Upper

Mississippi River

Basin Association

ILLINOIS, IOWA, MINNESOTA, MISSOURI, WISCONSIN

December 17, 1999

Gulf of Mexico Hypoxia Working Group

National Oceanic and Atmospheric Administration (NOAA)
National Centers for Coastal Ocean Science

Room 9127

1305 East-West Highway

Silver Spring, Maryland 20910

To the Gulf of Mexico Hypoxia Working Group:

In response to the “Notice of Availability of an Integrated Assessment of the Causes and
Consequences of Hypoxia in the Gulf of Mexico” published in the October 21, 1999
Federal Register, these comments are submitted by the Upper Mississippi River Basin
Association and the five upper basin states’ members of the Mississippi River/Gulf of
Mexico Watershed Nutrient Task Force. These comments are supplementary to, but are in
no way a substitute for, the five states’ individual comments.

First, we would like to express our disappointment at not receiving a response to our letter
of August 13, 1999 containing comments on the six hypoxia assessment reports and the
assessment process. A written response to these comments on the Integrated Assessment
would be welcome.

The Integrated Assessment is intended to document the state of knowledge regarding the
extent, characteristics, causes, and effects of Gulf hypoxia. As it necessarily relies upon
existing data and analysis, the Integrated Assessment must clearly describe both what is
currently known and unknown about the scientific questions surrounding Gulf hypoxia. In
order to assure that, despite its inherent limitations, the Integrated Assessment can be used
as a credible basis upon which to build an Action Strategy, it is recommended that:

e The final version of the Integrated Assessment clarify that the scenarios it evaluates
are not presumptive of the management actions that will ultimately be
recommended. While the scenario evaluations are useful in addressing the
fundamental question of whether there are indeed courses of action that may be
effective and in suggesting the relative effectiveness of some of those approaches,
it is important that the Integrated Assessment not inadvertently foreclose
consideration of other approaches. As we have previously commented “the
scientific reports and subsequent Integrated Assessment should not convey the
mistaken impression that policy makers are predisposed to specific solutions before
the public has had an opportunity to help shape policy recommendations.”

415 HAMM BUILDING

408 ST. PETER STREET

ST. PAUL, MINNESOTA 55102
TELEPHONE: 651-224-2880
FACSIMILE: 651-223-5815



Page 2

December 17, 1999

The final version of the Integrated Assessment should explicitly address the issue
of scientific uncertainty and the existence of alternative hypotheses. As the draft
Integrated Assessment acknowledges, “there are, however, always uncertainties in
scientific analysis.” The final version of the Integrated Assessment should
therefore explicitly describe levels of confidence for each major scientific finding
and how such confidence levels have been derived. In addition, the final Integrated
Assessment should acknowledge the variety of hypotheses, describe what existing
data reveal regarding those hypotheses, and what additional data and analysis are
needed.

It would be beneficial if conclusions of the scientific workshop held on

December 3, 1999 in St. Louis, Missouri could be posted on the Assessment Web
site. The final Integrated Assessment should incorporate these conclusions and
additional data and material submitted through the public comment process. Such
documentation and inclusion would be helpful for both the scientific and non-
scientific communities and be useful in considering the merits of pursuing various
action strategies.

Many of the scientific issues associated with Gulf hypoxia will undoubtedly continue to be
debated and likely be resolved only to varying levels of satisfaction. With this in mind, we
offer the following recommendations:

The scientific dialogue should be supplemented, as soon as possible, with policy
dialogue. Science alone will not define the appropriate management response.
That will only be possible by bringing other social and economic considerations to
bear.

The policy process must involve not only consultation among the federal
government and the basin states, but also with the full array of stakeholder groups.
The states reiterate their concern that meaningful public involvement may require
extending the current schedule for development of the Action Plan.

A consensus Action Plan must build upon the principles presented at the

November 18, 1999 Task Force meeting by the Coordination Committee. Namely,

the Action Plan must include:

— A goal that clearly states what outcomes the action plan is designed to achieve —
it need not be a numeric goal

— Areasonable timeframe for implementation and evaluation

— Flexibility in implementation

— Enhanced monitoring and analysis

— Enhanced resources to effectively carry out whatever plan is ultimately agreed
upon



Page 3
December 17, 1999

Finally, we reaffirm the upper basin states’ commitment to collaborating with the other
members of the Mississippi River/Gulf of Mexico Watershed Nutrient Task Force and the
full range of potentially affected stakeholders to craft a consensus, science-based Action
Plan that will meet the needs of the Mississippi River Basin and the Gulf of Mexico.

Sincerely,

Gordon Wegwart god Kevin Szcodronski

Minnesota Pollution Control Agency Iowa Department of Natural Resources
On behalf of the UMR State Members Chair, Upper Mississippi River Basin
of the Mississippi River/ Gulf of Mexico Association

Watershed Nutrient Task Force

cc: Representative Bud Shuster, Chairman of the House Committee on Transportation and

Infrastructure

Representative James Oberstar, Ranking Minority Member of the House Committee on
Transportation and Infrastructure

Senator John McCain, Chairman of the Senate Committee on Commerce, Science, and
Transportation

Senator Ernest F. Hollings, Ranking Minority Member of the Senate Committee on
Commerce, Science, and Transportation

Senator Olympia J. Snowe, Chair of the Senate Subcommittee on Oceans and Fisheries

Dr. Neal Lane, Assistant to the President for Science and Technology

Dr. D. James Baker, Under Secretary for Oceans and Atmosphere, Department of
Commerce

Dr. Rosina Bierbaum, Associate Director for Environment, Office of Science and
Technology Policy

Members of the Mississippi River/Gulf of Mexico Watershed Nutrient Task Force

Upper Mississippi River Basin Association Representatives and Alternates