Almost forgot - the public comment period is at 10:30 AM
-----Original Message-----
From: Iowa Discussion, Alerts and Announcements
[mailto:[log in to unmask]]On Behalf Of Tarah Heinzen
Sent: Thursday, July 15, 2004 3:55 PM
To: [log in to unmask]
Subject: Talking points for Monday's EPC vote on factory farm pollution
Importance: High
Hello all,
The Environmental Protection Commission will be voting on a very important
issue Monday, July 19th at the DNR Air Quality Bureau, 7900 Hickman Avenue
in Urbandale:
We need your help to pass a meaningful hydrogen sulfide standard to protect
public health from factory farm pollution!
Attached, and pasted below, are talking points put together by Iowa Citizens
for Community Improvement, the lead organization working to pass factory
farm air quality regulations.
If you plan to attend the meeting and make a public comment as a Sierra Club
member (highly encouraged!) please focus your comments on these talking
points. We need to make sure the Commissioners know exactly what the
environmental community wants them to do, so they'll need to hear pretty
much the same thing from everyone.
Specifically, say that:
1)you're a sierra club member who
2)supports a strict hydrogen sulfide standard of 15 parts per billion, not
the 30 ppb standard being proposed. The commissioners have the authority to
amend the rule to adopt the 15 ppb standard (the DNR's original
recommendation)
3)If they won't go back to 15 ppb, they should change the exposure time from
60 minutes to 30 minutes. This would be comparable to what other states
(incl. MN and CA) have done, and would be more protective of public health.
4)Allowing 7 annual exceedences of the standard is ridiculous. They should
drop this from the proposed rule.
I hope to see some of you there!
Tarah Heinzen
Sierra Club Conservation Organizer
3839 Merle Hay Road, Suite 280
Des Moines, IA 50310
(515) 251-3995
[log in to unmask]
Complete talking points:
Tell the DNR “Protect our Health, Set Strong Clean Air Rules Now!”
DNR’s Proposed Standard
The Department of Natural Resources is proposing a hydrogen sulfide air
quality standard of 30 parts per billion that would apply to factory farms.
This new proposed standard of 30 parts per billion is weaker than the 15 ppb
the DNR originally proposed in December 2003. The rule also can only be
used to measure air monitor data and can not be enforced. The rule is only
for hydrogen sulfide and does not include an ammonia or odor standard that
was recommended in the joint University of Iowa/Iowa State University air
quality study. The rule also grants 7 free” days that a factory farm can
pollute the air before the DNR even starts to take action.
In the proposed rule, monitoring can only happen within 100 meters of a
separated location and must be placed further than the applicable
separation distance. This means that if a factory farm illegally built to
close to your home, you won’t be protected. In addition, if you happen to be
unlucky enough to live next to a factory farm built prior to the
establishment of separation distances you also won’t be protected. In
addition, this can create potential problems by limiting the DNR’s choice of
good locations to place the monitor. It sends the message that we really don
’t care about protecting people’s public health.
The Environmental Protection Commission (DNR’s nine member citizen oversight
board) will vote at their Monday, July 19 meeting to approve, reject, or
modify the DNR’s proposed rule. Here is your chance to help speak out
against factory farm air pollution and voice your support for moving forward
with strong clean air rules!
Key Points
1.) Keep the originally proposed 15 ppb standard. The joint
University
study recommended a hydrogen sulfide standard of 15 ppb. Commissioned by
Governor Vilsack, the joint University study was compiled by 27 state
university scientists and peer-reviewed by eight national and international
experts. The joint University study is current, sound and based on the best
science available. The DNR’s decision to back away from the joint
University study and propose a weaker standard of 30 ppb sends a clear
message to rural Iowans that politics is more important than public health.
The DNR also states that the HEV level was changed to 30 ppb
to base it on
the state of California’s hydrogen sulfide standard. However, California
has an ambient air quality standard of 30 parts per billion that can be
enforced anywhere on a neighbor’s property, not just at the separated
location, and only allows for one grace day (not seven like the DNR is
currently proposing). All of these factors make California’s standard
significantly stronger than what is being proposed by the DNR.
2.) Remove siting restrictions and Protect all residences. It is
important
to make sure that all people are protected and that the
DNR can place the
monitors in a way to show the true picture of what is
happening. Limiting
the siting of monitors to within 100 meters of a separated location and
outside of the legally required separation distance, just doesn’t
make
sense. Just because a there were not legal separation distances
when some
facilities built or a facility built illegally, does not mean that people
should not be protected. In many cases these are the
people who need
protection the most - because the facilities are so close to
their homes.
In the denial of the Agribusiness’ proposed air rules that contained very
similar restrictions about the siting of the
monitor, the DNR stated that
it was denying the rules in part because “these
limitations would hinder
the DNR’s ability to gather the baseline data necessary to make an informed
decision to move forward with plans and programs”.
3.) Move forward immediately with an ammonia and odor rule.
All of the
health standard recommendations in the joint University study must be
followed, not just a select few. The EPC must move forward with an ammonia
standard of 150 ppb and an odor standard of 7:1 dilution rate at a separated
location as recommended in the joint University air quality study.
4.) Drop the Seven “Grace Period” Days. The DNR and EPC
must remove the
seven day grace period because this rule has nothing to do with the
protection of public health. This rule allows citizens to be exposed to any
level of exposure, no matter how high, of hydrogen sulfide seven times a
year and not be protected by the state. In order to establish a health
effects standard that has the protection of public health in mind, the seven
day grace period must be removed from the rule.
5.) You CAN have strong clean air rules and livestock in
Iowa! Factory
farm supporters try to argue that any meaningful clean air rules for Iowa
will drive ag out of Iowa. That simply isn’t the case. 27 states have
established standards for hydrogen sulfide and 11 have standards for
ammonia -- many of these states, including Nebraska, Minnesota, Illinois,
North Dakota and Missouri have livestock. It is time Iowa joins it’s
neighbors in putting public health above the profit margins of corporate
factory farms! Family farmers will not have trouble meeting clean air
rules -- it is the factory farm owners who are afraid of clean air rules
because they don’t want to pay to clean up their air pollution!
Help Make a Difference!
Sign up to speak during the public comment period to voice your
support for
strong clean air rules!
ü Give your personal experiences with factory farm air pollution
ü Mention if you are a family farmer or member of Iowa Citizens for
Community Improvement
ü Talk about any of the above listed key points and your thoughts on
the
importance of protecting public health!
(Public comments will more than likely be limited to two
minutes a person)
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