If you haven't already submitted comments, please consider doing so.

In accordance with 2002 Iowa Acts, Senate File 2293, the IDNR has proposed amendments to incorporate the master matrix into Chapter 65.  

To view the proposed matrix, go to the Iowa Department of Natural Resources page, under the Environmental Protection Commission's most recent meeting agenda, Item 8: www.state.ia.us/epd/epcmintz/02oct21a.htm

Written comments can be submitted on or before December 5 to:
Robin Pruisner
Iowa Department of Natural Resources
Wallace State Office Building
502 East 9th Street
Des Moines, IA 50319
fax 515-281-8895
[log in to unmask]

The IDNR will also host a public hearing on December 5, 2002, from 1:00 to 4:00 PM via the ICN network at:
Spencer High School
North Iowa Area Community College, Mason City
North Fayette High School, West Union
Maquoketa High School
Fairfield High School
Kuemper High School, Carroll
Osceola Public Library
Southwestern Community College, Red Oak
Department of Economic Development, Des Moines


The IDNR welcomes public comment on all the proposed rules, but specifically requests public comment on several facets of this rule package.  The master matrix was created based upon a recommendation by a committee of 10 individuals representing organizations, as directed by SF2293.  The committee did not reach a consensus on the inclusion or exclusion of two possible mitigating factors: 1) awarding points for the absence of non-therapeutic use of antibiotics, and 2) awarding points for demonstrated community support.  The IDNR asks the public to comment on whether these two mitigating factors should be included in the matrix, and if so, how many points should be awarded and under what circumstances.

Secondly, the committee could not reach a consensus decision on the use of subcategory scoring on the master matrix.  The IDNR specifically requests public comment on the feasibility of requiring minimum threshold passing scores in the three subcategories of "air," "water," "and community impacts," as well as an overall minimum passing score.

Thirdly, the committee did not provide the IDNR with a recommended minimum threshold passing score on the master matrix.  In light of this, the IDNR has set forth proposed minimum threshold scores of A) attain a minimum of 50% of the points available in the overall score column, and B) attain a minimum of 30% of the points possible in each of the subcategories of air, water, and community impacts.  The IDNR specifically requests public comment on the achievability of these scores.  The IDNR is interested in what the public feels is a fair minimum passing score(s).

Finally, the IDNR requests public input on the mitigating factors listed in the master matrix.  Does the general public believe that all the listed factors belong in the master matrix?  Does the general public feel that the mitigating factors have been assigned reasonable scores?  Are there mitigating factors that should be listed in the master matrix but are not currently listed, and if so, how many points should be awarded and under what circumstances?


Here's a copy of comments made to the EPC in September, when the master matrix was introduced to the Commission.


September 16, 2002

Environmental Protection Commission
Iowa Department of Natural Resources
Wallace Building
502 East 9th Street
Des Moines, IA 50319


Dear Environmental Protection Commissioners:

Thank you for the opportunity to comment on the master matrix.  The Iowa Chapter of the Sierra Club has some recommendations on how the IDNR might address some of the issues left unresolved by the matrix committee.  I have listed these recommendations and concerns below.

1.  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.  

2.  Applicants should be required to receive a certain percentage of the total points to get a passing score.  We recommend 75% for the threshold score for the entire matrix.

3.  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.

4.  Applicants should also be required to 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).

5.  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.

6.  The mitigating factors left unresolved by the matrix committee should be included in the final matrix.  The absence of non-therapeutic antibiotic use as a mitigating factor could serve as an important incentive for producers to reduce the risk to the surrounding communities of antibiotic resistance.  With regard to the mitigating factor of demonstrated neighborhood support, the applicant should be required to demonstrate support from 100% of the neighbors in order to receive matrix points.

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. 
Thank you for this opportunity to comment.


Erin E. Jordahl
Director, Iowa Chapter Sierra Club
3839 Merle Hay Road, Suite 280
Des Moines, IA 50310
515-277-8868
[log in to unmask] - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - To view the Sierra Club List Terms & Conditions, see: http://www.sierraclub.org/lists/terms.asp