Comments to Jefferson County Board of Supervisors and Iowa DNR Regarding
Hill View Site #2 Master Matrix
Diane Rosenberg, President and Executive Director
John Ikerd, JFAN Board Member
Francis Thicke, JFAN Board Member
JFAN reviewed and analyzed the Hill View Site #2 Master Matrix and found four questions do not deserve the points it took.
Question 5. Separation distance of 300 feet or more from the proposed confinement structure to the nearest thoroughfare.
The measurement of the CAFO to the road is 302 feet. Therefore, the DNR needs to carefully check this measurement from where the stakes are placed to make sure it’s eligible for the 30 points it takes.
However, the question of the accuracy of the stakes and what means are provided to accurately ensure it will indeed be 302 feet away should be carefully considered in awarding the 30 points. It should be noted that the DNR will not make another site visit to ensure the distance of the building is the 302 feet that is claimed when it’s actually constructed.
Question 17. Proposed manure storage structure is formed.
The plan says the maintenance will be minimal but it does not say how often the pit will be checked for cracks in the concrete, and how it would be checked. The plan doesn’t give information as to how quickly problems will be reported and resolved. The plan does not give information as to which contractors would be called upon or at least provide a listing of possible contractors.
Cracking of manure pit concrete can release manure into surface and/or groundwater. If that happens, it is important that the problem be fixed quickly. The plan should detail preparedness for that possibility. The information presented is insufficient and therefore does not deserve 30 points.
Question 24. Facility size.
According to a letter included with the Master Matrix from Tim Messenger at PSI, the engineering company for Hill View Swine Site 2, the CAFO has the capacity to hold a total of 1860 animal units (4650 hogs). But the construction application and manure management plan is only for 1488 animal units (3270 hogs).
Considering the expense of building a confinement, why would Tom and Jacob Adam construct a larger building that can hold more animals if they do not intend to use it? How would we know if the number of hogs would be increased and the MMP adjusted if the CAFO owner is not required to report on the manure management plan (MMP) but once a year? These records are confidential the rest of the time. How do we know they will report the increase to their concerned neighbors who are already suffering the ill effects of nearby CAFOs?
While it’s not valid to take off points for this question, it does point out that over time there may be more hogs and more manure spread than is current claimed, and it’s important for neighbors to be aware of this.
Question 26. Liquid or dry manure (choose only one subsection from subsections "a" - "e" and mark one score in that subsection).
Thirty points were taken for injecting manure the same day it is land applied.We have no proof that there will be same day injection. There are no contracts or written agreements with a manure hauler that the manure will indeed be injected as indicated in the manure management plan or incorporated on the same day if it may be spread. We just have a check mark on an application form. This could potentially have a significant negative impact on the environment if it is not followed. Documentation is insufficient, and 30 points should not be given.
Points denied for three questions (5, 17 and 26) would result in a 90 point reduction and a failing score of 410 points.
Hill View Swine LLC Trucks Not Following Traffic Rules
JFAN received a phone call and follow-up social media message from a neighbor of Hill View Swine LLC, the Adam’s first CAFO located ¾ mile east of the new proposed site, who said she is opposed to all their hauling equipment not following traffic rules. She said when manure is being hauled to fields with tankers 24 hours a day for three days, the trucks often do not stop at the four-way traffic stop sign. She said children are in the area, and she expressed much concern. This neighbor spoke to Tom Adam about the situation but was unsatisfied with the result of their conversation.
Construction Permit Application Form Missing Important Documentation
On the Construction Permit Application Form, Page 5, Item 5 SUBMITTAL REQUIREMENTS – “The proposed confinement feeding operation structure will be or will use a formed manure storage structure. Check one of the following boxes.” In the form Box A.5. Is checked – “None of the above information. Use Submittal Checklist No. 1 (page 10).” This information is not included. There is no page 10.
Construction Design Statement Missing Important Documentation
On the Construction Design Statement, Item 3 – Construction Design Standards, Page 3, Item C – “Details of the proposed design”: Box b was checked. It requires information on soil classification which is not provided. Tables D3 and D4 on pages 7-8 are to be supplied under certain conditions with regards to the soil referenced, which this CAFO meets. There are no Tables D3 and D4 provided.
Wind Direction in Jefferson County – Wind is not always out of the SW.
At the public hearing, Jacob Adam said the wind primarily comes out of the SW and the nearest home northeast of the CAFO site is 1.3 miles away to the northeast. As you can see from this wind rose map http://windhistory.com/station.html?KFFL, the wind primarily comes out of the south in the summer months and even more strongly from the northwest in the winter months. But wind comes from any direction during the entire year.
According to the CAFO map provided with the Construction Permit Application, the closest neighbor is 2232 feet west of the site, the closest northern neighbor is 4425 feet away and the closest eastern neighbor is 3740 feet from the site. All these measurements are considerably less than 1.3 miles away as Jacob Adam claimed at the public hearing and within a one mile radius. Neighbors living within one mile of a CAFO experience a greater burden of noxious odors emanating from a hog confinement.
There are a multitude of reasons why more confinements in Jefferson County would erode the environment, public health and quality of life of Jefferson County residents, many of which you heard at the public hearing and that we will speak of at tomorrow’s scoring session. As a county board of supervisors you may be forced to pass the Master Matrix if you feel it has enough points to pass. The state does not give counties local control, and the Master Matrix is a deeply flawed system that doesn’t give you much latitude to protect the Jefferson County community. It hobbles your ability to adequately safeguard the very individuals you are elected to protect.
But as a county board, you do have the authority to deny the Master Matrix and construction permit application on other grounds according to the Construction Evaluation Resolution that you sign every year.
Many state counties have failed a Master Matrix/Construction Permit Application that would have passed on points – at least 8 counties last year - to make a statement to the State Legislature and Governor that our present regulatory system is deficient and unacceptable. You can do the same.The DNR will likely pass this application in spite of your denial, but you would be taking a stand representing the majority of Jefferson County residents who do not want to live in a county where CAFOs proliferate and may destroy the county’s quality of life, public health and economic vitality.
The Washington Post recently published an article that finds animal agriculture accounts for 17,900 deaths every year, more than the burning of coal. You can read about it here. CAFOs are a very real threat to Jefferson County residents.
Therefore, if you feel you must pass the Master Matrix on the score itself, we urge you courageously deny this application today to make a statement that the Master Matrix and Iowa CAFO regulatory process needs to be completely overhauled in order to take the well being of the community, public health, and environmental into consideration.
Thank you for your consideration.