The Fertilizer Institute (TFI) last week submitted 14 pages of comments to EPA on its Draft Science Advisory Board (SAB) Hypoxia Report, in which TFI disputes several report recommendations, including the implementation of fertilizer taxes and a 40 percent reduction in phosphorous loadings to the Gulf, which TFI said would seriously impact U.S. farmers’ phosphorous fertilizer use.
TFI cited a USDA economic analysis to refute the effectiveness of fertilizer taxes, arguing that an increase in fertilizer prices is unlikely to affect fertilizer demand, and specifically that a tax on fertilizer is unlikely to reduce fertilizer use in corn production. TFI also argued that the poor correlation between nitrogen and/or phosphate fertilizer use and the size of the Gulf hypoxic zone indicates “a more complex problem than simply nutrient over-enrichment,” and that the report should take into account all sources of nutrients and their ability to be controlled.
“Synthetic fertilizers comprise a variety of sources including enhanced efficiency products that delay the release of nitrogen; or more closely approximate the uptake curve of the crop,” TFI said. “The implementation of nutrient management plans and best management practices are most easily accomplished with synthetic nitrogen fertilizers, with more predictable release and dissolution curves, and significantly less volatilization into air per unit nitrogen.”
TFI further argued that fertilizer use efficiency is at an all-time high, and estimated that U.S. farmers since 1980 are applying 41 percent less nitrogen and 53 percent less phosphate per bushel of corn produced. “The science of best management practices has grown,” TFI said, “providing farmers with a variety of practices that promote the use of the most appropriate nutrient products, applied at the right rate, time and place.” TFI said progress has also been made in conservation practices such as wetland and riparian buffer creation and restoration.
TFI said the final SAB report should dedicate more time to examining current adoption of best management practices and potential means of enhancing farmer’s nutrient stewardship strategies. TFI also disagreed with the report’s conclusion that reduced fertilizer use translates into reduced nutrient loss to the environment, and argued that lower fertilizer application rates may actually mean increased losses of nutrients to the environment, depending on site-specific conditions.
“Maximized nutrient use depends on several factors, including balanced nutrition and interrelationships among nutrients for efficient plant uptake and use,” TFI said. “While crops can mine soil nitrogen reserves to counter short-term nitrogen application reductions, arbitrary fertilizer reductions will result in longer-term increases in edge-of-field nutrient losses. This is particularly true in high-yield farming practices in use today.”
A second draft of the EPA SAB hypoxia report will be released later this year. Congress established the EPA Science Advisory Board in 1978 and gave it a broad mandate to advise EPA on technical matters. The SAB will report its advice and recommendations to the EPA Administrator; its duties are solely advisory in nature.