Protect Iowa's Water Quality

Please write a letter . Your letter will help stop the adoption of weak rules.
Please write to Environmental Protection Commissioners

Rozanne King            Charlotte Mohr          Gary Priebe
1568 170 th Trail       121 North 5th St.       1909 90th Ave.
Mondamin, IA 51557      Eldridge, IA 52748      Algona, IA 50511


Iowa Department of Natural Resources (DNR) has proposed strong rules. These
rules are coming under fire from factory farms.   Your letters are needed.

Issues:
Definition of a Release
Permits -  DNR should have the ability to change, refuse, or
revoke a permit
        - No new permits until one year after completion of
the last construction.
Strong Lagoons Standards
Testing of Manure Applicators


DEFINTION OF A RELEASE. The definition of a release should include a spill that
goes into a tile line whether or not that tile line discharges to the waters of
the state. The purpose of a tile line is to convey water. If this water is
contaminated with manure, there will be damage to the environment.  All spills
should be reported whether they end up in the waters of the state or not.

This is an approach that would bring to the department's attention any
environmental risk.   It would remove the necessity to determine or interpret
the end point of a tile system.

PERMITS. DNR should have the ability to modify, suspend, refuse to renew, or
revoke an operating or construction permit based on the confined feeding
operation being a clear, present and impending danger to the public health or
the environm ent and not just an habitual violator.

DNR should not issue a construction permit to expand or modify a confinement
feeding operation for one year after completion of the last construction.
This will close the loophole created when a producer will build structures on
a site up t o the animal weight capacity without a permit then apply for a
permit for the la st structure. There is a variance provision allows enough
producer flexibility f or expansion.

Operations that have a long term expansion plan can always include those plans
in a permit application if the expansion is contemplated with one year period
fr om the previous construction. This rule encourages all animal feeding
operations structures for an operation that will eventually require a permit
to meet the c riteria.

LAGOONS.  A logoon is a common way to store manure before it is land applied.
The liner is suppose to allow a minor amount of waste to go through.   This is
calle d the percolation rate. The percolation rate in a lagoon should be
1/16th inch p er day at the design depth of  the lagoon.  The current rule is
written for lago ons at 6 feet of waste. This is the standard for municipal
lagoons. Many hog lag oons do not operate in the same conditions of a
municipal lagoon; they often hav e more that 6 feet of waste in them.

Allowing the rule to remain will allow lagoons that have a greater depth than 6
feet to be designed improperly. An ISU study showed that many lagoons designed
to meet the 1/6 inch at a six-foot depth actually exceed the criteria, and
exceed 1/16 inch by much more under actual conditions.

APPLICATORS CERTIFICAION. Applicators in order to be certified should have to
pass a test and not just attending a class.   Initial certification should be
by tes ting with renewal qualification by continuing instruction courses or
the test. Pesticide applicators must take a test.

----------------------------------------------------------------------
To get off the IOWA-TOPICS list, send email to [log in to unmask]
Make the message text (not the Subject): SIGNOFF IOWA-TOPICS