After a two-and-a-half-year process of petitions, drafts, comments, and regulatory analysis, the Environmental Protection Commission (EPC) initiated a final, formal rulemaking process for animal feeding operation (AFO) rules on November 21. The rules govern AFO siting, management, and manure storage. Unfortunately, the rules package lacks protections for Iowa’s water quality and backtracks on stronger provisions for facilities sited in vulnerable karst terrain that were included in previous drafts. This is the last opportunity to use your voice to tell the DNR and the EPC that AFO rules must protect public health and water quality in Iowa. 

In 2021, IEC petitioned for new rules to protect sensitive Iowa waters from feedlot pollution. We requested that the EPC adopt rules to increase water quality protections for AFOs sited in porous karst terrain. DNR’s technical experts agreed that manure storage structures within 25 feet of karst terrain should have more protective requirements. In October 2023, the DNR submitted rules with more protective karst provisions to the Governor’s office for review. The Governor’s office  pre-cleared the rules package to go before the EPC only after those provisions were removed from the draft. A DNR spokesperson told the Gazette that the provisions were removed because "stakeholders were unable to come to a consensus."  

We can tell you that IEC was not asked to participate in any kind of stakeholder consensus-building process. Furthermore, consensus among "stakeholders" (such as the regulated groups) is not how regulation works. For the Environmental Protection Commission, regulation should be about protecting the environment.  

In addition to removing stronger karst protections, the final draft of the AFO rules package weakens critical DNR oversight and fails to make common-sense changes that would protect water quality and public health.  

Enough is enough – we cannot let the regulatory capture of the DNR continue. We must tell the DNR and the EPC to protect Iowa’s drinking water, Outstanding Iowa Waters, and other waters of the state by adopting stronger AFO rules.  

Make your voice heard: send an email to afo@dnr.iowa.gov or use the form on the right to submit your comments to the DNR by 4:30 p.m. on Friday, February 23rd. We highly encourage you to customize the email template with your own words. 

Additionally, the DNR will hold two public hearings with time for oral comments. We encourage you to attend and make comments in person if possible: 

In-Person: Wednesday, February 14, from 1:30 - 3:30 pm, Auditorium - Wallace State Office Building 

Virtual: Monday, February 19, from 1:30 - 3:30 pm. To participate in the virtual hearing, please submit a request for the link to afo@dnr.iowa.gov. All requests for the link must be received by 9:00 am on February 19.