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JFAN Calls Out DNR's Failure to Protect Iowans in Final Set of Chapter 65 Public Comments

Updated: Mar 15

Protesting Weak DNR Regulations
Photo: F. Hiatt

In February, JFAN submitted a final set of Chapter 65 public comments to the Iowa Department of Natural Resources (DNR) urging it to strengthen factory farm regulations. It was the fourth set of recommendations JFAN provided during a two-year rule-making process. The DNR ignored 66 of our recommendations while incorporating more than half of the livestock industry's points.

JFAN's final comments called out the failure of the DNR to protect the public health of Iowans and the state's water quality and, instead, prioritizing the financial interests of the multinational, multibillion dollar livestock industry.

The following is the introduction to our final set of public comments.

The DNR is tasked with an important mission that directly affects every citizen in Iowa:


“To conserve and enhance our natural resources in cooperation with individuals and organizations to improve the quality of life in Iowa and ensure a legacy for future generations.”


Pure and simple, it’s the DNR’s duty to protect the state’s natural resources for the people of Iowa. 


Jefferson County Farmers & Neighbors, Inc. works closely with communities in Jefferson County and in other Iowa counties to address the factory farming issues they face. Our 19 years of experience gives us firsthand knowledge and insights as to how the CAFO rules and regulations affect water quality, public health, and quality of life.


This experience guided the recommendations we offered in three sets of public comments in October 2022, June 2023, and September 2023. They aimed to improve the Iowa code to better “improve the quality of life in Iowa and ensure a legacy for future generations,” something the DNR is not currently achieving.


Therefore, it is disappointing and troubling that the DNR rejected most of the recommendations JFAN proposed.


Of the 72 recommendations JFAN made since 2022, five mostly small recommendations were incorporated. An additional three were initially incorporated then later rescinded. (Changes incorporated at the recommendation of the Iowa Environmental Council concerning karst terrain – modified from their original recommendations – were also initially incorporated than removed.)


The agricultural industry and JFAN agreed on two logistical recommendations: returning the definitions to Chapter 65 and hyperlinking the code to the (unfortunately) removed language incorporated by reference.


A total of 66 recommendations were ignored. These are common sense recommendations that would address weaknesses in the regulations in order to better protect water quality and public health. They were made based on years of experience working with people in rural communities and observing how the regulations currently fail Iowans, fail to protect our waterways, and provide significant advantages to the livestock industry – a consequential industry for all of Iowa.


Unfortunately for the people of Iowa,  it’s evident that the DNR favors the health and wellbeing of the multibillion-dollar, multinational livestock industry over the health and wellbeing of Iowa’s 3 million residents and its 300,000 waterways.


According to a May 2023 document obtained from the DNR through a Freedom of Information Act request, we learned the producers group submitted at least 52 recommendations. They resubmitted this document in September 2023 and highlighted several points they still wanted adopted. The DNR replied, “I’m pretty sure we did some of the things they are still questioning.”


Yes, the DNR did. Of the 52 recommendations we are aware of, 33 were incorporated into this latest revision of Chapter 65.


Executive Order Number Ten also adversely impacted the revision of Chapter 65 by calling for a reduction of restrictive language, removal of language found in the corresponding statute to be incorporated by reference, and a prohibition of strengthening current rules and regulations.


Not only does this create a disjointed, less usable version of Chapter 65, it also poses great environmental harm because no rule or regulation could be made more stringent than what is already in the Iowa Code however much that may be needed for the public good.


We already see directly see the influence EO10 had on the removal of initially adopted karst language that would better protect water quality and reduce the risk of Iowans drinking water high in nitrates from well water contamination.


EO10 is unjust and a public health threat that benefits no one from the multibillion-dollar multinational livestock industry.

[The State Legislature is currently considering a bill that would permanently prohibit the DNR from strengthening CAFO rules and regulations. Learn more here.}


JFAN supports the comments submitted by the Iowa Chapter Sierra Club on the damaging impacts, and unconstitutionality, of Executive Order Number Ten.


It is very clear from the direction both the DNR and the Governor’s Office currently takes that this agency will never fulfill its mission and that water quality and public health are low on the list of DNR and state government priorities. This is unacceptable.


The DNR can remedy this by changing its priorities and taking significant action to correct the weaknesses in CAFO rules and regulations during this last revision of Chapter 65.


Our final set of public comments urges the DNR to live up to its responsibilities: make public health and water quality a priority over the financial interests of the livestock industry.


We have included a list of the 66 recommendations not incorporated into Chapter 65 that we believe would help reduce the pollution risks of animal feeding operations as well as the language we recommend for each. We urge you to adopt them.



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