The Environmental Protection Agency’s Region 7 commented last week on the draft Iowa Nutrient Reduction Strategy, which was released Nov. 19, 2012. The Iowa Department of Natural Resources (IDNR) and Iowa Department of Agriculture and Land Stewardship (IDALS) helped develop the strategy, which aims for ambitious specific nutrient reduction targets. EPA commended IDNR and IDALS for their efforts.

“The EPA views the draft Iowa Nutrient Reduction Strategy as a great start to set in motion actions that will begin to yield measureable nutrient pollution reductions from point and nonpoint sources,” said Karl Brooks, regional administrator, EPA. “EPA looks forward to working collaboratively with IDALS and IDNR on implementation of the strategy to achieve our mutual goals of water quality improvement in Iowa.”

EPA stressed that although it supports Iowa’s efforts, it is not mandating specific strategies or solutions.

A copy of the full letter is available at

Some of the general comments in the EPA letter included:

• While the draft strategy does address all framework elements the EPA has identified to maximize progress in reducing nutrient pollution, the section "Numeric Nutrient Criteria Limitations" does not reflect the EPA's current thinking about numeric criteria development and implementation. The EPA views numeric criteria as important tools for effective water quality management of nutrient pollution. Many of the concerns with numeric nutrient criteria described in the strategy focus on the EPA eco-regional criteria published in 2000, which were intended to be a starting point for states and others to develop more refined criteria that fully reflect localized conditions and protect specific designated uses. We have made a lot of progress working with states and authorized tribes since the 2000 document was issued to identify a range of options available to them in developing and implementing numeric criteria. This agency is available to work with you on the scientific underpinnings of numeric criteria that would be appropriate for water bodies in Iowa and that represent best available science. Such approaches may include: derivation of numeric nutrient criteria using stressor-response approaches, use of mechanistic models currently used in TMDL development, and approaches that better link biological responses to numeric nutrient criteria assessment procedures.

• The Iowa draft strategy highlights the costs to dischargers of complying with nutrient standards but does not recognize the wide range of water quality standards and permitting implementation flexibilities the EPA has been exploring with states that have protective numeric criteria in place. These tools include site-specific criteria, revisions to designated uses, pennit compliance schedules, water quality standards variances, and trading. Which regulatory tool is appropriate depends upon the circumstances.

• 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.