EPA comments on Iowa’s Nutrient Reduction Strategy
• This agency is pleased to see that the accountability and verification measures and public reporting sections of the draft strategy outline a number of actions that meet the objectives of the March 2011 EPA memorandum. The final strategy should include a schedule for putting these actions in place.
• The draft strategy tasks the Water Resources Coordinating Council to develop indicators of success and annually evaluate the need for updates to the strategy. The EPA requests the opportunity to participate in the Water Resources Coordinating Council activities related to the nutrient reduction strategy.
• The strategy should explicitly establish how progress will be monitored/measured. For example, will measurements be applied to the quality of water leaving Iowa? We recommend evaluating existing data and measures from state and federal agencies to develop indicators of success. For example, since the NPSMP and nutrient reduction strategy goals are the same-improving water quality-there are opportunities for similar/same measures and joint reporting.
• The draft strategy is unclear where nutrient reductions will be measured and/or modeled as there are references to "edge of state" and "edge of watershed." Please provide clarification about how and where nutrient reductions will be measured or quantified. (Is there an inventory of nutrients entering/leaving Iowa?)
• The draft strategy references operational plans. Are these operational plans for action items listed in the strategy? The strategy should include specific action steps, milestones and timelines for implementation of actions included in the strategy.