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ACTION ALERT! Tell the DNR to Put Iowans First and Strengthen CAFO Regulations!


Strengthen CAFO Regulations Chapter 65

DNR Accepting Public Comments on Chapter 65 until 4:30 pm Friday. February 23
Public Hearing Scheduled for Monday, February 19 from 1:30 – 3:30 pm via Zoom


We have one last opportunity to make public comments to strengthen Chapter 65 of the Iowa Code, the rules and regulations that govern CAFOs, during this formal public comment period.  Since June 2022, JFAN and the Iowa Environmental Council (IEC) submitted three sets of public comments. Very few were incorporated.


Tell the DNR to do a better job protecting Iowans and our precious water resources and adopt JFAN’s and IEC’s recommendations!

Public comments are being accepted until 4:30 pm on Friday, February 23. Click here for a sample letter. Email comments to Kelli Book, DNR AFO Attorney at


Participate in a Zoom public hearing on Monday, February 17 from 1:30 – 3:30 pm. Register at to get a link.


JFAN made a total of 64 recommendations in three sets of public comments based on 19 years of experience working directly with communities on factory farm issues.


The DNR ignored 56 of them. Four small recommendations were incorporated.


An additional two were initially incorporated then rescinded, including critical language about siting CAFOs in karst terrain. The livestock industry and JFAN agreed on two logistical recommendations.


The livestock industry fared much better. Of their 56 recommendations that we identified in documents obtained from the DNR, 33 are in the latest version of Chapter 65.


Evidently, the health and well-being of  the livestock industry has priority over the health and well-being of Iowa’s 3+ million people and Iowa’s 300,000 streams.


Tell the DNR to protect the public health of Iowans and prevent further water degradation by adopting all of JFAN’s recommendations, especially the following:


1.     Get serious about closing the LLC loophole! Confirm ownership of adjacent CAFOs held in separate LLC’s by requiring CAFO owners to submit each LLC’s Operating Agreement. This is a legal document that proves ownership. A letter with a single line is not proof.


2.     Update the antiquated and ineffective paper manure management plan (MMP) system with an online database of MMPs including a geospatial mapping system to identify fields in more than one MMP. Require real-time reporting of manure applications to eliminate over application. The DNR doesn’t have a handle on where toxic hog sewage is going, and our 751 polluted waterways illustrate that.


3.    Require CAFOs to have a 25’ vertical separation distance from karst bedrock. The risk of groundwater contamination from a catastrophic failure of a concrete confinement pit in areas where sinkholes can unexpectedly develop is just too great.


The DNR adopted a modified version of this recommendation made by the Iowa Environmental Council and supported by JFAN, but the governor’s office and DNR apparently caved to political pressure from the livestock industry, and the original language, which doesn’t adequately protect water quality, was returned.


Send in  your public comments to the DNR by 4:30 pm Friday, February 23. We have a sample letter here that you can use or edit as you see fit along with a list of all 56 recommendations that were not incorporated into Chapter 65.


Sign up also to participate in a public comment period on Monday, February 17 from 1:30 – 3:30 pm by emailing Participation is limited and speakers will be given 3-5 minutes depending on the number of attendees.


Let’s flood the DNR with comments and demand that they fulfill their mission: “To conserve and enhance our natural resources in cooperation with individual and organizations to improve the quality of life in Iowa and ensure a legacy for future generations.”


Let’s tell the DNR that people and the environment come first, not the livestock industry!


Thank you for all you do,

JFAN Board of Directors


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