DES MOINES, IOWA (February 23, 2024) — A coalition of ten environmental organizations has submitted comments to the Iowa Department of Natural Resources (DNR), highlighting the inadequate protections for water quality in Iowa’s concentrated animal feeding operation (CAFO) rules.

The comments were in response to draft rule changes for CAFO siting, which were weakened during the Governor's preclearance process. Public comments on the draft rules closed today at 4:30PM. Iowa Economic Council (IEC) staff attorney Michael Schmidt attended a DNR public hearing to make comments in person on February 14; IEC submitted the coalition's written comments on February 23.

The written comments highlighted that the proposed rules ignored DNR’s own experts, who stated stronger rules were needed to protect water quality in vulnerable karst terrain. Records obtained by the IEC showed that the DNR proposed stronger rules to the governor’s office in October; the governor's office reportedly refused to allow the rules to proceed because they would not reduce regulatory burden, which was the stated goal of the governor’s Executive Order 10.

The coalition submitting comments includes ten organizations: Allamakee County Protectors — Education Campaign, Common Good Iowa, Des Moines County Farmers and Neighbors for Optimal Health, Environmental Law and Policy Center, Food and Water Watch, Iowa Citizens for Community Improvement, Iowa Environmental Council, Jefferson County Farmers and Neighbors, Poweshiek CARES, and the Socially Responsible Agriculture Project.

The Iowa Environmental Council and Environmental Law & Policy Center previously petitioned DNR to adopt rules that would increase protections for karst terrain and increase water-quality monitoring. The Environmental Protection Commission (EPC) denied the petition after DNR stated the agency would address the issue through a larger rulemaking.

"The refusal to adopt appropriate, scientifically-based, protective rules will harm Iowans across the state," said Michael Schmidt, Interim Executive Director and staff attorney for the Iowa Environmental Council. "Environmental regulation should not be about reducing burden, but preventing pollution of our rivers, lakes, and streams. These rules will perpetuate poor water quality."  

The comments highlight the economic costs of pollution from CAFOs, including health-care costs from increased cancer rates, water-quality treatment costs, and recreational value. 

"Clean water provides many benefits, economic and otherwise, but these rules only serve polluters. They do not protect our land and water, and the Iowans who call this state home. These rules will continue to allow pollution that degrades our waterways," said Alicia Vasto, IEC’s Water Program Director. "Iowa’s water quality is shameful, and the state is willfully ignoring the voices of all Iowans in this debate. They are missing a real chance to make meaningful, measurable progress."

Food and Water Watch Attorney Dani Replogle said, "Governor [Kim] Reynolds’ reckless Executive Order is encouraging a rollback of regulations required to protect clean water from Iowa’s ubiquitous factory farms. These industrial animal factories are polluters by design — DNR knows this. A failure to protect Iowa’s unique karst regions from their excessive waste will only worsen Iowa’s water-quality crisis. Gov Reynolds’ DNR must side with science and clean water and strengthen CAFO regulations in karst regions."

DNR undertook a lengthy process of rule revision and considering stakeholder comments, which was extended to incorporate requirements of Gov Reynolds’s Executive Order 10. The order, signed in January 2023, imposed a moratorium on formal rulemaking until agencies had reviewed existing rules and conducted a cost-benefit analysis. DNR completed the cost-benefit analysis of CAFO rule management in September 2023 based on draft rules that had stronger protections for water quality. The department did not update the analysis based on the weaker rules approved by the Governor’s office.

Elements of Executive Order 10 are being considered as part of Senate File 2370. SF 2370 would codify changes to the agency rulemaking process under Iowa’s Administrative Procedure Act, such as pre-approval of rules by the governor’s office. The bill survived the legislature’s first 'funnel' because it passed out of the Commerce Committee in the Senate.

"It is frustrating to go through a years-long stakeholder process that ignores comments from the department’s own experts," said Schmidt. "The DNR and the Environmental Protection Commission need to put the public’s interests first, not the parties they regulate."

The rules will be on the agenda for a future meeting of the Environmental Protection Commission, whose members are directly appointed by Governor Reynolds, likely in April. The rules will go into effect once approved by the EPC.

Read the joint comments on IEC's website.

The Iowa Environmental Council (IEC) is the state's largest and most comprehensive environmental alliance, comprised of diverse organizations and individuals working together to protect Iowa's natural environment. Through education, advocacy, and coalition building, the Council raises awareness, generates action, and creates large-scale change. We work on federal, state, and local public policy issues to ensure a just, healthy environment and sustainable future for all Iowans. Learn more at

Support the River Cities' Reader

Get 12 Reader issues mailed monthly for $48/year.

Old School Subscription for Your Support

Get the printed Reader edition mailed to you (or anyone you want) first-class for 12 months for $48.
$24 goes to postage and handling, $24 goes to keeping the doors open!

Click this link to Old School Subscribe now.

Help Keep the Reader Alive and Free Since '93!


"We're the River Cities' Reader, and we've kept the Quad Cities' only independently owned newspaper alive and free since 1993.

So please help the Reader keep going with your one-time, monthly, or annual support. With your financial support the Reader can continue providing uncensored, non-scripted, and independent journalism alongside the Quad Cities' area's most comprehensive cultural coverage." - Todd McGreevy, Publisher