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Concentrated Animal Feeding Operations 




The Iowa Chapter has waited since September 2007 when it filed a dedelegation petition with the Environmental Protection Agency (EPA) for the Iowa Department of Natural Resources (DNR) to develop and approve rules requiring concentrated animal feeding operations – particularly swine operations – to comply with federal Clean Water Act requirements. There is now light at the end of that tunnel.

The proposed rule went before the legislative Administrative Rules Review Committee (ARRC) on October 14, the first of second examinations by the committee. If the ARRC members do nothing, the rule will become effective.

The proposed changes are required by state law and satisfy the terms of a work plan the DNR and the EPA signed in September 2013. The proposed rule changes would adopt federal regulations requiring totally roofed, concentrated animal feeding operations to comply with federal National Pollutant Discharge Elimination System (NPDES) permit requirements. The changes would also require animal feeding operations that have NPDES permits to comply with federal setback requirements for land application of manure.

Some of the history can be found below.

EPA reviewed DNR enforcement records after the dedelegation petition was filed and concluded that DNR does not adequately enforce the Clean Water Act against CAFOs that discharge waste into our waters.

EPA expected DNR to adopt rules on issuing NPDES permits to CAFOs that discharge (accidentally or on purpose). NPDES permits are one of the most important tools used to control water pollution.

The DNR hosted six public hearings and asked for public input on proposed rule changes regarding concentrated animal feeding operations.

Sierra Club Iowa Chapter wanted the rule to include DNR's building a comprehensive, user-friendly, online database of manure spills, Clean Water Act inspections and permitting so that everyday Iowans can audit the DNR's inspections and permitting decisions and hold them accountable.


EPA Representatives Meet to Discuss CAFO Permits

UPDATE: The EPA has posted its draft work plan agreement with the Iowa Department of Natural Resources.  See the draft agreement.

Region VII EPA representatives met with members of Sierra Club Iowa Chapter and Iowa Citizens for Community Improvement in Des Moines in October.  David Cozad, Regional Counsel, and Karen Flournoy, Water, Wetlands and Pesticides Division director, heard from those affected by CAFOs and answered questions.

The meeting was part of an ongoing effort to keep communication lines open between EPA and members of three organizations who filed a dedelegation petition in September 2007 that would strip the Iowa DNR of its authority to manage federally mandated water permitting programs.  

EPA Region 7 in Kansas City also accepted comments on  regulation of Concentrated Animal Feeding Operations (CAFOs) in Iowa. Officials wanted to hear from members of the public about the problems with CAFOs and how CAFOs can be better regulated to protect the public and the environment.  

Read the comments submitted by Sierra Club Iowa Chapter, Iowa Citizens for Community Improvement and the Environmental Integrity Project, the three organizations that filed the dedelegation petition that prompted the investigation.  

Environmental Protection Agency Report Validates Local Activists Complaint That Iowa DNR Has Failed To Adequately Regulate Factory Farm Water Pollution

On July 12, 2012, the federal Environmental Protection Agency (EPA) released a long-awaited report, finding that critical elements of Iowa’s program to regulate water pollution from factory farms, or “Concentrated Animal Feeding Operations” (CAFOs) fail to meet minimum federal requirements.  The report is a response to a petition filed in September 2007 by Iowa Citizens for Community Improvement (Iowa CCI), Environmental Integrity Project (EIP) and the Sierra Club, which alleged widespread failures to regulate illegal factory farm discharges and asked EPA to withdraw Iowa’s authority to run the state’s Clean Water Act permitting program. 

EPA’s findings include:

  • Iowa a DNR does not issue permits to factory farms when required by the Clean Water Act.  

  • Iowa DNR does not have an acceptable system to figure out which factory farms need Clean Water Act permits in the first place, and has an inadequate inspection program.

  • Iowa DNR failed to act in response to CAFO Clean Water Act violations or failed to follow its own response policy in nearly half of cases reviewed by EPA.

  • Iowa DNR does not assess adequate penalties following CAFO violations of the Clean Water Act.

See EPA’s Preliminary Results of an Informal Investigation of the National Pollutant Discharge Elimination System Program for Concentrated Animal Feeding Operations in the State of Iowa.


DNR responds to EPA informal investigation on permitting

On September 11, 2012, the Iowa Department of Natural Resources (DNR) issued its response to the Environmental Protection Agency’s (EPA) July 2012 informal investigation of the DNR’s animal feeding operations permit program (see article below).  

DNR has agreed in its response to include:

  • Commencing the rulemaking process by November 1, 2012

  • Recommending an additional 13 full-time employees and associated funding for fiscal year 2014

  • Revising its Environmental Management System (EMS) and associated enforcement documents to properly account for penalty calculations and submit to EPA by January 31, 2013

  • Including better documentation in its files on what is witnessed during inspections

  • Pursuing the planned rule modifications as part of the rulemaking regarding NPDES permitting for confinements described in the EPA report. The DNR will also update nutrient management plan templates and application forms

  • Revising its construction permit application form to include the predictive modeling requirement

See DNR’s response .

See the news release partner organizations distributed on September 12, 2012.


Protesting Tax Assessments

The Vermont Law School, in conjunction with contact persons in various states, has published state-specific handbooks for challenging property tax assessments based on lowering of land value because of nearby CAFOs. The thinking is that if local governments feel the effect of reduced tax revenue because of lower property assessments, they will be more active in helping us fight CAFOs. Click here for the Iowa handbook. Please feel free to copy this and distribute far and wide. Anyone interested in organizing a training session, or if you have any other questions or comments, contact Wallace Taylor at 319-366-2428 or wtaylor784(at)


Unregulated Industrial Farm Air Pollution at Some Sites Now Dirtier than America's Most Polluted Cities


Clean Air Act Needed in Countryside, Not Just in Metro Areas:  Citing Health Concerns, New Report Calls For End of Pollution Exemptions for Livestock Operations; Major Pollution Exposures Detailed At Mega-Farming Operations Across U.S., Including CA, IN, IA and NC.


New federal and industry data show that the air at some factory farm test sites in the U.S. is dirtier than in America’s most polluted cities and exposes workers to concentrations of pollutants far above occupational safety guidelines, according to a new report from the Environmental Integrity Project (EIP).   While the measurements were taken onsite at factory farms, the pollution levels are high enough to suggest that those living near these massive livestock operations also may be at risk.  Estimated emission levels for some pollutants were higher at some test sites than amounts reported by large industrial plants.


In outlining needed action steps, the EIP report concludes that the problem is sufficiently grave that it should lead to the  overturning of a 2008 Bush Administration “backroom deal” that gave concentrated animal feeding operations (CAFOs) amnesty from federal pollution reporting rules.


The new EIP report states: “Five years ago, EPA suspended enforcement of air pollution laws against CAFOs until the study was complete, and in 2008, EPA exempted CAFOs from most pollution reporting requirements altogether.  But the study shows that many CAFOs pollute in quantities large enough to trigger emission reporting laws that have applied to most other large industries for decades, and that Clean Air Act protections may be warranted to protect rural citizens … [The new] research confirms that the large CAFOs, or factory farms, that dominate the nation’s meat industry are major sources of ammonia emissions and other dangerous air pollutants.” 


Among the EIP report’s key findings:   


·     Fine particle pollution can damage the lungs and heart and cause premature death.  The EPA/industry study measured levels of particle pollution well above Clean Air Act health-based limits at some sites: Fine particle pollution was much higher than the federal 24-hour exposure limit on the worst days at 6 of 15 study sites, including 5 poultry operations in California, Indiana, and North Carolina, and a Washington dairy.   Peak 24-hour exposures at two henhouses in California and one in Indiana were more than three times higher than EPA’s 35 microgram standard. 


·     Ammonia can damage the respiratory system and is life-threatening at high concentrations. Based on sampling results, 11 of 14 CAFOs in the study emit more than 100 pounds of ammonia on average days, which triggers pollution reporting requirements for non-livestock industries.  Some CAFOs emitted thousands of pounds on their worst days.  These industrial-scale emitters include hog CAFOs in Indiana, Iowa, Oklahoma, and North Carolina, dairies in Indiana, Washington, and Wisconsin, and egg layer or broiler chicken facilities in California, Indiana, and North Carolina.


·     Hydrogen sulfide also causes respiratory symptoms, damages the eyes, and is fatal at high concentrations.  Federal right-to-know laws also require companies to report hydrogen sulfide emissions that exceed 100 pounds per day.  While oil refineries are a recognized source of hydrogen sulfide, the data suggest that some large hog and dairy CAFOs release comparable amounts of the same pollutant. Texas has established an enforceable air quality standard of 80 parts per billion of hydrogen sulfide averaged over half an hour, due to the pollutant’s effects on those downwind.  The air around 7 hog and dairy sites – nearly half of the confinements studied – exceeded this level for entire days during the study.  Long-term ambient levels of hydrogen sulfide were also significantly higher than EPA’s reference concentration of 1 ppb at most study sites.”


The full EIP report is available online.


Commenting on the findings, Tarah Heinzen, attorney and report author, Environmental Integrity Project said, “No other major industry in the U.S. would be permitted to pollute at these levels without EPA oversight.   Our findings indicate that citizens near factory farms may be breathing unsafe levels of small particle pollution, ammonia and other toxic gases, and that EPA's failure to regulate air pollution from these operations may threaten public health.  It is time for EPA to overturn the Bush Administration’s backroom deals with the factory farm industry and begin applying consistent federal standards to all major polluters.”

“The findings of the EIP analysis corroborate a large body of scientific evidence,” said Keeve E. Nachman, PhD, MHS, program director, Farming for the Future, Johns Hopkins Center for a Livable Future Bloomberg School of Public Health.  “Animal production sites have been repeatedly demonstrated to release a wide spectrum of particulate and gaseous contaminants of concern; exposures to contaminants measured in the NAEMS study have been linked to a spectrum of adverse respiratory and mental health effects.” 


Brent Newell, general counsel, Center on Race, Poverty & the Environment, said, “President Obama made a campaign promise to protect rural Americans from animal factory air and water pollution.  If EPA accepts this industry-tainted junk science and implements this Bush EPA policy, then the President will break that promise and sacrifice the health of rural Americans.”


Lori Nelson, a Bayard, Iowa resident with 5,000 hogs in two factory farms within one-half mile of her house, said, “Factory farms need to be held accountable for their air pollution and should be regulated by the Federal EPA under industry guidelines under the Clean Air Act.  Communities, and residents in close proximities, such as me, should have the right to know what is in the air we breathe.  The EPA needs to reverse its regulation that exempts factory farms from reporting toxic ammonia and hydrogen sulfide emissions.”




The EIP report spells out a number of needed to steps to remedy CAFO pollution problems:


·         Rescind the 2008 rule that arbitrarily exempted CAFOs from most of the pollution reporting requirements in two federal environmental laws.


·         Contract with independent experts to peer-review the industry’s analysis and establish an independent committee to oversee the emission estimating methodology process.  This process will enable CAFOs to begin estimating their pollution based on the results of EPA’s study and existing scientific research. The committee should include representatives from the public health, environmental justice, and environmental communities.


·         Re-calculate daily and overall emissions averages with all negative values and other clearly erroneous data points removed, and use the resulting total emissions to determine whether CAFOs of a certain size should be regulated under the Clean Air Act.


·         Use the study’s minute-by-minute monitoring data to calculate short-term pollution levels as well as 24-hour averages, and determine whether spikes in pollution in either emissions or the air surrounding CAFOs pose a threat to public health.


·         Drafting regulations necessary to use the Clean Air Act to protect public health from ammonia, volatile organic compounds, and other factory farm pollution.




With industry support and funding, Purdue University conducted the two years of air quality monitoring at 15 livestock confinement sites, 9 livestock waste lagoons, and a dairy corral in nine states, measuring background concentrations and emissions of ammonia, hydrogen sulfide, particulates, and volatile organic compounds (VOCs).  EPA approved Purdue’s methods and supervised the study.  In January, Purdue presented the results to EPA as a series of summary reports and data sets that EPA made available to the public without further analysis.  The Environmental Integrity Project analyzed these initial reports, comparing CAFO air pollution with established health standards and emissions reporting rules to assess the need for increased public health protections from factory farm emissions. 


Manure on Frozen Ground 

The Department of Natural Resources adopted amendments to update rules to conform with statutory amendments in 2002 (SF 2293), in 2006 pertaining to open feedlot stockpiles (SF 2369), and in 2009 pertaining to dry manure stockpiling (HF 735), application of manure on snow covered and frozen ground (SF 432, Division I) and dry bedded confinement feeding operations (SF 432, Division II). 

The rules, which were approved in November 2010 by the Iowa Environmental Protection Commission, were drafted from legislation passed in the 2009 session by the Iowa Legislature and signed by Gov. Chet Culver.

The rules limit the application of liquid manure on frozen ground from February 1 to April 1 and on snow-covered ground from December 21 through April 1. The measure provided exemptions for farmers facing unusual circumstances, such as weather or storage capacity limits, to apply manure under a plan approved by the DNR. The legislation exempts livestock operations that are 500 units or smaller.

The proposed DNR rules took effect in the winter of 2010-11.



Updated 10.15.14


Iowa Chapter Documents:


Report Card for CAFOs: An Industry That Has Failed  


CAFOs and Your Property Taxes

Why Industrial Livestock Factories Want to Silence Whistleblowers

Sustainable Farming and Eating


Contaminated Eggs: A Policy for Health and Safety Improvement


About CAFOs



(courtesy Iowa DNR)

Animal Feeding Operations In Iowa
This map shows known animal feeding operations in Iowa greater than 200,000 lbs. live weight. They are broken out into permitted facilities – those with a construction permit; non-permitted facilities – those facilities required to submit a manure management plan exclusive of those with a construction permit; and registered open feedlots. Low-Res Size: 197KB High-Res Size: 1,047KB

Animal Feeding Operations in Iowa and Groundwater Vulnerability - Aquifers and Wells
The animal feeding operations are laid over groundwater vulnerability regions. The correspondence between the feeding operations and aquifers or wells is visible. The various background colors indicate the level of vulnerability to pollution from surface contaminants. Low-Res Size: 231KB High-Res Size: 4,437KB

Animal Feeding Operations in Iowa and Groundwater Vulnerability - Special Areas
Animal feeding operations are here shown against locations of sinkholes and agricultural drainage wells. Because sinkholes and drainage wells are more direct conduits to groundwater, surface pollutants may reach groundwater more rapidly and at higher concentrations. Low-Res Size: 223KB High-Res Size: 1,137KB

Animal Feeding Operations in Iowa and Distribution of Reported Manure Spills
The animal feeding operations are here shown in conjunction with human-caused spills. The spills are broken down by type, and manure spills for the 2000-2001 period are shown with circles of increasing size to indicate the number of spills at a location. The insets show a 3.5 mile radius around fishkill locations. These illustrate the relationship between AFOs, human-caused spills, and fishkills. Low-Res Size: 223KB High-Res Size: 1,135KB

Animal Feeding Operations in Iowa and Impaired Waters (TMDL Program)
This map was designed to show the distribution of animal feeding operation and human-caused spills among impaired watersheds (as designated by the Total Daily Maximum Load program). A discussion of the watershed boundaries is included on the map. Low-Res Size: 269KB High-Res Size: 3,841KB<

Animal Confinements in Iowa by Number of Animal Units
This image shows the locations of known confinement feeding operations by the size of operation measured in animal units. Animal units are determined by multiplying a factor times the number of animals. For example, the factor is 1 for beef cattle and immature dairy cattle, so a confinement with 500 beef cattle would have 500 animal units. The factor is 0.4 for swine that weigh more than 55 pounds, so a confinement with 4,000 finishing swine would have 1600 animal units. Turkeys weighing less than 7 pounds have a factor of 0.0085, so 100,000 turkeys would have 850 animal units. Low-Res Size: 285KB

Animal Feeding Operations in Iowa and Reported Fish Kills Attributed to Human Causes
In this map, the distribution of AFOs and fishkills is shown on the largest map with a 3.5 mile radius around human-caused fishkills. The percentage of the total number of fish killed between January 1981 and November 2001 attributed to certain causes is broken out in an inset. According to records kept by the DNR, the number of fish killed for the stated period as a result of manure spills is far higher than any other category (61%). Low-Res Size: 257KB High-Res Size: 2,596KB

Non-Permitted Animal Feeding Operations in Iowa
This image shows the locations of known animal feeding operations required to submit manure management plans to the DNR, exclusive of permitted operations. A confinement is required to submit a manure management plan if it has a live weight over 200,000 pounds. The data is current as of December, 2001. Low-Res Size: 284KB

Permitted Animal Feeding Operations in Iowa
In this image, the locations of those animal feeding operations requiring a permit are shown. Facilities requiring a permit are those with certain waste control structures, and those over a designated live weight. The data is current as of April 2001. Low-Res Size: 232KB

Registered Feedlots in Iowa
Those feedlots registered with the DNR are shown here. To date, this has been a voluntary process, so the distribution does not reflect the complete distribution of feedlots. The data is current as of June 2001. Low-Res Size: 241KB



Grounds for Confusion. The Iowa Fiscal Partnership's report demonstrates how Iowa distorts farm property assessments.  According to the report, farm buildings and farmland need to be assessed and taxed separately as a first step toward a more understandable and fair system of assessing Iowa farm property.  Read the executive summary or the full report.

Putting Meat on The Table: Industrial Farm Animal Production in America.The Pew Commission on Industrial Farm Animal Production was formed to conduct a comprehensive, fact-based and balanced examination of key aspects of the farm animal industry.



Iowa Select Farms Undercover Video: Mercy For Animals Footage Shows Inside One Of Nation's Largest Pork Producers (GRAPHIC)

CNN Features Bills Regulating Videotaping Animal Factories

HF589, which passed the Iowa House on March 17 and is on the Senate debate calendar, would prohibit videotaping animal factories.  See CNN's story about Iowa's bill and attempts by Minnesota and Florida to pass comparable legislation.


A New Strain of Drug-Resistant Staph Infection Found in U.S. Pigs

A strain of drug-resistant staph identified in pigs in the Netherlands five years ago, accounting for nearly one third of all staph in humans there, has been found for the first time in the U.S.

Read the Scientific American article here...

Livestock Manure Stinks for Infant Health

Science News reports that a new study, reported in the February American Journal of Agricultural Economics, finds a positive relationship between increased livestock production at industrial farms and infant death rates in the counties where the farms reside.  Find out more here...

Human Health, Community and Environmental Impacts of CAFOs

A scientific conference and workshop was held in 2004 in Iowa City, Iowa, that brought together environmental scientists from North America and Europe to address major environmental health issues associated with concentrated animal feeding operations (CAFOs) in large, industrialized livestock production facilities.

Workgroup reports outline the state of the science and public health concerns relating to livestock production.  Read our summary of the report here...