YOUR INPUT IS NEEDED!
SUBMIT COMMENTS NOW!
ATTEND THE EPC MEETING IN CLEAR LAKE ON SEPT. 16!


The CAFO legislation that passed this year set up a master matrix committee
whose job was to recommend to the DNR what a scoring matrix should look like.
 The scoring matrix is to be used by county Boards of Supervisors when they
decide whether to accept a CAFO application.

The DNR is currently using an interim matrix that was set up in the
legislation.  But the master matrix committee has finished their meetings and
DNR is preparing to present the recommendation to the Environmental
Protection Commission on Monday, Sept. 16.

However, certain very important issues were not resolved by the matrix
committee, so the DNR will need to determine how to deal with these issues.
Which is why our comments to the DNR are important and must be made NOW,
before the 16th.

Points to include in your email comments to Robin Pruisner, Coordinator of
rules development for SF2293  ([log in to unmask]):

-The master matrix needs to be set up so applicants are required to go beyond
the legislative requirements, so applicants are actually addressing proposed
site issues and community concerns.  If there is not a threshold score for
the entire matrix and each subcategory, the matrix is just a checklist and
not a potentially valuable tool for applicants, communities, and boards of
supervisors.

-Applicants must receive a certain percentage of the total points to get a
passing score.  We recommend 75% for the threshold score for the entire
matrix.

-Point totals should be assigned to each of the three subcategories of the
matrix representing the three risk categories of air quality, water quality,
and community concerns identified by the committee.

-Applicants must also receive a certain percentage of points in each of the
three subcategories (air quality, water quality, and community concerns) to
get a passing score.  Recommended category minimums are 25% in each of the
three subcategories and 25% of the points of the whole matrix used to address
the specific issue/concern of the proposed site (these points would give the
applicant flexibility in achieving a passing score).

-The percentages in the subcategories agreed to by the matrix committee in
the scoring process should be used to calculate point values within the three
risk categories and to determine the minimum threshold scores needed within
each risk category.

-If threshold scores are not included for the whole matrix and each
subcategory, the result of three months of work by the matrix committee will
be a meaningless form for applicants to fill out during the permit process.
The result will also probably be calls for other solutions, including zoning
and local control, by community residents during the 2003 legislative session.


Erin E. Jordahl
Director, Iowa Chapter Sierra Club
3839 Merle Hay Road, Suite 280
Des Moines, IA 50310
515-277-8868
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