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Letter to the Editor: Executive Order Number Ten Is a Threat to Iowans


Published in the March 8 edition of the Southeast Iowa Union


Governor Reynolds’ Executive Order Number Ten will have significant and far-reaching consequences for Iowa and deserves much greater public awareness and attention. It establishes a moratorium on administrative rulemaking and requires every state agency, board, and commission to conduct a comprehensive overhaul of the Iowa Administrative Code in order to promote private sector development.

While this directive will greatly affect every state agency, I am especially concerned about its impact on the Iowa Department of Natural Resources (DNR) and the agency’s ability to protect Iowans’ health and safety particularly with regards to regulating concentrated animal feeding operations (CAFOs).

The Iowa Administrative Code is comprised of rules and regulations that interpret and implement all statutory laws passed by the Iowa State Legislature. The Executive Order bans rulemaking until a retrospective evaluation, including a rigorous economic cost-benefit analysis, of each existing administrative rule is undertaken.

Further, the order directs each agency to rewrite the rules. From scratch. Within one year.

Duplication of rules and regulations do exist within the Iowa Administrative Code, and review is not without merit. However, every Iowa agency is already charged with conducting five-year reviews of each chapter to eliminate outdated, redundant, inconsistent, or incompatible rules.

This blanket directive has the potential to throw our state government into chaos, fostering the financial gains of private business at the general public’s expense.


The DNR, chronically underfunded and unstaffed for years, administers 349 chapters of the Code and manages many areas crucial to environmental and public health.


Chapter 65, which regulates CAFOs, is 220 pages. With an additional 348 chapters, is it even possible for the DNR to review, comprehensively analyze, and rewrite each and every rule it oversees within 12 months while still continuing its critical functions of oversight and enforcement? The DNR is already challenged to investigate all CAFO complaints in a timely manner.

The order requires rules and regulations to be eliminated or simplified without compromising Iowans’ health and safety. But this directive does just that and flies in the face of the DNR’s mission, “to protect the quality of life in Iowa.” We already have weak CAFO rules and regulations that compromise water quality and public health. CAFO rules need to be strengthened, not diminished.

We’ve limited confidence that an agency run by political appointees favorable to the pork industry can conduct a fair cost-benefit analysis that doesn’t benefit the CAFO industry at the expense of public health and further water quality deterioration.

We’re especially concerned about the long-term threat to vulnerable communities and our already polluted waterways if rules and regulations are eliminated or weakened. Rules and regulations have purpose: they guard against harm.

At the very least, the DNR should be exempt from Executive Order Number Ten.

Iowans deserve a government that puts the health and well-being of its residents before the financial gains of the CAFO industry. If you’re also concerned, the Governor’s Office needs to hear from you.



Diane Rosenberg

Executive Director, Jefferson County Farmers & Neighbors, Inc.

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UPDATE: At the beginning of March the Governor's office issued its schedule for agencies to carry out Executive Order Number Ten. It would be very difficult to know what agencies are scheduled for which chapter from this list unless you are familiar with the agencies and their corresponding chapters. Named the "Red Tape Review", you can view it here. Chapter 65 is scheduled for this year. We are continuing our conversation about Chapter 65's five-year rules review with the DNR.


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