In accordance with 2002 Iowa Acts, Senate File 2293, the IDNR has proposed
amendments to incorporate the master matrix into Chapter 65.
To view the proposed matrix, go to the Iowa Department of Natural Resources
page, under the Environmental Protection Commission's most recent meeting
agenda, Item 8: www.state.ia.us/epd/epcmintz/02oct21a.htm
Written comments can be submitted on or before December 5 to:
Robin Pruisner
Iowa Department of Natural Resources
Wallace State Office Building
502 East 9th Street
Des Moines, IA 50319
fax 515-281-8895
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The IDNR will also host a public hearing on December 5, 2002, from 1:00 to
4:00 PM via the ICN network at:
Spencer High School
North Iowa Area Community College, Mason City
North Fayette High School, West Union
Maquoketa High School
Fairfield High School
Kuemper High School, Carroll
Osceola Public Library
Southwestern Community College, Red Oak
Department of Economic Development, Des Moines
The IDNR welcomes public comment on all the proposed rules, but specifically
requests public comment on several facets of this rule package. The master
matrix was created based upon a recommendation by a committee of 10
individuals representing organizations, as directed by SF2293. The committee
did not reach a consensus on the inclusion or exclusion of two possible
mitigating factors: 1) awarding points for the absence of non-therapeutic use
of antibiotics, and 2) awarding points for demonstrated community support.
The IDNR asks the public to comment on whether these two mitigating factors
should be included in the matrix, and if so, how many points should be
awarded and under what circumstances.
Secondly, the committee could not reach a consensus decision on the use of
subcategory scoring on the master matrix. The IDNR specifically requests
public comment on the feasibility of requiring minimum threshold passing
scores in the three subcategories of "air," "water," "and community impacts,"
as well as an overall minimum passing score.
Thirdly, the committee did not provide the IDNR with a recommended minimum
threshold passing score on the master matrix. In light of this, the IDNR has
set forth proposed minimum threshold scores of A) attain a minimum of 50% of
the points available in the overall score column, and B) attain a minimum of
30% of the points possible in each of the subcategories of air, water, and
community impacts. The IDNR specifically requests public comment on the
achievability of these scores. The IDNR is interested in what the public
feels is a fair minimum passing score(s).
Finally, the IDNR requests public input on the mitigating factors listed in
the master matrix. Does the general public believe that all the listed
factors belong in the master matrix? Does the general public feel that the
mitigating factors have been assigned reasonable scores? Are there
mitigating factors that should be listed in the master matrix but are not
currently listed, and if so, how many points should be awarded and under what
circumstances?
Here's a copy of comments made to the EPC in September, when the master
matrix was introduced to the Commission.
September 16, 2002
Environmental Protection Commission
Iowa Department of Natural Resources
Wallace Building
502 East 9th Street
Des Moines, IA 50319
Dear Environmental Protection Commissioners:
Thank you for the opportunity to comment on the master matrix. The Iowa
Chapter of the Sierra Club has some recommendations on how the IDNR might
address some of the issues left unresolved by the matrix committee. I have
listed these recommendations and concerns below.
1. The master matrix needs to be set up so applicants are required to go
beyond the legislative requirements, so applicants are actually addressing
proposed site issues and community concerns. If there is not a threshold
score for the entire matrix and each subcategory, the matrix is just a
checklist and not a potentially valuable tool for applicants, communities,
and boards of supervisors.
2. Applicants should be required to receive a certain percentage of the
total points to get a passing score. We recommend 75% for the threshold
score for the entire matrix.
3. Point totals should be assigned to each of the three subcategories of the
matrix representing the three risk categories of air quality, water quality,
and community concerns identified by the committee.
4. Applicants should also be required to receive a certain percentage of
points in each of the three subcategories (air quality, water quality, and
community concerns) to get a passing score. Recommended category minimums
are 25% in each of the three subcategories and 25% of the points of the whole
matrix used to address the specific issue/concern of the proposed site (these
points would give the applicant flexibility in achieving a passing score).
5. The percentages in the subcategories agreed to by the matrix committee in
the scoring process should be used to calculate point values within the three
risk categories and to determine the minimum threshold scores needed within
each risk category.
6. The mitigating factors left unresolved by the matrix committee should be
included in the final matrix. The absence of non-therapeutic antibiotic use
as a mitigating factor could serve as an important incentive for producers to
reduce the risk to the surrounding communities of antibiotic resistance.
With regard to the mitigating factor of demonstrated neighborhood support,
the applicant should be required to demonstrate support from 100% of the
neighbors in order to receive matrix points.
If threshold scores are not included for the whole matrix and each
subcategory, the result of three months of work by the matrix committee will
be a meaningless form for applicants to fill out during the permit process.
The result will also probably be calls for other solutions, including zoning
and local control, by community residents during the 2003 legislative
session.
Thank you for this opportunity to comment.
Erin E. Jordahl
Director, Iowa Chapter Sierra Club
3839 Merle Hay Road, Suite 280
Des Moines, IA 50310
515-277-8868
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