The DNR is proposing new environmental standards for large open feedlots and we have until Monday at midnight to weigh in on the rules. Please take the time to read the following talking points and send some brief comments, in your own words, to Gene Tinker at the DNR at [log in to unmask]<about:blank>

- We support the DNR's policy of requiring each open feedlot CAFO
(concentrated animal feeding operation) to apply for individual operating permits. General "one size fits all" permits would be inappropriate for open feedlots and would violate the DNR's existing agreement with the Cattlemen's Association

- We support the DNR's proposed deadlines of 180 days' notice before building or expanding a feedlot. This should not be shortened.

- We believe that all open feedlot CAFOs should be required to submit their Nutrient Management Plans (NMPs) to the DNR and that the NMPs should be public record. Allowing feedlots to write their own NMPs and keep them private, as proposed in these rules, does nothing to protect water quality.  The public has a right to know whether factory farms are over-applying manure, and these feedlots must be held accountable to the DNR and the public for having protective NMPs.

- DNR should not allow any open feedlot CAFO construction or expansion in Karst regions; allowing earthen or formed manure basins in areas with fractured rock poses a serious threat to groundwater and public health.

- DNR should prohibit artificial lowering of the groundwater table to
accommodate a manure effluent basin. Past experience with mechanical failure (pumps failing, etc.) shows that lowering of the groundwater table does not adequately protect groundwater from manure contamination.

Neila Seaman, MPA
Director
Sierra Club, Iowa Chapter
3839 Merle Hay Road, Suite 280
Des Moines, IA  50310
[log in to unmask]<mailto:[log in to unmask]>
515-277-8868

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