Cami Koons covers agriculture and the environment for Iowa Capital Dispatch, where this article first appeared.

Iowa counties can have their own review on proposed animal feeding operation permits if they adopt a construction evaluation resolution and submit it to the Iowa Department of Natural Resources by the end of January each year. 

But not all counties are taking this step, giving up the ability to have a say in the permitting process.

The resolutions allow counties to submit formal recommendations to DNR, send county officials to the DNR inspections of a site, appeal a DNR decision on a construction permit, and implement more stringent construction requirements through the state master matrix.

Iowa Citizens for Community Improvement, or CCI, a community group organizing on farm and environmental issues and other topics, encourages counties to pass the resolutions. 

Caitlin Golle, a community organizer with CCI focused on farm and environment, said passing the resolution is the best protection a county has to make its voice heard in the matters of large animal feeding operations. 

“Without passing this resolution, there’s virtually no way for the county to provide input or fight to protect their community,” Golle said. 

Proposed animal feeding operations in counties that have passed the resolutions have to meet a state master matrix scoring criteria to receive a permit. 

According to DNR documents about the matrix, this means the operation will adhere to “to higher standards than required by law” typically involving “more conservative” manure management plans and “increased” separation distances.

The proposed operation must score a minimum of 440 points, which is 50 percent of the total points, on the master matrix criteria to receive a recommendation from the county. 

Golle said the matrix system provides some protections to counties, but is “no substitute for local control.” 

“For most people, a 50 percent grade is failing, but for factory farms requesting to build a new or expanding factory farm, they only need that 50 percent,” Golle said. “It’s intended to hold factory farms to a higher standard than what the law requires, where really the law should be requiring these higher standards.” 

The matrix is scored by the applicants and then it is up to the county to verify the distances and other requirements that go beyond state law requirements that are verified by DNR. 

“We want there to be that opportunity where, if (applicants) are not fully truthful … we can catch them on anything where points can be reduced, or where the permit can be denied,” Golle said. 

According to the DNR document detailing the matrix scoring, the county is obligated to score the matrix in a “professional” and “objective” manner. It cannot award or deny points “arbitrarily.” 

DNR has maps of the counties that have passed and submitted resolutions in the past several years on its website, which show all but around fifteen of Iowa’s 99 counties have submitted resolutions the past three years. 

A map from Iowa Department of Natural Resources shows counties that submitted construction evaluation resolutions in 2024. (Map courtesy of Iowa DNR)

Golle said some counties don’t submit because it means they would have to do the additional work of evaluating the master matrix. Others feel like it won’t make much of a difference if they evaluate it or not, since DNR ultimately has the final say. 

“Oftentimes supervisors can feel like their hands are tied, but still giving that input can make a big difference,” Golle said. 

Golle noted several instances where county evaluations of a master matrix and public input on a proposed operation led to permit denials or withdrawals. 

Iowa Capital Dispatch reached out to several county auditors in counties that have not passed resolutions the past couple of years. Some auditors responded that their boards of supervisors had passed the resolutions, but the county did not properly submit the documents to DNR. 

Other counties said they didn’t pass the resolutions because their boards felt it would not make a difference to the process, and another said it makes most sense to leave the decisions to DNR. 

Nan Benson, the auditor and recorder for Marshall County, said the county approved a resolution in 2024, but the former staff member responsible for submitting the document was unaware they needed to submit it to DNR. 

Benson said the county has passed a resolution for 2025 and will get it turned in this time.

Kelli Book, an attorney with DNR, said counties are notified each December to remind them of the process to submit the resolutions.

“Most counties that have the master matrix have done permits before, so they’re well aware of the process, but our engineers do send it to them,” Book said.

Golle said the master matrix ultimately gives the community the ability to share their opinions about the projects being built in their counties. 

“It is one of the greatest strengths—a tool that they have in order to give their input,” Golle said. “So they have that opportunity to stand up and make a public stance on how they feel about this specific permit request.”