Please contact your State Senator and ask them to vote
against SF372-HF805· You can find their e-mail address
at www.legis.state.ia.us

The Iowa Chapter of the Sierra Club opposes this
legislation for the following reasons:

 Language in the bill always refers to "waters of the
United 
States."
> Because "waters of the United States" refers to
waters that flow into
> navigable waters, all references to "waters." should
be changed to "waters
> of the state" to include groundwater and other,
temporary water sources
such as ditches, sink holes and tile lines.
>
> · Senate File 372 allows for alternative treatment
technologies before
> research demonstrating these alternative methods
meet the federal
> performance standards required for CAFOs has been
completed. The performance
> standard is a zero discharge except in storms that
exceed the 25-year
> 24-hour storm event.  Compliance with the federal
Clean Water Act and the
> federal CAFO rules allows for alternative treatment
technologies only if
> they meet or exceed the federal performance
standard.  An equivalent level
> of control, as included in the legislation, is not
defined.  In addition,
> monitoring must be required to demonstrate that
permitted open feedlots are
> not causing water quality standards violations. 
Because the research has
> not yet been completed for the alternative
technologies, monitoring
> requirements at these sites must establish that the
technology is meeting or
> exceeding the federal performance standard.
>
> · The bill allows for the mechanical lowering of the
groundwater table.
This> language is unacceptable and should be removed.
>
> · Both the bill and the amendment allow for open
feedlot construction in the
> floodplain or floodway of a river or stream. This is
unacceptable and should> be amended.
>
> · The bill does not call for construction standards
or tile line
> investigation/removal for the solids settling
facility (the area that holds
> the manure runoff from the feedlot and allows
> the solids to settle out). Construction standards
should minimally 
require
> selection of areas with suitable soil material and
tile line removal in the
> areas where solids settling facilities are to be
built.  Liners and
> permeability testing similar to that required for
effluent basins 
should be
> required for solids settling facilities that will
hold liquid for more than
> 72 hours. Again, this language is unacceptable and
should be changed.
>
> · Senate File 372 provides for nutrient management
plans to be kept
> confidential by the Department of Natural Resources.
 Nutrient 
management
> plans should be made available for public review
using the same 
process
> required for confinement facilities' manure
management plans.
>
> · Drainage tile lines should be installed at least
50 feet away from 
the
> settled open feedlot effluent basin not 25 feet as
included in the 
bill.
>
> · A site engineer should be required to inspect the
settled open 
feedlot
> effluent basin during critical steps of construction
not simply when
design
> plans are submitted to the DNR and after completion.
>
> · Language should be included in the bill that
requires the animal 
unit
> capacity of an open feedlot operation to include the
animal unit 
capacity
of
> any confinement feeding operation buildings that are
part of the open
> feedlot operation.
>
> Again, the Sierra Club cannot support this
legislation.  It's 
unnecessary
> because proposed DNR rules address all of these
issues.

Charles Winterwood
State Legislative Chair
Iowa Chapter
Sierra Club


		
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