December 20, 1999

Gulf of Mexico Hypoxia Working Group

National Oceanic and Atmospheric Administration
National Centers for Coastal Ocean Science
Room 9127

1305 East-West Highway

Silver Spring, MD 20910

RE: Comments on the Integrated Assessment of Hypoxia
In the northern Gulf of Mexico

The undersigned agricultural organizations submit these comments on
issues presented in the Integrated Assessment of Hypoxia in the northern Gulf of
Mexico.

We represent a vast array of agricultural interests, all of which have a
vested and demonstrated concern about our environment. We have a long
history of implementing conservation and other stewardship practices. We
represent the majority of privately held land in the Mississippi River basin, and
strongly believe that successful plans to reduce nutrient losses to the
environment will be built on current practices and programs which are voluntary
and incentive-based.

While the integrated assessment attempts to draw a simple picture of the
causes, consequences and cures for hypoxia, a close reading reveals a more
complicated scenario. Data provided in the report indicates that nutrient loads to
the river are a contributing factor to hypoxic conditions, not a directly correlated
primary cause of hypoxic conditions. In fact, there are many factors that play a
role in the incidence and extent of Gulf hypoxia. An action plan that deals with
one factor — nutrient enrichment — will be unlikely to significantly reduce Gulf
hypoxia. Further, we strongly urge that this report be revised with a critical eye
toward the use of proper terminology and consistent units for the following data
elements: nutrient inputs to the soil, edge-of-field nutrient load lost to the river,
and nutrient loss reductions.

While we believe the assessment should more accurately reflect the
multiple contributors, we do not believe corrective action needs to be delayed. In
fact, our members have been and are involved in implementing water quality
protection measures each and every day. These actions take the form of an
array of best management plans that farmers implement to become more
efficient and productive in their farming operations. Farmers have an

DEC 20 ee



economic self-interest in reducing nutrient losses. Nutrient loss reductions are
direct cost-savings for farmers. That's why farmers are continuing to use soil
tests, fertilizer timing and placement methods, nutrient management plans and
other BMPs to make maximum use of all nutrient sources. The widespread
adoption of conservation tillage practices has helped reduce nutrient loss.

The integrated assessment provides evidence these efforts are working.
Figure 2.6 shows outputs, or production, in the basin has been climbing even
faster than inputs, leaving less residual nitrogen in the basin. This declining
trend in residual nitrogen is a result of farmers implementing practices that make
them more efficient. This is a success story that should be heralded and built
upon in the action plan.

The Action Plan should build on existing, voluntary, incentive-based
program to address nonpoint source pressures rather than rush to place blame in
order to justify a regulatory program. As outlined in the integrated assessment,
there are several federal incentive programs available to help farmers control
nutrient runoff. These include the Conservation Reserve Program, Conservation
Reserve Enhancement Program, the Conservation Buffer Initiative, the Wetlands
Reserve Program, and the Environmental Quality Incentive Program. An action
plan that successfully reduces nutrient loss will build on these existing, incentive-
based federal programs as well as voluntary BMPs being implemented by
farmers out of their own self-interest. Nutrient loss is a field-specific problem; it
will be reduced through farmer education, technical assistance and conservation
incentives, leaving them the flexibility to make site-specific management
decisions in conjunction with the local public and private advisors. National
regulatory measures such as those suggested in the integrated assessment will
not be effective and may unintentionally undermine existing, successful water
quality improvement initiatives.

The integrated assessment contains many proposals for increased
research and monitoring efforts, and we support these proposals. Increased
research into the effects and causes of hypoxia and the impact of agricultural
practices on water quality will build a better base of understanding of what can
and should be done about hypoxia. Increased monitoring is essential to
understanding the long-term benefits of these practices.

We in the agricultural community are committed to more efficient nutrient
use, which will reduce the incidence of nutrients in water. We continue to
support voluntary, incentive-based programs that help farmers adopt these types
of practices. We hope the action plan will be built on current voluntary programs
that are successful, and not suggest new, regulatory requirements. We continue
to call for representation of private agricultural interest in the development of the



final Integrated Assessment and the Action Plan, as required under section 603
(c ) of Public Law 105-383.

Sincerely,

Agricultural Retailers Association

American Farm Bureau Federation

American Soybean Association

National Association of Conservation Districts
National Association of Wheat Growers

National Association of State Conservation Agencies
National Association of State Departments of Agriculture
National Cattlemen's Beef Association

National Conservation Buffer Council

National Corn Growers Association

National Cotton Council

National Council of Farmer Cooperatives

National Milk Producers Federation

National Pork Producers Council

The Fertilizer Institute