acy UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
g WASHINGTON, D.C. 20460

AUG 2 - 1999

OFFICE OF
WATER

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

1305 East-West Highway

Silver Spring, MD 20910

Gulf of Mexico Hypoxia Working Group:

This letter summarizes the Environmental Protection Agency’s comments on the six
science reports developed at the request of the National Science and Technology Council’s
Committee on Environment and Natural Resources (CENR) for an assessment of the causes and
consequences of hypoxia in the Gulf of Mexico. First, let me thank the Working Group and
especially the six report team leads for doing a credible and commendable job on finalizing these
reports. The reports provide a valuable source of scientific information, not only for use by the
Mississippi River/Gulf of Mexico Watershed Nutrient Task Force, but also for the worldwide
scientific community. Our comments on the reports are limited to a few major areas which
should be considered by the Working Group in the development of the Integrated Assessment on
the reports. Our overall review disclosed some apparent inconsistencies among the reports which
should be resolved through the Integrated Assessment process.

Review of the topic two report on “Ecological and economic consequences of hypoxia,”
shows that considerable effort was made to analyze available data within the existing time and
resource constraints. However, we want to emphasize that the conclusions for the ecological
assessment only relied on a limited analysis (trawlable species in 1987-88 and 1993-94) of the
SEAMAP (Southeast Area Monitoring and Assessment Program) Environmental and Biological
Atlas of the Gulf of Mexico database. Further analysis of the SEAMAP data is pertinent to better
characterize the relationship between hypoxia and living resources in the Gulf of Mexico.

Also, the economic methods used in developing the topic two report may not represent
the best ways of properly valuing all the economic consequences of hypoxia. The evaluation of
the economic consequences of Gulf hypoxia was based solely on an evaluation of economic
effects on the fisheries. The economic methods used may have understated the total benefits of
Testoring the ecosystem, which can be estimated using other natural resource economics -
approaches. Finally, the'fishery data that were available for conducting this evaluation may, not
‘be as accurate as is desirable, due to fishery reporting problems.

The topic six report on “Evaluation of economic costs and benefits of methods for

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reducing nutrient loads to the Gulf of Mexico,” also contains limitations in its analysis of
economic benefits and does not elaborate on some of the methods mentioned in the previous
reports. These include benefits involving more efficient use of organic and inorganic fertilizers
and the energy associated with them as well as the premise that keeping nitrogen on the fields
would represent a benefit. In addition, the benefits of riparian buffers are understated. In cited
literature, depending on the location, nitrate loading reductions vary from zero to ninety percent
by using riparian buffers. In conclusion, the economic analysis is limited in its discussion of
economic and ecological benefits of restoration and alternative floodplain management practices
within the Mississippi River Basin.

We agree with the recommendations, especially in report five “Reducing nutrient loads,
especially nitrate-nitrogen, to surface water, groundwater, and the Gulf of Mexico” that
flexibility of techniques and consideration of appropriate places for actions will need to be
considered when using the information presented for any policy recommendations or actions.

In regard to research needs, each report had its own focus. There needs to be more
specificity with respect to the research activities and we believe this could be addressed in the
Integrated Assessment. We thank you for the opportunity to comment on these reports and look
forward to working with the Working Group once the Integrated Assessment is drafted.

Wy

Robert Was#tand, Director
Office of Wetlands, Oceans, and Watersheds