Designed to Fail: The Truth About Illinois Nutrient Loss Reduction Strategy
By Chris Jones
In 2010 the U.S. Environmental Agency (USEPA) established a Total Maximum Daily Pollutant Load (TMDL) for the Chesapeake Bay, the world’s largest estuary and a high value water resource plagued by nutrient and sediment pollution from agriculture and urban discharges in its 64,000 square mile watershed (1). Efforts to improve the Bay’s water quality over the previous 25 years were unsuccessful, and the watershed’s state jurisdictions asked USEPA to develop the ‘pollution diet’ for the basin which would provide a regulatory framework as one piece of a larger planning and restoration process. The TMDL set watershed limits (per year) of 186 million pounds of nitrogen (N), 12.5 million pounds of phosphorus, and 6.45 billion pounds of sediment. To reach these pollutant levels, the individual loadings would need to be reduced by 25, 24, and 20%, respectively.
These Chesapeake Bay developments did not go unnoticed in the U.S. Corn Belt, where nutrient pollution impaired lakes, aquifers, and Mississippi River tributaries and ultimately the near shore areas of the Gulf of Mexico where Mississippi River discharge creates an annual low-oxygen zone commonly known as ‘The Dead Zone’ or ‘Hypoxic Zone’. Elevated river nutrients (N and P) trigger explosive algae and cyanobacteria growth in the Gulf, and their decomposing cells consume oxygen needed by desirable species such as shrimp and fish. USEPA and Mississippi Basin jurisdictions formed the Gulf Hypoxia Task Force (GHTF) in 1997 to understand the drivers of the Dead Zone phenomenon and in 2001 the GHTF released an Action Plan to reduce the extent of the annual hypoxic area to 5000 km2 by 2015 (2). Evidence has shown this will require about a 45% reduction in annual N and P loading to the Mississippi River.
Around the time USEPA established the Chesapeake Bay TMDL, it was becoming apparent that the 2015 GHTF goal would not be met. In fact, nutrient loading has often appeared to be worsening in the Mississippi Basin since 2001 (3,4). It was during this time (2010-2015) that the states in the Mississippi Basin began developing policy initiatives that were presented as ‘plans’ to reduce N and P loading to the Basin. Iowa issued its Nutrient Reduction Strategy in 2013 that included both a science assessment and a policy section. The science assessment identified practices from the scientific literature shown to reduce nutrient loss from both point (primarily municipal and industrial discharge) and non-point (primarily agriculture) sources. The policy section pointedly stated that efforts to reduce non-point source pollution should be voluntary and not driven by regulation. Illinois soon followed Iowa with its own Nutrient Reduction Loss Strategy, which is patterned after the Iowa plan, most notably in that the non-point source component be addressed through voluntary adoption of best management practices (BMPs).
The concept of ‘voluntary’ approaches for Mississippi Basin non-point source pollution, in clear contrast to the regulatory component (i.e. TMDL) for the Chesapeake Bay, was endorsed by USEPA in a March 16, 2011 memo to EPA Region Administrators authored by Nancy Stoner, then Acting Assistant Administrator for USEPA Office of Water. The significance of the Stoner memo cannot be understated. With only four short years to meet the then-2015 goal set by the GHTF, it was clear that the states’ voluntary strategies would not have time to affect significant landscape-scale change such that the annual Gulf hypoxic areal extent would be reduced. The GHTF accordingly revised the timeline for its goals in 2014, pushing back the 2015 target date to 2035 for a 5-year running annual hypoxic area average of less than 5000 km2, and establishing an interim 2025 target date for a 20% reduction in N loading (6). Clearly the actions of the GHTF over the last eight years conveniently provided cover for state jurisdictions and effectively endorsed the voluntary BMP adoption approach for non-point source pollution. Some of the state officials charged with implementing the state’s nutrient reduction policies also serve as members of the GHTF (7).
After decades of enduring polluted water, residents of Illinois and other Corn Belt states deserve to know if the state strategies, and especially the voluntary portion of each that targets agricultural pollution, are viable going forward such that water quality can be improved and maintained. It’s important to recognize that the state strategies are aligned with water quality objectives in the Gulf of Mexico and were never intended to address issues such as aquatic life and drinking water supply affecting populations near the source of nutrient pollution.
Several things about these strategies make assessing progress difficult. Firstly, since the vast majority of Corn Belt nutrient pollution is from agriculture, and year to year variations from this source are largely weather driven (8), disentangling the effects of weather from land use decisions is difficult and controversial. This is true for both for water that is improving and that which is declining in quality. Crop areas and selection are both quite stable in Corn Belt states and thus landscape changes made under the auspices of Illinois’ Nutrient Reduction Loss Strategy are more of a ‘fine tuning’ of the existing system rather than transformations to alternative production systems.
There is also a strong temptation to equate BMP adoption with ‘success.’ This ignores the contributions to increased pollutant loading linked to drivers such as increases in agricultural drainage tile (which hastens nitrate loss), increased crop area, increased livestock populations, and changes in the amount and timing of fertilizer application. There is some thought that lag times will delay water quality improvements that result from practice adoption and that legacy nutrients from decades of input overapplication will confound conclusions taken from actual water monitoring data (9).
After a decade, it’s apparent that the voluntary approach to non-point source nutrient pollution will take a very long time to drive changes in water quality. So long, in fact, that few Illinoisans alive today will see benefit, at least at the current rate of change. The Nutrient Loss Reduction Strategy’s own report (10) shows statewide 2017-2021 N loading slightly higher than the GHTF baseline period (1980-1996) with very little change in the 1997-2021 time frame. Statewide stream P loads are about 30% higher in the 2017-2021 compared to the 1980-96 baseline and about 17% higher than the pre-nutrient strategy 1997-2011 period. And it’s important to note that the point source load from municipal and industrial wastewater discharges (i.e. that subject to regulatory enforcement) has declined 34% for P and 12% for N compared to a pre-2011 baseline period, indicating continued increases from agriculture, post-strategy.
Adoption of some on-farm BMPs targeting nutrient losses, critical for the success of a voluntary strategy, actually appear to be declining in Illinois. Acres planted with cover crops, plants that sequester water and nutrients in the fall and early spring before the cash crop is planted, declined 14% from 2021 to 2022 according to Illinois Farm Service Agency, and over 60% of Illinois farmers report being not knowledgeable or only slightly knowledgeable about this practice. Successful implementation scenarios for the strategy estimate 18-22 million acres in cover crops for Illinois; current adoption rates are 1/20th of that level after a decade of the strategy.
Other indicators of adoption are similarly dismal. Acres of corn planted with a nitrogen rate management strategy has declined 5% since 2015. The state has 37 woodchip bioreactors treating 1500 acres, a nitrogen reduction strategy designed to intercept nitrate-laden water at tile outlets. Implementation scenarios call for 2-4 million acres treated in this manner. About 14,000 Illinois acres are enrolled in the wetland reserve program; implementation scenarios call for 1-3 million acres treated in this manner.
There are ample reasons to conclude this voluntary approach of BMPs will fail. A recent paper in the Journal of The American Water Resources Association (11) shows the folly of this approach. The researchers state that farmers and technical service providers at the agencies are rewarded for practice adoption, whether it improves the water or not: “The use of conventional BMPs (best management practices), most of which do not address significant nutrient imbalances, offers limited potential to reduce non-point (i.e., agricultural) source loads.” A reasonable person might ask why Illinois and other Corn Belt states have embraced this approach.
Asking taxpayers to pay some or all of the cost for these implemented BMPs seems wrongheaded when the likelihood of this approach to produce improved water quality within reasonable time frames is low. And giving farmers license to do whatever they want with on-farm decisions when it comes to fertilization, tillage, tiling, and other practices while taxpayers shoulder the burden of mitigating the pollution that results from those practices seems perverse. Taxpayer assisted adoption of conservation has a long history in US agriculture; the likelihood of this approach satisfactorily addressing farm nutrient pollution seems low without effective regulation of pollution-causing on-farm decisions.
- USEPA, Chesapeake Bay TMDL Fact Sheet, August 10, 2021.
- USEPA, History of the Gulf Hypoxia Task Force, August 29, 2023.
- Sprague, L.A., Hirsch, R.M. and Aulenbach, B.T., 2011. Nitrate in the Mississippi River and its tributaries, 1980 to 2008: are we making progress?. Environmental Science & Technology, 45(17), pp.7209-7216.
- Rabalais, N.N. and Turner, R.E., 2019. Gulf of Mexico hypoxia: Past, present, and future. Limnology and Oceanography Bulletin, 28(4), pp.117-124.
- Stoner, N. Memorandum, Working in Partnership with States to Address Phosphorus and Nitrogen Pollution through Use of a Framework for State Nutrient Reductions. USEPA, March 16, 2011.
- Gulf of Mexico Hypoxia Task Force, December 3, 2014. Mississippi River Gulf of Mexico Watershed Nutrient Task Force New Goal Framework.
- USEPA. Mississippi River/Gulf of Mexico Hypoxia Task Force, Task Force Members. November 14, 2023.
- Jones, C.S., Schilling, K.E., Simpson, I.M. and Wolter, C.F., 2018. Iowa stream nitrate, discharge and precipitation: 30-year perspective. Environmental management, 62, pp.709-720.
- Van Meter, K.J., Van Cappellen, P. and Basu, N.B., 2018. Legacy nitrogen may prevent achievement of water quality goals in the Gulf of Mexico. Science, 360(6387), pp.427-430.
- Illinois Department of Agriculture, Illinois Environmental Protection Agency, and University of Illinois Extension. Illinois Nutrient Loss Reduction Strategy Progress Report, November, 2023.
- Stephenson, K., Shabman, L., Shortle, J. and Easton, Z., 2022. Confronting our agricultural nonpoint source control policy problem. JAWRA Journal of the American Water Resources Association, 58(4), pp.496-501.
