JFAN'S Comments to Jefferson County Board of Supervisors and Iowa DNR Regarding Daniels Site Master Matrix
President and Executive Director
JFAN reviewed and analyzed the Daniels Site Master Matrix and found four questions do not deserve the points taken for a total of 70 points we strongly urge the Jefferson County Supervisors to deny.
19. Proposed confinement site has a suitable truck turnaround area so that semitrailers do not have to back into the facility from the road. – 20 points
The design plan provided is not a suitable drawing to demonstrate that the truck turnaround will be the required 120 feet in diameter. The drawing provides no measurements except for what is written in the comments section. An engineering drawing with exact measurements should have been supplied to receive these points. It was not and what is provided is insufficient.
20 points should be removed.
24. Facility Size – 2001–3000 animal unit capacity – 10 points
As per discussions with former DNR employee Gene Tinker, the DNR can only ask how many hogs are intended to be placed in confinement. The DNR can’t ask how many are actually held in the confinement nor can they go in and count them. According to Mr. Tinker, the DNR knows that frequently CAFOs hold more hogs than an application states and the agency went as far as working with the Attorney General’s Office to address this issue.
Mr. Huber’s application says there will be 2998.0 animal units (7497 hogs) in the Daniels Site. But we don’t have documentation to prove that is actually the case. Therefore, to prove the Daniels Site will actually hold 2998.0 hogs (7,497 hogs) and not 3000 animal units (7500 hogs) or more, which would yield no points for this question, documentation from the hog supplier should be included, such as a contract.
There is none. Therefore, points should not be granted for this question.
10 points should be removed.
26. Liquid or dry manure(e) Injection or incorporation of manure on the same day it is land-applied. - 30
The Master Matrix requires a design, operation, and maintenance plan for this question. While the Master Matrix provides several papers on manure application, none of it meets the purpose of design, operation or maintenance plans.
There are no contracts supplied between the Daniels Site and any manure hauler and applicator that demonstrate that there is in fact a plan and an agreement to inject or incorporate manure the same day it’s applied. All we have is a statement in the Master Matrix that it will be done in this manner.
Further, one of the fields is already in two manure management plans and a third is in three. The contract should also stipulate that only the manure from the Daniels site would be applied on those fields in designated years so there is no over application. We don’t have evidence of that.
30 points should be removed.
33. Additional separation distance of 50 feet, above minimum requirements (0 or 200 feet, see below), for the land application of manure to the closest private drinking water well or public drinking water well - OR well is properly closed under supervision of county health officials. – 10 points
Two of Mr. Huber’s fields that will receive manure show evidence of homesteads dating back to the 1960’s that are no longer there. The Leeland Horras-Veo Site map from 1960 shows two homesteads were present along a road that no longer exists.
The Leeland Horras – Watson map from the 1960s shows a homestead along Nutmeg Avenue that is also no longer there.
Well closing documentation is provided for the location of the CAFO on the Daniels North/South fields. But there is no well closing documentation for these other two fields, which undoubtedly had wells to support those homesteads.
10 points should be removed.
Conclusion and Recommendation
The Daniels Site confinement is the largest CAFO to be proposed for Jefferson County with the potential to significantly impact the environment, local community, and local farms. Over 2.2 million gallons of liquid manure will be applied locally. Therefore, all elements of the Master Matrix should be handled with the highest standards intended by law.
JFAN found four questions that don’t meet those standards. We highly urge the Jefferson County Supervisors to deny the points for those questions and deduct a total of 70 point from this application.
That would give the Daniels Site a failing score of 435 points.
Further if the supervisors have any question as to whether the question merits the points, we strongly recommend they do not grant the points because then the Iowa DNR can review the Daniels Site Master Matrix.
JFAN urges the Jefferson County Supervisors to fail the Daniels Site Master Matrix.