Action: Public comments needed on Iowa's Impaired Waters List

John Norwood is a Polk County Soil and Water Commissioner. Readers can email comments to Dan Kendall at or mail them to the address enclosed at the end of this post. -promoted by Laura Belin

Friends, Polk County Residents, Iowans,

Below, please find public comments I filed with the Iowa Department of Natural Resources (DNR) last week on our 2018 Impaired Waters List. The public comment period closes December 28.

My most important takeaway and message to Iowans is that our impaired waters need to be addressed by first, modernizing the vision for our state's agricultural "machine," and second, looking at how to support that new vision through systems, conservation infrastructure, policies and practices, and local, regional, national, or international markets.

In my world, we need a new ag vision which stresses quality over quantity, profitability over production, diversification over concentration, sustainability over "unavoidable" depletion/leakage, and collective action over "everyone on their own."

We would be wise to recognize that the coming electric vehicle (EV) revolution will disrupt the internal combustion engine in ways that will profoundly impact our agricultural economy, such as less need for ethanol and biodiesel.  We can choose to be proactive or reactive.  

In addition, climate change demands will present new opportunities from carbon sequestration to methane capture, potentially enabling tremendous gains in soil health, water and air quality, and rural community health.  Many of these challenges will be best addressed working in teams.

I welcome your thoughts.  More info on my Facebook page John M. Norwood/NorwoodforIowa.


The Iowa Environmental Council noted in a recent action alert,

The Iowa Department of Natural Resources released the draft 2018 303(d) Impaired Waters List for the state of Iowa on Thursday, November 14, 2019. The list is comprised of lakes, wetlands, streams, and rivers that do not meet all state water quality standards. Review of the list reveals that of the waters tested by IDNR staff for the 2018 report, more than half (54%) are impaired for a variety of reasons such as indicator bacteria, turbidity (soil in the water), pH, and algae.

The 2018 report lists 767 total waterbodies assessed with 1,110 impairments. The 2016 report listed 750 waterbodies with 1,096 impairments. Of the 43 new segments that were assessed, 34 (or 79%) were listed as impaired. Those remaining on the list are carryovers from previous reports. Few waters were removed from the list for TMDL completion or water improvements.

The DNR is accepting public comments on the draft list now through December 28, 2019. Following the end of the public comment period, the draft list will be modified based on the comments received, and the revised list will be forwarded to U.S. EPA for their review and approval or disapproval.

The Iowa Environmental Council is encouraging Iowans to submit their own comments, either modeled on the council's letter (available here) or addressing any of the following points.

  • overall takeaways
  • data accuracy
  • the process by which the DNR creates the list
  • actions the DNR should take in response to the list
  • specific water quality standards used to assess the waters

    Another option is for Iowans to "view the DNR's interactive map to identify an impaired water body (red or yellow) near your home, work, or vacation spot and write a general message highlighting how you use the water and that you'd like them to address and correct the impairment in a timely fashion." (The map is on the DNR's website.)


    Dear Mr. Kendall:

    My name is John Norwood, and I am a resident of West Des Moines, Iowa, as well as one of five elected Polk County Soil and Water Commissioners, representing the 500,000 residents of Polk County on water quality and soil health issues, as authorized by Chapter 161 of the State of Iowa Code.

    I have four (4) suggestions for tackling Iowa’s Impaired Waters, which stem, primarily from our tremendously productive, but also huge agricultural footprint:  23 million acres of corn and bean ground, 50 million hogs produced annually, and 12 million acres of that corn and bean ground tiled, about half of which is controlled by our state chartered 3,700 drainage districts which were envisioned as part of our state’s constitution.

    My first suggestion is the state would greatly benefit all Iowans if we were to adopt a systems vision and approach to tackling our impaired waters within the agricultural system in which we operate. 

    This requires a drainage district level modernization effort, prioritizing, first, the modernization of those drainage districts which are the biggest contributors of nitrogen, phosphorus and other micropollutants and toxins that threaten both human health and animal health.  The current farm-by-farm approach as outlined by the Iowa Nutrient Reduction strategy is not working. 

    In fact, I would argue the so called Nutrient Reduction Strategy is not a strategy, rather it is simply a menu of options, many of which are economically, technically or politically infeasible.  Biofilters being an example.  There is no conceivable way we will ever get 170,000 of those installed and keep them functioning with an average operating lifespan of ten years.

    Instead of this piece meal, haphazard approach that is lacking in economic and technical feasibility, we need to recognize the importance of scale and scope economics in building the kind of long lasting (100+ years), durable infrastructure like breakpoint and tile zone wetlands that can filter water, assist in aquifer recharge, flood control irrigation, and provide much needed wildlife and pollinator habitat. 

    We are building these one-by-one, here and there, instead of utilizing a drainage system-by-drainage system approach, which is a mistake both from a hydraulic systems perspective as well as a cost perspective and an “opportunity cost” perspective.  We waste private and public resources when we pursue suboptimal solutions.

    Like conventional wastewater, storm water and drinking water systems, we should be conducting hydraulic modeling at the drainage systems level, and then identifying the “solution set” for each system which may will require new financial approaches to help incentivize and install this infrastructure.  The original function of these systems was drainage and today we need them to serve multiple functions. 

    I’d start by finding a few forward-thinking county Boards of Supervisors and drainage district landowners in priority watersheds who are forward-thinking and see these improvements as “market differentiators” for those food companies who are interested in supporting regenerative agriculture.  Part of our construction approach should be to improve these systems in “phases” which bundle construction activities to save on design and construction costs. 

    Over the past 15 years we’ve installed 90 of so called CREP [Iowa Conservation Reserve Enhancement Program ] style wetlands.  We have more than 1,400 potential sites identified statewide.  To date, we are building about 6-8 per year even with the new state 512 monies. 

    We should be building more like 100 per year and over time we’d have close to 4.5 million acres of tiled ground filtered by this system of infrastructure.  We have a waiting list for these sites, and yet we have insufficient funds, and stage agencies that are not set up to handle the increased throughput we need to accomplish this work.  I’d suggest we need to look at how we maintain and build our state network of county and state roads using public-private partnerships as a model for how we could begin to build the capacity to improve our green drainage infrastructure.

    My second suggestion is to create a state and matching federal green, conservation infrastructure fund(s) that are dedicated to helping those drainage districts who would like to modernize with making those improvements on a systems level, provided they meet certain design standards and improvements. 

    We may need to come up with some of those as we learn how to best do the modernization work.  One benefit would be that these modernization efforts may begin to help farmers differentiate how they are growing corn and beans and other crops that may be of interest to food companies that are increasingly interested in regenerative farming practices. 

    Given the enormous private investment to date in our 3,700 drainage districts, I don’t think it is unreasonable to believe that we will need to spend on the order of $50-$200 million annually for a period of at least 20 years across the state (we spend billion on roads and we’ve spent billions over a century building these drainage systems), but perhaps with most focus on those drainage districts in the 15 or so counties on the Des Moines lobe and upstream of the state’s most populous water supply. 

    As far as the federal government, I see a similar funding role for how it helped coastal cities modernize their wastewater treatment plans back in the 1970s and 1980s (in some cases the federal government provided 90% cost share).  We need a pot of money to help our drainage districts do what was done for coastal systems. 

    I’d also suggest if the federal government can find $16 billion in emergency farm payments to address essentially the overproduction of corn and soybeans, we need to rethink how we use subsidies to promote sustainable farming practices vs. one time relief payments. 

    We should be able to come up with another $50-$200 million per year of Federal monies to help drainage districts modernize, including the conversion of 500,000 or so agricultural acres to produce environmental services instead of crops.  The CREP program provides a series of payments to producers which can help diversify the ups and downs of commodity cycles.  Our green wetland infrastructure should be thought of as having similar functional importance to farm roads and we recognize, there, the need to take land out of production for machinery to get into the fields and transportation of farm inputs and outputs to market. 

    The millions of dollars that we need to INVEST in diversifying the rural Iowa agricultural landscape is a HUGE opportunity (borrowing from our president’s lexicon) to generate new jobs, new services, and new economic development opportunities, and community vitality.  Imagine what we could do for the rural quality of life if we can take the stink out of manure with a systems approach to anaerobic digestion or aerobic digestion of the manure.

    My third suggestion is to convene a panel of state health experts to identify the biggest threats in our impaired waters with a particular focus on human health and animal health here in Iowa.

    I recently listened to a University of Iowa health expert at a water quality workshop on threats to our drinking water system that had me very concerned.  I think more Iowans would be concerned if they understood better what our science is beginning to tell us about long term chronic exposure to contaminants even at parts per million or billion. 

    I believe nitrogen in our water is a symptom of a system that is out of balance, but it isn’t nitrogen that we need to be most concerned with.  It’s the byproducts of nitrogen and phosphorus in our waters which produce toxic algae or microcysts, and it’s other contaminants from manure runoff including pathogens and antibiotic resistant strains of bacteria that we should be focused on.  Things that can lead to pandemics.  

    The World Health Institute has issued a number of warnings, for example, about the loss of front line antibiotics that are in part the result of overuse, and there is concern that our animal livestock industry is contributing to that loss of efficacy.  We need advanced treatment technology across our public water supply systems, Reverse Osmosis (RO) systems for example, which remove a wide spectrum of contaminants, since unlike most other major cities we don’t have protected watersheds and in the case of Des Moines we receive our drinking water from one of the most intensively farmed regions of the world.  Similarly, we need to have heightened focus on protecting our rural water supplies including private wells.

    My final suggestion is that working with the Iowa Department of Agriculture and the US Department of Agriculture we need a systems wide approach to aligning state and federal policies that support re-diversification of our agriculture lands away from such a heavy focus on row crop agriculture, and financial incentives that encourage the over application of commercial fertilizers to protect “downside risk” and add additional focus on perennial systems that can help stabilize soils on highly erodible and steep sloped grounds. 

    This would include modifying crop insurance policies to move away from quantity based production goals to new sustainability based goals and limiting crop insurance to certain types of ground which are suitable to row crops (not steep slopes or buffer areas).  We also need a “team based” approach to cover crops so that each farmer doesn’t have to “reinvent the wheel” in terms of learning how to do this, we can create teams of cover crop users to buy down the cost of inputs, and perhaps create new markets for cover crops or forage systems that tie landowners together in cooperative efforts. 

    In my vision, payments would be made not just to individual farmers, but to teams of farmers that achieve pre-determined targeted objectives that are likely to be county-by-county based on the local geography.  One such cooperative effort on the crop production side (Carson Baron farms sp?) is on-going up in Northeast Iowa as Market to Market featured last night in an episode.  We need to apply that approach to conservation practices and new cropping systems, as a form of portfolio diversification, cost control and risk mitigation.

    Our public servants are hard-working but we need to provide a new vision and new resources to how we address the opportunity and the challenge before us.  Iowans deserve clean water.  We can be a leader in teaching the world how to configure new agricultural systems that produce clean water and clean air.  Thank you for the opportunity to comment.

    John Norwood
    Polk County, Soil and Water Commissioner
    West Des Moines, IA
    December 21, 2019

    Editor's note: Given the approaching deadline, it would be best for readers to email comments to Dan Kendall at However, people can mail comments to:

    Iowa Department of Natural Resources Attention: Dan Kendall
    Water Quality Monitoring & Assessment Section
    Wallace State Office Building
    502 East 9th Street
    Des Moines, IA 50319

    John Norwood wanted to share this slide from a presentation Charlie Schafer, Agri Drain President, gave at the Iowa Drainage Districts Annual meeting in Fort Dodge in November.

    The blue counties have the highest potential impact for a systems approach to water management that begins by working collaboratively with and through our 3,700 drainage districts.

    There are about fifteen counties upstream of central Iowa’s water supply that we need to target for drainage district infrastructure modernization.

    This will need to include installation of constructed wetlands and wetland restoration work with funding for land acquisition, design and construction coming from a dedicated green infrastructure fund.

    Our Des Moines confluence of two of Iowa’s great river systems, the Des Moines and the Raccoon, is at the bottom of the funnel of one of the world’s most intensively cultivated regions of the world where we land apply untreated manure from 50 million hogs annually plus manure from millions more of turkeys, egg laying chickens, and beef cattle.

    Top image: Spring in Waterloo, Iowa by Shutterstock creator Amdizdarevic.

    • Thank you, John Norwood, for a very good post!

      A few additional thoughts from someone who has worked on Iowa water issues for a few decades.

      First, I attended one Iowa meeting about rural water-quality wetlands earlier this year in which it was stated that in order to save money, the amounts of reconstructed prairie around the wetlands would be as small as possible. It is partly that kind of one-track thinking that landed us in the unsustainable situation we are in now.

      We need to recognize that our Iowa landscape problems are interrelated, and that we need to think about water quality AND climate change AND biodiversity AND pollinators AND soil health, etc. We need broad holistic thinking. Trying to figure out how we can take the teensiest-weensiest-possible amounts of land out of rowcrop production and still try to get some nitrogen out of our water is not going to get us where we need to go. I appreciate John Norwood's recognition that we need to think about our entire agricultural system.

      Second, it would be really great if a tsunami of consumer demand resulted in corporate offers of huge piles of money for Iowa farmers, piles that were contingent on genuinely good farm conservation. I hope that will happen, and happen soon.

      Meanwhile, it would help Iowa water quality if Iowa did not have the current trifecta of Republican control that consistently stabs Iowa water quality proposals until they are very dead. I would much rather talk about conservation than politics. But alas, an Iowa conservationist who doesn't want to talk about politics in 2019 is kind of like a drowning person who doesn't want to talk about water.

      The most recent obvious example is the farm buffer-strip requirement that is already in place in Minnesota and was proposed for Iowa. But it was killed by an Iowa state committee, apparently mostly because some Minnesota farmers don't like it. As long as "universal farmer applause and acclaim" is a hurdle that all proposed new Iowa water policies must be able to clear, our water-quality progress will continue to be laughably slow.

      Which brings up my final point. I have attended Iowa drainage-district meetings, and the expressed concern by landowners for water quality was pretty much non-existent. The discussions and concerns revolved almost entirely around the need for more and faster farmland drainage and the painfully-large amounts that such drainage improvements will cost.

      There is an Iowa drainage proposal that has been circulating, in various changing forms, for a number of years. It basically amounts to taxpayers ponying up for major drainage improvements on private land in return for some new wetlands to remove farm nutrient pollution. Some of the drainage improvements might be bigger than what is now permitted by the feds. If that plan makes an appearance during the upcoming Legislative session, it needs to be closely scrutinized. Emphasis on closely.

      • this is all useful information

        Would you consider submitting it in the form of a guest commentary, to be published after January 1?

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