IEC and coalition partners respond to DNR's draft CAFO rules

Coalition submitting formal response to Iowa DNR's draft CAFO rules

DES MOINES -- A coalition of environmental organizations called on the Iowa Department of Natural Resources (DNR) requesting stronger protections for water quality in Iowa’s concentrated animal feeding operation (CAFO) rules. 

The group filed official comments with the DNR today requesting DNR lower the allowable rates of manure applied to crops, increase protections for karst terrain, close loopholes that evade regulatory oversight, and retain the ability to stop high-risk facilities. 

The coalition includes 15 organizations: 100 Grannies for a Livable Future, Allamakee County Protectors - Education Campaign, Des Moines County Farmers and Neighbors for Optimal Health, Environmental Law & Policy Center, Food & Water Watch, Henry County Farmers and Neighbors, Iowa Alliance for Responsible Agriculture, Iowa Citizen Action Network, Iowa Citizens for Community Improvement, Iowa Environmental Council, Jefferson County Farmers & Neighbors, Inc., Poweshiek CARES, SILT (Sustainable Iowa Land Trust), Socially Responsible Agriculture Project, and Southern Boone County Neighbors. 

"The proposed rules will not protect surface water, groundwater, or drinking water sources from nitrate, bacteria, and other contamination," said Michael Schmidt, staff attorney for the Iowa Environmental Council. "This is DNR’s chance to properly balance the public’s interest in clean water with private interests of AFO owners. DNR must reduce the amount of manure allowed on cropland as called for in the state’s Nutrient Reduction Strategy."  

The comments also cite the failure to close loopholes that enable CAFOs to avoid being regulated as larger confinements. "The DNR attempted to close the LLC loophole in 2019," said Diane Rosenberg, executive director with Jefferson County Farmers & Neighbors, Inc. "But their solution was only to require a simple letter stating the owners of adjacent CAFOs didn’t hold a 10% or more interest in both. This proves nothing, and in essence, still leaves the LLC loophole in place." 

The comments respond to proposed revisions DNR released on August 12, 2022. DNR had promised to revise AFO rules in its response to an IEC-ELPC petition filed in August 2021 for rulemaking to protect karst and drinking water. The Environmental Protection Commission ultimately denied the karst and drinking water petition, stating they anticipated it would be addressed as part of the DNR’s five-year review process.   

"Manure from CAFOs is a pressing problem for drinking water, aquatic life, and recreation," said Josh Mandelbaum, senior attorney for the Environmental Law & Policy Center. "Protecting karst terrain will go a long way toward preventing manure from directly entering our groundwater." 

The rules also address a second IEC-ELPC petition filed in May 2022 to stop allowing AFO siting in floodplains, which is still pending. The proposed rules would adopt a floodplain map, as the petition requested, by adding it to the DNR’s AFO Siting Atlas. As noted in the petition, in 2002 the legislature directed DNR to adopt a floodplain map that would restrict feedlot construction in the 100-year floodplain.  

"Our leaders should support pastured livestock systems that let animals grow like they were meant to. Then we wouldn't have to argue about how to make farming less dangerous to our health. We'd simply have healthy farming, healthy land, and healthy Iowans," said Alexis Huddleston, farm coordinator with SILT (Sustainable Iowa Land Trust).

Read the comments submitted by IEC and coalition partners to the DNR.

1. cafos
2. dnr
3. drinking water
4. karst
5. phosphorus pollution
6. water quality