Comments submitted on Jan. 3, 2008 regarding Hypoxia

January 3, 2008

U.S. Environmental Protection Agency
Docket ID No. EPA-HQ-OW-2007-1126
EPA Docket Center (EPA/DC)
Water Docket, MC 2822T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Comments Draft 2008 Hypoxia Action Plan

The Ohio Farm Bureau Federation (OFBF) would like to thank you for the opportunity to provide comments regarding the Draft 2008 Gulf Hypoxia Action Plan for Reducing, Mitigating, and Controlling Hypoxia in the Northern Gulf of Mexico and Improving Water Quality in the Mississippi River Basin (Action Plan).  OFBF is the largest general farm organization in the state of Ohio with members in all of Ohio’s 88 counties.  Our members produce virtually every kind of agricultural commodity and as a result, OFBF is strongly interested in environmental policies and their potential impact to sustaining a viable agbioresource industry in the state.

OFBF policies support the rights of states to develop programs that are scientifically based, economically sound and to the maximum extent possible, delivered in a flexible and voluntary manner to address the agricultural portion of the Gulf of Mexico Action Plan.  We believe that strategies to implement the goals and objectives of the Action Plan must be delivered and administered at the local level.  Any policies made regarding the implementation of the Action Plan must be based on sound scientific data and must give proper consideration to the sustainability of a viable agbioresource industry in the state of Ohio.

OFBF’s comments will address the following items – goals of the Action Plan, availability of resources, the reassessment of the scientific knowledge regarding hypoxia and the action agenda.

Adequacy of the goals of the Action Plan

Coastal Goal – We agree with the statements made by the Science Advisory Board Hypoxia Panel and their recognition of the difficulty in achieving the Coastal Goal of a hypoxic zone of less than 5,000 square kilometers by the year 2015.  Continuing to reinforce an unattainable target establishes unrealistic expectations and sets the Action Plan up for failure in the eyes of the general public.

The complexity and annual variability inherent in natural systems suggests that a 2015 target date and/or a less than 5,000 square kilometer hypoxic zone target is overly optimistic and unattainable.  Extending the target date to a more realistic 2030 or changing the target size of the hypoxic zone to 10,000 square kilometers would be more appropriate.  The adaptive management process embedded within the Action Plan provides continual feedback between management actions and the interpretation of new information and should serve as the appropriate mechanism to adjust these targets in the future.

Within Basin Goal – Restoration and preservation of the surface water resources within each of the 31 basin states, while considering down-stream benefits to the Gulf of Mexico, is the correct strategy to implement.  Nutrient and sediment reduction strategies must be developed at the state level, reflecting the input of those individuals ultimately responsible for their implementation – the farmers.

Every landowner and agricultural operation is unique.  Nutrient and sediment reduction strategies and implementation actions must allow individual flexibility.  Solutions cannot be “cookie-cutter” solutions established at the national level if consistency with the voluntary, practical and cost-effective guiding principle of the Action Plan is to be maintained.

Quality of Life Goal – As the implementation of the Action Plan takes place in the Mississippi/Atchafalaya River Basin, the removal of cropland acres for conservation set-asides will have an impact on the local economy due to the loss of agricultural production.  These social costs have the potential of being quite large and could impact the rural quality of life.  As programs are developed, the potential detrimental impact to local communities must be considered.

Adequacy of Available Resources

Successful implementation of the Action Plan is dependent upon the availability of adequate technical assistance and financial resources at the state and federal level.  Even with limited additional resources, landowners in the Mississippi/Atchafalaya River Basin have undertaken numerous nutrient and sediment reduction activities impacting a significant acreage of cropland.  The fact that millions of acres of cropland have been affected with existing resources since the release of the 2001 Action Plan is a success story that needs to be recognized, actively promoted and used as leverage for additional support as future critical needs are identified.

Science Reassessment

Conclusions from the reassessment of the science related to hypoxia in the Northern Gulf of Mexico highlight the complexity of the issue.  While nutrient loading to the Coastal Gulf is identified as one of the primary causes of hypoxia, the time of the year that the loading takes place (spring versus summer) and the form of nitrogen and phosphorus (nitrate and/or dissolved phosphorus) are critical factors.  Nutrient reduction strategies targeting time of year and chemical form, while necessary for success will be challenging to develop and implement.  Many agricultural management measures will address only part of the concern, necessitating a comprehensive system approach.  The limited technical and financial resources currently available will make the development of site specific solutions a challenge.

Getting Results

OFBF agrees with the general overarching tone of the statements made in the “Next Steps” section of the Action Plan:
* Incentive-based, voluntary efforts to address nonpoint source nutrient loading to the Gulf of Mexico are imperative.
* The current level of available funding to implement the Action Plan is insufficient.
* Nutrient reduction strategies must be developed at the state level.
* Existing conservation programs must be refocused to address local, state and regional water quality concerns.
* Identification of the most effective nutrient reduction practices is key to the success of the Action Plan.
* The continued collection of information is necessary to reduce scientific uncertainties regarding nutrient source, fate and transport as well as the relationship between nutrient loads and the formation, extent, duration and severity of the hypoxic zone.
* Commitment to adaptive management by the Task Force is essential to the success of implementation of the action Plan.

Thank you again for this opportunity to comment.


John C. Fisher, Executive Vice President
Ohio Farm Bureau Federation


Cc:    Bob Peterson, President OFBF
    OFBF Board of Trustees

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