Please contact your State Senator and ask them to vote against SF372-HF805· You can find their e-mail address at www.legis.state.ia.us The Iowa Chapter of the Sierra Club opposes this legislation for the following reasons: Language in the bill always refers to "waters of the United States." > Because "waters of the United States" refers to waters that flow into > navigable waters, all references to "waters." should be changed to "waters > of the state" to include groundwater and other, temporary water sources such as ditches, sink holes and tile lines. > > · Senate File 372 allows for alternative treatment technologies before > research demonstrating these alternative methods meet the federal > performance standards required for CAFOs has been completed. The performance > standard is a zero discharge except in storms that exceed the 25-year > 24-hour storm event. Compliance with the federal Clean Water Act and the > federal CAFO rules allows for alternative treatment technologies only if > they meet or exceed the federal performance standard. An equivalent level > of control, as included in the legislation, is not defined. In addition, > monitoring must be required to demonstrate that permitted open feedlots are > not causing water quality standards violations. Because the research has > not yet been completed for the alternative technologies, monitoring > requirements at these sites must establish that the technology is meeting or > exceeding the federal performance standard. > > · The bill allows for the mechanical lowering of the groundwater table. This> language is unacceptable and should be removed. > > · Both the bill and the amendment allow for open feedlot construction in the > floodplain or floodway of a river or stream. This is unacceptable and should> be amended. > > · The bill does not call for construction standards or tile line > investigation/removal for the solids settling facility (the area that holds > the manure runoff from the feedlot and allows > the solids to settle out). Construction standards should minimally require > selection of areas with suitable soil material and tile line removal in the > areas where solids settling facilities are to be built. Liners and > permeability testing similar to that required for effluent basins should be > required for solids settling facilities that will hold liquid for more than > 72 hours. Again, this language is unacceptable and should be changed. > > · Senate File 372 provides for nutrient management plans to be kept > confidential by the Department of Natural Resources. Nutrient management > plans should be made available for public review using the same process > required for confinement facilities' manure management plans. > > · Drainage tile lines should be installed at least 50 feet away from the > settled open feedlot effluent basin not 25 feet as included in the bill. > > · A site engineer should be required to inspect the settled open feedlot > effluent basin during critical steps of construction not simply when design > plans are submitted to the DNR and after completion. > > · Language should be included in the bill that requires the animal unit > capacity of an open feedlot operation to include the animal unit capacity of > any confinement feeding operation buildings that are part of the open > feedlot operation. > > Again, the Sierra Club cannot support this legislation. It's unnecessary > because proposed DNR rules address all of these issues. Charles Winterwood State Legislative Chair Iowa Chapter Sierra Club __________________________________ Do you Yahoo!? Yahoo! Mail - Find what you need with new enhanced search. http://info.mail.yahoo.com/mail_250 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - To get off the IOWA-TOPICS list, send any message to: [log in to unmask]