Numerous large-scale hog confinements in five Iowa counties are not following recommended practices for applying manure to farmland, according to findings the advocacy group Iowa Citizens for Community Improvement released today. Under Iowa law, livestock farms “with 500 Animal Units or more (equivalent to 1,250 hogs)” must have a Manure Management Plan. Iowa CCI members studied 234 of those plans in Adair, Boone, Dallas, Guthrie, and Sac counties (central and western Iowa). They found “missing documents, double-dumping, over-application, potential P-index violations, incorrect application rates, and potential hazards of manure application based on the geography and farming practices of the land.” Iowa CCI filed a complaint with the Iowa Department of Natural Resources today, requesting a thorough investigation of manure management plan violations as well as reforms “to improve oversight and to hold factory farm polluters accountable,” including stronger enforcement of plans and permits, “increased public access to manure application records,” more thorough inspections of livestock farms, and “better training across field offices for DNR staff.”

I enclose below the executive summary of Iowa CCI’s findings. The full complaint to the DNR is available here (pdf). Pages 4 through 6 offer detailed recommendations for “next steps” to address the problems. Appendix A lists 91 farms in the five counties that are large enough to need Manure Management Plans, but for which such plans are missing. Appendix B lists five farms for which Manure Management Plans were not in the DNR’s animal feeding operations database. Appendix C shows which documents were missing from dozens of farms’ Manure Management Plans across the counties. The file also includes county maps of watersheds and roads to show where the farms in question are located.

Since Iowa CCI members examined Manure Management Plans in only five of Iowa’s 99 counties, today’s case study reveals only a small fraction of statewide problems related to manure application. Kudos to those who researched and exposed the DNR’s failure to do its job.

Calls for tougher enforcement may be a dead letter, given the Branstad administration’s hostility to regulations that inconvenience business owners and the Iowa legislature’s resistance to approve even small measures to improve water quality (and I’m not just talking about Republican lawmakers).

Iowa CCI’s mission and methods have made it unpopular in powerful circles. But those who criticize the group’s controversial acts (like heckling politicians) should also acknowledge important work like today’s case study. While some Democratic elected officials are deeply committed to addressing our water pollution problem, as a group Iowa Democratic officialdom has said little and done less about agricultural runoff. Iowa CCI speaks for many people who are angry about pollution impairing hundreds of waterways, and who know that electing more Democrats alone will not solve the problem. That’s why it has long been among the largest non-profits working on environmental and social justice issues in this state.

Iowa Citizens for Community Improvement press release of November 3 (executive summary of full report “TOO MUCH MANURE: Iowa CCI Case Study Exposes DNR Failure to Crack Down on Factory Farm Pollution”)

TOO MUCH MANURE:
Iowa CCI Case Study Exposes DNR Failure to Crack Down on Factory Farm Pollution

Des Moines, IA. Today members of Iowa Citizens for Community Improvement (Iowa CCI) filed an official complaint under Iowa Code Chapter 561 – 3.3 (17A,455A) requesting that the Iowa Department of Natural Resources (DNR) open a formal investigation into allegations of widespread Manure Management Plan (MMP) violations. MMPs are a document required for factory farms with 500 Animal Units or more (equivalent to 1,250 hogs).

Iowa CCI members spent 2015 auditing and mapping 234 MMPs in five Iowa counties – Adair, Boone, Dallas, Guthrie, and Sac. In these five counties there are 325 factory farms large enough to require a MMP. We looked for – and found – missing documents, double-dumping, over-application, potential P-index violations, incorrect application rates, and potential hazards of manure application based on the geography and farming practices of the land.

CCI members believe that DNR should not approve another factory farm construction or expansion permit in Iowa.

“For years we have been saying that factory farm manure is being dumped with disregard for People and Planet,” said Barb Kalbach, CCI member and 4th generation family farmer from Adair County. “We believe there are too many factory farms in our state and no political will from Iowa DNR to permit, inspect, and enforce the law against them to crack down on factory farm pollution to protect our water, land, and communities.”

Iowa’s waterways are becoming increasingly more polluted and it is clear that the biggest threats to our water are agricultural fertilizer and factory farm manure runoff. In Iowa we’ve seen:
· an increase in polluted waterways from 630 in 2012 to 725 in 2014 – a 15% hike in just two years,
· 25 beach closing due to toxic algae levels,
· Des Moines Water Works has had to run its denitrification system for a record 148 days in 2015, and
· over 800 documented factory farm manure spills in recent years.

“How much manure is too much manure for Iowa? Iowa already has over 9,000 factory farms producing 10 billion gallons of manure annually. DNR is approving 300-600 more factory farms a year. What’s the cutoff point? I think we’ve already passed it. DNR should not approve another factory farm in this state,” said Kalbach.

Like the Des Moines Water Works Lawsuit, CCI members are calling on Iowa DNR to enforce the Clean Water Act to hold factory farm manure polluters accountable.

“We want tough enforcement measures including Clean Water Act permits and Nutrient Management Plans, increased public access to manure application records, thorough inspections that find and fix problems, and the toughest fines and penalties possible when violations occur,” said Rosie Partridge, a lifelong conservationist and small business owner in Sac County.

CCI members developed common-sense proposals to improve oversight and to hold factory farm polluters accountable to protect our water, land, and communities.

These proposals consist of:
· tough enforcement measures including Clean Water Act permits and Nutrient Management Plans,
· increased public access to manure application records,
· thorough inspections that find and fix problems,
· better training across field offices for DNR staff.

We believe that if Iowa DNR implements our proposals and goes after the polluters instead of continuing business as usual, Iowa’s water quality will begin to improve and we can build an agricultural system that puts People and Planet First.

This case study alleges violations of water pollution laws, which should trigger a mandatory DNR investigation under Iowa Code 561 – 3.3(17A,455A).

Iowa CCI is a statewide, grassroots people’s action group that uses community organizing to win public policy that puts communities before corporations and people before profits, politics, and polluters.

For more information, visit www.iowacci.org .

Groups that support the Iowa CCI’s case study and policy recommendations:

Dallas County Farmers & Neighbors
Des Moines County Farmers & Neighbors
Food & Water Watch
Humane Society of the United States
Iowa Citizens for Community Improvement
Poweshiek CARES
Southern Boone County Farmers & Neighbors