Here are the comments I submitted on behalf of the Iowa Chapter at Elk
Horn.  Jane and Charlie worked with me on this.

Peggy Murdock

Thank you for providing this opportunity to speak out about the challenges
we face in dealing with the problems associated with concentrated animal
feeding operations.

The Sierra Club of Iowa supports protection of valuable and vulnerable
areas, local control of siting, banning earthen manure storage lagoons, and
a phosphorus standard for manure application rates.  No confinements should
be located in flood plains and geological and soil types should be taken
into consideration when making siting decisions.

In order to be permitted, a facility should have an emergency response and
remedial action plan on file with the DNR.

The final cost of cleaning up these operations once they have reached the
end of their expected lifetime should be provided for in permit
requirements just as it is for tire waste sites.  Each facility should have
a site closure plan describing the actions that would have to be taken in
order to properly dispose of the animals and their waste, as well as the
structures required for the operation, so that the land can again be used
for agricultural purposes.  A financial assurance instrument should be
provided with sufficient funds to cover the cost of this closure and clean
up when permits terminate, expire or are revoked.

Until such measures have been enacted, and until the state has time to
accumulate the necessary resources, there should be a moratorium on the
construction of new confinements.

In the past we have protected farmers by banning nuisance suits in rural
areas. Now we need to provide a rural nuisance standard to protect rural
residents.  CAFO neighbors should have the same right to sue that is
granted to neighbors of organic composting facilities.

Preliminary research indicates that the hydrogen sulfide emissions may
cause neurological damage. Whether or not neurological damage is being done
to people living near CAFOS, we know the areas around these facilities are
a living hell for the people trapped there. Science should not be in the
business of deciding what is acceptable for other people's lives, it should
simply clarify the relationship between cause and effect. Iowans should not
abdicate our responsibility to set reasonable limits on CAFOs by relying
exclusively on scientific studies to do it for us. Setting reasonable
limits is not the responsibility of scientists, it is ours.

We know that what is happening around these facilities is unacceptable. We
don't need scientific verification for that. We must find a way to take
back our community responsibilities and begin making decisions that respect
the value of scientific contributions but also factor in common sense and
the value of Iowans.