I wrote another letter, but it is hard to understand why they seem to keep
bringing up and going over the same territory again and again.  Why do they
need to keep reconsidering this?

Peggy M.

At 07:17 PM 3/7/99 -0800, you wrote:
>FROM : Debbie Neustadt, Sierra Club, Iowa Chapter
>To: Sierra Club activists
>Re: Adoption of hog lot rules
>3/8/99
>
>This is the third time the Iowa Environmental Protection Commission (EPC) has
>been asked to adopt rules since HF 519 was passed. Each time there has been
>stronger rules proposed by the Department of Natural Resources and weaker
>rules proposed by "Big Agricluture". The first time the EPC adopted the
weaker
>rules, the second time the stronger rules. The second time the idea of
>allowing lagoons below the water table was turned down. This is the third
>time. Please help by writing to all three or any one of the following EPC
>Commissioners.
>
>Rozanne King            Charlotte Mohr          Gary Priebe
>1568 170 th Trail       121 North 5th St.       1909 90th Ave.
>Mondamin, IA 51557      Eldridge, IA 52748      Algona, IA 50511
>
>
>Issues:
>Definition of a Release
>Permits -  DNR should have the ability to change, refuse, or
>          revoke a permit
>        - No new permits until one year after completion of
>          the last construction.
>Strong Lagoons Standards
>Testing of Manure Applicators
>
>
>DEFINTION OF A RELEASE. The definition of a release should include a spill
that
>goes into a tile line whether or not that tile line discharges to the
waters of
>the state. The purpose of a tile line is to convey water. If this water is
>contaminated with manure, there will be damage to the environment.  All
spills
>shoud be reported whether they end up in the waters of the state or not.
>
>This is an approach that would bring to the department's attention any
>environmental risk.   It would remove the necessity to determine or interpret
>the end point of a tile system.
>
>PERMITS. DNR should have the ability to modify, suspend, refuse to renew, or
>revoke an operating or construction permit based on the confined feeding
>operation being a clear, present and impending danger to the public health or
>the environm ent and not just an habitual violator.
>
>DNR should not issue a construction permit to expand or modify a confinement
>feeding operation for one year after completion of the last construction.
>This will close the loophole created when a producer will build structures on
>a site up t o the animal weight capacity without a permit then apply for a
>permit for the la st structure. There is a variance provision allows enough
>producer flexibility f or expansion.
>
>Operations that have a long term expansion plan can always include those
plans
>in a permit application if the expansion is contemplated with one year period
>fr om the previous construction. This rule encourages all animal feeding
>operations structures for an operation that will eventually require a permit
>to meet the c riteria.
>
>LAGOONS.  A logoon is a common way to store manure before it is land applied.
>The liner is suppose to allow a minor amount of waste to go through.
This is
>calle d the percolation rate. The percolation rate in a lagoon should be
>1/16th inch p er day at the design depth of  the lagoon.  The current rule is
>written for lago ons at 6 feet of waste. This is the standard for municipal

>lagoons. Many hog lag oons do not operate in the same conditions of a
>municipal lagoon; they often hav e more that 6 feet of waste in them.
>
>Allowing the rule to remain will allow lagoons that have a greater depth
than 6
>feet to be designed improperly. An ISU study showed that many lagoons
designed
>to meet the 1/6 inch at a six-foot depth actually exceed the criteria, and
>exceed 1/16 inch by much more under actual conditions.
>
>APPLICATORS CERTIFICAION. Applicators in order to be certified should have to
>pass a test and not just attending a class.   Initial certification should be
>by tes ting with renewal qualification by continuing instruction courses or
>the test. Pesticide applicators must take a test.
>
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