DNR: Strengthen CAFO Rules in Iowa

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Tell DNR to strengthen AFO rules in Iowa

DNR has released another round of proposed rules for animal feeding operations (AFOs) and a draft regulatory analysis for public comment. While some proposed changes are positive, the proposed rules still do not protect groundwater and drinking water sources from pollution. We must again call on the DNR to strengthen the proposed rules to protect Iowa's waters, public health, and wildlife. Submit your comments to the DNR now.

In 2021, IEC petitioned for new rules to protect sensitive Iowa waters from feedlot pollution. We requested that the Environmental Protection Commission adopt rules to require water pollution monitoring systems, consideration of environmental factors before approval, and increased separation distance from karst terrain for new feedlots. Now, DNR is proposing changes to the rules – but not fulfilling what IEC requested.

To protect Iowa’s drinking water, Outstanding Iowa Waters, and other waters of the state, the adopted rules must require consideration of environmental factors and greater separation from karst terrain before approval of feedlot construction. Taking these steps can avoid hundreds of millions of dollars in pollution costs for Iowans.

The DNR must also move away from inefficient paper manure management plan submission and require submission through an online form. The plans must include geospatial data. This would allow DNR to use its limited resources to evaluate whether operators are complying with requirements and prevent inappropriate approvals of unacceptable plans.

The rules also need to reduce over-application of manure. The current approach results in pollution of Iowa’s groundwater and surface water with nitrate and phosphorus. The method in the proposed rules would change to reflect current science of the nutrients a crop can actually use, which could significantly improve water quality. The livestock industry does not want to see this change go through – we must demonstrate support for the rule change.

Please use the email form at right to submit your comments to the DNR by 5 p.m. on Tuesday, September 26.

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DNR

Subject: AFO Rulemaking

Message:

Dear DNR, The DNR has a legal duty to prevent and control water pollution by setting requirements for animal feeding operations (AFOs). DNR’s proposed rules would not do enough to protect groundwater and drinking water sources from AFO pollution, especially in karst terrain. As a result, thousands of private wells will continue to be polluted with unsafe levels of bacteria and nitrate. DNR’s duty to protect water means that it must stop the most egregious proposals that threaten water quality. DNR should not withdraw the rule allowing DNR to evaluate and stop the proposals that pose the most serious threats to water quality. DNR should also increase the minimum separation distance from karst to 25 feet. The proposed rule includes adoption of a floodplain map, as required by state law. The cost- savings of having a designated, electronically available floodplain map is one of the many benefits of adopting it. The same logic can be applied to requiring manure management plans to be submitted and available online with geospatial data. This would allow DNR and the public to efficiently evaluate submissions and compliance. The DNR should add this to the rules. The change to allowable manure application rates in the proposed rules would require manure management plans to properly determine the application rate based on crop needs and account for other fertilizer sources. This change would be a major improvement from the existing rule, which allows gross over-application of manure that leads to significant nitrogen and phosphorus pollution. The final rules must adopt these proposed changes to reduce manure and fertilizer contamination in our rivers, streams, and groundwater. To protect Iowa’s drinking water, Outstanding Iowa Waters, and other waters of the state, I ask you to adopt rules requiring greater separation from karst terrain for new construction, online submission, and consideration of environmental factors before approving feedlots. These changes could save Iowans hundreds of millions of dollars per year while improving water quality and protecting public health. Thank you,

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Tell DNR to strengthen AFO rules in Iowa

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