top of page

Sample Letter to DNR Attorney Kelli Book during the Chapter 65 Formal Comment Period - Due 4:30 pm Friday, February 17

Use this letter to submit comments on Chapter 65 to Kelli Book, DNR AFO Attorney at by 4:30 pm, Friday, February 23. Cut and paste it into your own email, personalizing it as you see fit. You can also mail written comments to Ms. Book at Iowa Department of Natural Resources, Wallace State Office Building, 502 East Ninth Street, Des Moines, IA 50319. All written comments must also be received by 4:30 pm on February 23. Thank you for all you do. 
Click here for a list of JFAN's recommendations that were rejected by the DNR.
Read JFAN's statement made at the DNR's February 19 virtual public hearing.

Read JFAN's final set of public comments submitted to the Iowa DNR.

Dear Ms. Book,


Iowans have a right to clean water. They have a right to live without risk to their physical health. But 751 waterways, half of those tested, are polluted. The state ranks #2 in the nation for cancer – and that number continues to rise. The state’s agricultural practices are significant contributing factors to both its water degradation and cancer crisis.


Stronger CAFO regulations can reduce water pollution and protect public health. That’s why I urge you to strengthen CAFO regulations and adopt all the recommendations to Chapter 65 submitted by Jefferson County Farmers & Neighbors (JFAN).


It’s the DNR’s responsibility to protect our natural resources, but weak CAFO regulations do anything but that. The DNR needs to prioritize both rural and urban Iowans who want to drink clean and safe water, swim in its beaches, and enjoy fishing opportunities and other recreational water activities by adopting recommendations that put the wellbeing of Iowans before the financial interests of the multinational livestock industry.


During the last two years, JFAN and the Iowa Environmental Council (IEC) each made a host of recommendations to strengthen Chapter 65 that would help better protect our waterways and public health. Very few were incorporated. But many of the livestock industry’s recommendations were adopted further weakening CAFO regulations.


It’s time for the DNR to stop giving in to special interests. I urge you to adopt the 56 recommendations JFAN made including:


1. Close the LLC loophole once and for all. While the DNR rightfully requires adjacent CAFOs held in separate LLC to be regulated as one larger confinement if there is common ownership of 10% or more, it doesn’t have a legal mechanism to prove ownership. But JFAN’s recommendation to require submission of each LLC’s legal Operating Agreement would resolve that issue. 

In Jefferson County at least one quarter of the CAFOs are either suspected to be commonly owned or have been identified to be so. We highly doubt Jefferson County is an anomaly in the state. Adjacent CAFOs should be required to submit their LLC’s Operating Agreements.


2. Update the antiquated and ineffective paper manure management plan (MMP) system with an online MMP database and a geospatial mapping system. Currently, the DNR doesn’t have a handle on where manure is applied, and many fields are in more than one manure management plan. An electronic system accompanied by real-time reporting when manure application takes place would eliminate the risk of overapplication.


3. Require CAFOs to have a 25-foot vertical separation distance from karst bedrock. CAFOs should not even be sited in karst terrain because of its porous nature and the potential for sinkholes to unexpectedly develop. Many rural residents in areas of karst rely on private wells for drinking water. The risk of groundwater contamination from a catastrophic failure of a concrete pit caused by an unexpected sinkhole is too great and consequential.


At the very least, an adequate vertical separation distance can provide some groundwater protection. I urge you to return the language recommended by the IEC, echoed by JFAN, that the DNR initially adopted but later rescinded because of political pressure. Put the well-being of Iowans first.


These recommendations, along with all the others made by JFAN and the IEC, not only protect public health and water quality, but they are fiscally responsible. Iowans pay dearly for costs associated with CAFOs: $6.25 - $27.5 million in direct medical expenses; $35-$167 million in indirect medical expenses; $165 for public water supply treatment, and $4 -$7.4 million for private well treatment. That doesn’t even take into account lost productivity from those suffering from illness caused by CAFOs.


It’s time for the DNR to put the needs of 3+ million people before the financial interests of the livestock industry. Adopt JFAN and IEC’s recommendations to strengthen Chapter 65’s, and do your job to protect the citizens of this state.


Sincerely yours,




bottom of page