1) Nitrate is the most soluble and important form of nitrogen if commercial fertilizer is the
major increasing nutrient factor.

2) Nitrate levels are three times higher than 30 years ago and come mostly from non point
sources.

The report suggests that there have been improvements made in fertilizer technology that can
help reduce nutrient loss by delaying nutrient mobilization. The way these formulations are used
today and how these can help reduce nutrient loss should be the subject of future research.

We have specific concerns with the information presented about contributions from atmospheric
deposition. We are concerned with the nitrogen balance table shown in Topic 3 with atmospheric
(wet and dry) at 7.9%. At the Farm Bureau sponsored workshop From the Corn Belt to the Gulf

Agriculture and Hypoxia in the Mississippi River Watershed of July 14-15, 1997, USGS’ Dr.
Richard Hooper claimed 25% of the Gulf’s nutrients were from NOx. On page 72 of report six,

literature cited estimated atmospheric deposition from 17% to 23%. These differences need to
be explained and reconciled. :

More information is needed to evaluate the significance of atmospheric contributions of
stationary sources of NOx to deposition in the watershed. The airshed of the basin needs to be
identified and EPA’s NET database should be used for assessing point, area, and mobile sources.

The relative contribution of mobile area and biogenic sources of NOx need to be included in the
integrated assessment.

The report identifies the degree of uncertainty and severe limitation on the authors efforts to
accurately estimate NOx deposition using CASNET and NADP measurement approaches. This
uncertainty needs to be reduced to be able to more accurately evaluate the costs of control verses
the benefits to the Gulf. Comparisons of model predictions with observed data should be
considered to produce more accurate estimates of the quantity and patterns of nitrogen loading to
the Gulf from atmospheric sources.

We have seen data analysis from other scientists that suggests the nitrogen flux has declined
since the 1950’s, rather then increased as these reports suggest. Whether the flux is increasing or
decreasing needs to be resolved before solutions and implementation mechanisms are
recommended.

We understand there is a 1950’s study of the Gulf conducted by Scripps Institute of
Oceanography that showed significantly more phytoplankton productivity than these assessments
show for the 1990’s. If this 1950’s report is valid, and the 1990’s data quoted in the assessments
are valid, then the trend in productivity would be decreasing rather than increasing as the
assessment indicates. A downward trend would indicate a reduction in nutrient flux to the Gulf.
The 1950’s data did not support the assumption that the nutrient flux to the Gulf has
increased over the past 40 years. This discrepancy needs to be addressed during
development of the integrated assessment.


programs and any anticipated fiscal benefits generated locally for those attempting to reduce
sources.

This report makes extensive use of assumptions without proof. It is not a creditable reference for
determining the least cost methods of reducing nutrient inputs to streams. The report does not
examine cost per unit of nutrient removed by buffers or wetlands and seems to conclude that
there should be a wetland below every cornfield. This report also includes alarming statements
such as:

1) “Little data has been collected that allow economic impacts of hypoxia to be estimated.”

2) “Little systematic data has been collected that would allow the identification of the
economic effects of hypoxia.”

3) “Farmers may believe their right to farm gives them a right to pollute.”

Such statements make the'job of addressing non-point source pollution more difficult.

The report states that “fertilizer restrictions are more cost-effective means of reducing nitrogen
losses than strategies based only on wetland restoration or buffers.” This conclusion does not
take into account many other economic benefits that would be associated with the restoration of
wetlands including flood control, reduction in sediment load, and restoration of wildlife habitat.
Wetlands can reduce the severity of floods, which over the long run would have tremendous
economic benefits. Any cost-benefit analysis of wetland restoration needs to consider all the
benefits, not just those directly related to nutrient reduction in the Gulf of Mexico.

The report states that “administration, monitoring, verification, and enforcement costs have not
been included” in the cost-benefit analysis discussion of alternative solutions. This is a
significant shortcoming of the report as these costs may be considerable depending upon the
specific solutions chosen. These costs should be included in the final plan that is to be submitted

to Congress.

The report acknowledges limitations on the implementation of recommendations on the
questionable extent of return (measurable reductions in nutrient loading) and the difficulty in
terms of least cost economies. Instead, benefits that accrue locally for on-site improvements are
analyzed. We agree that local people solving local problems is the best way to address non-point
source issues.

Missouri has long been cognizant of agricultural non-point source pollution. Missouri’s economy is
built on a strong agricultural foundation that generated $5.6 billion dollars in agricultural production
during 1996 with a wide variety of crops and livestock.

In order to deal with soil and water conservation problems, including those identified in these
assessments, Missouri voters passed a one-tenth of one percent Parks and Soils Sales Tax in 1984,
which funds the Soil and Water Conservation Program (SWCP), a part of the Missouri Department
of Natural Resources (DNR). Prior to passage of the tax, Missouri had the second worst erosion rate


1970's, or the Black Sea of the 1980's is not fully described. These are very different water
bodies yet the authors tie them together without any data to substantiate their similarities. Ties
would just as easily be made to the Nile River delta, where a reduction in sediment and nutrients
has devastated the fishery.

Using seven-year moving average for fishery stock population changes reduces the apparent
impact that the 1993 flood of freshwater and nutrients had on the-Gulf. This needs explanation.
We agree that long-term monitoring is needed to measure dissolved oxygen at spatial and
temporal scales. Oxygen data can then be better compared with fish catch data, with
consideration of runoff anomalies.

A high priority for funding should be given to analyzing the large SEAMAP database mentioned
in the report, to reduce some of the variability encountered and allow for more meaningful
conclusions to be made.

Evaluation of the reports and references cited points out a critical lack of a basin-wide
monitoring network of comprehensive data. We suggest USGS be charged and funded for this
activity.

Hypoxia is a natural phenomenon in estuarine locations. It has been documented in the Gulf as
“Jubilee” events since the 1700’s. (Jubilee events were recorded when fish and shrimp moved
close to shore, allowing for extremely easy, abundant harvesting.) These events are apparently
contrary to the assessment statements that hypoxia in the Gulf is a recent phenomenon and the
nutrient flux increase over the last 40 years are the reason for its occurrence,

There are also historic records of massive fish kills in the Gulf. Since these have not occurred in
the last 50 years, it seems this would be anecdotal information that indicates that water quality
has been getting better in the Gulf in the last 50 years, not worse, as the assessments conclude.

The high variability in the data quality and quantity makes it nearly impossible to derive any
meaningful conclusions. (While the authors say as much, they need to emphasize this fact
more.) The fact that conclusions were made and implementation mechanisms recommended is
very disconcerting. The recommendations should be deleted from these reports.

Topic 3 — Flux and Sources of Nutrients in the Mississippi-Atchafalaya River Basin

This report identifies the sources of nutrients within the Mississippi Atchafalaya system and
transport to the Gulf of Mexico with two distinct components. The first is to identify where,
within the basin, the most significant nutrient additions to the surface water system occur. The
second to estimate the relative importance of specific human activities in contributing to these
loads. .

This report identifies sources of nitrogen and human activities that have contributed to nitrogen
loading. The report includes these as facts:


Topic 4 — Effects of Reducing Nutrient Loads to Surface Waters Within the Mississippi
River Basin and the Gulf of Mexico ,

This report estimates the effects of nutrient source reductions in the Mississippi-Atchafalaya
Basin on water quality in these rivers and on primary productivity and hypoxia in the Gulf of
Mexico. Modeling-analyses were conducted to aid in identifying magnitudes of load
reductions needed to effect a significant change in the extent and severity of hypoxia.

When estimating the effects nutrient source reductions would have on water quality in the
Mississippi-Atchafalaya Basins, this report extrapolated site-specific case studies to the entire
Mississippi watershed. The results found when analyzing measurable reductions of nutrient
loads in small watersheds cannot be extrapolated to estimate changes in nutrient delivery to the

* Gulf because of variations of soil type, slope, participation, and other parameters. Some
conclusions are drawn in the report that are based on data from a single year’s worth of field
studies. We believe better data and improved models are needed to be able to improve
predictions of this nature.

At present, we do not have the information base to determine how site specific management
practices will benefit water quality within the catchment, watershed, or basin.

The final plan should stress the need to create numeric standards for nutrients in waterways. In
setting standards then, a monitoring network would need to be established. Data gathered
through the monitoring network would help fill in some of the information gaps that currently
exist. How these new standards may effect the nutrient flux needs to be factored into the

integrated report.

In fact, we believe it will be necessary to acquire such monitoring information before the
agricultural community will embrace nutrient reduction on their farms to benefit the Gulf fishery.
In action last week, the Midwestern Association of State Departments of Agriculture agreed to
conduct an inventory of best management practices used, reconstruct data of the past 100 years,
draft an improved research plan and offer their assistance to the hypoxia research effort. We
believe their efforts are sincere and pledge our assistance to their analysis.

Topic 5 — Reducing Nutrient Loads, Especially Nitrate-Nitrogen, to Surface Water,
Groundwater, and the Gulf of Mexico

The main focus of this report was to identify and evaluate methods to reduce nutrient loads to
surface water, ground water, and the Gulf of Mexico. The analysis was not restricted to only
reduction of sources. It also included means to reduce loads by allowing the system to better
accommodate those sources through processes such as modified hydraulic transport and
internal cycling routes.


in the nation. Tremendous progress has been made in soil and water conservation in Missouri during
the past fifteen years. Missouri has reduced erosion on its agricultural land by almost half from 1982
to 1992 — more improvement than any other state (see attachment A). Working mainly in
conjunction with the USDA’s Natural Resources Conservation Service (NRCS) and local soil and
water conservation districts, the DNR has provided a multitude of financial incentives to landowners
since 1984 in order to promote improved land management practices on agricultural land. In
addition to the standard NRCS practices, Missouri offers incentives through several custom practices
that promote the reductions in nitrate loss delineated in the hypoxia reports (particularly the “Report
of Task Force #4”).

Historically, program efforts have focused only on combating soil erosion, which degrades water
quality as sediment laden with agricultural chemicals clogs streams, rivers, and lakes. Much
progress has been made in these efforts through regular cost-share, and loan interest share
programs, as well as through the 200 Special Area Land Treatment (SALT) or larger EARTH
projects initiated since 1986. SALT and EARTH projects are locally led and watershed based.
Working through soil and water conservation districts, landowners that farm in a targeted
watershed can take advantage of extra financial resources available through the program (see
attachment B).

The newest type of SALT project, the AgNPS SALTs, expand the focus of the traditional SALTs
to include emphasis on the reduction of all forms of agricultural non-point source (AgNPS) water
pollution. Objectives of these watershed projects embrace many of the recommendations
proposed in Topic 6. They include, but are not limited to, reducing pesticide and nutrient runoff
from cropland, improving pasture management, reducing sedimentation from agricultural land,
improving animal waste management, protecting and enhancing riparian corridors, and raising
awareness of agricultural non-point source water pollution issues. Twelve AgNPS SALTs are
currently being piloted across Missouri, and our District Commission intends to approve at least
thirty more projects over the next four years (see attachment C).


‘Mel Camahan, Governor * Stephen M. Mahfood, Director

OFFICE OF THE DIRECTOR
P.O. Box 176 Jefferson City, MO 65102-0176

August 2, 1999

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

1305 East-West Highway

Silver Spring, MD 20910

Dear Members of the Gulf of Hypoxia Working Group:

On behalf of the State of Missouri, I submit comments on the six Gulf of Mexico Hypoxia
Assessments. I request that these comments be available to the public. Additionally, I would
request that our comments be addressed by the scientists who are tasked with the preparation of
the Integrated Assessment.

While I commend the staff for the work performed on the six assessments, I have two primary
concems:

1) The breadth of the assessments could have and should have been greater taking
advantage of additional credible scientific data that currently exists and was available
to the investigators.

2) The time series relied on to determine the nature and extent of the nutrient flux to the
Gulf should be lengthened. If this is not pursued with vigor, I fear there will be no
end to an unsettled debate over the degree to which the hypoxia phenomena is a
natural occurrence.

Finally, I suggest that the schedule for the preparation of an action plan containing policy
recommendations be pushed back. Sufficient time should be allotted for issues in question to be
resolved. I do not believe it was the intent of Congress to push the policy development in front
of the science on which it should be based.


The report failed to address the impact of organic nitrogen flux on hypoxia in the Gulf of
Mexico. Organic nitrogen constitutes approximately 40% of the total nitrogen in the Mississippi
River, yet a thorough analysis of methods to reduce nitrogen loading was not provided.

The effects of coastal wetland loss on hypoxia needs to be addressed. Louisiana has already lost
over | million acres of wetlands in the last 10 years and continues to lose considerable acreage
annually. This wetland loss results in the reintroduction of nutrients to the Gulf. The loss of
thousands of areas of coastal wetlands each year can have a significant impact on the Gulf, but
that impact was not evaluated in this report.

The impacts the water control structure have on the Atchafalya River and the levees and pumps
protecting New Orleans have on the loss of wetlands needs to be evaluated. Little analysis is
included about the impacts the operation and maintenance of these structures have on wetlands,
even though these structures are mentioned in the report as contributing factors to the loss of
wetlands. We would like to see additional evaluation about modifying the operations and
maintenance of these structures and the potential benefit to the Gulf in the integrated report.

While the various wetland proposals make some sense, the idea of having small wetlands at the
outlets of tile drainfields needs to be tested before being implemented on a large scale. Diverting
floodwaters to backwaters of the Mississippi River Delta and coastal wetlands needs to be
evaluated further; if wetland improvements are not linked; upstream improvements may be
negated if the Delta area is not simultaneously addressed.

Changes in land use (urbanization, increased timber harvest using questionable timber harvesting
practices, etc.) undoubtedly contribute to the overall nutrient loading in the system. The effects
that land use changes, other than agricultural, have upon the overall problem were not adequately
addressed.

Recent information concerning the contribution from large concentrated animal feeding
operations to the atmosphere indicate a larger contribution than previously thought. This new
information needs to be incorporated into the integrated report discussion of atmospheric
deposition.

The report needs to make stronger statements promoting incentives to alter farming practices.
Missouri has made great progress in reducing erosion problems by providing state financial
assistance. We believe similar financial incentives programs can have a similar impact for
nutrients.

Topic 6 — Evaluation of Economic Costs and Benefits of Methods for Reducing Nutrient
Loads to the Gulf of Mexico

In addition to evaluating the social and economic costs and benefits of the methods identified
in topic 5 for reducing nutrient loads, this analysis included an assessment of various incentive


Gulf of Mexico Hypoxia Working Group
Page 2
August 2, 1999

The state's detailed comment on each of the six scientific assessments are appended. I am
grateful for the opportunity to comment. Thank you.

Sincerely,

DEPARTMENT OF NA’ LL RESOURCES

Stephen
Director

SM;jm
Attachment

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

Transportation

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

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

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

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

Mr. Chuck Fox, Chair Task Force on Hypoxia, Assistant Administrator for Water, U.S.
Environmental Protection Agency


STATE OF MISSOURI
COMMENTS ON GULF OF MEXICO HYPOXIA ASSESSMENTS

Topic 1 — Characterization of Hypoxia: Distribution, Dynamics, and Causes

This report describes the seasonal, interannual, and long-term variation of hypoxia in the
northern Gulf of Mexico, and its relationship to nutrient loadings. It also documents the
telative roles of natural and human-induced factors in determining the size and duration of the
hypoxic zone.

This report did not present a complete description of variations in Northern Gulf hypoxia, its
relationship to nutrient loadings, and roles of natural and anthropogenic factors. Very limited
data, spatially and temporally, as well as inadequate time to assimilate data from a variety of
sources were the primary reasons provided for the incompleteness of this description of the
Northern Gulf hypoxia phenomenon.

Since the Redfield ratio suggests that phosphorus, nitrogen, or silica may each be limiting factors
at times, the feasibility of decreasing phosphorus should be further investigated. It was not
apparent in the report if an analysis had been conducted to determine the overall contribution of
point source discharges and the potential effects and costs associated with phosphorus reduction.

Substantial reductions in sediment delivery to the Gulf have resulted from the construction of
dams on the Missouri, Ohio and upper Mississippi Rivers. The relationship of these sediment
reductions to Gulf hypoxia has not been adequately addressed.

As the report itself indicates, much more data and time to analyze that data is necessary if we are
to better understand hypoxia occurrences in the North Gulf waters to the extent that we can
predict the benefits of various remedial actions. We concur and would like to assist with the
effort. .

Topic 2 — Ecological and Economic Consequences of Hypoxia

This report presents an evaluation of the ecological and economic consequences of nutrient
loading, including impacts to Gulf of Mexico fisheries and the regional and national economy.

This report provides no evidence that the value of the Gulf fisheries have been adversely
impacted by hypoxia so we question why the implementation recommendations are so drastic
and time critical? We believe existing efforts are addressing the problems, so there is time for
more research.

The report only partially addresses the ecological and economic consequences of hypoxia. The
discussion uses empirical observations on eutrophication without actual data. For example, the
water quality relationship of the Gulf to the Baltic Sea in the 1950's, the Adriatic Sea of the