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State of Wisconsin

Deparmtent of Agriculture, Trade and Consumer Protection
Department of Natural Resources

December 20, 1999

Gulf of Mexico Hypoxia Working Group
National Centers for Coastal Ocean Science
WS 113446 SSMC:4

1305 East-West Highway

Silver Spring, MD 20910

Subject: Integrated Assessment
Dear Members of the Working Group,

We are writing to provide comments on the draft integrated assessment report for the Gulf of Mexico
hypoxia conditions as indicated in the October 21,1999 Federal Register notice. We appreciate the
opportunity to review this scientific assessment and to provide you with our thoughts on the report.

It was our view that the Integrated Assessment Report was to be the summary compilation of the six
technical reports. With this in mind, it is our belief that the assessment should identify both the “knowns”
and the “unknowns” regarding the state of scientific conclusions on the extent, duration, severity, impacts
and causes of a hypoxic zone in the Gulf uf Mexico, To address this concern, it would be appropriate to
include the conclusions from the svientific workshop which was held December 3,1999 in St. Louis.
Incorporating these conclusions will help to provide clarity between those areas of scivntific consensus
and those areas where scientific uncertainty remains.

It is also very important that the report identify the future management options it evaluates as examples
only. While these are helpful illustrations of the types of remedial possibilities, it should be explicitly
stated that the report was not intended to develop management options and that the examples should not
be presumed to be management responses or policy decisions derived from the review of the science. It is
critical that the policy makers and the public have the opportunity for full dialogue on possible
management options without prejudice or the presumption that management options are limited to only
those described in the report.



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In an effort to keep this process moving forward, we would suggest the following course of action:

|. Utilize a public consultation process which allows meaningful involvement for all the stakeholder
groups; even if the time required for this consultation requires an extension of the deadlines for action
plan development. This includes bringing social and economic considerations more fi ully into the
ongoing scientific dialogue. Scientific data can provide a foundation for management discussions but
alone, cannot be the basis for identifying appropriate management actions.

2. Involve states as full partners in the process to develop pollutant lvad reduction goals and
management options to achieve those goals,

3. Utilize the principles presented to the Task Force by the Coordination Committee at the November
18.1999 meeting to provide a framework for the action plan:

“The action plan needs to clearly state the expected outcomes—these outcomes need not be
expressed as numeric goals.

> There should be a reasonable time frame for both implementation and evaluation activities.

% Implementation actions or management responses must have the flexibility to allow states to
develop a variety of approaches which would he functionally equivalent.

> There needs to be a monitoring plan or strategy to establish an enhanced approach to data
collection and analysis.

‘> There will need to be increased resources to effectively carry out action plan recommendations.

In closing, we remain committed to participation in this effort and look forward to a process which can
build on the science through a broad based consultation effort to develop a consensus approach which
protects the Mississippi River basin and the Gulf of Mexico.

Sincerely,
) > <> a2
~ Ly Wrareel
George Meyer, Secretary Ben Brancel, Secretary
Wisconsin Department of Natural Resources Wisconsin Department of Agriculture,
Trade and Consumer Protection
c: Carol Browner. EPA

Francis X. Lyons, EPA Region $
NOAA Coastal Ocean Program