role (Sharpley et al.
1996). Many states are developing arbitrary "environmental" thresholds that are
at least 3 to 10 times higher than agronomic critical values (Sharpley et al. 1996).
There is an insignificant correlation between the soil test phosphorus levels and
total P loss from soils. Applying a threshold P concentration value on all soils
across a watershed is not scientifically defensible as a method of protecting
surface water.