DEC=20-99 14:19 From: 7-097 P.06/10 Job-260

about 50 million acres of intensively drained farmland. Most is drained through the use
of subsurface tile. In fact, there has been a significant increase in tile drainage in recent
years and it is likely that this tend will continue. In these areas, elevated levels of
nitrate-nitrogen concentrations in drainage water will be lost in tile-drained soil
tegardless of fertilizer management practices, This trend would appear to explain why,
despite purported decreases in the use of fertilizers on corn, no significant decrease in
nitrogen inputs to the Mississippi River has been observed: the increase in the acreage of
tile-drained fields has pojentially offset any reduction in fertilizer use. In light of the
clear role that "tiling" Plays in the levels of nitrogen entering the Mississippi River, any
approach to nitrogen reduction would need to address management of these drainage
systems. Given the impostance of this issue, discussions of the need for management

must be emphasized in the final Integrated Assessment.

We applaud the Assessmint's tecognition that improved management of feedlot runoff is
one of the measure with the greatest estimated Potential to reduce nitrogen sources to
Streams and rivers. However, we are distressed by the failure of the Integrated
Assessment to acknowledge the particular need to address large, concentrated animal
feeding operations ("CAFOs"). CAFOs contribute to nutrient pollution in several ways:
emissions of ammonia, excessive and concentrated disposal of manure, lagoon leakage,
and all-too-frequent total waste lagoon failures. In fact, the enormous volume of water
accumulated at these factary farms is so great that the Possibility of sustainable nutrient
cycling back to cropland ig virtually impossible, During his oral presentation on Draft
Report 6 at a Mississippi River/Gulf of Mexico Hypoxia Task Force meeting, Dr. Otto
Doering asserted that the threat of nutrient pollution from livestock agriculture is more
significant than calculations of manure output suggest. He further indicated that this is
due to the concentrated industrial manner in which animals are now raised and their
wastes disposed. Dr. Doesing's conclusions find support in recent publications, See, e.g.,
Carey, et al. "The Role of'the Mississippi River in Gulf of Mexico Hypoxia", 70 Envil,
Institute Rep. at 27 (May, }999); Clean Water Network and Natural Resource Defense
Council, America's Animal Factories: How States Fail to Prevent Pollution from
Livestock Waste (December, 1998).

Alternatives to concentrate! animal feeding exist, Most entail the redistribution of
livestock back onto the farms where the feed is being produced and the manure can be
economically and ecologically uscd as a fertilizer. This Te-opens the option for
sustainable nutrient cycling. Many alternatives are also associated with the increased
grazing and feeding of Perdnnial forage crops which has been acknowledged in the
Integrated Assessment as a‘useful means for teducing nitrate pollution. Yet, the
discussion of this issue within the Integrated Assessment is limited to the statement of a
need to better manage feediot runoff. Clearly, additional attention must be given this
issue.

The Integrated Assessment imakes passing reference to cover crops. However, no
significant discussion of the use of cover crops as a mechanism to prevent leaching is
included. The use of non-leguminous grasses as "catch crops" has long been a strategy for



DEC-20-88 14:21 From: T0087 P.09/10 Job-260

Harold E. Taylor, President
Pompeston Creek Watershed Association

Peg Jones, President
Save Our Rivers, Inc.

Jonathan T. Phinney PhD, Water Quality Scientist
Center for Marine Consefvation

Mark Davis, Executive Director
Coalition to Restore Louisiana

Joe Payne, BayKeeper/Executive Director
Friends of Casco Bay

Richard Hill, President STV
Save the Valley, Inc.

E.M.T. O'Nan, Director =
Protect All Children’s Environment

Robert E. Rutkowski, Esq.
Topeka, KS

Chester S. Williams, President
Friends United for a Safe Environment, Inc.

Randy Myer, Chairman :
Ocean City Chapter of the ‘Surfrider Foundation

Judith S. Weis, Professor :
Rutgers University

Robert Moore, Executive Director
Prairie Rivers Network -

Darryl! Malek-Wiley, President
M-W & Associates .

Karen McSpadden i
National Center for Appropriate Technology



DEC-20-99 14:18 From: T-007 P.05/10 Job-260

underscore the importange of the Assessments’ finding that any costs associated with
reductions in nitrogen injthe Mississippi/Atchafalaya river system would be offset by a
number of benefits including: improved water and habitat quality within the basin;
teduced soil erosion; redjiced contamination of drinking water by nitrates; improved
water quality for recreatipnal use; improved recreational fisheries and wildlife; and cost-
effective flood control injprovements. Just as meaningful is the finding that all nutrient
reduction approaches considered are expected to produce environmental benefits. The
valuable environmental and ecological benefits that will accrue to the Mississippi River
Basin from efforts to redijce nitrogen loadings have heretofore been largely ignored in
discussions of the costs and benefits of addressing the hypoxia issue. Yet, this is an
important consideration fpr the Mississippi River/Gulf of Mexico Nutrient Reduction
Task Force, or anyone attempting to craft a strategy to address the issue of nitrogen
pollution in the Mississippi River/Atchafalaya system.

Approaches For Reducing Nutrient Loads

In general, the findings ofthe Assessment with regard to methods for reducing nutrient
loads are accurate and teffect both in-depth analysis and creative thinking. Previous
sections of the Assessment address all possible factors linked to increased nitrogen levels
to the Gulf, including increases in nitrogen use, the rate of flow of water to the Gulf,
leveeing, damming, and channeling of the Mississippi River, and the loss of wetlands in
southern Louisiana. Section 5 of the Assessment Tightly notes that an optimal Strategy
would take appropriate advantage of the full tange of possible measures to deal with
hypoxia in the Gulf, including modification of farm Practices, creation and restoration of
wetlands and riparian ecosystems, implementation of nitrogen control on wastewater
plants, and diversion of fldodwaters to backwaters and marshlands of the Mississippi
Rivor delta and adjacent cgastal wetlands. The advantages of such an approach extends
beyond the issue of nitrogqn pollution, providing the additional benefits of flood control,
increased wildlife habitat, detoxification, erosion control, and reduced sedimentation of
water badies -- objectives gonsistent with other state and national policy initiatives. For
example, restoration of wetland and riparian areas have clear implications for
improvement of overall w4ter quality, increased wildlife habitat, and flood damage
reduction. These in tun create additional ecological and economic benefits.

The Assessment's discussign of changes in farm practices -- the integration of more
perennial crops, the reduction of subsurface drainage, better timing of manure and
fertilizer applications, and nutrient accounting -- is limited largely to the costs and effects
of such changes on productivity. ‘The discussion ignores the fact that such changes will
likely work toward the farniers’ long-term economic interests through more efficient use
of nutrients, reduction of off-farm input costs, and reduced pollution hazards for well and
pond water. We believe this issue must be addressed within the Integrated Assessment.

We are also concerned that the Integrated Assessment largely ignores the findings in
Draft Report 5 that subsurfyce drainage ("tiling") is a significant contributor to and
primary source of high nitrdte loads in the Corn Belt states. In those states, there are



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sequestering soluble nutgients and recycling them for subsequent crops. Considerable
Tesearch has already bee done on this technique, much of it using cereal rye and ryegrass
- species adaptable throughout most of the Mississippi River Basin. Techniques for
interseeding and overseeding these grasses have also been developed, and there would be
few barriers to implementation. In truth, cover cropping should, by now, be well
integrated into Best Management Practices for row crop production. Unfortunately, that
change has been too slow in coming.

Finally, the Integrated Agsessment fails to tecognize that individual farming practices are
bundled into farming sysiems. In a conventional farming system, installing subsurface
drainage to improve potential crops yields is generally bundled with reduced use of sod-
forming crops and increased use of nitrogen fertilizers. The Assessment ignores the
results of studies that denjonstrate the positive impact that whole farming systems — such
as organic farming -- can ave on nitrogen pollution. Organic farming is an approach to
agricultural production that replaces pesticides, soluble fertilizers, and monoculture with
biodiversity, cultural practices, and inputs that are more environmentally friendly.
Recently published results of a 15-year study reveal that nitrate leaching was 50% less
under organic production systems than under the typical conventional system.
Drinkwater, L.E. et al. "Legume-Based Cropping Systems Have Reduced Carbon and
Nitrogen Losses", 396 (19) Nature 262 (1998). Another recent publication reports the
large increases in nitrate leaching were found when several Illinois farm fields were
converted from diverse orjanic rotations and management to conventional com and
soybean production. W.A. Goldstein, et al., "Impact of Agricultural Management on
Nitrate Concentrations in Drainage Waters", 13 (3) American J. of Alternative
Agriculture 105 (1998).

Adaptive Management: Action, Monitoring, and Research

We concur with the Assesiment's finding that further monitoring and research are needed
to reduce uncertainties. We also agree that a comprehensive program of monitoring,
interpretation, modeling and research should be Coupled to initial management strategies,
However, as aptly pointed put within the Assessment there are always uncertainties in
scientific analysis. These uncertainties should not be used as an excuse for delay in the
development and implementation of an action oriented agenda to address the clearly
identified causes of hypoxia. Environmental responses to reductions in nitrogen will be
slow, possibly requiring decades, Continuing delay in implementation of needed
management measures will only serve to increase the risk to the valuable resources of the
Gulf associated with persisjent hypoxia.

With regard to research, wg would agree that significant attention should be accorded to
tesearch focused on the ecqlogical effects of hypoxia. The fishery resources of the Gulf
of Mexico are among the most valuable in the United States. Numerous coastal
communities are dependent upon these resources, Thus, it is essential that a better
understanding of the potential long-tenn impacts of hypoxia on the Gulf be obtained,



DEC-20-89 (14:21 From: T-097 P.10/10 Job-260

i

Duane Hovorka, Executive Director
Nebraska Wildlife Federation

Laura Huth, Executive Director
Illinois Student Environrhental Network (ISEN)
4

Dan Murchison :
Chilton Pride Watershed ‘Assessment Program

Joe Gutkoski, President :
Montana River Action Nétwork
Sol Simon i
Mississippi River Revival

:
James Scarcella President
Natural Resources Protective Association

Jerry Paulson
McHenry County Defenders

Cindy Skrukrud :
Friends of the Fox River :

Pete Emerson, Senior Ecqpomist
Environmental Defense Find

Ken Pulver
Lahontan Chapter of the National Audubon Society

Kay Friedlander
Alabama Environmental Gounci



DEC-20-99 14:17 From: T-087 P.02/10 Job-260

December 20,1999

Gulf of Mexico Hypoxia Working Group

National Oceanic and Atnhospheric Administration
National Center for Coastal Ocean Science

Room 9127 1305 East-West Highway

Silver Spring, MD 20910

To the Gulf of Mexico Hypoxia Working Group:

RE: COMMENTS ON THE INTEGRATED ASSESSMENT ON THE CAUSES AND
CONSEQUENCES OF H¥POXIA IN THE GULF OF MEXICO

The undersigned organizations submit the following comments on the Integrated
Assessment on the Causes'and Consequences of Hypoxia in the Gulf.

General Comments

Initially, we would like to commend the National Science and Technology Council's
Committee on Environment and Natural Resources (CENR) for compiling such a
comprehensive analysis of the existing data and applied existing models of the
Mississippi/Atchafalaya watershed-Gulf system. The Assessment makes important initial
findings regarding the relafionship between nitrogen and the Dead Zone, sources of
nitrogen entering the Mississippi River Basin, and potential strategies for reducing the
levels of nitrogen reaching:the Gulf.

The Integrated Assessment is an important first step. However, in order to make this
effort worthwhile, the administration must ensure that state and federal agencies use the
Assessment's as the basis fr an action agenda aimed at addressing the root causes of
nitrogen pollution in the Mississippi River Basin. Moreover, it is imperative that the
research needs identified in| the Assessment be incorporated into appropriate agency
budget priorities and that fill funding for all necessary rescarch be appropriated by
Congress. We look forward to working with the CENR and the Mississippi River/Gulf of
Mexico Watershed Nutrient Reduction Task Force to ensure that the Integrated
Assessment is fully utilized.

Causes of Gulf of Mexico Hypoxia

The Integrated Assessment thoroughly analyzes all factors identified within the Draft
Reports, as well as the public comments submitted on the Draft Reports, as potentially
contributing to Gulf of Mexico hypoxia. The Integrated Assessment finds that no single
factor is alone causative, but that all factors interact to produce the Dead Zone.
Nonetheless, the Assessment makes clear that only increases in nitrogen loading from the
Mississippi/Atchafalaya River system can account for the magnitude of the hypoxic zone



DEC-20-89 14:20 From: T0987 P.08/10 Job-260

We also agree with the Ajssessments' observation of the need to better quantify the effects
of on-farm practices and snethods that intercept agricultural nutrients between the field
and ground water and adjacent streams. Much discussion has been had regarding the
number of acres converted to buffer and the number of other on farm practices adopted by
agricultural interests. However, inquiries to the Natural Resource Conservation Service
and Department of Agriciilture have revealed very little data regarding the effectiveness
of those practices in reduging nitrogen and other nutrients reaching the ground water and
adjacent streams. Similayly, very little, if any, data has been produced reflecting the
offsetting effect of tiling on the adoption of on farm practices and methods intended to
intercept agricultural nuttients, In depth research to determine the effect of agricultural
conservation efforts being pursued by state and federal agencies is essential to the
development of an effective Strategy to address loadings of nitrogen entering local
waterbodies and eventually the Mississippi/Atchafalaya system. And detailed research is
needed to help us understand the relationship between fertilizer use, mineralization of
nitrogen from soil organic matter, crop rotations, and movement of nitrogen from fields
to streams.

Respectfully submitted:

Mona Shoup, Co-chair
. Galveston Bay Conservation and Preservation Association

Cynthia Sarthou, Executive Director
Gulf Restoration Network:

Carlton Dufrechou, Executive Director
Lake Pontchartrain Basin Foundation

Robbin Marks, Senior Resource Specialist
Natural Resources Defensé Council

Juan Parras, Community Organizer
Texas Southern University: Environmental Law and Justice Clinic

Paul Facth, Director of Ecgnomic Program
World Resources Institute ‘

Mary Ann Lucking, Project Coordinator
CORALations :

Dennis W. Schvejda
Sierra Club NJ Chapter

Rosa Hilda Ramos
Comunidades Unidas Contja la Contaminacion



DEC=20-99 14:17 From: T-087 P.03/10 Job-260

and its increase over tima, finding that no other factors, alone or in combination, can
explain the overall size of the Dead Zone. The Assessment's conclusions are clearly
consistent with findings i) other watersheds that anthropogenic sources of nutrients have
a pervasive ecological effect on shallow coastal and estuarine areas. See, e.g., J.M.
Burkholder et al., "Ruptufe of a Large Swine Waste Holding Lagoon in North Carolina,
U.S.A.: Impacts on a Coastal River and Estuary," J. Envtl. Quality (1997); Justi et al.,
"Trends in Oxygen Contet 1911-1984 and Occurrence of Benthic Mortality in the
Northern Adriatic Sea", 24 Estuar. Coastal Shelf Sci. 435 (1987).

Consequences of Hypoxia in the Northern Gulf Of Mexico

The Integrated Assessmenit corrects the errors within Draft Report 2, finding that the
consequences of hypoxia in the Gulf of Mexico are not fully known. The Integrated
Assessment also makes clar that the failure of the economic assessment based on
fisheries data to detect fers does not necessarily mean that effects are absent.

Prior to finalizing the disciission of effects, we would request that the authors of the
Integrated Assessment review an article recently published by Benny J. Galaway, John G.
Cole, Robert Meyer and Pusquale Roscigno entitled "Delineation of Essential Habitat for
Juvenile Red Snapper in the Northwestern Gulf of Mexico," Transactions of the
American Fisheries Sociery 128:713-726 (A copy is attached). The authors of the article
find that

a significant reduction (up to 25%) in red snapper habitat
carrying capacity has been observed in association with the
most recently observed expansion in the size of the hypoxic
region occuring in the Gulf of Mexico around the mouth of
the Mississippi River. This change, if real, may affect the
level to whith Gulf red snapper stocks can be rebuilt
relative to historical stock levels. ... Nearshore Species
dependent cn low-salinity conditions characteristic of the
white shrimp ground assemblage ... have likely undergone
much larger reduction in habitat carrying capacity because
alternative Ipw-salinity habitats are not extensive outside
the hypoxiciregion.

"Delineation of Essential Habitat for Juvenile Red Snapper in the Northwestem Gulf of
Mexico" at 722. Red Snapper and penaid shrimp are two of the most economically
important species in the Gulf of Mexico. If the assumptions employed by the authors
Prove correct, the economig implications of this finding for Gulf fisheries are significant.

We continue to be concem¢d that the Integrated Assessment fails to adequately discuss
the potential economic imppct of disruptions in shrimp migrations. It is undeniable that
the east/west movement of shrimpers Tesulting from changes in shrimp migration patterns
could have negative econorpic impacts. Recent data indicate that years of strong inshore



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shrimp production in Lowisiana have coincided with increased landings in Texas;
historically, that has not been the case. (Personal communication with Dr. James Nance,
National Marine Fisheries Service). It can be inferred from this recent change that
hypoxic conditions have Jed to a more east/west shrimp migration pattern rather than an
historical migration to the offshore waters south of Louisiana. Absent other factors, this
change in migration pattgm undoubtedly causes Louisiana shrimpers to travel greater
distances in the Gulf. Inqreases in distance traveled concomitantly increase the costs of
doing business (i.c., gasofine, ice, etc.), and decrease profits. See John A. Downing et al.,
Hypoxia in the Gulf of. México; Land and Sea Interactions, Ch. 3 at 18 (June 28,
1999)(hereinafter "CAST" Report)(noting that increased levels of effort required to catch
shrimp duc to the effects pf hypoxia on shrimp migration patterns decrease net revenue to
the fisheries, impacting sdcial welfare). We continue to believe that this must be
addressed within the Finaj Integrated Assessment.

Additionally, we remain concemed tegarding the methodology employed in attempting to
analyze the economic effacts of hypoxia. It is difficult to analyze the aggregate fisheries
impact of degraded water quality by examining landings or dockside values. See CAST
Report, Ch. 3 at 18. There are also dangers in using CPUE to estimate stock size.
Consistent landings or CPUE can be clouded by governmental management systems,
increased technology, improved shrimp location data, or the grouping of shrimp due to
hypoxia. For example, if iechnology improves catch per unit effort, the model employed
in the Report's analysis wquld assume higher stock size. Yet, this assumption would
clearly be erroneous, Addjtionally, a finding that fishery landings are constant is not an
absolute indication that thé fishery is healthy. For instance, with current increases in
technology it could be assumed that fisheries landings would be increasing. The fact that
they are not may be an indication that shrimp populations are declining, or it could just as
easily be the result of management measures.

Finally, although the Assegsment now discusses the consequences of nutrient
concentration in the Mississippi-Atchafalaya River Basin, this discussion is limited to
ecological and environmenfal impacts. Nitrogen pollution has numerous economic costs
to society. For example, djta from the Environmental Protection Agency indicate that
agriculture-related nutrients account for much of the degradation of water quality in rivers
throughout the Basin, and significant impairment of lake acreage. . U.S. Environmental
Protection Agency, Nationxl Water Quality Inventory (1994). Efforts to address these
water quality problems have real economic costs. For example, nitrate/nitrogen levels in
drinking watcr sources significantly increase treatment costs incurred by drinking water
treatment facilities. All of the economic impacts or costs of nitrogen pollution in the
Mississippi River Basin mist be discussed within the Integrated Assessment.

Effects of Changing Nutrient Loads

We commend the authors of the Integrated Assessment for the thorough discussion of

potential effects under a "ng loading change" scenario if the Gulf of Mexico continues to
suffer from annual losses of biodivesity, abundance, and biomass. Moreover, we wish to

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