Board of Directors
Marry Mogged, President
1701 N 200 E Ad.
Onarga, IL 60955
phone and fax: 815-265-4603

Robert Muich,
Secretary/Treasurer/
Legisiative

PO, Box 28

Raymond, IL 62560
phone and fax: 217-228-3108

Eart John Coers, Region |
27637 Arrow Rd
Deer Grove, IL 61243-9719
phone and fax: 815-436-4272

Orville Kuehi, Region |
27980 Madiyn Drive
Rock Falls, IL 61071
815-625-8229

Steve Degter, Region Vi
Rt 1, Box 21
Mattoon, IL 61938
217-234-7552

Jdonn Tanner, Region Vi
AA 1, Bax 59C
Stewardson, IL 62463
217-682-3222

Gordon Endsiey, Region Vil
RR 1, Box 145
Mt. Erie, IL 62446
618-854-2518

Maurice Lannon, Region Vit
1823 Co Rd 600 N
Sidney, IL 61877
217-684-2917

Gene Mahrenhoiz, Region Vil
RR 2, Box 62
Lawrenceville, IL 62439
Phone: 618-864-9092
fax: 618-943-6604

State Office
Executive Director
Heather Hampton Knodle
201 West Fairground Avenue
Hillsboro, IL_ 62049
phone: 217-532-5457
fax: 217-532-5468
‘e-mail: ink@cillnet.com

Legal Counsel
dim L. Ayers

Illinois Association of Drainage Districts

201 West Fairground Avenue, Hillsboro, Illinois 62049 Telephone 217-532-5457 FAX 217-532-5468

improving land and water management by sharing information and ideas.

Galf of Hypoxia Working Group

National Centers for Coastal Ocean Science
WS 13446 SSMC4

1305, East-West Highway

Silver Springs, Maryland 20910

August 10, 1999

To Members of the Working Group:

Ptease accept the following comments regarding the Gulf of Mexico Hypoxia Assessment made on
behalf of the Ilinois Association of Drainage Districts (ADD). The IADD membership owns the
land and manages water on one-quarter of the state’s farmland. [ADD also represents consulting
engineers and drainage districts that operate in completely urbanized areas. In rural and urban areas,
our membership is directly involved in land use decisions that can improve water quality. We have
followed the issue of hypoxia in the Guif of Mexico over the past three years. Following is a
summary of our review of the Gulf of Mexico Hypoxia Assessment.

Scfence

Background: The Assessment tested only one hypothesis. The hypothesis held that hypoxia in the
Gulf of Mexico is caused by nutrient overioads from freshwater sources — the Mississippi River Basin
(amore than 42% of our nation’s watershed) and that hypoxia has led to negative economic impacts in
the gulf.

IADD Comment: The Assessment falls short of exploring the many factors and conditions that create
hypoxia. There are more than 80 possible hypotheses that could explain gulf hypoxia. Also, only
selected data sets were used to test the hypothesis - versus following the scientific method of using ali
available data sets related to the topic of hypoxia.

IADD Comment: The hypothesis was not proven in the six reports comprising the Assessment. For
example; data shows that at least 70% of the water from the Mississippi River flows east ~ away from
the Gulf of Mexico where the hypoxic zone is located; there has been a reduction in nitrate (the
aqueous version of Nitrogen, “suspect” nutrient of the study) loads in the Illinois and Upper
Mississippi rivers over time; there have been no negative economic impacts on fisheries in the guif
attributed to hypoxia.

Policy

Background: The Assessment and accompanying documents recommended that changes to current
water laws be made based on the conclusions of the assessment.

TADD Comment: The science was inadequate, therefore the Assessment is not a valid basis for any
policy-related action. Specifically, there should be no change to the Clean Water Act or
creatiowalteration of existing watershed programs as a reaction to the hypoxia in the Gulf of Mexico
or what some have called the “dead zone.”

Summary Recommendations

Background: Hypoxia is a naturally occurring phenomenon in more than 40 locations around the
globe. For example; much of the Pacific Ocean is hypoxic with a distinct band of hypoxia that lines
the west coast of North America from Oregon south along Latin America to the middle of Chile.
IADD Recommendations: 1. We encourage exploring many hypotheses and complete data sets in
further study of the hypoxia phenomenon. 2. We encourage the involvement of state-based scientists
representing universities, industry, natural surveys and state agencies. 3. We encourage the
involvement of state-based agency, university and business economists to model cost-benefit
scenarios. 4. We encourage extensive public involvement — led by the Congress — in review and
discussion of the findings.

Thank you for your attention. Please call with questions, 217-532-5457.
cc: Members of Congress

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