Delta Chapter comments on Louisiana's Nutrient Management Strategy

Haywood Martin, Chair
Sierra Club Delta Chapter
PO Box 52503
Lafayette, LA 70505

January 27, 2014

Coastal Protection & Restoration Authority
Nutrient Management Strategy
P.O. Box 44027
Baton Rouge, LA 70804-4027

To Whom It May Concern,

The Delta Chapter of the Sierra Club offers the following comments on the Review Draft of the “Louisiana Nutrient Management Strategy” released on December 20, 2013 (www.lanutrientmanagement.org/review-draft).

The issue of the “Dead Zone” in the Gulf of Mexico has been of central concern to the Sierra Club for a number of years. The Club was one of a number of groups who joined to file the original petition under the Clean Water Act to the U.S. Environmental Protection Agency in 1995 that triggered federal action on this problem. The subsequent formation of the Gulf Hypoxia Task Force in 1997, and the agreement on an Action Plan in 2000, were part of a process aimed at addressing this serious threat to the health of the Gulf.

The term “Action” clearly needs to be emphasized, along with its central placement in the name for the national policy vehicle for reducing Gulf Hypoxia - The Action Plan for Reducing Gulf Hypoxia, signed in 2001 and revised in 2008. The 2001 Plan called for the size of the Gulf Hypoxic Zone to be reduced to an average annual size of 5000 square kilometers by 2015, a goal that clearly will not be met. The 2008 Action Plan states that state nutrient reduction policies are to be completed no later than 2013 (p. 32; http://water.epa.gov/type/watersheds/named/msbasin/upload/2008_8_28_msba...), another goal that will not be met.

Reading the Draft Louisiana Nutrient Management Strategy conveys no sense of the urgency that informed the first version of the Action Plan, nor does it lead the uninformed reader to recall that the state has been involved in this effort since 1997. Louisiana made the unilateral decision in 2012 to rename its strategy “Nutrient Management,” rather than the explicit “Reduction” strategy called for in the Action Plan. The Strategy itself largely consists of descriptions of activities and programs that are currently in operation in Louisiana for “management” of nutrients. This description is extensive, but programmatic – the biologic status of Louisiana’s water bodies is not described. The only mention of planned future actions are the coastal restoration diversions from the Louisiana Coastal Master Plan. The rest of the strategy appears to focus on assessment and planning rather than additional action.

The Executive Summary describes a “ten component framework for outlining and accomplishing action items” (p. ii):
1) Stakeholder Engagement; 2) Decision Support Tools; 3) Regulations, Policies, and Programs; 4) Management Practices and Restoration Activities; 5) Status and Trends; 6) Watershed Characterization, Source Identification, and Prioritization; 7) Incentives, Funding, and Economic Impact Analyses; 8) Targets and Goals; 9) Monitoring, and 10) Reporting.

The same ten items are referred to as ten strategic components for the Nutrient Management Strategy (Section E.2, p. 11), and form the “Strategic Actions” listed in Section E.3 (pp. 12-42). They also comprise the “Strategic Actions” presented in Appendix A (p. 92). There the “Actions” are each broken down into parts, but the verbs employed – “Identify,” “Evaluate,” “Document”, “Determine,” “Characterize,” “Explore” – are those of planning and assessment. The only active steps listed are to “Perform” outreach and education on the strategy (1.c), to “Promote” voluntary participation in incentive-based programs (7.a), as well as to “Model” nutrient removal from diversions (4.c) and “Monitor” various components of nutrient levels and water quality. The latter two are of course a key activities in water quality improvement.

What is missing are specific steps that Louisiana will take to contribute to the reduction in nutrient levels needed to reduce the Gulf Hypoxic Zone – the end results of targets and goals that constitute a strategy. Missing as well is an explanation of how Louisiana’s strategy fits in with the strategies of other states on the Gulf Hypoxia Task Force. The Task Force has posted a number of state strategies on their webpage, some of which are completed, others not (http://water.epa.gov/type/watersheds/named/msbasin/nutrient_strategies.cfm).

It is striking that two upstream states who have completed their strategies – Iowa and Minnesota – have both adopted numeric targets based on an eventual 45% reduction of their nutrient loads to the river. Iowa’s strategy states:

“Accounting for the potential reduction from point sources, the target load reductions for nonpoint sources is 41% of the statewide total nitrogen and 29% of the total phosphorus to meet the Gulf Hypoxia Action Plan goal.” (http://www.nutrientstrategy.iastate.edu/sites/default/files/documents/NR...)

Minnesota adopted a phased reduction of phosphorus losses of 35% and nitrogen losses of 20% by 2025. The contrast of Minnesota’s and Louisiana’s plans, even in their draft stages, was noted in an article in the Baton Rouge Advocate of September 29, 2013 (http://theadvocate.com/home/7155348-125/minn-taking-lead-to-reduce).

While these states are major contributors of nutrients to the Mississippi River (especially Iowa), there seems no reason why Louisiana could not set targets that achieve specific results. The overall impression given in the Louisiana Draft Strategy is that with the exception of river diversions, nothing more needs to be or will be done by Louisiana terms of reducing nutrient loading to the river or its tributaries, or the Gulf of Mexico. If this is the underlying assertion of the Strategy, then some scientific justification should be given for such a conclusion. It stands to reason that a strategy with some specific end result could be crafted from the many programs (along with a number of projects) that are described in the Draft.

Sincerely,

Haywood Martin, Chair
Sierra Club Delta Chapter

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