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Report from Monday’s Master Matrix Scoring Session for RWP, LLC


Jefferson County Courthouse

Today the Jefferson County Board of Supervisors held the initial scoring session for Mark Greiner’s Master Matrix for RWP, LLC. This is for a 2499-head expansion to the current 2499-head confinement for a total of 4998 hogs.

Mr. Greiner was present as was Rachel Rinner from Knee Deep Solutions, preparer of his Master Matrix and manure management plan. At least a dozen people attended the scoring session, almost all of whom were JFAN supporters and concerned residents, including several JFAN board members.

The meeting started off with Sandquist explaining why a public hearing wasn’t held for Bill Huber’s Daniels Site due to the timing of Dick Reed’s vacation. JFAN didn’t challenge that assertion in the meeting, not wanting to start off on an adversarial footing, however we feel that there was an opportunity to hold a public hearing for the Daniels Master Matrix that we explain here.

Rather than review each question individually, Sandquist asked for people to bring up their concerns on any of the questions in the Matrix.

JFAN President and Executive Director Diane Rosenberg conducted a detailed review of the 100+ page Master Matrix application and contested four questions totaling 80 points that she urged Jefferson County Supervisors Dee Sandquist, Lee Dimmitt and Dick Reed to deny.

While discussion took place on all the following points JFAN contested, the supervisors didn’t make any final decisions about the scoring during the afternoon session. That will be done during a meeting in September (stay tuned for a follow up email on that meeting).

The following is a summary of the discussion for each question.

Question 17 – Proposed manure storage structure is formed (30 points.)

On this question, Greiner is taking points for having a concrete confinement pit. Design, operation and maintenance plans are required for this question. Rosenberg said the maintenance plans were not adequate and discussed examples of what should be part of a plan. She also provided supervisors with a copy of the Master Matrix for an Adair County CAFO that had a more detailed plan that the DNR considered passable. Rinner countered that the operation plans included maintenance activities, but Rosenberg said even that didn’t cover many of the points she raised.

Question 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)

Rosenberg pointed out that the design plan didn’t include an engineering drawing to demonstrate the turnaround was to be constructed at a required minimum of 120 feet. Only an aerial photograph with a drawing superimposed was submitted. Sandquist said she had talked with Paul Petitti, the DNR engineer in charge of reviewing this Master Matrix, and was told an engineering plan wasn’t required.

Rosenberg countered in what was to become an ongoing theme that the supervisors have discretion at how they score the Master Matrix. She pointed out that Chapter 65 of the Iowa Code doesn’t give supervisors a clear roadmap as to how to score the application and encouraged them to score the Matrix using the highest standards. There was a lot of discussion about this general point raised by others at different times during the scoring session.

Question 24 – Facility Size is 1 to 2000 animal unit capacity (20 points)

Grenier's application says he will have 1999.2 animal units (4998 hogs). Rosenberg reported on a discussion with former DNR employee Gene Tinker whose responsibility was to educate CAFO owners and supervisors on animal feeding operation regulations. Tinker told Rosenberg that the DNR can only ask how many hogs are intended to be placed in a confinement, not how many are in there once they are delivered nor can they go into a facility and count them.

According to Mr. Tinker, the DNR knows that CAFOs are frequently stocked with 100-200 or more hogs than their application states. The DNR went so far as to work with the Attorney General’s office to address the issue. The DNR was told the laws must be changed, and there was nothing they could do.

Rosenberg acknowledged that the Master Matrix included an email from Tork Whisler of Eichelberger Farms stating RWP LLC would add only 2499 more hogs. However, she called the email insufficient and said anyone could write an email stating anything. She called for a signed contract to be submitted that would document the information that RWP LLC would indeed have 1999.2 animal units.

Greiner offered to privately show the supervisors his contract that he is receiving only 2499 more hogs. But another discussion initiated by Supervisor Lee Dimmitt ensued over the issue of trust. Dr. John Ikerd said that all Rosenberg was asking for was higher levels of documentation than has been included with the Master Matrix application. It was obvious in cases where points were challenged that the requirements were not clear or concise, meaning the supervisors have the discretion to require more than some perceived minimum documentation, he said. Ikerd commented that the supervisors seem to consistently defend the applicants’ matrix “scoring” rather than considering how best to carry out the intent of the scoring process.

Question 33 – Additional separation distance of 50’ above minimum requirement for land application of manure to the closest drinking water well or public drinking water well or well is properly closed under supervision of county health officials. (10 points)

The Master Matrix included a lot of documentation demonstrating active, inactive and plugged wells. However, Rosenberg identified two fields with former homesteads that might still have unplugged wells, providing historic aerial photographs to the supervisors as proof.

Since the question also requires that manure be injected or incorporated the same day it’s applied, the Rosenberg said there should be a signed manure application contract that outlines that, but there was none.

Rinner said that the question only pertains to the closest drinking water well to the CAFO operation, but Rosenberg disagreed saying the question is in the Manure Management Practices Section of the application and should apply to each field. She pointed out that if manure were to be applied over an unplugged well it would pollute groundwater. Again, she reminded the supervisors that they have the discretion to interpret this question since the Iowa Code doesn’t provide specific guidance.

Points for the Public Hearing THIS Tuesday Evening, 6:00 pm

Jefferson County Supervisors have said several times that they can score the Master matrix, that it’s a numerical system, and the state doesn’t provide much else for them to do. JFAN’s position is that while they don’t have a lot of options at their fingertips, they are not powerless. You can read our letter to the editor in last Thursday’s Fairfield Weekly Reader on what supervisors COULD do with regards to the Master Matrix here.

Most especially, our supervisors need to be reminded who they represent and be encouraged to score the Master Matrix using the highest standards possible. They have some discretion. They need to be encouraged to:

  • Consider the environmental, health, and quality of life impact on neighbor. 80 families live in a two-mile radius.

  • Consider the amount of manure that will be applied – 1.2 million gallons EVERY YEAR. They need to make a good decision on Question 33.

  • Ask themselves do they need to score each new Master Matrixes like every other one has been scored in Jefferson County or other counties or instead set the bar higher than where they and others have previously set it. This is the one opportunity they have to weigh in on an industry that has industrial-level impacts on communities and the environment but is not regulated like other polluting industries.

Additional point: In his Thursday, August 23 letter to the editor in the Fairfield Ledger, Supervisor Lee Dimmitt wrote the following:

“The board of supervisors could reject every application who came before us. However, if the DNR determined that the required points were met when we denied the application, the DNR could approve the permit to build anyway. At the same time, because we did not provide a legitimate scoring report, the DNR would revoke our Matrix resolution, and our participation would cease.”

This is not accurate!

If the supervisors fail a Master Matrix that the DNR deems passable, it's true the DNR could overrule the supervisors and grant a construction permit for the CAFO. The supervisors have the right to then appeal that decision to the Environmental Protection Commission.

BUT, according to a conversation JFAN had with DNR engineer Paul Petitti on Friday, August 24, the DNR would not (and have never) evoke the Master Matrix resolution if supervisors were to symbolically fail a Master Matrix as several counties have already done. They would only revoke the Master Matrix for the remainder of the year if supervisors didn't meet deadlines for returning all scoring documentation. In that case, counties would be able to opt for the Master Matrix during the following year.

Please come to THIS Tuesday’s (August 28) scoring session and encourage the Jefferson County supervisors to use their discretion and score the RWP LLC Master Matrix using the highest standards recommended by JFAN.

Thank you for all you do!

Photo credit: United Soybean Board

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