I recently attended a meeting on proposed rules that
would place certain animal feeding operations under
the National Pollutant Discharge Elimination
system(NPDES) which would make them point sources of
pollution instead of non-point sources as they are now
with other agricultural sources. There were 100
farmers ,one environmentalist, and one
farmer-environmentalist at my meeting. The farmers are
going to comment on the proposed rules. You need to
also by e-mailing [log in to unmask]
Below are my comments as an example:

I would like to support the following rule changes
placing CAFO's under the NPDES program:

Define CAFO's to include operations with at least 500
Animal Units

Eliminating the 25 year,24hour storm permit
exemption(6 inches of rain in Iowa/24hr).

Adopting a Phosphorous standard for Nutrient Permit
Plans
No application of manure on frozen Ground

Public Availability of Permit Nutrient Plan's
executive Summary

No CAFO's within 200 feet of a waterway,500 feet from
a sinkhole or agricultural drainage well and not in a
100 year floodplain.

Extending liability to include both owner and contract
owners.

Permit Nutrient Plans should show sufficient land is
available for manure application not to exceed the
nitrogen and phosphorous requirements of the crops.

Subject animal feeding operations less than 500 Animal
Units to similar restrictions if they are in the
watershed of an impaired waterway.

Charles Winterwood
Chair
Iowa Chapter
Sierra Club
3839
Merle Hay Road
Suite 280
Des Moines,Ia 50310



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