Iowa officials formally unveiled a new strategy yesterday "to assess and reduce nutrients delivered to Iowa waterways and the Gulf of Mexico." As the Des Moines Register's Perry Beeman reported last week, the policy related to farm runoff was drafted without input from key Iowa Department of National Resources personnel. Instead, it closely resembles positions advocated by the Iowa Farm Bureau Federation.
The best time to roll out a policy that goes against the public interest is when few people are paying attention. Citizens will have only 45 days to comment on the new Iowa Nutrient Reduction Strategy. Most of the comment period falls during the Thanksgiving to New Year's holiday season. More details are below.
Beeman's report provides essential background to understanding the Iowa Nutrient Reduction Strategy. Details and supporting documents about the new policy are available here on Iowa State University's website.
The Mississippi River/Gulf of Mexico Watershed Nutrient Task Force was established in 1997 to coordinate activities to reduce the size, severity and duration of hypoxia in the Gulf. Hypoxia is a large area of low oxygen that can't sustain marine life. Nutrients that lead to algae growth are the main culprit.
In its 2008 Action Plan, the task force called upon each of the 12 states along the Mississippi River to develop its own nutrient reduction strategy.
Working together, the Iowa Department of Agriculture and Land Stewardship, the Iowa Department of Natural Resources, and the Iowa State University College of Agriculture and Life Sciences developed this proposed strategy.
The Iowa strategy outlines a pragmatic approach for reducing nutrient loads discharged from the state's largest wastewater treatment plants, in combination with targeted practices designed to reduce loads from nonpoint sources such as farm fields. This is the first time such an integrated approach involving both point sources and nonpoint sources has been attempted.
This proposed strategy is the beginning. Public input will be considered before the strategy is finalized and as operational plans are developed. This is a dynamic document that will evolve over time as new information, data and science is discovered and adopted.
Iowa DNR officials drafted the part of the new policy related to "point sources" (wastewater treatment plants), but Iowa Department of Agriculture and Land Stewardship personnel wrote the policy on farm runoff. They lifted language almost verbatim from Iowa Farm Bureau Federation documents and shut out people with expertise on water quality.
Susan Heathcote, the [Iowa Environmental] council's water program director, said the DNR shared detailed information on plans for sewage plant improvements with the council last year. By comparison, she said the agriculture department revealed little about its plan for limiting farm runoff, saying only that programs would be voluntary. The environmental council, a key player in many water quality policy initiatives, hasn't been asked for input since, she added.
Jeff Berckes, who runs the DNR's runoff-prevention program, said the agriculture department did not consult him or his 11 staffers about its portion of the plan, which seem focused on maintaining the status quo.
He said the message seemed to be: "We're willing to keep doing what we've been doing."
It also appears the agriculture department's efforts to keep its draft under wraps extended even to the EPA, which started the debate in the first place.
Emails dated Nov. 9 and obtained by the Register suggest that EPA staffers were exasperated by the department's attempts to ensure secrecy.
In one email, Leah Medley of the EPA's regional water office in Lenexa, Kan., told a DNR employee that the only access she'd been given to the draft report was through a secure and restricted website. "It can't be printed or copied and is password protected!" she noted of the draft report.
Notably, the policy asks farmers to take "voluntary" steps rather than calling for any new regulations on runoff. Excerpt from Governor Terry Branstad's press release of November 19:
Iowa Gov. Terry Branstad today joined Iowa Secretary of Agriculture Bill Northey and Director Chuck Gipp from the Iowa Department of Natural Resources and Dr. John Lawrence from Iowa State University to announce the release of the Iowa Nutrient Reduction Strategy for public comment.
"Iowans care about our natural resources and want to protect them for future generations." Branstad said. "This strategy keeps us at the forefront of using voluntary, science-based practices to improve water quality in our state, and is an important step forward." [...]
The Iowa Department of Agriculture and Land Stewardship, Iowa Department of Natural Resources (DNR) worked with Iowa State University over a two-year period to develop the strategy. [...]
"The strategy's science assessment provides a research-based foundation to quantify the effectiveness of current practices for reducing nutrient losses from the landscape," said John Lawrence, associate dean for extension and outreach programs in ISU's College of Agriculture and Life Sciences and director of ISU Agriculture and Natural Resources Extension. "The assessment reflects two years of work to evaluate and model the effects of the practices by scientists from ISU, IDALS, DNR, USDA Agricultural Research Service, USDA Natural Resources Conservation Service and other institutions." [...]
To address nutrient transport from nonpoint sources the strategy uses a comprehensive, first of its kind scientific assessment of conservation practices and associated costs to reduce loading of nutrients to Iowa surface waters. [...]
"This strategy provides the most up-to-date scientific information available to farmers as they seek to use the best practices available to reduce nutrient delivery from their farm," Northey said. "The goal of this strategy is to get more conservation practices on the ground. This is not about rules or regulations, instead this strategy provides resources to farmers to help them improve water quality."
ISU Associate Dean Lawrence played up the new policy's "research-based foundation," but state employees with expertise in this area did not agree.
"We are not willing to endorse this document as written," a group of DNR runoff-pollution experts wrote in a lengthy comment letter after reviewing the plan. "Major fundamental flaws permeate the 'strategy' while concrete ideas for implementation are not provided."
The objections include what the staffers saw as a one-sided, agriculture-friendly strategy for solving long-standing pollution problems disrupting the Gulf's lucrative fishing industry as well as fouling waterways throughout the Iowa and other Midwest states.
"This document reflects a narrow view not appropriate for a state-issued document," the DNR letter reads. "This is evidenced by entire paragraphs being copied from an Iowa Farm Bureau comment letter (without proper citation) submitted in response to the Raccoon River Master Plan, and all costs and benefits being based on production of a single commodity crop."
Beeman reported yesterday,
DNR director Chuck Gipp said questions raised about the report have been addressed in the latest draft. Asked directly about the Farm Bureau language, and why it wasn't atrributed, he said. "Regardless of the source, that is not the story."
The story, in Gipp's view, is that this report holds both sewage plants, factories and farms responsible, so the various sectors can't point fingers at each other.
The latest draft appears to omit a previous section on fertilizer practices that was similar to a Farm Bureau comment letter submitted on another report, but still contains, beginning on page 13, a section untitled "Iowa Conservation Progress" that is nearly identical to a Farm Bureau flyer published this year.
Iowa Environmental Council Executive Director Ralph Rosenberg expressed valid concerns about the short public comment period.
"The authors of this Strategy took more than two years to complete it, yet members of the public will be provided 45 days-during the hectic holiday season-to comment on the document. To review what has been presented as a 'comprehensive and integrated approach' taking on Iowa's most widespread and complex water pollution problem, this period of time is not enough.
"The public comment period should be extended to 90 days. An extension would provide greater opportunity for public input, including from members of the newly elected state legislature which will not convene until after the current 45 day period expires.
"A short period for public comments is especially troublesome because of media accounts that certain agricultural organizations may have had disproportionate access to comment on and review early drafts of the strategy.
"The public, including the Iowa Environmental Council's members across the state, expect policies outlined in this strategy to be effective in producing clear results for cleaner water in Iowa's rivers and lakes, in addition to the Gulf of Mexico.
"The way a nitrogen and phosphorous strategy is implemented in Iowa will be critical to whether the program ultimately succeeds or not. It is clear implementing this strategy will require significant investment by Iowa's taxpayers at the local and state level. The public deserves a more transparent, inclusive process to review and improve this critical strategy to ensure public dollars will be well spent."
More details on the public dollars likely to be spent on this policy:
The voluntary work will end up costing Iowans and federal taxpayers plenty. The farm projects would cost landowners and federal taxpayers between $77 million and $756 million a year, plus upfront costs of $1.2 billion to $4 billion. Improvements to the state's 124 largest sewage systems would add another $956 million in capital costs and up to $38 million in annual operating costs, paid primarily by homeowners and businesses.
Last month DNR Director Gipp broke with precedent by refusing to extend the public comment period related to a new fertilizer plant's air permit. That project involves hundreds of millions of dollars of Iowa taxpayer money.
I don't expect Gipp, Branstad, or Northey to allow a longer comment period on the nutrient strategy. Branstad has consistently tried to increase the influence of corporate agriculture on Iowa's environmental policy and on water quality programs in particular.
Any relevant comments are welcome in this thread.
UPDATE: David Osterberg of the Iowa Policy Project comments, "Talk is cheap."
DECEMBER UPDATE: Jon Ericson published a good article in the Waterloo/Cedar Falls Courier:
As people start to dig in to it, they are finding a plan that could prove costly for cities, and therefore taxpayers, to remove nitrogen and phosphorous from sewage treatment discharges. While the point-source section of the document has strict benchmarks and regulations, it comprises only 12 pages of the document. Farmers and landowners have much more to mull over but less urgency to act. The document spends 159 pages outlining conservation and best practices for non-point sources that could reduce nutrients in runoff, but those tasks would be voluntary.
Lyle Krueger, water reclamation manager for the city of Cedar Falls, said additional monitoring could be on the way for that plant when its permit is up for renewal in January 2014 and the news on nutrient content likely will not be good. Both nitrogen and phosphorous levels are currently at 2.5 to 3 times the level allowed under the proposed guidelines. Krueger said most Iowa treatment plants will have a similar problem.
The Iowa Department of Natural Resources estimates it could cost $1.5 billion for the state's 130 largest treatment plants to meet new standards. Krueger said the DNR estimates could mean an additional $25 on the monthly sewer bill for households.
Cedar Falls is currently working on an $18 million treatment plant upgrade that focuses mostly on ultraviolet disinfection to meet other Environmental Protection Agency standards. Krueger estimated a nutrient removal projection could cost anywhere from $16.8 million to $32 million.