Pam Mackey Taylor is the Director of the Iowa Chapter of the Sierra Club.

Every three years, the Iowa Department of Natural Resources (DNR) conducts a Triennial Review of its water quality standards. Part of the review is a determination of what changes need to be made to Iowa’s existing water quality standards.

The agenda for the Triennial Review was simple. The DNR intends to focus on the following topic areas related to water quality standards:

• Tribal reserved rights
• Antidegradation
• Human health criteria
• Chapter 61/Surface Water Classification document cleanup
• Use attainability analysis
• PFAS (per- and polyfluoroalkyl substances, sometimes called “forever chemicals”)
• Lake nutrients

After digging into these topics during the review meeting, what jumped out was the lack of investment the State of Iowa and the DNR have made in water quality and improved water quality standards over the last two decades. 

The DNR plans to revise Iowa’s water quality standards to reflect the human health criteria the U.S. Environmental Protection Agency issued in 2015. As stated during the triennial review meetings, most of Iowa’s human health criteria are based on EPA’s 2002 criteria. 

It has been ten years since the 2015 criteria were issued. During that time, dischargers—sewage treatment plants and industries—may have been discharging harmful levels of those pollutants into the state’s water bodies, exposing humans who are wading, swimming, and boating to those pollutants, along with fish and other wildlife.

Each water body in Iowa is given use designations for aquatic life, for recreation uses, for drinking water use, and for human health. In order to make those designations, the DNR performs a Use Attainability Analysis. The whole process is lengthy, from on-site viewing of the water body, to writing a report and making a recommendation, having a public comment hearing, going through the rule-making process, and getting final approval from the Environmental Protection Agency. 

The DNR is so far behind in performing use attainability analyses that the state has some 250 water discharge permits (called NPDES permits) that have expired and are waiting for a new analysis to be completed.  Some of the permits have been expired since 2007, almost two decades. 

A review of the DNR’s NPDES permit listing spreadsheet shows 1,587 permits as of September 28, 2025. Of those, 451 permits had expired on or before August 31, 2025, and 22 permits were scheduled to expire on September 30, 2025. The oldest expired NPDES permit expired in 2002, more than two decades ago. 

Let that sink in: more than one-quarter of Iowa’s NPDES permits have expired! Some of the expired permits are for major sources, both municipal and industrial.   

The pollution levels are set for each pollutant based on the designated used for the water body. If pollution levels are tested above those that are designated for the water body, the water is put on the impaired waters list. The DNR is supposed to write a plan for bringing the water back into compliance with water quality standards; that plan is called a TMDL. 

Numerous waters on the current impaired waters have been on the list since 2006 and 2008, with no TMDL having been prepared in almost two decades. Some of the waters that have been on the list since 2006 and 2008 are designated as Outstanding Iowa Waters pursuant to Iowa’s Antidegradation Policy.  An Outstanding Iowa Water is considered the best of the best and is entitled to extra protection from pollution.

For years, the Sierra Club has been asking DNR to establish numeric criteria on the nutrients in lakes, rivers, and streams. DNR has refused and continues to resist setting those criteria. The criteria are important in our ability to measure reductions of nutrients in our water bodies.

The backlog of work needed to comply with the most basic requirements of the federal Clean Water Act is shocking. All of this points to a need for funds for staff, equipment, materials, and other resources. 

Iowans are sick and tired of poor water quality, swim advisories on the state park beaches, impaired waters that are not cleaned up, TMDLs not being implemented and not even written, point sources operating on NPDES permits that expired over a decade ago. Polk County residents were told this summer that they could not water their lawns, because the nitrates in the Des Moines and Raccoon Rivers were so high that the water treatment plant had trouble removing them.

The fingers are pointed at DNR Director Kayla Lyon, who is not showing the leadership to get adequate funding for the work on water quality standards and water quality improvement.

The fingers are pointed at Governor Kim Reynolds, who is not showing leadership in improving water quality in Iowa and is not seeking funds to support the work.

The fingers are pointed at the Iowa legislature for not allocating the funds to support a robust program within the DNR to protect the waters Iowans recreate in and around, waters that Iowans drink, and waters used by wildlife.

It is lack of funding, lack of investment, and lack of will. The state has more than enough money to protect and improve the water quality in Iowa’s waters. Protecting the state’s waters is something very basic. It should not take decades to improve Iowa’s water quality.

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Editor’s note: You can read the Sierra Club’s comments on the triennial review here.