Bob File: Op-Eds, Writings

Below are all writings in no particular order.

Cedar Rapids Gazette Sat 10-3-21 Will we be part of the solution?.pdfclimate washing gazette version.doc

Cedar Rapids Gazette Sat 10-3-21: “Will we be part of the solution?”

            It is interesting that industrial ag apologists, whether they be in government, business, or academia, never mention the inherent pollution from industrial ag that will continue to pollute Iowa no matter their schemes of green-washing – ag digesters for hog confinements, and now climate-washing – burying carbon dioxide (CO2) from ethanol plants. And, if these ideas are so good, why are they asking for subsidies from tax payers?

            These are two of the latest band aids that ag apologists put forth to allow the industrial row crop/confinement/and feedlot model of agriculture to continue with its onslaught of pollution to Iowa’s water, air, soil, and human health, and its effects on climate. Along with the myth that Iowa feeds the world (Iowa actually imports over 80% of its people food so if we can’t even feed ourselves, how do we feed the world?), ag allies come up with new climate- and green-washing schemes to try to confuse the public into thinking that modern industrial agriculture is actually good for the state and for farmers. It is not good for either but instead is good for the corporations that don’t care what happens to the environment or to farmers as long as they make money.

            Why should Iowa be the toilet for the hog confinement industry, leaving us with confinement waste which is made toxic through cooking for months in pits and tanks? That confinement waste pollutes our air, soil, and water, and harms human health, all prior to any proposed treatment or ag digesters. In the past, pig manure was deposited directly onto the land. It was broken down into its benign beneficial parts in a few days by sun, wind, water, bugs, and soil organisms, and taken up by plants in the nutrient cycle.

            Even if CO2 is collected from ethanol plants, Iowa will still have some of the most polluted streams, rivers, ponds, lakes, soil, and air in the US, and be a major contributor of pollution to the dead zone in the Gulf. This will continue to happen because modern industrial mono-cropping of corn and beans relies on polluting fertilizers, pesticides, and herbicides, and also results in soil erosion.

            There are crops and cropping systems that exist today, that can be adopted wholesale now by farmers that would make Iowa a source of clean water, a flood mitigating sponge, a soil building and carbon sequestering state with a healthy agriculture growing crops and animals in sustainable and non-polluting ways for both people food and manufacturing goods. This model of agriculture would revitalize and clean up our rural areas making them once again a vibrant place to live, along with manufacturing and processing of healthy agricultural products and food.

            Some of these crops and cropping systems can be read about in the epilogue of my co-authored book “Hog Confinements and Human Health: the intersection of science, morals, and law” which is free to read online at www.civandinc.com , click on Hog Ebook.

            This is Iowa’s choice. Will we continue to be one of the existential threats to human life on earth through this industrial model of agriculture now prevalent in Iowa, or, will we be part of the solution to those threats?

Bob Watson  

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ag digester letter.pdfag digester letter.doc

ag digester letter June 8, s021

Dear Editor,

            After turning in Big Ox for one of their violations, I was put on the Department of Natural Resourses committee whose job was writing regulations for agricultural digesters; there were none at that point. Re: Sunday’s Gazette article “Iowa bills encourage digesters to convert farm waste.”

            My first contribution to the committee was mentioning that even though the draft regulations said that no hazardous waste was to be allowed in these ag digesters, hog confinement waste fit Iowa’s definition of hazardous waste to a “T”. The confinement waste gasses, particulates, and antibiotic resistant organisms can make people sick, and can kill them.

            I didn’t hear anything from the committee after that and figured I was dropped from the committee for mentioning that observation. I found out subsequently that I wasn’t dropped from the committee, but rather the Iowa Legislature told the DNR they couldn’t regulate agricultural digesters, and the committee was disbanded.

            Using taxpayer money to subsidize an iffy and complicated technology (there are many abandoned ag digesters in the Midwest) just to provide another pseudo Band-Aid to the human health and environment-harming hog confinement industry is not what we pay our taxes for. These ag digesters have no regulations. The committee was disbanded.

Bob Watson

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draft and national service – apology (1).pdfdraft and national service – apology (1).doc

draft and national service – appology – 08/31/2020

Apology:

            It has been two generations since the loss of the military draft. Two generations since the loss of two of the last vestiges of shared American experience that the draft included which made America what it is/was. Those lost vestiges are the loss of the melting pot, and the loss of working for your country.

            The melting pot and the draft forced us to live and work with others who were unfamiliar to us. We overcame initial misgivings and got things done. The unknown “other” turned into the known and familiar.

            Working for your country gives a sense of ownership of the country and that sense of ownership promotes a responsibility towards that which is owned. The country, and the government that runs the country, are mine. I own and am responsible for my country and want my country and government to run correctly.

            Compare that to the body politic we find today, two generations after the loss of the draft. Segregated communities, and social media platforms, that never have to talk to each other, let alone live or work with each other. The government and others as “other” that should leave me alone, and even more, stay out of my community and even my country. The country is “mine” but I don’t want to be responsible for working for it, paying for it, working for society’s upkeep, or sharing it with anyone who I do not conceive of as like me.

            I have an Advanced Degree in Applied Foreign Policy from the School of Marines, University of South Vietnam, 1969 (school of very hard knocks). I double majored in Death and Destruction, and Real Time Moral and Ethical Decision Making. I graduated with Honors in Lifelong Studies of Living with Post Traumatic Stress Disorder and P-Falciparum Malaria, the cerebral and most dangerous form of malaria.

            On my first day in Vietnam I was told I was going to An Hoa which was considered “rocket city south” by Marines. My second day in Vietnam I took a chopper to An Hoa and landed as a mortar attack hit the landing zone. My year in the rice paddies and mountains of Vietnam went downhill from there. A year later the chopper that was taking me to Danang to get on a flight to leave Vietnam crashed (luckily, into a landing zone not too far south of Danang). We survived. The chopper didn’t.

            I mention this short history of my work for my country, and my continued work for my country as a disabled Vietnam veteran, to cite my bona fides as someone who owns my country. As such, I offer my apology to the rest of the world for the unseemly spectacle this current president and administration has presented. This is not who the majority of us are, or how we see the world.

            Forgive us. Give us time. This is the death throe of a very insecure and inexperienced “old white guys” demographic that, hopefully, will soon die out. The young multicultural, multiracial American society understands how to be civilized and inclusive.  

Bob Watson

formerly Sgt Robert P. Watson, 2nd Battalion 5th Marines

Bob Watson is an environmental activist who makes his living in the wastewater industry.

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2020 ias no names copy.pdf2020 ias no names copy.doc

2020 Iowa Academy of Science symposium: Transition to a clean agriculture.

1. It seems that we have many reports about how Iowa’s modern industrial agriculture is not working correctly to clean up its pollution. But, we don’t have many reports about transitioning to an Iowa agriculture that would result in Iowa becoming a carbon sink, an offset carbon trading bank, a water cleaning sponge, a pollinator – wildlife – and aquatic habitat, all the while growing small grains, vegetables, and fruits for people food along with providing crops for manufacturing goods which would revitalize rural Iowa, and would be an agricultural system that would begin to replenish our soils.

That is what this symposium would be about.

2. Even if we transitioned slowly away from industrial row crop corn and beans, by mandating and paying for 10% of all row crop fields to have the native prairie STRIPS system, and mandating that most Iowa county ditches were planted to native prairie, we would get rid of approximately 95% of current soil erosion, nitrogen pollution, and phosphorus pollution coming from row crop fields today.

3. If Iowa planted native prairie as an agricultural crop, we would be a carbon sink, we could be a carbon offset bank for trading carbon offsets, and our farm environment would become a water cleaning sponge helping to reduce flooding and providing habitat for pollinators – wildlife – and aquatic species.

4. Hemp would be similar to native prairie in that it is a cover crop with deep roots. But hemp can also be used for thousands of food and manufacturing products that can help revitalize rural Iowa’s small communities since hemp is a bulk commodity that would need to be processed locally.

5. Small grains, vegetables, fruits, Wes Jackson’s perennial polyculture grains, and other people food crops and cropping systems could become part of an agriculture which looks to benignly, in terms of pollution, feed Iowa, the Midwest, and the US instead of the current polluting industrial agricultural products mainly grown for the export market.

6. The world now produces enough food through grains to feed double our current population. By encouraging eating lower on the food chain and raising meat animals only for the US, we would no longer need the confinements and feedlots that are polluting Iowa’s air, water, and soils, and negatively affecting our human health.

Bob Watson

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2020 candidates.pdf2020 candidates.doc

2020 candidates coming to Iowa:

            There is a sense in which the Green Revolution, having morphed into modern industrial row crop and CAFO (confinements and feedlots) agriculture, can be viewed as one of the most serious and ongoing human-caused pollution events in the earth’s history.

            After World War II, agriculture changed from 10,000 years of a relatively biologically benign system of growing food to an agriculture that is inherently toxic for the environment and people. The use of chemicals and a toxic form of manure coming from the use of CAFOs have created polluted waters, polluted air, and soils that are so depleted that even earthworms don’t live in much of it anymore. This recent model of agriculture has turned Iowa into a sacrifice area where many people in closest proximity to these practices, if they are able, have left the rural countryside.

            Any 2020 candidate who comes to Iowa to either laud this modern agriculture, or to say that the problems that we have with agriculture are family farms versus corporate farms, or access to markets, or access to money, simply doesn’t understand this industrial agriculture’s inherently toxic nature. And that candidate probably doesn’t understand the extremely debilitating affects on human health from this agriculture, and from eating the highly processed foods that this industrial agriculture produces: obesity, heart problems, diabetes, asthma, to name just a few.

            The Green Revolution’s father Norman Borlaug’s admonition that no food revolution will help unless we deal with the problem of population is seldom remarked upon. It should be. This is a finite planet.

            With too many people, and an inherently toxic model of agriculture, we need candidates who understand what agriculture has turned into. As a candidate, you can’t say that growing food needs to harm us and the earth, and still be taken seriously as someone who wants to help lead our country. If you come to Iowa, you need to tell the truth.

Bob Watson

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dnr lawsuit email.pdfdnr lawsuit email.doc

Email for our lawsuit against the Iowa DNR.

            Between the attached powerpoint and our DNR lawsuit documents at the link below, you can get a pretty good understanding of what hog confinements are, why they produce the human health problems they do, what those health problems are, and why we have had such a hard time getting anything done to protect humans from hog confinement pollutants and toxins.

            Read the powerpoint first. The powerpoint explains hog confinement technology, how that technology affects the hog’s waste as it breaks down, and what human health harming constituent parts that waste produces as it breaks down in this sewer environment. Those constituent parts are vented or blown out into the surrounding neighborhood, and larger environment, 24/7/365.

            After reading the powerpoint go to the online DNR lawsuit documents at the link below. When you go online, it would be best to start with the media guide pdf. That document has notes in the margin to help understand what we are doing. The last page of the media guide is the template we had to follow in order to make our request of the DNR for a declaratory order. That will explain what we are about in the document when it says “this addresses template number such and such.”

            These lawsuit documents, along with the Jillian Fry 2014 Johns Hopkins study used in the main document, will let you understand why opponents of hog confinements have had such a hard time making any headway in protecting the public’s health; the regulatory scheme leaves out humans, hence there are no laws pertaining to the effects hog confinement waste has on people. And, the state has limited what regulations there are only to the water pollution avenue, which leaves out the other pollution avenue, the air avenue that is vented out into the neighborhood and the larger environment. That is the basis of our lawsuit.

            We have changed the lawsuit, but not in any real way. We have simply left out the original step of trying to get the DNR to agree with us and issue a declaratory order using our wording. Instead, we have skipped that step and are asking the DNR in our lawsuit to “retain” all excreta/waste/manure that the code/law says it is supposed to do. This is explained in the main document. Our arguments, and the documents that we use making those arguments, are still the same in this DNR lawsuit as they were original lawsuit.

            Our online documents:

https://drive.google.com/drive/folders/16JSVu2yMOKrVjajcmTudqT5eurkbkbDC?usp=sharing


            There is an online Decorah Newspaper article which sets the stage from a historical perspective as to why we have sued the DNR. The link to the local Decorah Newspaper article is:

https://decorahnewspapers.com/Content/News/Local-News/Article/Local-citizens-petitioning-DNR-to-regulate-hog-confinement-emissions/2/10/44441

            I had thought I would be doing more presentations of this powerpoint around the state. As that has not been the case, I have decided to send this powerpoint, and the legal documents, out in this form for you to use yourself. As I said before, this powerpoint and the lawsuit documents should give you a pretty good understanding of hog confinements and the danger they pose to human health. 

            If you belong to a group, or if there are people you know who you think might appreciate this information, please send this email along to them, and use this email text for directions for them.

            Contact me with any questions you may have. If you wish to be deleted from receiving emails about this issue from me, please let me know.

            Thanks.

Bob

Bob Watson
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puppy mills.doc

Dear Editor,

Re: “Legislators look to boost animal cruelty laws” Gazette Monday, April 1.

            It is pretty ironic that Iowa legislators equate “animal cruelty” in Iowa with puppy mills when there are 23 million pigs every day in Iowa who live in enclosed steel and concrete buildings with slated floors where their waste falls through into the pit below the floor. Those pigs live their whole lives knowing only a steel floor with sewer gas fumes coming up through the slats so toxic that fans need to constantly blow those gasses outside so the pigs don’t die from hydrogen-sulfide gas asphyxiation.

            Of course, the legislators are not too worried about the people who live in proximity to these hog confinements either as they have not regulated those toxic sewer gasses blown into the neighborhood. They have regulated the liquid waste which is spread only once every six months on fields. But they have not regulated the toxic gasses hydrogen-sulfide and ammonia, the greenhouse and explosive gas methane, the antibiotic resistant organisms, particulates, and many other toxins that are blown out of these confinements 24/7/365 affecting the health and well being of neighbors.

            A few puppy mills get the legislators up in arms. 23 million pigs living in a sewer environment their whole short life with sewer toxins blown into neighborhoods affecting the health of thousands of neighbors gets nary a nod.

Bob Watson

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ammendments needed for any particular.doc

Dear Editor,


Whether we like it or not, the political realm is where we as a society make our societal decisions. With the advent of money so controlling our politics (we are more an oligarchy than a democracy because of this), no matter what your particular issue is, or where your effort lies, unless we get money out of politics, you have little hope of affecting how your particular issue plays out.

To that end, we should adopt six amendments to our constitution:

1. Corporations are not people. A person is one human.

2. Money is not speech. Speech is what a human does to communicate.

3. Publicly funded political campaigns. The only money that can be spent on or about a political campaign is the public funding given to a particular candidate.

4. Voting districts will be chosen by an independent commission working off of census data. Districts should be the simplest geometric shape that divides population.

5. No negative campaigning. Only can talk about who you are and what you will do.

6. End that vestige of slavery, the Electoral College.

If we adopt these amendments, we will have the possibility of once again having statesmen (gender inclusive) elected to our government beholden to us and not the highest bidder.

Bob Watson

Rural Decorah

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using north winn.doc

Dear Editor,

            There have been recent letters promoting the use of the North Winneshiek school buildings in the future. That would be a very bad idea for any children who happened to have to attend school there.

            This probably would have been a good idea, in fact North Winn was a good idea, back in the early ‘60’s before hog confinements came to Iowa.

            North Winn is today surrounded by hog confinements, and sometimes, feedlots. The hog confinements (eight now or in the near future) are mostly west of the school and the prevailing winds are from that direction for most of the year.

            Because pigs are raised in buildings now, and not out on pasture, the waste that is collected in the pit beneath the pigs exists in an anaerobic environment; that is a sewer environment. That waste breaks down differently than it would in a natural setting. In a sewer environment it breaks down into dangerous constituent parts including hydrogen-sulfide, ammonia, methane, particulates, antibiotic resistant organisms, and many volatile organic compounds. Those constituent parts of the waste are vented out into the neighborhood and larger environment 24/7/365.

            This school year, more often than not, the North Winn playground has a distinct cloud of sewer gas hanging over it. That might not cause health problems for adults, but the scientific research is clear that it can cause long-term chronic health problems for children.

            Hydrogen-sulfide gas causes problems for people’s central nervous system and digestive system. Ammonia is a caustic gas that among other problems causes asthma, especially in children. Methane is a green house gas (climate change) and is the cause of confinement explosions and fires. Particulates cause respiratory problems. Antibiotic resistant organisms cause problems such as staph infections and MRSA (sores that don’t heal, and/or, people die from uncontrollable infections).

            There are ample studies that have shown these health problems as actual problems that people in proximity to confinements have; in a SE Iowa county 55% of kids on farms with confinements had asthma; veterans who live within one mile of a confinement have 3 times the likelihood of being colonized with antibiotic resistant MRSA than those veterans who live outside that distance; and, the study that was done on North Winn about ten years ago showed asthma rates for North Winn students at four times the average rate of other Iowans.

            To see more about the dangers to human health from hog confinements go to:

https://drive.google.com/drive/folders/16JSVu2yMOKrVjajcmTudqT5eurkbkbDC?usp=sharing

            You can have hog confinements surrounding the North Winn buildings. Or, you can have a North Winn school without the hog confinements. But, you can’t have both. Otherwise, you run the risk of harming children’s health and I don’t think the School District wants to jeopardize children’s health just to use some old buildings.

Bob Watson

Rural Decorah

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regulatory schemes.doc

            One of the first things that was done by the Winneshiek County Protectors (WCP) concerning possible frac sand mining in Winneshiek County was to look at the regulatory scheme that might be in place to protect the public and the county from any possible pollution problems stemming from frac sand mining; chronic long term pollution or particular immediate pollution events.

            Regulatory agencies that had jurisdiction were contacted or their proffered regulations or ordinances were reviewed. We contacted or reviewed regulations of the Mines and Minerals Bureau of IDALS, the Iowa Department of Agriculture and Land Stewardship; MSHA, the federal Mine Safety & Health Administration’s Fort Dodge office; the Iowa DNR; the State Fire Marshal; the Iowa DOT Vehicle Enforcement; and the Winneshiek County Zoning Code ordinances that were cited as ordinances that would regulate frac sand mining. You will notice the complete lack of any departments of health or human needs and services. The importance of this lack will be fleshed out in the Johns Hopkins study below.

            Our analysis of those proffered regulatory schemes yielded many areas of mining that are not regulated by any agency or entity. The shortcomings we found in the regulatory protections for the public we categorized using these seven words and phrases:

1. Patchwork: meaning there are different regulations in different areas none of which overlap, or cover, the entire industrial endeavor. Agencies are separate, regulate different aspects, and don’t talk with each other.

2. No one overall agency: meaning there is no agency that is in charge to make sure that all agencies that should be involved are involved in regulating an industry. And, that those separate agencies are coordinating with each other.

3. Complaint basis: meaning that ordinary citizens must know all about the industrial processes, chemicals used, etc, and know the regulations that should be being followed in order to report pollution events and to protect themselves from chronic long term pollution. This also means that any pollution event the public becomes aware of has already happened.

4. Self regulation: enabling type language in regulations means an industry decides and implements its own ways to meet some regulations. And, no agency regulates actual frac sand mining; the mining company decides how to mine.

5. Local officials lack expertise: meaning local officials are not experts in the regulated industry and have the same problems that are mentioned in #3.

6. Budgetary constraints – authority but no resources: meaning agencies have authority to regulate but no budget for enforcement.

7. Externalities: the human health, infrastructure, and environmental costs of areas considered externalities by industry are borne by the public: neighbor’s health and quality of life including noise, lights, views, constant truck travel, ease of travel, safety of travel on roads, children’s and adult’s ability to enjoy the outdoors, ability to enjoy your property; dust and diesel exhaust; hill and bluff removal; forest removal; the filling of adjacent valleys; roads, bridges and traffic; ability to enjoy the environment through tourism and outdoor activities; employment in tourism, farming, and outdoor activities; etc.

            So, how do we know that our regulatory analysis is correct? One way is to look at other analysis of similar regulatory situations. With the West, TX, fertilizer plant explosion a few days after our analysis was complete, investigative journalists looking at the regulatory scheme that was in place – local, state, and federal – found and identified weaknesses in those regulations that contributed to the explosion. Interestingly, those journalists used the same words and phrases describing the West situation that WCP used in describing the weaknesses in the proffered frac sand regulations. Those same descriptive words and phrases also showed up in the Charlotte, WV, chemical spill which affected drinking water for hundreds of thousands of people.

            And, the 2014 Johns Hopkins University study “Investigating the Role of State Permitting and Agriculture Agencies in Addressing Public Health Concerns Related to Industrial Food Animal Production” used the same descriptive words and phrases to show the gap between what “public health threats” are known coming from industrial ag animal production and what is being done through regulations to protect the public from those health threats. Besides bringing to light the lack of department’s of health in regulatory schemes, this is a seminal study on its own in the area of industrial agriculture. If you google and read the study, you will be introduced to the context those who have been active in this area have struggled under for the last twenty years. And, you will see why, as a result of which regulatory departments have a say, we have been able to make so little headway in protecting the public.

            What this regulatory analysis and these examples show is that this isn’t an industry specific problem. Rather, it is a systemic problem with the regulatory schemes put in place in the US to protect people from potentially harmful industries and processes.

            Understanding that existing local, state, and federal regulatory schemes leave out many important areas including human health, WCP put together what we considered the minimum land use ordinances to address those shortcomings. The intent was not to regulate the frac sand industry. The intent was to make sure the people of Winneshiek County, and Winneshiek County itself, would be protected from possible, and probable, pollution events, both long term and immediate, that might be caused by lack of regulations regarding the use of land for frac sand mining.

            If there are areas of WCP’s suggested ordinances that may seem peculiar or out of place, hopefully this explanation of what is lacking in local, state, and federal regulations will allow you to see that we are trying to provide protections for people and the county where no protections are provided.

Bob Watson

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8-27-02 ethanol.doc

Dear Editor,

            Sunday’s Minneapolis Star Tribune’s banner headline has to do with all the “dry process” ethanol plants in Minnesota being required by the EPA to spend tens of thousands of dollars on new equipment because of emitting carcinogenic and other harmful pollutants.  Monday Randy Uhl is back in front of the Winneshiek County Supervisors trying once again to site the “dry process” ethanol plant in the county that county voters already turned down.

            Randy Uhl and Rob Denson were going all over the county saying the only thing that would come out of these miracle ethanol plants were water and of course gobs of money. What really comes out, although those of us who tried to tell people this were shouted down and derided, is:

            Carbon monoxide: An odorless, colorless gas that reduces the flow of oxygen to the bloodstream.  In small amounts it can impair alertness, or cause fatigue and headaches.  In large amounts it can be fatal.

            Acetaldehyde: pungent, fruity odor. Cancer-causing in animals, probably in humans.

            Formaldehyde: pungent suffocating odor.  Cancer-causing in animals, probably in humans.

            Acrolein: piercing, disagreeable odor.  Toxic to upper respiratory system in animal studies.

            2-furaldehyde (furfural): almond-like odor. Moderately irritating to skin, eyes and respiratory tract at industrial concentrations. Little or no long-term health information.

            Acetic acid: vinegar. Unknown health effects.

            Lactic acid: skin and eye irritant at industrial concentrations.

            The residents of Winneshiek County deserve better than this.  When so-called leaders in the community can so blithely misrepresent industrial processes in their never ending pursuit of money, meanwhile risking resident’s health, their leadership is sorely called into question. 

            If they are still considering the original site west of Ossian, you people should be doubly concerned.  We have already said no to site-ing this miracle plant in our county.

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letter ammendments needed for any particular.doc

Dear Editor,


Whether we like it or not, the political realm is where we as a society make our societal decisions. With the advent of money so controlling our politics (we are more an oligarchy than a democracy because of this), no matter what your particular issue is, or where your effort lies, unless we get money out of politics, you have little hope of affecting how your particular issue plays out.

To that end, we should adopt six amendments to our constitution:

1. Corporations are not people. A person is one human.

2. Money is not speech. Speech is what a human does to communicate.

3. Publicly funded political campaigns. The only money that can be spent on or about a political campaign is the public funding given to a particular candidate.

4. Voting districts will be chosen by an independent commission working off of census data. Districts should be the simplest geometric shape that divides population.

5. No negative campaigning. Only can talk about who you are and what you will do.

6. End that vestige of slavery, the Electoral College.

If we adopt these amendments, we will have the possibility of once again having statesmen (gender inclusive) elected to our government beholden to us and not the highest bidder.

Bob Watson

Rural Decorah

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declaratory case strategy.doc

Declaratory case strategy:

Wally – Karl – Nate,

            As time runs out for the DNR to issue the declaratory order that we have requested, it may be time to start on broad outlines of what our court case might look like.

            Our section four, the context with Jillian Fry’s study, was hanging there without a hook until we had to follow the state’s template in order to file the request. The “class of citizens who would be affected” template requirement allowed our section four to be a legitimate (required) part of the would-be lawsuit.

            What is outlined and described in section four is ongoing, and will be ongoing still if we lose the technical argument about air emissions containing excreta/waste/ manure. We need to figure out how to make sure that we highlight this context from the beginning of a possible trial, throughout the trial, and in the closing of the trial.

            The court should be made aware that by the DNR arguing against our position, they are arguing for the continuation of this ongoing human health, and quality of life, problem. The court should be made to understand that if this technical manure stance by the state wins, it also allows the context that section four shows to continue. In essence, the state is arguing for the continued health hazards to people living in proximity to confinements by arguing against regulating manure in air emissions (an implicit argument). And we are arguing for a different outcome for those people if manure from air emissions are regulated accordingly (using Karl’s wording).

            It seems that section four is as important, or more important, than our technical argument about air emissions from hog confinements containing manure. It is as important both during the court trial as context, and in the public awareness about what the DNR’s stance means to people living in proximity to confinements, especially if the DNR prevails.

[I was at the DNR Monday and they are not going to issue the declaratory order we asked for. That is too bad and as I told the DNR person I was speaking with, they are making the implicit argument that profit for corporations through pollution as an externality is more important to the state than neighbors health. Not a good moral argument for the state of Iowa to be making.]

            So, we need to work on the technical “manure in air emissions”, but we also need to keep the context of “people living in proximity to hog confinements” front and center.

Bob

constituent parts – of manure – if we take all the constituent parts out of something X, we are left with nothing.

-our strategy is as simple as introducing our document. It has all the arguments and justifications that we need. Our job is simply to keep the court on track of our arguments against any strawman arguments the DNR/state comes up with.

-we don’t have to prove the studies, we are simply citing the studies.

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draft final petition to DNR.doc

Petition for a declaratory order from the DNR:

Our position is that air emissions from hog confinements contain excreta/waste/manure which according to Iowa code is to be retained in the building between application events, and our position is that the DNR should regulate these emissions accordingly. Referencing the technical information, government studies, and research studies in this document justifying our position, does the DNR agree with our position and will they issue a declaratory order stating such?

1. We agree with the state’s and DNR’s definition of excreta/waste/manure: Iowa Code Section 459.102(39) defines manure as “animal excreta or other commonly associated wastes of animals, including, but not limited to, bedding, litter, or feed losses.” The DNR rule has exactly the same definition.

This is a “quality” definition of waste in that it talks about what the waste is made of, its constituent parts; including hydrogen sulfide, ammonia, methane, antibiotic resistant organisms, and particulates which we cite in this document. As written, this definition includes everything that comes off of, or out of a pig, and any feed loss in a modern hog confinement. Basically, everything in a modern hog confinement is included in this definition except the hogs.

The state calls this material excreta. In the wastewater industry in similar environments, this material is called waste. The industrial agriculture people call this manure. We will use these terms interchangeably: excreta/waste/manure.

We are prepared to defend the state’s quality definition of excreta/waste/manure from other definitions including quantity definitions such as a materials handling definition. Quantity definitions say nothing about what is in the waste, its quality, i.e. what makes up the waste.

There may be some who say that air emissions from a modern hog confinement do not include excreta/waste/manure. That is a specious argument based on an idea of an “ideal historic excreta/waste/manure.” That “ideal historical excreta/waste/manure” which may be argued is not being discharged (but some other separate things are) is based on excreta/waste/manure from pigs in the past that were raised naturally on the land without the use of antibiotics, growth hormones, and such. Those pigs’ excreta/waste/manure, when deposited directly onto the land, naturally broke down through action by wind, water, sunlight, insects, animals, and soil organisms, into its beneficial constituent parts and contributed to the fertilization of the soil and the nutrient uptake cycle. That historical manure is not the waste that we see in today’s state mandated modern hog confinements. Modern hog confinements have a pit that the excreta/waste/manure drops into. This environment has no sunlight, wind, water, insects, animals, or soil organisms that help break down the waste as happens in a natural setting. The waste in a modern hog confinement breaks down in an anaerobic environment producing all of the constituent parts that we mention and cite in this document including gasses, particulates, and antibiotic-resistant organisms. These constituent parts of the excreta/waste/manure, the gasses, particulates, and antibiotic-resistant organisms, are vented or blown out of the confinement into the neighborhood and larger environment.

There is no argument that hydrogen sulfide, ammonia, methane, antibiotic-resistant organisms, VOCs, and particulates are constituent parts of the Iowa Code’s quality definition of excreta/waste/manure. This is, and has been, known through the literature and studies for many years and is an accepted fact.

2. Iowa Code Section 459.311(1) requires that a confinement feeding operation shall retain all manure produced by the operation between periods of manure disposal. A confinement feeding operation shall not discharge manure directly into a water of the state or into a tile line that discharges directly into a water of the state. 

This section contains two discreet sentences. The first sentence says that no excreta/waste/manure will be discharged between field application events. The second has to do with excreta/waste/manure reaching a water of the state.

Referencing Iowa Code Section 459.311(1), we contend the 24/7/365 discharge through air vents or blowers contain excreta/waste/manure.

The gasses hydrogen sulfide, ammonia, and methane, antibiotic-resistant organisms, VOC’s, and particulates are discharged out of hog confinement air vents/blowers 24/7/365. This is, and has been, known through the literature and research studies for many years and is an accepted fact. These are constituent parts of the waste as the waste breaks down in an anaerobic environment. We cite research in this area in this document.

3. We are asking the DNR for a “declaratory order” stating hog confinement air emissions contain excreta/waste/manure which according to Iowa code is to be retained in the building between application events, and that the DNR should regulate these emissions accordingly.

4. This section will reference studies that we have included in this document that will go a long way towards giving the court an understanding of the context surrounding this issue. That context has made it virtually impossible to use the regulatory system to protect human health from the harmful emissions coming from modern Iowa hog confinements.

There are times within an issue that someone does a study, or writes a paper, that allows all of the supposed disparate parts to fall into place. In this hog confinement issue that study is the 2014 Jillian Fry Johns Hopkins study. That study investigates the role of state permitting and agriculture agencies in addressing public health concerns related to industrial food animal production. The Fry study, included in this document, goes into great detail showing and discussing the gap between known public health threats from industrial agriculture and what is being done to protect the public through regulations from those known health threats.

From the Fry study:

            “Research linking IFAP (Industrial Food Animal Production) to public health concerns and impacts continues to increase. In addition to posing respiratory health risks to those residing near operations [4]-[8] due to emissions that include hydrogen-sulfide [9], particulate matter [9], endotoxins [10], ammonia [11], allergens [12], and volatile organic compounds [13], [14], odor generated by IFAP operations and spray fields has been associated with a broad range of health problems. Public access to information regarding hazardous airborne releases from IFAP operations is hindered due to exemptions in federal laws that require disclosure of such releases [15], despite research linking chronic exposure to odors from IFAP to headaches, nausea, upset stomach, mood disorders, high blood pressure, and sleep problems [16]-[20]. Additionally, there is growing evidence that livestock can transmit methicillen-resistant Staphylococcus aureus (MRSA) to humans [21]-[23].

            …Common across most states, however, is delegating the permitting to an agency without a primary mandate to address public health [31], raising concerns that public health issues may not be adequately monitored or addressed by the agencies tasked with regulating IFAP operations. …

            …No staff member, in permitting or agriculture agencies, said that they provided information regarding potential health issues related to IFAP. …

            …Our study reveals that sampled state permitting and agriculture agencies have taken limited actions to prevent and/or respond to public health concerns arising from IFAP operations. The main barriers identified that prevent further engagement include narrow or inadequate regulations, a lack of public health expertise within the agencies, and limited resources. There was widespread agreement among permitting and agriculture agency interviewees that health departments (HDs) should play a role in regulating IFAP operations, partly due to their own agencies’ limited mandates and available expertise in public health. Yet previously published findings show limited involvement by local and state HDs due to political barriers and a lack of jurisdiction, expertise, and resources [36].

            These results indicate a fragmented system to protect public health where no agency has ownership of monitoring or addressing the impact of IFAP on people’s health. In short, HDs generally lack jurisdiction over IFAP operations [36] and permitting and agriculture agencies generally lack jurisdiction over and the capacity to address public health concerns. A growing divide between environmental and public health agencies was identified in the 1990’s as a trend that threatens public health protections [42]. Research has found that the main foci of environment agencies have shifted to permitting, enforcement, record keeping, and standard setting, and away from public health evaluations [43]. Our findings are consistent with these trends.”

5. All of our information including some 800 studies, research articles, powerpoints, etc, will be filed along with this “request for declaratory order” to justify our perspective and contentions (See attached Appendices A-C).

Bob Watson

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Unintended 9-14-2017.ppt

Bob Watson

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july 15 P&Z presentation.doc

            One of the first things that was done by the Winneshiek County Protectors (WCP) concerning possible frac sand mining in Winneshiek County was to look at the regulatory scheme that might be in place to protect the public and the county from any possible pollution problems stemming from frac sand mining; chronic long term pollution or particular immediate pollution events.

            Regulatory agencies that had jurisdiction were contacted or their proffered regulations or ordinances were reviewed. We contacted or reviewed regulations of the Mines and Minerals Bureau of IDALS, the Iowa Department of Agriculture and Land Stewardship; MSHA, the federal Mine Safety & Health Administration’s Fort Dodge office; the Iowa DNR; the State Fire Marshal; the Iowa DOT Vehicle Enforcement; and the Winneshiek County Zoning Code ordinances that were cited as ordinances that would regulate frac sand mining. You will notice the complete lack of any departments of health or human needs and services. The importance of this lack will be fleshed out in the Johns Hopkins study below.

            Our analysis of those proffered regulatory schemes yielded many areas of mining that are not regulated by any agency or entity. The shortcomings we found in the regulatory protections for the public we categorized using these seven words and phrases:

1. Patchwork: meaning there are different regulations in different areas none of which overlap, or cover, the entire industrial endeavor. Agencies are separate, regulate different aspects, and don’t talk with each other.

2. No one overall agency: meaning there is no agency that is in charge to make sure that all agencies that should be involved are involved in regulating an industry. And, that those separate agencies are coordinating with each other.

3. Complaint basis: meaning that ordinary citizens must know all about the industrial processes, chemicals used, etc, and know the regulations that should be being followed in order to report pollution events and to protect themselves from chronic long term pollution. This also means that any pollution event the public becomes aware of has already happened.

4. Self regulation: enabling type language in regulations means an industry decides and implements its own ways to meet some regulations. And, no agency regulates actual frac sand mining; the mining company decides how to mine.

5. Local officials lack expertise: meaning local officials are not experts in the regulated industry and have the same problems that are mentioned in #3.

6. Budgetary constraints – authority but no resources: meaning agencies have authority to regulate but no budget for enforcement.

7. Externalities: the human health, infrastructure, and environmental costs of areas considered externalities by industry are borne by the public: neighbor’s health and quality of life including noise, lights, views, constant truck travel, ease of travel, safety of travel on roads, children’s and adult’s ability to enjoy the outdoors, ability to enjoy your property; dust and diesel exhaust; hill and bluff removal; forest removal; the filling of adjacent valleys; roads, bridges and traffic; ability to enjoy the environment through tourism and outdoor activities; employment in tourism, farming, and outdoor activities; etc.

            So, how do we know that our regulatory analysis is correct? One way is to look at other analysis of similar regulatory situations. With the West, TX, fertilizer plant explosion a few days after our analysis was complete, investigative journalists looking at the regulatory scheme that was in place – local, state, and federal – found and identified weaknesses in those regulations that contributed to the explosion. Interestingly, those journalists used the same words and phrases describing the West situation that WCP used in describing the weaknesses in the proffered frac sand regulations. Those same descriptive words and phrases also showed up in the Charlotte, WV, chemical spill which affected drinking water for hundreds of thousands of people.

            And, the 2014 Johns Hopkins University study “Investigating the Role of State Permitting and Agriculture Agencies in Addressing Public Health Concerns Related to Industrial Food Animal Production” used the same descriptive words and phrases to show the gap between what “public health threats” are known coming from industrial ag animal production and what is being done through regulations to protect the public from those health threats. Besides bringing to light the lack of department’s of health in regulatory schemes, this is a seminal study on its own in the area of industrial agriculture. If you google and read the study, you will be introduced to the context those who have been active in this area have struggled under for the last twenty years. And, you will see why, as a result of which regulatory departments have a say, we have been able to make so little headway in protecting the public.

            What this regulatory analysis and these examples show is that this isn’t an industry specific problem. Rather, it is a systemic problem with the regulatory schemes put in place in the US to protect people from potentially harmful industries and processes.

            Understanding that existing local, state, and federal regulatory schemes leave out many important areas including human health, WCP put together what we considered the minimum land use ordinances to address those shortcomings. The intent was not to regulate the frac sand industry. The intent was to make sure the people of Winneshiek County, and Winneshiek County itself, would be protected from possible, and probable, pollution events, both long term and immediate, that might be caused by lack of regulations regarding the use of land for frac sand mining.

            If there are areas of WCP’s suggested ordinances that may seem peculiar or out of place, hopefully this explanation of what is lacking in local, state, and federal regulations will allow you to see that we are trying to provide protections for people and the county where no protections are provided.

Bob Watson

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ag terrorisim.doc

Dear Editor,

            I agree with the president of the Iowa Pork Producers that the current bio-security system of Iowa hog confinements is inadequate. (“We must do more to protect our farms from terror threats” DSM Register 7-10-17) You see, it seems we can’t keep any of the dangerous toxic sewer gasses, antibiotic resistant organisms, and other harmful constituents of confinement waste (so-called valuable manure) inside the confinements.

            These toxic, lethal, human health and environment damaging gasses and organisms must be vented out into the surrounding neighborhoods in order to keep the pigs inside healthy and alive. This dangerous pollution blown out of confinements, called an externality by corporations, is left up to neighbors, the environment, and taxpayers to deal with.

            Confinements don’t just stink. Hydrogen-sulfide causes central nervous system and digestive system problems in neighbors of confinements, and can be lethal to both pigs and people. Ammonia causes respiratory and other diseases including asthma, especially in children. Ammonia forms a cloud over Iowa which comes down on us in rain events and is a major factor in the new acid rain, nitric acid rain, causing damage to the environment that is similar to the old acid rain scourge.

            Methane is an explosive and greenhouse gas which causes confinement fires and is thirty times worse for climate change than carbon dioxide. Antibiotic resistant organisms from confinements, including MRSA, harm human health and beneficial soil organisms. If you are already colonized with MRSA, you are more likely to get a MRSA infection when you go into a hospital environment. And, by harming beneficial soil organisms these antibiotic resistant organisms interfere with the natural nutrient uptake cycle of plants.

            In the wastewater industry, through understanding the causes of diseases and deaths from these gasses, regulations and design standards no longer allow normal human workplace proximity to places that produce these toxic sewer gasses. Entry into these types of “confined spaces” is strictly controlled through the federal OSHA Confined Spaces Regulations. People are protected from these toxic sewer gasses by regulations in every sector of America except in agriculture. Neighbors suffer, but we are told this is the safest and healthiest way to raise pigs. A confinement can be seen as a poorly designed and poorly operating wastewater anaerobic digester; or if you wish, an outhouse on a massive scale.

            Over the last 25 years, I have been to many county meetings talking about or protesting hog confinements. The only place that I can recall hearing farm and rural women cry as long and as hard as I have heard women cry at these meetings is when I was a combat Marine in the rice paddies of Vietnam where we were destroying farm women’s crops, their farms, killing their farm animals, and their farmer husbands, fathers, brothers, and sons.

            Worrying about a fifteen year old piece of cave writing out of Afghanistan purporting to use bio-weapons against US agriculture, while ignoring the current ongoing onslaught of rural neighborhoods and communities from the harmful, lethal, and apparently legal, pollution from hog confinements, seems a little like the pot calling the kettle black.

Bob Watson

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history and iec.doc

All,

            We are getting a little off base here with groundwater conferences and such. We have no studies in Iowa that show groundwater pollution coming from hog confinements that I know of. There are a few studies that show groundwater pollution, but I only know of them from the state of Washington and those were from dairy farms. We have almost a 1000 studies showing human health, soil, wild animal, and other environmental harm coming from confinement waste, including studies on hydrogen-sulfide and ammonia, methane, other gasses and toxic compounds, and antibiotic resistant organisms, in and from the waste, moving through the air, physically through spreading waste, contaminated trucks and other vehicles, or through bodily transfer. An early 177 of those studies were the basis of our EPA lawsuit, and they weren’t disputed by the courts or the EPA. We lost only because the statute language in the Clean Air Act said that even if the EPA administrator knew of these problems, she (in this case) had the discretion to not take any action.

            I worked in my first confinement in 1960 in Greeley de-beaking chickens  I started working on the affects of hog confinements in the 1980’s. I have a long history with this issue in the state. I don’t recall IEC being a player in hog confinement issues. I do know of some of their history as it has to do with cranking on wastewater plants – the anti-degradation regulations, and their stance on the Iowa Plan – which somehow was going to help stop runoff and pollution from corn and bean fields by making the diameter of field tile lines larger. I argued against the anti-deg reg’s because of the background pollution in our water from ag; intra-Iowa waters wastewater permit reg’s allowed 200 fecal colonies per liter (or milliliter) from wastewater plants, and the background in the Upper Iowa (and other waters I’m sure) was one million; the Mississippi was two million. The cleanest places in most Iowa rivers are at the discharge pipes of treatment plants. This is a rate payer argument. Why was IEC arguing something that would keep lowering discharge limits for wastewater plants and increasing rates for people when the unregulated ag discharge is what is making our waters polluted. The Iowa Plan should be obvious. It was a forerunner of the Iowa Nutrient Reduction Strategy. How’s that doing?

            At the Monday Winneshiek County Supervisor’s meeting, John and I sat through another permitting process for two more confinements around North Winn School. Waukon Feed Ranch was involved. Waukon Feed Ranch has some of the semi’s running up and down Water Street that I wrote about in the Decorah truck route letter I sent you last week. North Winn was the basis for our EPA lawsuit because of asthma rates four times the state rate in their students – the Kline study that I gave you. And these two new confinements will make North Winn’s air environment even worse. No regulations protect North Winn students from air pollution from hog confinements.

            Kewaunee County has only recently woken up to the fact that their dairy confinements, and the recent introduction of industrial row crop agriculture to their agricultural landscape, has turned Green Bay into a cesspool and a growing dead zone (from dairy confinement waste and dissolved reactive phosphorus from no-till for the most part) – see http://elpc.org/wpcontent/uploads/2015/02/ConfCon15_KevinFermanich.pdf . Kewaunee County has nothing to tell us about farming and hog confinements in Iowa that we don’t already know.

            I appreciate IEC as a group. I appreciate that IEC was asked to facilitate meetings for this group. But, IEC is doing what they know how to do, conferences, water, and bringing in so-called experts. That isn’t going to help fight the confinement nursery in Allamakee County that this group was originally put together to address. Or, the two more confinements going in around North Winn in the near future.  

            Our problem is legislative and political. We already understand the technical problems. We aren’t going to get people from out of state that will solve our legislative problems for us. In fact, ALEC, the out of state group, is doing a very good job of screwing us and making our problems worse.

            Larry and I, separately and together, have given presentations around the state, and in other states, to government entities and private groups for over 20 years. We have worked with many Iowa based experts in those 20 plus years. There are many Iowa experts and I have used a quite a few Iowa experts in my now five, as of this April, Iowa Academy of Science Symposiums, which have all been on industrial ag issues.

            There is nothing that we can do to stop these confinements unless there is a change in who we elect both in the Iowa Legislature, and the US House and Senate. Or, unless we can get sane legislation through in Iowa, or, unless our lawsuits in the future will make changes.

            You know, just saying…we might want to work more on confinements in karst.

Bob Watson

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iowa experts.doc

Experts’ response from Bob Watson.

Some of us are getting a little off track here. We need to focus on confinements in Iowa and especially in NE Iowa karst!

We don’t need people from other states telling us what to do. We know how to farm.

If you have been involved in this issue, you’d know we’ve been trying to educate people and to fight these battles with assistance from a number of expert Iowans for over 20 years.

The problem is politics – not a lack of information. This is the problem both in Iowa and nationally.

Why spend $100 and drive to Newton to ask a question?

Kewaunee County has only recently woken up to the fact that their dairy confinements, and the recent introduction of industrial row crop agriculture to their agricultural landscape, has turned Green Bay into a cesspool and a growing dead zone (from dairy confinement waste and dissolved reactive phosphorus from no-till for the most part) – see http://elpc.org/wpcontent/uploads/2015/02/ConfCon15_KevinFermanich.pdf .

When I first was asked to join this group, it was because I had a pretty good understanding of this issue and a long history in it. I was told that IEC was asked to facilitate meetings for people that didn’t know what to do but were in opposition to a large nursery complex in a sensitive area of karst. There are some good aspects to what is going on in the group, the county supervisor resolutions, Karl’s attempt to write legislation, and David’s work in the legislature to name some. But, there are people in this group who have little history with the issue and may be getting a little off track. In my mind, the focus needs to return to confinements increasing in number in karst, and elsewhere, and what can be done about that. John and I were at a Winneshiek county supervisors meeting Monday that was about permitting two more confinements around North Winn school. We need Iowa people working for, and helping, Iowa people. How that happens with this group, I’m not really sure. But, driving 3 hours to Newton and spending $100 to ask a question, or bringing in someone from Wisconsin to tell us how to farm, is not going to do anything to educate Iowa people about the dangers of hog confinements.

Larry Stone and I, both together and separately, for the last 20 years have given presentations on the hog confinement issue (Unintended Consequences of CAFOs), and crop and cropping system issues (5 Pillars of Ag), in other states and around Iowa. Those presentations have included many county supervisor boards, Iowa government departments – including the Dept of Health, and many public and private groups around the state interested in, or affected by, this issue. We are Iowa people. There are other Iowans who do this, too. We know what we are talking about.

Larry and I have been asked to give, and have given, presentations in other states because we understand the hog confinement issue. I, and other Iowans, have been asked to send, and have sent, information to activists, and lawyers who had cases, across the US. If you have been involved in the hog confinement issue, you would know that Iowa people are asked for their knowledge by people from other states.

Our problem is legislative and political. We understand the problems. We aren’t going to get people from out of state that will solve our legislative problems for us. ALEC, the out of state group, is doing a very good job of screwing us and making our problems worse.

Those are the short questions/comments to Larry’s question.

Here is more background talking about some Iowa experts, if you choose to read it.

There are many others who work across the state in this issue, but here are some Iowans from my experience who are “experts” in our industrial ag and hog confinement issues:

Twenty years ago I put together a series of lectures in Decorah having to do with the spread of hog confinement systems. They were all Iowa people including Dennis Keeney – Leopold Center; Kendall Thu – U of Iowa now at Northern Illinois, who did many early studies on affects on neighbors; Eric Sessions talked about marketing of pasture raised pigs, and now does garden CSA field days for Practical Farmers of Iowa. PFI as well as Iowa RC&D’s, many college and university people, and regular Iowans understand cropping systems that can keep soil and pollution on fields. I talked about the technology of confinements, and that the waste is no longer “manure” which breaks down into harmless and helpful constituent parts in a few days, but is now, because of cooking in an anaerobic pit for 6 months to a year, a toxic brew containing many harmful toxins and antibiotic resistant organisms that harm human health, soil organisms, and the environment. We were Iowa people.

My first symposium for the Iowa Academy of Science some ten years ago, “Stressing Iowa’s Environment”, included Jim Stricker – Region 5 DNR Supervisor talking about the history of the Clean Water Act. Mary Skopec, PhD – DNR Water Quality Section talking about the state of our state waters. And myself talking the stress being put on Iowa’s environment from industrial ag, and specifically about our lawsuit against AgriProcessors mini-mountaintop mining putting up their 50,000 head chicken confinements by knocking the tops off of hills here in NE Iowa. We were Iowa people doing this symposium.           

My second IAS symposium included Tara Smith, PhD – then at the U of Iowa, now at Kent State, who is the leading expert on antibiotic resistant organisms coming out of hog confinements in the US. She was the person who first discovered MRSA ST398 in the US which is unique to hog confinement hogs and people who work in hog confinements. And she did the study which showed Iowa City VA veterans who lived one mile or less from a hog confinement were three times more likely than vets who lived outside that one mile radius of being colonized with MRSA. Joel Kline, MD – U of Iowa spoke about his research on rural school students in proximity to hog confinements and asthma rates (4 times the state rate at the time of the study – and that study was done on North Winneshiek School students). And, I talked about the technology of hog confinements which allowed these things to happen. We were Iowa people.

My third IAS symposium included Keith Schilling, PhD – then with the DNR, now with U of Iowa, talking about water pollution from corn and bean industrial row crops. Mary Skopec, PhD – DNR talking about what happens to living organisms and small aquatic fish and animals because of that pollution. And, I presented my (with Larry Stone) 5 Pillars of agriculture which talks about crops and cropping systems that would end our ag pollution problems, and the Gulf’s Dead Zone. Again, Iowa people.

My fourth IAS symposium “Water Quality in Iowa: Background, Challenges, Solutions” included Jerry Anderson, J.D. – Drake University laying out the background (now head of Drake Law School) of the issue. Lora Friest, Executive Director of RC&D Postville (from Decorah and part of this group) discussing watershed work that can help prevent runoff. Matt Liebman, PhD ISU discussing STRIPS (native prairie) ability to mitigate erosion, nitrogen, and phosphorus coming from corn and bean industrial ag row crop fields. Kathleen Delate, PhD – ISU talking about how organic agriculture can mitigate ag pollution. Fred Kirschenmann, PhD – Leopold Center talking about a systems approach to fight ag pollution. Bill Stowe, CEO DMWW talking about the DMWW lawsuit. Steven Bruere, Co-Chair of Iowa Soil and Water Future Task Force talking about ways to limit ag pollution. I was not a presenter this time. I put the symposium together. We were all Iowa people.

My fifth IAS symposium which I have put together, and which is on April 21st of this year at UNI, is also a water symposium. This includes Chris Jones, PhD – U of Iowa (previously the chief scientist for the DMWW and then for the Iowa Soybean Association) presenting his research that shows if you do industrial ag corn and beans, you must have pollution; and making the argument that if you don’t test, you will never understand or know how to affect the pollution problem. Matt Helmers, PhD – ISU presenting new research that shows STRIPS not only mitigates surface water pollution, but can also mitigate groundwater pollution. Kristin Nemec, PhD – Director of the State Roadside Management Program which works with counties to plant native prairie in county roadside ditches (should get the same pollution mitigation numbers as does STRIPS in fields) talking about that program and what the Iowa legislature could do to help more counties become involved in that program. And, Senator David Johnson (our David Johnson) talking about what could be done in the legislature, and what might be done in the legislature, to address Iowa’s water pollution problems. These are all Iowa people.

I am already planning my sixth IAS symposium for next year which will in part talk about antibiotic resistant organisms from hog confinement waste harming beneficial soil organisms to the point where the soil is useless unless soil amendments are added to grow crops. And, what 60 years of fertilizers, herbicides and pesticides have done to our soils. And, what needs to be done to rebuild our depleted soils.
To write an op-ed against the Iowa Plan some ten years ago, which the IEC thought was a good idea at the time, and which was an early version of the Iowa Nutrient Reduction Strategy and is probably a part of the INRS, I put together a group of Iowans that included myself, Chris Jones, Jim Stricker, Bill Stowe, and Mike Burkart an Iowa State hydro-geologist. That op-ed ended up in the Des Moines Register among other papers. We are Iowans. 

In a separate symposium at this year’s IAS conference, Matt Liebman is back with a presentation on “Cropping System Diversification Strategies for Enhanced Performance and Greater Resilience – Two Case Studies.” This is about runoff.

As you can see, there are many Iowa people who can speak authoritatively to our issues.

And again, our problem is legislative and political.  

Bob Watson

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a not so funny thing.doc

            A not so funny thing happened on the way to a safer and healthier town for children and their parents who live in or visit Decorah.

            Three years ago an effort was started to curtail idling of diesel engines within the city limits of Decorah, and provide a truck route around Decorah for those trucks which were not based in Decorah or which didn’t have a Decorah delivery to make. This effort was started because the science and medical understanding of the negative health effects of particulates from diesel exhaust, and antibiotic resistant organisms coming from animal confinements and their equipment and trucks, for humans, especially children, is now well understood and not disputable.

            Although we had given this information to the city, it was two years before it was taken up by the Street Committee. And even then, it was apparent that some of the committee members had not taken the time to even read about what we were asking for, or read the information packet we had supplied to justify the idling ordinance and truck route request.

            A year ago we were pleased that four members of the City Council, Andy Carlson – Dan Bellrichard – Kirk Johnson – Steve Luse, were taking the request and the information that we had given them seriously, and also subsequently voted for the idling ordinance portion of the request.

            The information packet given to the city included, among other items, 156 peer-reviewed journal studies focused exclusively on the impacts of diesel exhaust and particulate matter on the brain. And, an additional 116 research-based reports, government reports, and related research focused on a multitude of other negative impacts on health by traffic-related air pollution and by diesel exhaust. The exhaust particles bypass the blood-brain barrier and go directly from your nose to your brain.

            The idling section also included research that is focused on solutions to the problems identified in the research, such as local government and state efforts to control diesel emissions (many city idling ordinances were included as examples), and solutions to mitigate the impact of traffic-related particulate matter (including native prairie planting as it mitigates diesel exhaust particles).

            Antibiotic resistant organisms, including MRSA, are such a big problem in hog and other confinement systems, that the FDA has recently enacted a new program, the Veterinary Feed Directive, to try to address that issue. Confinement bio-security systems cannot keep these antibiotic resistant organisms inside the confinement buildings so that they won’t negatively affect human health. Antibiotic resistant organisms infect at least 2 million and kill at least 23,000 Americans every year (CDC numbers).

            As part of the truck route packet we gave the city 297 peer-reviewed research studies, 38 research-based reports by government agencies, by independent, non-industrial organizations, or by university researchers, and 43 media articles, in these areas: detection of MRSA in livestock, particularly swine; links between human exposure to pigs and human MRSA colonization/infection; MRSA in meat products; spread of swine MRSA and antibiotic resistance to humans and wildlife through field application of pig waste, and via air transport; the role of antibiotic use by CAFOs in developing antibiotic resistance; other antibiotic-resistant pathogens resulting from agricultural use of antibiotics; and, risks to humans posed by MRSA colonization.

            In the city of Decorah, we have trucks and stock trailers traveling on Water Street filled with confinement pigs and their waste. We have trucks that transport feed to confinements traveling up and down Water Street. We have known since the 1976 Levy study that antibiotic resistant organisms move easily from confinement animals to farm families and workers, and neighbors of those confinement farms.

            We have known since the 2008 Johns Hopkins “Food Animal Transport” study that antibiotic resistant organisms blow off of trucks transporting confinement animals, and trucks that go to and from confinements. Those organisms settle on everything on and by the roads including sidewalks. If we know this, and if Decorah has become a tourist destination with many of us, and many tourists, eating and drinking and sitting on Water Street, or walking up and down Water Street shopping, why wouldn’t we enact a truck route to keep those trucks and stock trailers and their antibiotic resistant organisms from needlessly driving through town?

            It seems that the mayor, Don Arendt, and council members, Gary Rustad (who by the way wants to be mayor), Chuck Lore, and Randy Schissel are confused in their understanding of what is more important: human health, or the ability of some businesses to pollute, spread disease, and travel needlessly where they don’t need to be.

            Because of the mayor’s veto, the idling ordinance will have to wait until there is a new mayor to be brought up again. The truck route portion of our initial request is due to come before the city council Monday, March 20th. You should come to that meeting as it will be interesting to see who votes for the truck route resolution that night. And, to see if there is another mayor’s veto in the wings.

            If you value a healthy and clean place to live in, you might want to take an interest in these issues. And, you might want to educate yourselves as to who holds your and your children’s health more important than allowing some businesses to pollute. The ballot box is where you have the most influence. You might want to remember who votes for what when the elections come around.

            If you would like an electronic version of the Truck Route and Idling Packet that was given to the city, the city council, and the mayor, contact Bob Watson bobandlinda@civandinc.net , or Dick Janson harlan.janson@gmail.com . The city also has the electronic version of that packet and could send it to you. And, there are numerous downtown business people who have the electronic version of the packet and would share it with you.

Rural Bob Watson and Dick Janson

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post IAS water symposium musings and initiatives.doc

Iowa Academy of Science Water Symposiums 2016 and 2017 and beyond:

Musings and initiatives from the 2016 Iowa Academy of Science annual conference’s Water Symposium. The Water Symposium line-up of speakers is at the end of the musings and initiatives (below). Other speakers for 2017 are listed below also, along with how the 2017 symposium ended up and how that symposium fits together and what it tries to say. A 2018 symposium is foreshadowed in the Colorado soil organism article. This would be about the state of soil organisms and what could be done to start building those organisms back up.

Initiatives:

1. Extending the STRIPS system concept to address pollution issues from tile line flow. Tile lines are not considered part of surface runoff and another way of addressing this pollution coming directly from tile lines is needed.

We know that the STRIPS system, if adopted for all annual row crop fields, would stop 95% of the erosion from those fields along with the majority of nitrogen and phosphorus pollution from this surface runoff. We also know that there is some unpublished work that shows prairie root systems deep enough to affect tile line pollution may remove some 75% of nitrogen in groundwater that it comes in contact with. (Matt Helmers research)

If native prairie were planted in all county roadside ditches, this version of the STRIPS system could affect nitrogen and phosphorus from tile lines. Counties could adopt the state program (headquartered at UNI) of roadside management (which a number have done) using native prairie in ditches. This would directly affect the pollution coming from tile lines that empty into ditches.

1a. If the STRIPS system is adopted wholesale, original prairie soil microbes may be a necessary piece in order for that prairie to operate at its fullest capacity. Original prairie plots (remnants and pioneer cemeteries) could be cored and that soil profile, containing the original microbes, could be transplanted to those areas seeded into prairie. The pioneer cemeteries would have an added advantage of having microbes that are locally adapted to further enhance the ability of prairies to flourish in those local areas. (see the Dust to Dust article at the end of this document)

1b. Soil District tile line drainage ditches could also be planted to native prairie bringing the effectiveness of native prairie’s ability to mitigate tile line pollution to drainage district ditches.

1c. 1a and 1b would go a long way to cleaning up ag pollution without interfering with current cropping systems.

2. A three year CRP program titled “3 Year Conversion to Organic”.

During discussions on becoming organic, one of the reasons that is most often remarked upon as a problem for a farmer to convert to organic is the chemical free three years it takes to convert fields for organic certification. A simple “3 Year Conversion to Organic” program in the Conservation Reserve Program would allow income for the three years that fields must be chemical free in order to receive organic certification.

Musings:

1. The state could legislatively act on the roadside management program to make it easier for counties to adopt and afford. The roadside program people have many ideas on how to help this program.

2. The state could also help make it easy and affordable for soil/drainage districts to plant their ditches to native prairie.

This would have a major affect on the pollution coming from tile lines which are a different flow than surface runoff that the normal STRIPS system affects.

3. The state could also lobby the federal government to make the STRIPS system mandatory in the farm bill for all annual fields.

Since farmers did not choose this model, which has to pollute, they only did what the farm bill, land grant colleges and universities, extension services, and corporate ag entities have told them to do, the 10% of annual fields put into native prairie should have the seed provided by the government. And, the average profit per acre on that field should be paid to the farmer for that 10% acreage seeded to native prairie. (if we are a society, and if we all want clean water, air, and soil, we should all contribute to that end)

4. The state could lobby the federal government to introduce a “3 Year Conversion to Organic” program in the Conservation Reserve Program. If we are serious about an agriculture that doesn’t pollute in its normal practices, this conversion to organic is a good program towards that end.

5. Microbes article – original soil organisms from pioneer cemeteries:

[From the article: Dust to Dust: a man-made Malthusian crisis, by Ambrose Evans-Pritchard, Nov 2013.

American scientists have made an unsettling discovery. Crop farming across the Prairies since the late 19th Century has caused a collapse of the soil microbial that holds the ecosystem together.

The do not know exactly what role is played by the bacteria. It is a new research field. Nor do they know where the tipping point lies, or how easily this can be reversed. Nobody yet knows where this is happening in other parts of the world.

A team at the University of Colorado under Noah Fierer used DNR gene technology to test the ‘verrucomicrobia’ in Prairie soil, contrasting tilled land with the rare pockets of ancient tallgrass found in cemeteries and reservations. The paper published in the US journal Science found that crop agriculture has “drastically altered” the biology of the land. “The soils currently found throughout the region bear little resemblance to their pre-agricultural state,” it concluded.

You might say we already knew this. In fact we did not. There has never before been a metagenomic analysis of this kind and on this scale. Professor Fierer said mankind needs to watch its step. “We really know very little about one of the most productive soils on the planet, but we do know that soil microbes play a key role and we can’t just keep adding fertilizers,” he said.

The Colorado study has caused a stir in the soil world. It was accompanied by a sobering analysis in Science by academics form South Africa’s Witwatersrand University. They fear that we are repeating the mistakes of past civilizations, over-exploiting the land until it goes beyond the point of no return, and leads to a vicious circle of famine, and then social disintegration. …. google the title to read the rest of the article.]

Other speakers and ideas for 2017:

1. Chris Jones could present the op-ed that he had recently in the Gazette. In that op-ed he lays out in scientific facts and historical data the understanding that we will not end nutrient pollution until we end corn and beans. Chris and Keith Shilling just had an op-ed in about testing so that there would be actual numbers to go by.

2. Eric Baack from Luther College, biology prof, has been collecting data on antibiotic resistant organisms in springs around Decorah. These resistant organisms can be from industrial ag confinement waste spread on farm fields.

3. Kristine Nemec from the State Roadside Management program housed at the Tallgrass Prairie at UNI. How to get the legislature to help get this program adopted statewide.

4. Matt Helmers STRIPS and STRIPS groundwater research.

5. Drainage District STRIPS ­ John Torbert IDDA strips to drainage district land. Still have to talk with him. Mentioned him to Laura Jackson last week.

6. Laura Jackson 50 year farm bill.

7. David Johnson, ­ Iowa Senate, what the legislature could do to promote mitigation of ag pollution. We would have to have conversations with David about the things that could be done before the conference so that he would be able to coordinate his legislative suggestions with our practical suggestions.

Bob Watson

Who the 2017 Iowa Academy of Science Water Symposium speakers ended up being and how the symposium is designed and what we hope to show with the symposium:

Chris – Matt – Kristine – David,

            This short note is just to let you know how, in my mind, the symposium fits together with what each of you will bring to it.

            Chris will start off reprising his two recent op-ed’s which talk about the inherent pollution from planting corn and beans in this model. And, his contention that unless we test the waters of the state, we have no notion of where we are and therefore what we need to do to get cleaner water.

            Matt will follow with a short reprise of surface STRIPS which Matt Liebman presented last year, and then talk about what his research has shown on what STRIPS can do to clean up ground water.

            What native prairie can do to mitigate nitrogen and phosphorus pollution will then lead in to Kristine’s presentation on the State Roadside Management Program and its use of native prairie. And, what the legislature could do to make that program more easily adoptable and usable by counties. And, hopefully adopted by all Iowa counties.

            In light of these presentations and other thoughts, David will then be able to discuss what the legislature could do to help mitigate water quality issues in the state from his perspective of being in the state senate.

            So, that to me, is my simple explanation of the symposium and what I hope the symposium may accomplish, both through education and showing possible avenues of help in cleaning up Iowa’s waters.

            Not connected directly to the symposium, but as an offshoot of last year’s, and this year’s, water symposium, I have been in contact with John Torbert, Ececutive Director of the Iowa Drainage District Association, about the possibility and probability of planting drainage district ditches to native prairie the same as county ditches. There are some issues to work through, mostly that drainage districts supposedly are set up to get water away from fields as fast as possible, but since all tile lines are daylighted at some point, native prairie might work its magic in those ditches, too.

            The native prairie in drainage district ditches flows question is one that I will, at some point, ask Chris, Keith Schilling, and Matt and Matt, and Kristine, about. Since STRIPS is in the INRS but maybe not being promoted enough, and since no one seems to want to give up 10% of their fields to native prairie (unless the farm bill is changed somehow to pay for it), ditches of all kinds statewide planted to native prairie may be something that can help mitigate pollution until something better comes along. Again, this is not in this symposium, but is an offshoot of thinking about what we can do coming from what the symposiums have shown us.

Bob

The 2016 IAS Water Symposium line-up of speakers:

I helped designed a water quality symposium for the Iowa Academy of Science’s annual conference this year at Grand View University in Des Moines. The water symposium part of the conference is Friday, Apr 22nd (earth day), at 2pm in the Student Center – Speed Lyceum. This 2 1/2 hour symposium part of the conference is open and free to the public and the press.

This is the fourth symposium that I have put together for the IAS, but the first that I am not one of the presenters. This symposium will discuss the water quality issues that led to the DMWW lawsuit, and what is, and can be done, to address those issues. There will be an overview, practices inside the Iowa Nutrient Reduction Strategy, practices outside the INRS, and a discussion of the lawsuit itself.

There will be seven speakers. This is the lineup: (this is not an official press release – see IAS for that)

Jerry Anderson – Drake Law School – environmental lawyer who will do an overview of the nitrate pollution problem.

            From inside the INRS:

Matt Liebman, ISU professor and Henry Wallace Chair, STRIPS – 10% of native prairie stops 95% of erosion in annual row crop fields – pretty amazing when you understand that along with 95% of erosion that is stopped, the majority of the nitrate nitrogen and phosphorus pollution would be stopped, too. (this should be in the farm bill)

Lora Friest (from Decorah), NE Iowa RC&D does watershed work of the kind that is called for in the INRS.

            From outside the INRS and the industrial model:

Fred Kirschenmann, Leopold Center, who along with Wes Jackson and Wendell Berry wrote a 50 year farm bill which uses Wes’s perennial polyculture native prairie plants bred for large seed heads for human and animal consumption.

Kathleen DeLate from ISU will talk about how organic/small farms can help the water pollution problem.

            The lawsuit argument:

For: Bill Stowe – Gen Mgr of the Des Moines Water Works. Lawyer and civil engineer.

Against: Steve Bruerer – (even though the Dept of Ag (Northey), DNR (Gipp), Farm Bureau (Rick Robinson), and the Soybean Association (Roger Wolfe) are all against the lawsuit, all declined to be a part of this Iowa Academy of Science symposium.)

            Each presenter will have up to 20 minutes with time left over for Q&A.

This should be an interesting discussion.

Bob

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ISU and FDA final antibiotic resistance presentation.doc

            The presentation went forward over the next two hours with a conversation showing how to fill out forms correctly, etc., so that the producers, feed mill operators, and veterinarians could essentially continue doing exactly what they had been doing in the past as far as antibiotic use in CAFO’s. This presentation seemed more about gaming this new FDA program than following its directive to reduce the amount of antibiotics being used in agriculture.

            I had assumed I was going to a straight forward presentation of the FDA’s latest attempt to lower antibiotic use in agriculture. The 3 hour presentation by ISU Extension – Iowa Veterinary Medical Association – and the Farm Bureau was advertised as a discussion of what the FDA’s new Veterinary Feed Directive (VFD) program would mean for veterinarians, feed mill operators, and producers in Iowa in relation to antibiotic use.

            It was then somewhat surprising to walk into an “us versus them” presentation with environmental groups being mentioned as the “them” responsible for this new FDA regulation on antibiotic use in agriculture. It was more surprising when it was said that they could argue all day about whether there was an antibiotic resistance problem coming out of agriculture.

            That statement was alarming since the FDA’s website about why this program was developed specifically cites an antibiotic resistance crisis. Even an early 1970’s study of a Massachusetts chicken farm showed antibiotic resistant organisms took only two months to end up in that farm’s family’s bodies, and in the bodies of neighbors of that farm. We have compiled 575 peer reviewed journal studies that all have to do with antibiotic resistance problems coming out of agriculture. So that was a pretty strange perspective to introduce into the presentation.

            The presentation continued without any mention of the possibility of uncounted antibiotics getting into animal feed. I finally asked about the antibiotics used in the ethanol process that end up in dried distillers grains (DDGs) which is sold as feed. I was told that the FDA (and the presenters agreed with the FDA on this) said those antibiotics were not important for human medicine and there weren’t enough of them in the DDGs to worry about. That is a very troubling perspective in light of recent research and the understanding of what a confinement actually is.

            Studies looking at the efficacy of different hog confinement waste treatment systems show that while no treatment system studied successfully treated all antibiotic resistant organisms in the waste, anaerobic digestion (which Iowa hog confinements essentially are – a closed system with a fecal waste soup in the bottom decomposing into toxic sewer gasses blown out into neighborhoods negatively affecting neighbors health), besides being the least effective at treating antibiotic resistant organisms, actually allowed antibiotic resistant organisms to flourish in the waste through multiplying and trading parts.

            Iowa requires absolutely no treatment of confinement waste. Even worse, DNR design requirements for hog confinements have inadvertently required a building which allows antibiotic resistant organisms to flourish.

            When confinement waste is spread on fields, besides being a health hazard to humans, antibiotic resistant organisms negatively affect beneficial soil organisms’ role in providing plant nutrients.

            Regardless whether the amount of uncounted antibiotics in DDGs is small or large, those antibiotics add a different resistance gene pool to the waste that resistant organisms can use, allowing for new possible combinations of resistance creating more problems for antibiotic resistance in the future.

            This FDA VFD program is supposed to be about using fewer antibiotics in agriculture so that these kinds of environments become less of a problem and antibiotic resistance coming out of agriculture will decrease.

            I may be giving ISU Extension – Iowa Veterinary Medical Association – and the Farm Bureau too much credit for seemingly figuring out how to show people how to continue using antibiotics in agriculture the way they are accustomed to. We will probably never know whether the VFD program was originally set up by the FDA to be a sham program easily gamed (co-opted) by states. Michael Taylor, the lawyer who came from Monsanto and led this program, has since left government, so we can’t ask him. Furthermore, the FDA does not have authority to collect data that would show whether or not this program will do what the FDA says it is supposed to do. So if the FDA can’t collect data, it can’t know if the program is being gamed by the states.

            My perspective that this presentation showed people how to continue using antibiotics as they have in the past was shared. In informal conversations afterwards, it was mentioned that people who thought this program would lower the use of antibiotics in agriculture might be disappointed because it didn’t look like that use, or amount of use, would change much.

            Whether a sham FDA program from the beginning, or a program that can easily be gamed, that an original “land grant college”, Iowa State University, might seem to be working to co-opt a federal program designed to mitigate an antibiotic resistance problem coming from agriculture is very troublesome.

Bob Watson

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nafta and immigrants.doc

Dear Editor,

            The recent political season has loosed upon us some of the worst ethnic racism that we have seen to date in this country. Anti-immigrant postures and actions have been given license by some politicians.

            A real problem with this is that our children have, innocently, begun to mimic their parents and have acted, mostly unknowingly, in racist and derogatory terms towards other children and even adults.

            NAFTA has fueled much of the racism and anti-immigrant language and actions that we have seen. Well, are the stories about NAFTA that are being told to justify these actions true? I wonder.

            A recent op-ed in the Cedar Rapids Gazette talks about what happened to Mexico, and especially Mexican farmers, as a result of the bloated welfare queen that modern corporate industrial agriculture has become. As you read this excerpt, keep in mind what you would think if Mexico would have done to US farmers what we did to Mexican farmers.

            From Mohammad Chaichian’s, professor of sociology at Mount Mercy University in Des Moines, op-ed:

            “Championed by President Bill Clinton, NAFTA was implemented with the objective of breaking trade barriers and integrating the economies of Mexico, the United States and Canada, and closing the wage gap between American and Mexican workers. Instead, heavily subsidized American corn, beef and poultry products were dumped on the Mexican market, devastating Mexico’s agrarian economy, pushing millions of farmers out of rural areas, and forcing them to come north in search of jobs.

            In the meantime, U.S.-based multinational corporations established Maquiladora factories south of the U.S.-Mexico border, using the cheap labor of thousands of unemployed farmworkers. By destroying Mexico’s rural economy, NAFTA unleashed a northward migration of rural population, which in turn led to criminalization of migration, increasing militarization of the U.S.-Mexico border, and eventual erection of the wall along the U.S.-Mexico border by 2009.

            In order to secure American corporate interests, some pro-business politicians and lawmakers also advocate border fortifications and the use of implicit/explicit force and violence against undocumented migrants, as well as racially charge language.”

            So, as an American farmer, what would you do and feel if Mexico had done this to you? These are farmers, millions of farmers, who lost their farms and their livelihoods because of modern U.S. industrial agriculture and NAFTA.

            Quit enabling your children’s, and your own, boorish behavior and figure out the truth of what has happened to fellow North American farmers.

Bob Watson

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zero discharge argument.doc

This will be a little disjointed as it is a first draft of this line of argument. Bob.

Wally wants to add on to the zero discharge argument the argument that confinements are actually wastewater treatment facilities that have been erroneously named confinements.

1. Hog confinements are poorly designed and poorly operated anaerobic digesters.

            a. an anaerobic digester is a closed system that has fecal waste in the bottom of it constantly creating poison sewer gasses. To have humans go inside a digester, or any confined space, good air must be blown into the space blowing the bad air out or otherwise the people will die. (this is the constant venting of poison gasses we see in a hog confinement)

            b. anaerobic digesters, or any confined space (in any industry besides agriculture) are covered by the Federal Confined Spaces Regulations. Those regulations lay out how to enter a confined space, regulate what equipment and education people who have to work in these systems must have, and regulate how long people can be in these systems. Those regulations are in effect in all industries in the US except agriculture when people are working with confined spaces.

2. The DNR describes hog confinements as zero discharge storage facilities that also house pigs. The true description of a hog confinement is they are anaerobic digesters whose products from the fecal waste in them breaking down are the poison sewer gasses hydrogen-sulfide and ammonia, the greenhouse and explosive gas methane, antibiotic resistant organisms, particulates, and many other waste and pig products that are blown 24/7/365 into the surrounding neighborhood and the larger environment.

            a. confinements must constantly vent or blow out those products or the people and pigs inside will die. In the wastewater industry, through understanding deaths and diseases, we no longer allow normal workspaces in proximity to confined spaces. Design standards and regulations control human proximity to confined spaces whether they be anaerobic digesters, sewers, equipment vaults, etc.

            b. research looking at the efficacy of wastewater treatment in relation to treating antibiotic resistant organisms in hog confinement waste shows that while no treatment is very effective, anaerobic digestion is by far the worst treatment option. It turns out that anaerobic digestion is the best environment for the antibiotic resistant organisms to multiply in and to trade parts and pieces in. If we were looking to create an environment that allows for an explosion of antibiotic resistant organisms, we could not have created a better environment that the modern hog confinement building. It has all of the ingredients, a continuous supply of antibiotics – fecal waste – closed system – no oxygen – and vents and fans blowing all of that out into the environment.

            c. we have some 900 peer reviewed journal studies showing the human health and environmental damage done by the products of the anaerobic digestion and antibiotic resistant organism soup that is being called a hog confinement.

3. So, we are now making the claim that hog confinements should be designated (described) as wastewater facilities that should be regulated as any other wastewater facility because they are sewer environments that constantly discharge poison sewer gasses, antibiotic resistant organisms, particulates, and many other products from pigs living in an anaerobic digester, to the surrounding neighborhood and larger environment.

            a. Instead we are told that these are pig barns that store waste until it can be put on the land and used as valuable manure. That they are “zero discharge” facilities and that this is the safest and best way to raise pigs. (aside: in a sewer prison from birth to death) And, we are told that this is agriculture as we have always known it.

4. Confinement buildings are not the only source of danger here. There has been research that shows MRSA, and other antibiotic resistant organisms, can colonize and infect people in proximity to fields where confinement waste has been spread. Research shows you are three times more likely to be colonized with MRSA, etc, if you live within one mile of a confinement, versus people who live outside that one mile radius. And, that people who live in proximity to confinements have much higher rates of those diseases associated with hydrogen-sulfide and ammonia. The constant venting of the volatized waste products from confinements affect both the surrounding environment and also up to hundreds and thousands of miles away through nitric acid rain and the Gulf dead zone.

5. Probably more to follow as this argument is refined.

Zero discharge argument:

        A more concise statement of the zero discharge concept.

1. Address zero discharge status of confinements only. State by state, or federal?

2. Bypass the Clean Air and Water Acts by simply showing that discharge of pollutants is 24/7/365 from fans and natural vents.

        a. those pollutants – sewer gasses, greenhouse gas, antibiotic resistant organisms – are only being discharged because they are products of the waste. They are the waste.

3. Use same studies, plus hundreds of new studies, that have been accepted (not disputed) by the Federal District and Appellate Courts as well as the EPA.

        a. these studies show the human health and environmental harm being caused by these discharged pollutants. If these affects exist, and the court has accepted those studies, then confinements are discharging.

4. By going after the zero discharge designation of confinements, if we win, all permits, regulations, and ordinances that rely on “zero discharge” for their justification, will no longer have that justification and authorities will have to come up with a new scheme for allowing confinements to discharge (pollute). Or, they will have to agree that confinements discharge pollutants and will have to address that new status.

        Wally?

Bob

Wally,

        So, is a confinement a “zero discharge” entity as is claimed by the DNR?

        In a conversation with Mary Dougherty this week, she was wanting to know if a case could be made that when ammonia from confinements hits water, would that resultant product be a discharge? My answer at the time was that since that wasn’t what was considered a liquid discharge, a case probably couldn’t be made.

        But!!! Upon thinking about that line of thought later in the day, it seems that an argument could be made (without going where Mary was going) that since the gasses that are discharged 24/7/365 are a product of the liquid waste (the gasses wouldn’t be there if not for the waste), that could be deemed a discharge of the waste.

        We already have had our 177 studies (many more today – hundreds when you include the antibiotic resistant studies we now have), which were not disputed by the federal court or the EPA, that show what happens when these gasses are discharged (24/7/365), so we would not need to do any other work as far as finding facts to go with our case. We would just need to make an argument that these gasses are “waste discharged from the confinements”.

        What we would do with a lawsuit is change the designation of confinements as “zero discharge” facilities, which should throw a wrench in permits and regulations now on the books. Could be a big wrench when one thinks about all the different aspects that “zero discharge” now allow confinements to get away with. (that’s your world, Wally)

        Comments?

        Mary has said that the organization they have put together is looking to work on something like our lawsuit was with someone else. Maybe this would be a vehicle that we could partner with them on.


Bob

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terrorism.doc

Dear Editor,

        As someone who experienced terrorism firsthand while part of an occupying military, and someone who has studied historic causes of terrorism for the last 40 years, I can confidently say to you that there is a simple historically factual answer to terrorism for the US; get the hell out of other countries. We have military troops in 130 countries. Bring them home and terrorism will end.

        If you look at the history of terrorism, in part it is an act of violence against those who would conquer and occupy a country not their own. Or, it is an answer to perceived terrorism by an occupying, or hostile, country.

            Think whether or not you would consider a drone strike on a wedding party in Decorah an act of terrorism by “name your own country or group.” Then change the place of the wedding party to the Middle East and the drone to the US and see if you could possibly imagine why terrorism is being waged against us.

        The chickens are coming home to roost and we seem to be confused about this. What a bunch of dumb asses.

Bob Watson

Rural Decorah

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5-31-16 supervisors presentation.doc

May 31, 2016 9:30am presentation to the Winneshiek County Supervisors.

This is the outline for my presentation on 5-31.

1. new use document: first and last in presentation. We are beyond “this is agriculture” and we are into “this is a dangerous business practice”. See new use doc.

2. science is settled. the studies were not disputed by the Federal District Court, the Appeals Court, or the EPA. See story of lawsuit doc.

3. Jillian Fry study shows that humans are not included in the federal and state regulatory schemes when it comes to cafo’s – confinements and feedlots. So, it is left up to you to figure out how to protect county residents. See 460 study health board packet for the Jillian Fry Johns Hopkins study. It is a seminal paper and shows the same regulatory scheme as I found in the frack sand investigation, and the same scheme as was found when the West, TX explosion was investigated; people are not included in regulatory schemes.

4. the new unintended consequences powerpoint. You can go to www.civandinc.net appendix E to see a version of the power point presentation I will give you. The new ppt will leave out the North Winn section and put in an antibiotic resistant section (the 268 studies from the health board packet). I will also mention research that shows antibiotic resistant organisms spread in hog waste actually kills beneficial soil organisms.

5. end with the new use document again.

Documents and ppts:

1. this 5-31-16 supervisors presentation.

2. story of lawsuit.

3. new use document

4. email 460 study health board packet.

5. deliver to John the powerpoint presentation.

(only need to hard copy this document for supervisors)

Bob Watson

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story of lawsuit.doc

Zook, et al plaintiffs and funders,

            Well, the end of the road with the lawsuit has been reached. The Supreme Court decided not to hear our case and sent notice of that decision on Nov 2, 2015.

            Thank you very much plaintiffs for lending your names and yourselves to this effort over these last few years. It took much courage on your behalf’s to allow this lawsuit to go forward and to do as much good as it did during the journey through the courts. And, thank you very much to the funders for the financial support to make this lawsuit happen. A short summary of the lawsuit’s trip through the courts is included below.

            Although this part of the journey is over, other aspects have yet to be undertaken. We have learned much during this process. We have discovered much that we didn’t know before. And, we have amassed a huge number of studies that support our position.

            That information, and the history and story of the lawsuit, I hope to put into book form in the future; for two reasons. First, so that when I am asked to make presentations on this issue, all of the information we have – and how to use it – will be available in one document for people who are fighting this same issue. Second, we were beat by one word in the language of the EPA statute: “discretion”. With all our information in one document, we can lobby legislators to get that word changed so that “even though the EPA knows the human health and environmental damage” (some of the studies we site were conducted under the auspices of the EPA), they will not be able to “ignore” these facts because they have “discretion” to ignore these facts.

            So, I have put together a short summary of the lawsuit’s trip through the courts with some interesting facts that happened at each level. I will send this document to funders notifying them of what the outcome has been, and letting them know that they will receive some money back (percentage of what is left multiplied by what amount they put into the lawsuit fund).

            Since I have written the previous paragraph about returning unused money, I have had a number of people who wanted us to keep it for other purposes. We may intervene in a similar lawsuit, Humane Society v EPA. That lawsuit lacks our plaintiff standing, and our 177 scientific and medical studies. With that information and plaintiff standing, with knowing the shell game that the EPA is playing (see below), our intervening in that case makes for a better opportunity for that lawsuit to be successful. If you would like your remaining contribution to go towards our possible intervention in that case, let me know. Otherwise, we will return the % of your contribution that we have not used.

        The “book” is mostly written already. A dialogue to tie together the different aspects of what we have been doing is what is needed now. I’ll have Wally check, and hopefully add some information, about the court effort itself. The history of the North Winn confinements, the studies, the op-eds, letters, and powerpoints should all go together in an easily understandable chronology of events. What those events mean to us, to the public, and to the environment, will hopefully be clear at the end of this writing process.

        So this part is over. I hope you cherish this experience. It has been a wonderful learning experience for me, and I hope for you.

Bob

Bob Watson

A short story of our EPA lawsuit in the courts:

            We have a lawsuit against the EPA asking them to regulate hydrogen-sulfide and ammonia (they, and hundreds of other gasses are on the toxic list, but only 7 or 8 gasses are regulated), and to designate confinements as stationary sources of these gasses.

            Our case alleges that EPA has a non-discretionary duty to list ammonia and hydrogen sulfide as regulated pollutants and CAFOs (confinements and feedlots) as stationary sources of pollution to be regulated under the Clean Air Act. The Clean Air Act says EPA shall, from time to time, list pollutants and stationary sources that in EPA’s judgment reasonably endanger public health and welfare.

            EPA is arguing that the so-called “endangerment finding” is in EPA’s judgment, so the listing is discretionary, so we cannot sue them. Our argument is that because the law says “shall” and “from time to time,” EPA has a mandatory, or non-discretionary, duty, and we can sue them.

            In two previous cases, interpreting identical language in another section of the Clean Air Act, two courts have reached opposite conclusions. One court said EPA’s duty to list is non-discretionary and the other court said it is discretionary. But even the latter court agreed with the same arguments we are making but reached a different conclusion. The judge in our case said the endangerment clause made the duty discretionary.

            One of our main arguments is that because of the 177 studies we submitted to the court showing that pollutants from CAFOs, especially ammonia and hydrogen sulfide, cause health problems, EPA cannot claim that it could reasonably make a judgment that those pollutants should not be regulated under the Clean Air Act. EPA has known about these studies for years. In fact, some of the studies we site were conducted under the auspices of the EPA.

            While finding for the EPA, the Federal District judge in our case (Richard Leon who ruled NSA spying on Americans unconstitutional) said he did not dispute our facts, the 177 studies. The EPA did not dispute those facts either. Although in a footnote, the judge said his reading of the statute language, he thought, didn’t allow him to find for us. We are arguing about statute language instead of getting to argue our evidence in court.

            We appealed to the Appellate Court. Four things of note happened at that level: 1-we added the Jillian Fry Johns Hopkins study on the “gap between known public health threats coming from CAFOs and the regulations that are supposed to protect the public from those known public health threats”. We added the Fry study to give the Appeals Court’s three judges a contextual understanding of what rural neighbor’s of confinements existence is like. 2-One of the judges asked the EPA lawyer what if all of what we say is true. The EPA lawyer shrugged his shoulders and said he didn’t know. 3-When Wally was walking out of the courtroom, a career EPA employee thanked him for bringing the lawsuit. 4-Then we found out that the EPA had no defense, but they were playing a shell game – another suit asked a similar request of the EPA but used a different way – the EPA’s motion to dismiss in our case said we should do what that other lawsuit was doing instead of the way we were doing it, and in the other case said they should be doing what we are doing. We asked for a rehearing based on that information, but were denied. So, no defense by the EPA, only a shell game. The EPA knows what is happening to neighbors and the environment; they just won’t do anything about it, yet.

            We have not had an evidentiary day in court yet. We have been arguing “statute” language. We are now appealing to the Supreme Court, and we will be adding John Roberts’ recent major opinion in the Obamacare case to our appeal in which he argued that you can’t take words or phrases of a statute out of context. The EPA’s context is to protect the environment so that it doesn’t sicken and kill people. That appeal went to the Supreme Court on Sept 26, 2015.

            The Supreme Court decided not to hear our case and sent notice of that decision on Nov 2, 2015. They gave no reason.

            So, we will use the story of the case, and the evidence we filed with the case, to lobby legislators to change the statue to take “discretion” out of the mix when there is overwhelming evidence presented showing human health harm and environmental damage.

            Stay tuned.

Bob

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new use health board packet.doc

Even though odor from confinements is bad enough in itself, we are beyond odor. This packet of 460 peer reviewed journal studies will allow you to understand that we are beyond odor, and what we are really dealing with are toxic sewer gasses that negatively affect human nervous systems, digestive systems, and respiratory systems. We are also dealing with MRSA and other antibiotic resistant organisms that breed in this toxic sewer environment and are spread to the local environment. This packet gives you 460 peer reviewed journal studies that show that the science is settled on this issue. We are past the time where people could argue that confinements are just farming and just odors. It is well known that “public health threats” are posed to people who live in proximity to confinements and fields where confinement waste is spread. [Some of these studies were filed along with our lawsuit against the EPA and were not disputed by the Washington DC Federal District Court, the Federal Appeals Court, or the EPA.]

This packet also shows, through the Jillian Fry Johns Hopkins study, that people are considered “externalities” and are not covered in the regulatory scheme. You will find no human health, or human health and services (quality of life) federal or state departments that have authority to protect people in this regulatory scheme.

We are also beyond “this is agriculture”. This is no longer about farming. This is a dangerous business practice putting the health, and in some cases the life, of those living in proximity to confinements, and fields where confinement waste is spread, in danger. I am sure you would not allow a factory to be built in your county if you knew beforehand that the result would be that the neighbors around it would suffer harmful health effects as a result of the way the factory operated and discharged its pollutants.

We know that you can’t put a moratorium in place to stop new confinement buildings in the county. But, until you can figure out how to protect people from these known human health threats coming from confinements and fields where confinement waste is spread, we would ask that you vote to deny new permits so that you do have time during that process to try to figure out some way to protect the health of county residents that you represent. Since the federal and state regulatory schemes do not protect the health of your county citizens, it is going to be up to you to find a way to protect their health.

As one way to help county residents who find themselves in proximity to confinements and waste fields, you could use this packet to educate the public about this “known public health threat” and help them to understand what they can do now to protect themselves. [The suggestions in the packet.]

Bob Watson

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organic nitrogen vs synthetic nitrogen.doc

Explanation of organic nitrogen versus manufactured synthetic nitrate nitrogen:

Organic nitrogen is that nitrogen bound up in organic materials. All organics (read this as living things or previously living things or byproducts of living things [manure and urine]) contain nitrogen. Materials containing organic nitrogen have to decompose and then the organic nitrogen has to decompose before it is available to plant life as ammonia or nitrate. Ammonia is the “un-oxidized” form; nitrate is the “oxidized” form, based on whether it has been completely decomposed in the presence of oxygen (as in activated sludge) or not (as in the case of anaerobic digestion).

Organic nitrogen would include things like manure, urine, meat scraps and byproducts, but also grass, hay (as above, really anything living or previously living — biological).  The amount of organic nitrogen in various living things and byproducts varies. Corn has less than soybeans. Trees have less than animals. Nitrogen is just a compound that is critical to life (hence the algal blooms when it is plentiful) and is incorporated into cell structure. It takes a lot longer for organic nitrogen to become available for use by organic life because it has to decompose to a readily available form before it can be taken up.  That’s why farmers (should) really prefer manure to nitrogen fertilizer. The manure breaks down over a long period of time (kind of like a time release cold pill) and provides small amounts of nitrogen into the soil for plants over a long period of time (also the nitrogen runoff with manure is less immediately available to algae because much of it continues to be bound up in an organic (unavailable) form. It has to decompose to ammonia or nitrate before becoming available.

Manufactured (synthetic) nitrate nitrogen is readily available for plant uptake. It does not need to be broken down like organic nitrogen does for plants to be able to use it. Thus, with synthetic nitrate nitrogen, we see the pollution problems in our waters today that we did not have in years past when the only nitrogen in water was organic.

Manufactured nitrate nitrogen was transferred to agriculture after WWII. Bomb making companies needed a market for their nitrate nitrogen (used to make explosives) and Norman Borlaug’s Green Revolution needed copious amounts of nitrogen for their hybrid plants. Hence, nitrate nitrogen began to be used in agriculture. And we started having nitrate nitrogen problems in our water.

Bob Watson

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don scavia great lakes phosphorus.doc

Don Scavia’s latest work with phosphorus caused algae blooms in the Great Lakes.

Study: Farmers doing too little to stop Lake Erie algae. 3-22-16.

Traverse City – Cutting phosphorus runoff into Lake Erie enough to prevent harmful algae outbreaks would require sweeping changes on the region’s farms that may include converting thousands of acres of cropland into grassland, scientists said in a report Tuesday.

The study released by the University of Michigan Water Center found current efforts to keep phosphorus, which is found in livestock manure and artificial fertilizers, on fields instead of flowing into the lake are falling drastically short of results needed to achieve a 40 percent drop in runoff – a target set by the U.S. and Canada in February.

Excessive levels of the nutrient are the leading cause of increasingly massive blooms, which in 2014 left more than 400,000 people in Toledo, Ohio, and southeastern Michigan unable to consume tap water for two days because the bacterial algae produce a toxin. Another bloom last year was the largest on record. Phosphorus also causes a “dead zone” in Lake Erie’s central basin with so little oxygen that fish cannot survive.

Using computer modeling, a team of scientists tested different combinations of best-management practices that could bring the algae under control. Some are already in use, such as planting vegetation buffers between cultivated fields and waterways. Others include applying phosphorus-based fertilizers beneath the land’s surface instead of on top, where it’s more likely to wash away, and planting cover crops such as winter wheat.

Ohio and Michigan rely largely on voluntary compliance, but too few farmers are participating, the report found.

“Our results suggest that for most of the scenarios we tested, it will not be possible to achieve the new target nutrient loads without very significant, large-scale implementation of these agricultural practices,” said Don Scavia, a University of Michigan ecologist who led the study.

The study focused on the Maumee River watershed, which includes 17 counties in northwestern Ohio and smaller sections of Michigan and Indiana. High phosphorus runoff from farms in that area is the primary cause of toxic algae in western Lake Erie, it said.

Policy alternatives described as “most promising” by Jay Martin of Ohio State University, the report’s co-author, included widespread use of the best-management practices and conversion of some croplands to switchgrass or other grasses. One called for removing nearly 30,000 acres in the watershed from production. That’s the equivalent of 6,300 farms, as the average farm in the area consists of 235 acres.

Jeff Reuter, past director of Ohio Sea Grant and a Lake Erie specialist who wasn’t involved with the study, said some cropland is so overloaded with phosphorus that turning it into grassland or wetlands is the only way to stop runoff.

Such a requirement could drive some farms out of business, said Joe Cornely of the Ohio Farm Bureau Federation, who criticized the study for focusing only on the Maumee basin and agriculture instead of other phosphorus sources such as sewage treatment plants.

“Yes, agriculture’s got some things we need to do,” Cornely said. “But to give the idea that a single sector of our economy or a single geography is the only way to attack this … runs the risk of raising unrealistic expectations among the public.”

Government could pay subsidies to farmers who convert their land to protect water quality, Scavia said.

“This study is a strong affirmation that we can once again restore the health of Lake Erie, but it cannot be done with half-measures and a piecemeal approach,” said Jack Schmitt, deputy director of the Michigan League of Conservation Voters.

Bob Watson

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redone register and nitrates.doc

            It is true that during the first 9,930 years of our 10,000 year plant and animal agriculture history, there was nitrogen in our surface waters. But not much, and it was organic nitrogen not the recent manufactured synthetic nitrate nitrogen, used in fertilizers today, which is causing our problems. Organic nitrogen is hard to break down. Synthetic nitrate nitrogen is readily available for plant uptake. The use of nitrate nitrogen, and the amount used, are the major reasons for our recent nitrogen pollution problems.

            After WWII there was a perfect marriage of chemical companies needing some place to sell their bomb making nitrogen products, and Norman Borlaug’s Green Revolution’s need for massive amounts of nitrogen. A perfect marriage made in hell as it turns out, in that there is a sense in which the Green Revolution can be viewed as one of the most serious and sustained human-caused pollution events in history. We see it in Iowa every day now with our 23 million acres of corn and beans and their need for toxic fertilizers, herbicides, and pesticides to grow.

            Norman Borlaug had 2 pillars to his agricultural program. At a time when there were fewer than 2 billion people on the planet, Borlaug said that no agricultural model would feed us unless we tackled our population problem. Borlaug early on was talking about the planet’s carrying capacity. That pillar of his program has languished.

            It is hard not to be a little skeptical about the effort to clean up our agricultural environment what with two new nitrate nitrogen manufacturing plants being built, one on the Mississippi and one on the Missouri. Local, state, and federal governments have gifted the two plants some $700 million dollars.

            This recent Green Revolution/GMO/confinement and feedlot model of agriculture has to pollute. It needs toxins to work and creates toxins as it works. That cannot be changed with this model. Iowans can have clean water or this industrial way of raising corn and beans and animals. We actually raise enough food grains for 12 to 15 billion people if we would just quit feeding it through animals. The question for the public then is: do we need this model of agriculture to feed ourselves and provide the raw material for our manufacturing needs?

            In the first 9,930 years of agriculture there were, and there are today, crops and cropping systems that foster a non-polluting, biologically benign and beneficial, soil building agriculture that would re-perennialize our agriculture with sponge-like root systems that would mitigate the flooding, erosion, and nutrient pollution problems caused by this recently adopted industrial model of agriculture.

            A clean agriculture is pretty simple really. Here are five crops and cropping systems that would help us get there: strips of perennial native prairie in all annual fields; edible perennial prairie grains for humans and animals; prairie and grass based animal farming; industrial hemp (George Washington and Thomas Jefferson grew hemp); small grains, hays, fruits, and vegetables; political will – personal courage. A presentation of these systems is at www.civandinc.net appendix G.

Bob Watson

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why wait 20 years.doc

            Why should we wait 20 or more years (“The Long Haul – Most believe reducing nutrients in Iowa’s drinking water will take decades” – Gazette 3-13) and spend billions of dollars to maybe achieve a 40% reduction in the pollution coming from this corn, beans, confinement, and feedlot industrial model of agriculture?

            Why shouldn’t we end this pollution now by adopting crops and cropping systems, which exist today, that would clean up our agriculture without sacrificing our food and manufacturing needs? Imagine an agriculture that would clean up our water, rebuild healthy soil, allow us to fish and swim in our public water, safely drink water from wells and rivers, improve our diet, and end the Dead Zone.

            The list of good things that would happen if we quit using this recent industrial model of agriculture, which must pollute, is almost endless. The reason that we don’t adopt these clean crops and cropping systems is the rather effective myth-making that corporate industrial agricultural apologists have utilized. Even some so-called environmental groups seem to have assumed that agriculture must be corn, beans, confinements, feedlots, and polluted water.

            Let’s be clear about a few things. Farmers did not choose this inherently polluting model of agriculture. They only did what land grant colleges and universities, extension services, corporate agricultural suppliers, and the farm bill have told them to do. This industrial model is only one model of agriculture – one which externalizes the costs of its pollutants on to us the public, and makes corporations money.

            In the first 9,930 years of our 10,000 year history of agriculture there were, and there are today, crops and cropping systems that foster a non-polluting, biologically benign and beneficial, soil building agriculture that would re-perennialize our agriculture with sponge-like root systems that would mitigate the flooding, erosion, and nutrient pollution problems caused by this recently adopted industrial model of agriculture.

            Five of those crop and cropping systems are:

1. strips of perennial native prairie in all annual fields – 10% of a field in prairie strips stops 95% of soil erosion (let me say that again, 10% stops 95% of erosion along with the majority of pollutants – today), builds soil, provides habitat, sponge-like root system allows 7-13”/hr rain infiltration rate(rir). Why isn’t this low hanging fruit, which has been around for a few years, in the farm bill by now? And since farmers didn’t choose this polluting model, all of us should pay for the prairie seed used in these strips.

2. edible perennial prairie grains for humans and animals – no erosion, no yearly tillage, builds soil, provides habitat, exists today – the first variety should be scaled up for sale to farmers by the 2020’s, 7-13”/hr-rir.

3. prairie and grass based animal farming – no erosion, builds soil, provides habitat, 3-13”/hr-rir, no confinements or feedlots with their toxic sewer gasses and antibiotic resistant organisms. (ag uses 80% of all US antibiotics – with no CAFOs, the need for the vast majority of that 80% is gone)

4. industrial hemp – deep rooted cover crop, no fertilizers if used in crop rotations, used with strips, provides habitat, provides food and fiber, replaces many petro-chemical based manufactured products, revitalizes rural America with factories and processing plants, 350 year history as a crop in North America, 3-7”/hr-rir. (George Washington and Thomas Jefferson grew hemp)

5. small grains, hays, fruits, and vegetables – used with strips, provides habitat, builds soil, 1-7”/hr-rir.

            This change will require political will and personal courage. We, the public, need to demand a clean, non-polluting agriculture.

Bob Watson

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zoo and pigs gazette.doc

            “Cricket Hollow Zoo violations ‘pervasive,’ judge finds”, Feb 12 Gazette front page headline. Judge orders troubled Iowa zoo to relocate 3 lemurs, 4 tigers after “…inspections found “chronic” problems, including excessive feces in enclosures.”

            Each year 40 million Iowa pigs spend the entirety of their 6 month lives in giant closed sewers referred to as confinement buildings. Never living outside smelling or rooting in dirt, grass, trees, or streams, these pigs live in a closed building. Their feces and urine drop through a slatted floor to a pit which is their basement. That waste, never pumped out while the pigs are there, decomposes into poison sewer gasses including hydrogen-sulfide and ammonia, and the explosive and green house gas methane. The fumes from that waste pit are so poisonous that air must be vented continuously 24/7/365 or the pigs will die.

            Those poison sewer gasses are blown out into the surrounding neighborhoods affecting the health of humans. Studies have shown heightened respiratory ailments (including asthma) and central nervous system problems in humans, especially children, who live in proximity to these buildings. And we know about the human and pig deaths in confinements from these poison sewer gasses.

            Because confinement pigs live in a sewer environment, sub-therapeutic antibiotics have to be administered through feed to protect their health (80% of all antibiotics used in the US each year are used in agriculture). Confinement sewer environments allow antibiotic resistant organisms to flourish. Studies have shown that people can be colonized and infected with MRSA and other antibiotic resistant organisms simply by living in proximity to confinements or fields where confinement waste has been spread. One study showed veterans who used the Iowa City VA Hospital and who lived 1 mile from a confinement had almost three times the risk of being colonized with MRSA versus a veteran who lives outside that 1 mile distance. 

            In our lawsuit against the EPA (Zook, et al v EPA), we filed 177 medical and scientific studies showing the human health and environmental damage from poison sewer gases that are created by using confinement buildings to raise pigs. Although the lawsuit was unsuccessful (the US Supreme Court declined to hear our case), the Washington DC Federal District Court did not dispute our 177 studies. Neither did the EPA since some of those studies were done under their auspices. It turns out that even though the EPA knows the damage to people’s health who live in proximity to these buildings, because of statute language in the Clean Air Act, they don’t have to do anything about it.

            In Iowa 3 lemurs, 4 tigers, 40 million pigs, and 1000’s of people are at risk from “excessive feces” in enclosures.

Bob Watson

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agri-news and confinement fires.doc

Dear Editor,

            The first recorded methane fire/explosion in a hog confinement was in 1969. The problems were known that long ago.

            There is no technical solution to foaming, to fires from methane, deaths from hydrogen-sulfide, respiratory illnesses from ammonia, or antibiotic resistant organisms proliferating in confinements.

            Hog confinements are poorly designed and poorly operating anaerobic digesters transferred from the municipal and industrial wastewater sector to the industrial ag sector without the regulations, protections, and education that have matured with that technology. If you are going to use wastewater technology in agriculture, you are going to have the historical problems associated with that technology, and new problems unique to the agricultural setting.

            Due to illnesses and deaths from sewer gasses, wastewater industry regulation and design standards do not allow normal work spaces to be built in proximity to confined spaces; and no one is allowed into a confined space unless all procedures and equipment are in place. And yet people in the ag sector, mostly unaware of the dangers from these gasses and with no requirement for education or safety equipment, are told this dangerous sewer environment is the best and healthiest way to raise meat animals. And, we allow those dangerous sewer gasses to be vented into neighborhoods affecting the people who live there.

            Humans domesticated pigs some 5-7000 years ago. We didn’t have these particular life threatening, and human health, problems until we started using wastewater technology to raise pigs. Corporate ag apologists have done such a good job of myth-making surrounding industrial agriculture that many people think it is normal to have an agriculture that pollutes our water, air, soil, and environment, and endangers our lives and health.

            The only solution to foam, fires, explosions, illnesses, and deaths in confinements is to quit using wastewater technology to raise pigs. That is, quit using confinements.  

Bob Watson

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register and stowe.doc

Dear Editor,

            Beyond editorializing about how the Farm Bureau’s new group’s ad is portraying, and potentially putting in danger, Bill Stowe [Ads are smear campaign against Stowe, Dec. 11], the Register’s editorial staff should understand they are, in some respects, responsible for these continuing attacks on Stowe.

            In the guise of “editing,” the Register’s editorial staff has not allowed the public to understand that agriculture in Iowa can be clean (non-polluting), can build soil, provide habitat for animals, birds, insects, soil microorganisms; and, rather than ethanol fuel, can raise food products that are healthy for humans. The Register could allow the public to know about crops and cropping systems that exist today, that if adopted into the farm bill, would do all this and more, and also lessen the impact of floods from climate change-enhanced rain events.

            The Farm Bureau, and other industrial ag commodity and apologist groups, spend money repeating myths: that we feed the world; that this industrial model is the only way to feed a hungry world; that industrial ag farmers are stewards of the soil; that industrial ag provides inexpensive food. Repeat something enough times, especially without counter examples, and the uninformed public can be duped. And, people like Stowe can be demonized.

            The Register’s Opinion editors should quit being the gate-keepers for industrial agriculture in this state. There is an agriculture, and an agricultural culture, that will not pollute, stink, poison, or depopulate our rural small towns and countryside. If you allow that story to be told by those who understand it, and in their own words, what Bill Stowe and the Des Moines Water Works are doing would be understood by the public as something extremely important for the future of Iowa, and of agriculture.

Bob Watson

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icci complaint to dnr.doc

Review of ICCI’s complaint to the DNR on hog confinements:

Section 4: page 3 bottom paragraph – [ ]’s refer to my notes below.

            “There is no state law or DNR rule that prohibits producers from using fields listed in more than one MMP. The fact that a field is in a MMP does not mean manure will be applied to that field. [1]DNR has no evidence that manure was over applied in one field by numerous producers. [2]DNR has not received any specific complaints of over application and [3]a review of DNR enforcement actions does not indicate any enforcement actions for application to the same fields. [4]Manure is a valuable commodity and DNR believes it is unlikely that over application in single fields is occurring.”

            “[5]Manure application records are deemed confidential by Iowa Code 459.312(12) and a change in this determination would require a legislative amendment. [6]Tracking manure application in a GIS format or any form would also be contrary to Iowa law. [7]The application records are maintained by the individual producers and the records are [8]not generally submitted to the DNR. [9]The application records are reviewed by DNR while conducting [10]onsite inspections.”

            “[11]In conclusion, DNR does not have any evidence of water quality violations occurring from over application of manure from more than one facility on a single field. [12]DNR will continue to investigate specific complaints and if a violation is verified appropriate enforcement will be pursued.”

1. DNR does not keep application records, so how would they know. This is by a complaint basis and how would the person know whether too many trips were made across a field if they don’t have access to the records because they are deemed confidential by the state?

2. see #1.

3. Even if there is over application, there apparently is no law against it.

4. This is simply corporate ag apologist-speak and should have no place in DNR’s thinking or behavior. In fact, scientific studies show that hog confinement waste is a toxic brew five times more polluting than raw human waste, and contains antibiotic resistant organisms including MRSA.

5. How can something that has been proven to be hazardous to human health (MRSA colonization and infection from confinement waste fields) be deemed confidential? Doesn’t the public have a right to know that their health may be in danger just by being in proximity to confinement waste?

6. How does a county know when its waters are being overloaded with CBOD, TSS, and ammonia from too much confinement waste being spread on too little ground if tracking in any form is contrary to Iowa law? This seems to be similar to “even if testing of field runoff is done through the INRS, it will be considered confidential and not made public because the runoff may include product trade secrets which are considered proprietary property.

7. This should be public knowledge so that over application can be reported.

8. The DNR should have this information so they can know if over application is happening.

9. It is a little late to correct deficiencies in MMP’s if you have to wait until someone goes to perform an inspection. The DNR should have the application records as that application happens (along with soil and manure testing results).

10. Visits? Really? When? The DNR is understaffed (by design).

11. Of course the DNR doesn’t have any evidence. No one knows how much or where application is happening. So, how could anyone make a complaint to the DNR of over application if no one knows if over application is happening?        

12. How are complaints supposed to happen when all of the above show that there is no way to know if over application is occurring? And, the DNR says it isn’t against the law so there is no penalty for over application even if it is occurring.

Bob Watson

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isis.doc

Dear Editor,

            Poverty, hopelessness, incomplete integration into society, these have long been understood to foster “terrorism.” Economic help, education, health care, and food security rather than nation-building, military intervention, and conquest for raw materials would be antidotes to recent problems both in the wider world and here at home with the new emphasis on “Black Lives Matter.” Poverty and hopelessness; think about living with those as your “everyday.”

            The current problems of the “Greater Middle-East” go back some 100 years with the drawing of “country boundaries” by Western powers irrespective of historic traditions. George Bush’s illegal and immoral invasions of Afghanistan and Iraq set off this most recent turmoil. And that turmoil now includes Syria because of the CIA’s unfortunate attempt at regime change in that country.

            It is too bad that most Americans are ignorant of what our government has been up to. And, it is unfortunate that Obama took off the table an investigation of war crimes by Bush, Chaney, Rumsfeld, and the Neo-Conservatives who advised the Bush Administration. Had those investigations happened, we would at least have understood the origin of those wars, these refugees, and these demented terrorists.

            Buckle-up your seat belts because those same Neo-Con’s are now beating the war drums for the Republican presidential primary contestants. “USA-number-one” is about as in-depth a foreign policy understanding as most politicians and voters get now-a-days, Hillary included. So you might want to get ready for more of the same.

            Our future could be different. A “non-military interventionist foreign policy” with economic aid, education, health care, and innovative technologies as our main gifts to the world would help the poor, the sick, and the up-rooted of the world. And, if we understood that that same poverty and hopelessness is here in America, “Black Lives Matter” (and its European counterpart “Muslim Lives Matter”) wouldn’t be a cry for help, but rather a call for a complete inclusion of all Americans in the bounty that this society creates.

            There are answers. They just don’t include guns, regime change, and killing people.

Bob Watson

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memo to monte shaw.doc

Memo to Monte Shaw:

            It is true that during the first 9,940 years of our plant and animal agriculture there was nitrogen in our surface waters. But not much, and it was organic nitrogen not the recent manufactured synthetic nitrate nitrogen used in fertilizers today. Organic nitrogen is hard to break down. Synthetic nitrate nitrogen is readily available for plant uptake and that is causing our nitrogen pollution problems.  

            After WWII there was a perfect marriage of chemical companies needing some place to sell their bomb making nitrogen products, and Norman Borlaug’s Green Revolution’s need for massive amounts of nitrogen. There is a sense in which the Green Revolution can be viewed as one of the most serious and sustained human-caused pollution events in history. We see it in Iowa every day now with our 23 million acres of corn and beans and their need for toxic fertilizers, herbicides, and pesticides.

            This recent Green Revolution/GMO/confinement and feedlot model of agriculture has to pollute. It needs toxins to work and creates toxins as it works. No product, whether it be ethanol, cellulostic, or biodiesel, can be called renewable if it comes from this industrial model of agriculture; no matter where you start or stop your Btu calculations.

Bob Watson

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register and nitrates.doc

Re: “Finding fixes for Nitrates” Register Sunday 9-13

            It is true that during the first 9,940 years of our plant and animal agriculture there was nitrogen in our surface waters. But not much, and it was organic nitrogen not the recent manufactured synthetic nitrate nitrogen, used in fertilizers today, which is causing our problems. Organic nitrogen is hard to break down. Synthetic nitrate nitrogen is readily available for plant uptake. The use of nitrate nitrogen, and the amount used, are the major reasons for our recent nitrogen pollution problems.

            After WWII there was a perfect marriage of chemical companies needing some place to sell their bomb making nitrogen products, and Norman Borlaug’s Green Revolution’s need for massive amounts of nitrogen. A perfect marriage made in hell as it turns out, in that there is a sense in which the Green Revolution can be viewed as one of the most serious and sustained human-caused pollution events in history. We see it in Iowa every day now with our 23 million acres of corn and beans and their need for toxic fertilizers, herbicides, and pesticides to grow.

            Norman Borlaug had 2 pillars to his agricultural program. At a time when there were fewer than 2 billion people on the planet, Borlaug said that no agricultural model would feed us unless we tackled our population problem. Borlaug early on was talking about the planet’s carrying capacity. That pillar of his program has languished.

            It is hard not to be a little skeptical about the effort to clean up our agricultural environment what with two new nitrate nitrogen manufacturing plants being built, one on the Mississippi and one on the Missouri. Local, state, and federal governments have gifted the two plants some $700 million dollars. (How’s that for one time spending, Iowa school children?)

            This recent Green Revolution/GMO/confinement and feedlot model of agriculture has to pollute. It needs toxins to work and creates toxins as it works. That cannot be changed with this model. The question for the public then is: do we need this model of agriculture to feed ourselves and provide the raw material for our manufacturing needs?

            In the first 9,940 years of agriculture there were, and there are today, crops and cropping systems that foster a non-polluting, biologically benign and beneficial, soil building agriculture that would re-perennialize our agriculture with sponge-like root systems that would mitigate the flooding, erosion, and nutrient pollution problems caused by this recently adopted industrial model of agriculture.

            A clean agriculture is pretty simple really. Here are five crops and cropping systems that would help us get there:

1. strips of perennial native prairie in all annual fields – 10% of field in prairie strips stops 95% of soil erosion (let me say that again, 10% stops 95% of erosion along with the majority of pollutants), builds soil, provides habitat, sponge-like root system allows 7-13”/hr rain infiltration rate(rir). Why isn’t this low hanging fruit, which has been around for a few years, in the farm bill by now? And since farmers listened to land grant colleges and universities, extension agents, and corporate entities as to how they should farm, it is not their fault that we find ourselves here today. As such, the government (we) should pay for all prairie seed used in these strips.

2. edible perennial prairie grains for humans and animals – no chemicals, no erosion, no yearly tillage, builds soil, provides habitat, exists today – the first variety should be scaled up for sale to farmers by the 2020’s, 7-13”/hr-rir.

3. prairie and grass based animal farming – no chemicals, no erosion, builds soil, provides habitat, 3-13”/hr-rir, no confinements or feedlots with their toxic sewer gasses and antibiotic resistant organisms. (ag uses 80% of all US antibiotics – with no CAFOs, the need for the vast majority of that 80% is gone)

4. industrial hemp – deep rooted cover crop, no fertilizers if used in crop rotations, used with strips, provides habitat, provides food and fiber, replaces many petro-chemical based manufactured products, revitalizes rural America with factories and processing plants, 350 year history as a crop in North America, 3-7”/hr-rir. (George Washington and Thomas Jefferson grew hemp)

5. small grains, hays, fruits, and vegetables – used with strips, provides habitat, builds soil, 1-7”/hr-rir.

6. political will – personal courage.

To see this op-ed pictorialized, go to www.civandinc.net appendix G “Conservation Bandaids or Real Watershed Changes”.

Bob Watson

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ists intro.doc

Introduction to the ISTS presentation:

Hog confinement technology is important for you as science and math teachers to understand correctly because of its ubiquitous nature in the state of Iowa. With 21 million pigs being housed and raised in confinements, this technology affects almost all aspects of our lives and of Iowa’s environment.

As teachers, you hold a position that is looked on as a role model, and as an authoritative source of information about those scientific and technical issues that a modern society must deal with. There is a conversation that is happening state wide around this confinement technology, and as a science teacher you may be asked about that issue or to take part in that conversation. So it would be good for you to be acquainted with that technology, where it came from, how it is being used, and its many affects on Iowa and its citizens.

If you are a teacher in a rural setting, this technology is even more important in that it affects you and your students immediately, and also affects their ability to learn. The human health problems caused by using this technology in agriculture is more acute for people in proximity to confinements, but it affects all Iowans generally because air and water know no boundaries.

Because of our reductionist tendencies, we can lose sight of a contextual whole. That possibility leaves room for explanations that may be narrow in scope and allow the justification of a technology’s use while ignoring what that technology’s overall affects may be. By being narrowly defined, a technology’s use can be justified without looking at that technology’s wider impacts. 

There are moral and ethical issues surrounding a technology that we know harms humans and the environment. There are moral and ethical issues surrounding a regulatory scheme that doesn’t take into account the wider ramifications of a technology’s use. Regulatory schemes are how we protect ourselves from known public health and environmental threats. This asks the question: is it fair for people to get sick because of what someone else is doing? This gets in to the “how do they look at themselves in the mirror” dilemma.

There are further questions surrounding technology that this hog confinement issue brings up that you may be asked to address: is it appropriate that we should use a technology just because we can; is there a technological fix to problems that are created by technology in the first place; if a technology is inherently polluting, should we be using it?

So, let’s look at this technology. Let’s explore the contextual whole that this technology affects. Let’s have a conversation about science and teaching science. And, let’s talk about the appropriate use of science and the technology that comes from science.

You can see much more of this conversation at www.civandinc.net appendix E, and other appendices.

Bob Watson

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Cylinder deaths.doc

            In all sectors of the US where the toxic sewer gasses hydrogen-sulfide and ammonia, and the explosive and greenhouse gas methane, exist in closed spaces, the controlling regulations are the OSHA enforced federal “Confined Spaces Regulations”, except in agriculture. (“Father, son die from manure pit fumes” DM Register 7-29-15).

            It is unfortunate that wastewater technology, in this case poorly designed and poorly operating anaerobic digesters which are being called hog confinements, has been inappropriately transferred to industrial agriculture without the education, regulations, and safety procedures and equipment that are required by the “Confined Spaces Regulations.” Without the protections provided by regulations, and with no reporting requirements, these accidents are more common than most people know, and many could be prevented.

            Corporate agricultural apologists would have you believe that hog confinements are just agriculture as we have always known it, just bigger and better, and therefore don’t need regulations. The first explosion of a hog confinement was in 1969. You would have thought someone might have asked what this technology really was and why a confinement would explode.

            Due to illnesses and deaths from these sewer gasses, wastewater industry regulation and design standards do not allow normal work spaces to be built in proximity to confined spaces; and no one is allowed into a confined space unless all procedures and equipment are in place. And yet people in the ag sector, mostly unaware of the dangers from these gasses and with no requirement for education or safety equipment, are told this dangerous sewer environment is the best and healthiest way to raise meat animals.

            Those toxic sewer gasses (euphemistically referred to as “odor” by industrial ag proponents) are constantly 24/7/365 blown out of the confinement and into the surrounding neighborhoods and larger environment. If the fans quit, the pigs inside will die. And yet we allow those dangerous sewer gasses to be exhausted into neighborhoods affecting the people who live there. Iowa studies have shown significant increases in respiratory ailments in neighbors of confinements, including asthma, from ammonia exposure, and in central nervous and digestive system ailments from hydrogen-sulfide exposure.

            Waste from pigs on pasture decomposes into its harmless and beneficial forms within a few days. Waste from pigs in confinement buildings is stored in an anaerobic (no oxygen) condition for six months to a year. That confinement waste “cooks” and ends up being five times more polluting than raw untreated human waste. With 20 million hogs at any one time in Iowa, that is equal to 100 million people living in Iowa, collecting but not treating their waste, and dumping it on the land and calling it manure.

            Anaerobic digestion of confinement pig waste creates toxic compounds, including the aforementioned hydrogen-sulfide, ammonia, and methane, and volatile organic compounds. Recent studies show that MRSA and other antibiotic resistant organisms can colonize and infect people living in proximity to confinements and fields where confinement waste is spread.

            Humans domesticated pigs some 5-7000 years ago. We didn’t have these particular life-threatening and human health problems until we started using wastewater technology to raise pigs. Corporate ag apologists have done such a good job of myth-making surrounding industrial agriculture that many people think it is normal to have an agriculture that pollutes our water, air, soil, and environment, and endangers our health.

            This recent post-WWII Green Revolution/GMO/confinement and feedlot model of agriculture depends on toxins to work and creates more toxins as it works. There are crops and cropping systems that exist today, that could be put in the farm bill now, that would clean up our agriculture, and Iowa, almost overnight. That “clean” agriculture would build soil, reduce flooding, provide habitat, and reduce the Gulf dead zone, all without sacrificing our food or manufacturing needs.

            Whether this farm bill change happens depends on people saying no to this dangerous and polluting corporate model of agriculture, and yes to a clean agriculture; no matter what the corporate ag apologists tell us is good for us.  

Bob Watson

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co and bob anderson.doc

Re: “How can Sanders be commander in chief?”

Dear Editor,

            My late friend Bob “Decorah eagle cam” Anderson and I had just finished a day of pulling water samples in his fight against a hog confinement next to his rural Decorah/Bluffton property. Everyone else had left that evening and Bob and I, having recently met because of this confinement, were outside talking and smoking cigarettes.

            Knowing from my writing that I was a former combat Marine and a disabled Vietnam veteran, Bob quietly said, “I want you to know that I am a conscientious objector.” Into that vulnerable and honest moment, I responded as I do to conscientious objectors with my telling Bob that he, and other CO’s, were, and are, much more brave than I was.

            I had been in the Marine Corps for 2 ½ years before I got orders to Vietnam in 1969. I understood that there was something very wrong with that war, but I was more afraid of going to jail or Canada than I was of the unknown Vietnam.

            As we now know, Vietnam was an immoral and illegal war based on the “Gulf of Tonkin” lie and our refutation of the U.N. agreed upon Vietnam elections of 1956.    

            Bob Anderson, and other conscientious objectors, show bravery and moral courage where supposed “heroes” like me are too fearful to take a stand. Can a conscientious objector be the president/commander in chief? I hope so. We need moral courage in the White House today when violence, individual and government, is seen to be the only answer the United States has to offer.

Bob Watson

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Stowe defense.doc

            There are some pretty stark numbers that you will have to deal with if you want to argue against Bill Stowe and the DMWW’s lawsuit. I will go through only a few below.

            At any time now in Iowa, we have some 20 million pigs in confinement buildings. Because of the way those buildings work, waste from confined pigs is 5 times more polluting than raw human waste. That is like having 100 million people, a third of the US population, living in Iowa (not the 3 million we have) just walking outside their houses and peeing and crapping. And that 100 million number is just for pigs. We also confine dairy cows, chickens, and turkeys; and most beef cows today are kept in feedlots which act like uncovered confinements. We at least treat human waste.

            Simply using no-till as a practice has resulted in new or expanding dead zones in the Great Lakes and the Gulf of Mexico. It turns out that no-till releases “dissolved reactive phosphorus” from the soil. That phosphorus then runs into rivers and streams and lakes contributing to the problems we see in our waters that affect the DMWW and that led to Toledo, Ohio’s drinking water problem in August of 2014. How does the Iowa Nutrient Reduction Strategy, or any new future regulation, affect this no-till pollution avenue?

            Organic nitrogen has always been in our rivers. But today most nitrogen put on crop fields is synthetic nitrogen manufactured in factories like those being built in Iowa on the Mississippi and the Missouri rivers. In the 10,000 year history of agriculture prior to WWII, agricultural nitrogen was organic and naturally occurring. Organic nitrogen is much harder for plants to break down than the nitrate form of nitrogen manufactured today. Nitrate nitrogen is in a form readily available for plant uptake and its use is one of the main contributors to the pollution we see in our rivers, streams and lakes.

            Between 2008 and 2012 7.3 million acres of mostly grasslands were converted to row crops in the US (this is still ongoing). Southern Iowa followed only North and South Dakota in the number of acres converted. That conversion was and is mostly for corn for ethanol which is a commodity and not a food. Iowa farmers who use cover crops estimate that there are 130,000 acres of cover crops in Iowa. We have 24 million acres just in corn and bean row crops in Iowa and only 130,000 acres of cover crops. That is 0.5%.

            Pollutants from this industrial ag model are considered “externalities” by industrial agricultural entities. The public is expected to bear the brunt of the cost, monetarily, human health wise, and environmentally, that these “externalities” bring. This is the basis of Bill Stowe’s “rate payer’s argument.” Ag pollutes the water and you pay to clean it up through ever higher water and sewer bills.

            As long as we use this corn and beans, confinements and feedlots post WWII industrial model of agriculture, we will always have unsolvable pollution problems. Fortunately we can, almost overnight, end these pollution problems by adopting crops and cropping systems that exist today that would clean up our agriculture without harming our food or manufacturing needs. But that would take telling the truth and making changes to the farm bill. And that is something that the corporate commodity masters in Iowa have not yet allowed.

            We don’t need to have a polluting agriculture. You should be asking questions of agricultural leaders, not bashing Bill Stowe and the DMWW’s lawsuit.

Bob Watson

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same farmers diff crops.doc

Dear Editor,

Same Farmers – Different Crops and Cropping Systems:

            The same farmers with different crops and cropping systems could end, almost overnight, the need for the DMWW lawsuit, and Bill Northey’s request of the EPA for an extra 20 years for the Iowa Nutrient Reduction Strategy to show results.

            That would mean, of course, that corporate friendly industrial agriculture and its hallmark (inherent and continuous pollution from synthetic fertilizers, herbicides, pesticides, confinements and feedlots) would be at the end of its run. Corporations and commodity groups would have to figure out how they could plug into an agriculture that is about raising food and providing manufacturing needs without polluting the environment or harming human health.

            Is Iowa, and are Iowans, ready for a non-polluting, biologically beneficial, soil building and habitat enhancing agriculture, which would still meet our food and manufacturing needs?

            Some of those crops and cropping systems are: growing perennial prairie grains for food (Wes Jackson’s perennial polyculture); planting strips of perennial native prairie in all annual fields (10 percent of all annual fields in native prairie would stop 95 percent of the erosion); adopting intensive rotational grazing for animal farming (gets rid of all the air and water pollution from confinements and feedlots); planting industrial hemp (which supplies nutrition and manufacturing needs); and producing small grains, fruits and vegetables that people actually eat.

            These crops and cropping systems exist today. It is up to the people of Iowa to make it possible for their farmers to raise food for all of us in a clean, healthy, and sustainable way.

            Same farmers – different crops. Leading to a different Iowa.

Bob Watson

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northey’s hands.doc

Northey’s hands: an op-ed.

            On the one hand Iowa Secretary of Agriculture, Bill Northey, argues against the Des Moines Water Works lawsuit which wants to use the court system to try to clean up our water. Northey’s premise is that given time, voluntary measures will work.

            On the other hand and at the same time, Northey, apparently understanding the unlikely nature of voluntary only requirements meeting EPA mandated targets, is asking the EPA for a 20 year extension.

            Meanwhile with his virtual hand, Bill Northey receives a national environmental award:

Iowa Secretary of Agriculture Bill Northey received a National Association of Clean Water Agencies (NACWA) National Environmental Achievement Award for excellence in Public Service.  Northey is the first state Secretary of Agriculture to receive the award.

NACWAs Public Service Award is presented to current or former elected or appointed public officials at the local, state and federal level of government who have demonstrated exemplary commitment and service to their community, the environment and to NACWA.

Northey was selected for this honor for his leadership in establishing and growing the Iowa Water Quality Initiative and for working in a collaborative manner with both point sources and nonpoint sources to improve water quality. 

“It is an honor to receive this recognition from such a distinguished organization that has a long history of working on water quality issues, Northey said. Our approach has always been to work together with point sources to address water quality, an issue we all care about. This award is an opportunity to highlight the tremendous work that has been done in Iowa and to showcase our leadership role nationally in addressing water quality.”

            Um, what? Putting together the Iowa Nutrient Reduction Strategy (INRS) behind closed doors with only corporate ag and commodity groups invited to the table is collaborative? Asking the EPA for another 20 years to produce results highlights “the tremendous work that has been done in Iowa and to showcase our leadership role nationally in addressing water quality”?

             Sorry Bill, but the same farmers with different crops and cropping systems could clean up our agriculture almost overnight.

            This intensive, petro-chemical, fossil fuel based, post WWII model of farming must produce pollutants – nitrogen, phosphorus, eroded topsoil, and toxic waste from confinements and feedlots – that make our soil, water, and air a toilet for industrial agriculture. But the rest of society, as rate payers of water and wastewater treatment systems, and as people who live with the health effects of this pollution, bears the cost of what this industrial Green Revolution and CAFO agriculture considers “externalities.”

            We can continue with this inherently polluting, soil losing industrial agriculture, or have Iowa’s farmers switch to a non-polluting, biologically benign and beneficial, soil building agriculture, that exists today and which would still meet our food and manufacturing needs.

            What some of these non-polluting crops and cropping systems might look like:

1. edible perennial prairie grains for humans and animals – no chemicals, no runoff, no erosion, no yearly tillage, builds soil, provides habitat, exists today – scaled up for sale to farmers by 2020;

2. strips of perennial native prairie in all annual fields – 10% in strips stops 95% of soil erosion, builds soil, provides habitat;

3. prairie and grass based animal farming – no chemicals, no runoff, no erosion, builds soil, provides habitat;

4. industrial hemp – cover crop, no chemicals if used in crop rotations, used with strips, provides habitat, provides food and fiber, replaces many oil based manufactured products, revitalizes rural America with factories and processing plants, 350 year history as a crop in North America;

5. small grains, hays, fruits, and vegetables – used with strips, provides habitat, builds soil.

            This current industrial model of agriculture is unsustainable and polluting. The biological organisms in our soil are being destroyed through years of chemical application. And through unsustainable erosion, even that polluted soil will someday be completely gone. What is at stake is our continued ability to feed ourselves.

            We, and Secretary Northey, still have time to choose a different path. The political process could help make that choice. Cities, counties, and individuals can use their political capital to push for changes in the farm bill to promote sustainable cropping systems (re-perennialize agriculture) – rather than policies that encourage all-out commodity production and subsidize clearing of fragile and virgin lands as the current farm bill does.

Bob Watson

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delay response.doc

Board of Health Members,

            This is my response to Mark’s suggestion to delay notification of the public. I was going to address this at the next meeting, but that would delay your decision on notification language even longer.

            In the quotes below is the email that I received from Mark Gowdy-Jaehnig about why he wanted to delay notification. Let me say at the outset of this discussion that I am not accusing Mark of any untoward actions or intentions. I am agreeing with him that he might be a bit naïve about some of this. But, this discussion may provide some historical perspective on this issue.

“I wanted to let you know where I am with my thinking and what I am recommending to the board. The MRSA studies show an association between proximity to hog confinements and increased risk of MRSA infections. However it is less clear about actual causation. Dr. Tara Smith’s new study aimed to address the connection. Unfortunately she is still working on getting it published. I am also interested in seeing Dr. O’Connor’s systematic review of research on the health effects of living near hog confinements. Would it be Ok for me to forward your lists of research studies to her in case she is unfamiliar with any of the studies?” (Watson – I told Mark not to forward our studies. They are the result of years of work, and many, many days of researching the more recent studies. O’Connor can do her own work.)

“There are a couple of things I wanted to share. The study from Dr. Tara Smith looking at 1300 pig farmers and veterinarians in NW Iowa which is the first to make the connection between pig strains of MRSA and human infection in the US was rejected for publication. This does not necessarily invalidate the findings, but it makes me more cautious about relying on the study until I can read it. She is currently rewriting it for submission to another journal. I also received an e-mail from Dr. Ramirez at ISU saying that Dr. O’Connor at ISU is doing a systematic review of research on the health effects of living near confinement. It is due out in June. Systematic reviews are considered very strong scientifically. So I would recommend that we put off considering making any statements until the review comes out.” (Watson – more about O’Connor’s review below)

            There is one study and one review that Mark wants to wait for before he decides he can write notification language. The study is Tara Smith’s ongoing study of MRSA. Waiting for this study to be accepted would give you 269 studies. You already have 268 studies. It seems you would have to have pretty strained logic to not understand higher rates of MRSA from living close to hog confinements as being anything other than LA-MRSA as is the case in Tara’s Iowa City VA study. Remember, Tara has already found ST398 (LA-MRSA) in confinement pigs and workers; and LA-MRSA in wildlife. Waiting for smoking guns will be addressed below.

            The context for understanding the gap between what is known about public health threats and what is being done to protect people is the Fry study. The review Mark is asking you to wait for is the ISU O’Connor review. By asking you to wait for this review to be completed, Mark has introduced another context within which your decision will need to be made. That context is the historical record of delay and obfuscation by industries who were being threatened with regulations as a result of studies and data that showed their products, by-products, or practices were harming the health of the public. Think of the tobacco industry, lead in gas, lead in paint, DDT, sulfuric acid rain, etc.

            Industry experts were trotted out to tell us not to worry. Their industry-funded studies and their industry-funded scientists said that there was no harm to humans from these products, by-products, or practices. Many non-industry funded independent studies showed there were problems. But it took years of studies and lawsuits, and deaths and illnesses, before action was taken. This has all been in the public health domain, your Board’s domain. I’m sure you are all familiar with many of these histories.

            The O’Connor review is not a new review but is a continuation of her 2010 review. This 2010 review was funded by the United Soybean Board (pig feed) and the National Pork Board. I remember this review. It said they looked at 4,908 studies about health problems in people who lived in proximity to hog confinements. Of those 4,908 studies, only 9 seemed to meet their criteria and were reviewed.

            The principle finding, and conclusions and significance, from those 9 studies were:

“A negative association was reported when odor was the measure of exposure to AFO’s and self-reported disease, the measure of outcome. There was evidence of an association between self-reported disease and proximity to AFO in individuals annoyed by AFO odor…There was inconsistent evidence of a weak association between self-reported disease in people with allergies or familial history of allergies. No consistent dose response relationship between exposure and disease was observable.”

            It seems O’Connor is saying that in the 9 studies reviewed, only people who don’t like confinement odor report being sick. This seems absurd to me. It seemed absurd in 2010 and it seems absurd now especially in light of the 192 studies we have given you. But, it fits in the context and history of industry delay and obfuscation.

            This review has been largely ignored by researchers in this field. I can find only 10 citations since it was published; three times by O’Connor herself; one a study of ag workers; one about total industrial ag pollution; one about distribution of farms; one on low weight births in North Carolina; one about studies; one letter; and one in Spanish.

            But now it seems the National Pork Board apparently thinks they need something to counter the many recent studies showing harm to humans from living in proximity to confinements; including many of the 460 studies we have given you. So the National Pork Board alone funded O’Connor to update her 2010 review. And, O’Connor now is a National Pork Board panel member. This should be seen in the context of an industry fighting against regulation. We have seen it before in other industries. What did waiting do historically besides allow many more people to become sick or die from an industry’s pollution?

            It seems the O’Connor review criteria may misunderstand what many of the 4899 left out studies were designed to do. These studies were not designed to show a smoking gun connection, but to show an association with illnesses and deaths generally found from exposure to hydrogen-sulfide, ammonia, and particulates. The studies could have been as simple as (this was actually a study) reviewing hospital records pre- and post-hog confinement introduction into a community. That review found hydrogen-sulfide related problems tripled and ammonia related problems quadrupled. If people have illnesses that are associated with exposure to these gasses, and if the only source of those gasses in the community or neighborhood are hog confinements, it is logical to assume a connection. We have given you 192 studies on hydrogen-sulfide and ammonia coming from confinements.

            This proximity problem is not a new problem. In my industry, the wastewater industry, we have regulations in place to protect workers and the public from hydrogen-sulfide, ammonia, and harmful bacteria. These regulations are the result of deaths and illnesses to people from working in proximity to these gasses and bacteria. Confinements are wastewater technology – in this case poorly designed and operated anaerobic digesters – inappropriately transferred to agriculture without the education and regulation to protect the public that this technology has matured with.

            Confinements are sewer environments which exhaust that sewer environment out into neighborhoods and the larger environment. As the Fry study makes clear, there are no regulations in the ag area because industrial ag has been legislatively exempted from most regulations. Hence my reliance on educating the public to allow them to make educated choices on how to protect themselves.

            Because both confinements and feedlots are sewer environments, there is constant need for antibiotics to be given to the confined animals. Antibiotic resistance takes little time to jump from organism to organism, and from animals to people. MRSA is just part of this antibiotic resistance problem.

            To get a better understanding of confinement technology and why they are sewer environments, and what that means for the health of people in surrounding neighborhoods, go to my website www.civandinc.net appendix E. The powerpoint and the documents will give you a good basis for understanding where these problems come from and how they affect people and the larger environment.          

            So, I have asked you to make a notification to the public of new pathways into the community of known “public health threats” based on 268 peer-reviewed published studies about livestock associated MRSA (LA-MRSA) – if you wait on Tara’s study as Mark wants, you will have 269 studies – , and 192 peer-reviewed published studies about the harm from hydrogen-sulfide and ammonia. The new pathways into the community for these three “threats” are hog confinements. I hope we don’t have to argue about the dangers that these two poison gasses and MRSA pose to people. That should be settled science and the pathways should be the issue here.


            The Johns Hopkins Jillian Fry study was used as the organizing document and contextual basis for my request to you. It is the context within which you find yourselves as a result of my request that you notify the public. I think you need to understand the delay Mark is asking for in this context. If you have been involved in this issue, you will know many of the Iowa people, and the studies, in the Fry references. And, like me, maybe even have worked with some of them. It is a familiar story.

            The Fry study shows that this sort of delay has been going on for many years. In fact, I sent an email to Jillian Fry and told her that her study described perfectly the context within which those of us fighting hog confinements have found ourselves in these last 20 years. The Fry study context needs to be kept in mind as you think about this issue. We have been working for years to find some way of protecting the public from known poison gasses and antibiotic resistant bacteria coming from confinements. This is not new. And the science, irrespective of ISU’s O’Connor’s review, is overwhelming in consistently showing harm.

            Hydrogen-sulfide was put on the EPA’s toxic gasses list (different from their regulated list, the inclusion on that regulated list is what our lawsuit is about) along with ammonia twenty-one or two years ago. Industry got hydrogen-sulfide taken off that list within a year. It took twenty years of fighting with industry on EPA panels to get it back on the toxic list. That was one year ago. This is industry’s dance. We suffer, they make money.

            I am simply asking that you notify county residents that known “public health threats”, hydrogen-sulfide, ammonia, and MRSA, now have pathways into the community that weren’t there before hog confinements started being used. By being educated about these human health threats, people could make informed decisions about how to protect themselves and their children from these threats.

            To wait for one more study (269 versus 268), and one continuation of a 2010 review, is simply a part of the historical industry dance. How long will we wait to educate the public about this? How many more kids will get sick in the meantime?

            I don’t know if any of you have attended County Supervisor public meetings about siting new, or expanding existing, confinements. I have attended them for the last 25 years all across the state. They are remarkable, and sometimes terribly difficult to witness. Some of the women cry so hard during their testimony about what has happened to their, and their children’s, lives, that they are barely understandable. They get sick. Their children get sick. Their daily lives are ruined. It is a fact that most people who are against confinements are other farmers, farm wives, and farm widows. That is logical. They live in the country.

            The only experience I have of the level of anguish coming from these women is the anguish I caused Vietnamese women when I literally destroyed their farms, and lives, in Vietnam. I have seen and heard this anguish before. I’m not interested in destroying people’s lives for a particular model of agriculture. We have raised pigs for 5000 years. We never had these problems until we started using confinements in the 70’s. People do not need to suffer this pollution. We know how to raise pigs safely.

            Remember the “gap between what we know and what we do” context that the Fry study lays out, and within which you find yourself, in this issue. Please act on my request and notify the public of known “public health threats” coming into the community from these new pathways of hog confinements and fields where confinement waste is spread. There is more than enough evidence and we have had it for years.

Thanks.

Bob Watson.

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dmww lawsuit.doc

Op-ed:

            Is the DMWW lawsuit really needed? Well no, not if we return our agriculture to crops that people actually eat, and crops that we could use to replace many of the petro-chemically derived manufactured products we use today.

            Iowa imports 85% of its people food. So, how can an argument be made that farmers must be allowed to pollute our water, air, and soil because they need to feed the world? Iowa’s farmers don’t even feed us.

            Iowa’s corn and bean crops are not food for people, but instead are commodities used for industrial animal feed or other industrial processes including ethanol and bio-fuels. We do not need them to feed ourselves. And, we certainly do not need the nutrient pollution that must result from using this industrial model.

            The Iowa Nutrient Reduction Strategy (INRS) is needed only because this recent industrial model, the favorite of corporations, must pollute. But, the INRS will not address, let alone clean up, many avenues of pollution that are inherent in this industrial corn and beans model of agriculture. Even if every farmer adopted every practice that the INRS promotes, we would still have pollution because some of those practices actually pollute themselves.

            Corporations make money on commodities especially when you consider what economists call “externalities”, the nutrient pollution that the public must pay to clean up and that corporations don’t have to pay for. If we insist on this corporate friendly production of commodities, we will always have pollution.

            We should return farming to growing food for people to eat and crops for our manufacturing needs. That model is available today and if adopted today, would result in a clean, non-polluting, soil building, flood decreasing, and habitat enhancing agriculture.

            Five pieces of that model are Wes Jackson’s perennial polyculture (eating the prairie), STRIPS (10% of all annual fields in native prairie would stop 95% of the erosion), animals in intensive rotational grazing, industrial hemp (supplies nutrition and manufacturing needs), and small grains, fruits and vegetables that people eat.

Alternative wording: “Five pieces of that model are: growing perennial prairie grains for food; planting strips of perennial native prairie in all annual fields (10 percent of all annual fields in native prairie would stop 95 percent of the erosion); adopting intensive rotational grazing for animal farming; planting industrial hemp (which supplies nutrition and manufacturing needs); and producing small grains, fruits and vegetables that people eat.”

            DMWW would not need to sue if we had a sane and clean agriculture.

Bob Watson

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mrsa public primer.doc

Towards Public Knowledge – Primer on the Request Packet

The request that the county notifies its residents of known “public health threats” due to living in proximity to hog confinements, and fields where confinement waste is applied, will be informative and will operate on a number of levels.

It will:

1. Generally: it will educate the public. By being educated about the dangers coming from industrial hog confinements, the public will be empowered to make informed decisions, rather than working from ignorance.

2. Particularly: it will allow the public to take measures and precautions to protect themselves. Such as:

a. putting correct bio-filters in your HVAC system that will filter out hydrogen-sulfide and ammonia gasses.

b. cancel, or don’t renew, hog waste application contracts you may have signed.

c. ask neighbors to cancel or not renew application contracts.

d. get baseline testing of your well.

e. if you wish to file a nuisance suit, start keeping a log of times and dates, for both inside and outside your house, when odor is present. Nuisance suits have not shut down confinements, but might get you a fair market buyout if you want to move. (include well testing in those logs)

f. keep your children away from confinements and fields where confinement waste has been applied.

g. if hospitalized, make sure you tell your doctor you may be colonized with MRSA due to living in proximity to confinements or fields where confinement waste is applied. If you are already colonized with MRSA, your chances of getting a MRSA infection increases.

h. move.

3. Contextually: it will end the corporate ag apologists’ (they say there is no danger) dominance in the conversation about the dangerous reality of industrial hog confinements. People will have the knowledge to make their own decisions about the relative safety or danger from living in proximity to confinements or fields where confinement waste is spread. And, they can take part in conversations knowing they understand their situation correctly.

One argument that you may hear when you take this to your County Board of Health or Supervisors is that this is not credible science, or it is just a few studies. Do not worry about those arguments. We have given you two sets of studies: 268 studies having to do with MRSA and antibiotic resistance, and 192 studies having to do with the human health and environmental damage caused by hydrogen-sulfide and ammonia being vented 24/7/365 into the neighborhood and the larger environment from industrial hog confinements. Those are published peer-reviewed studies and tell a consistent story of the prevalence and dangers of MRSA, hydrogen-sulfide, and ammonia for human health, animals, and the environment.

We are hoping that we have put this together in a way that is understandable and useable for you. If you have questions, please contact us. If you wish to have us come with you as you present this to your Board of Health, or, if you don’t have a Board of Health, to your County Supervisors, please contact us.

This primer is for you and should not be included with the packet you give to your county officials. The reasoning behind the request and the advantages for the public mentioned in this primer are also in the cover letter in the packet. The cover letter and the packet should be enough for your county to understand the dangers from hog confinements, and what the request of them is about.

Nuts and Bolts: besides supplying the packet electronically, we recommend that you print a hardcopy of the packet for each official of the Board you are making the request of. To adapt the cover letter to your county, simply change the appropriate names to reflect your county, and to reflect who is making the request.

Bob Watson

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mrsa and hog waste studies cover letter.doc

Towards Public Knowledge

Winneshiek County Board of Health Members,

The Johns Hopkins University study, Fry JP, et al (document 1 of the attached TABLE OF CONTENTS), which investigates the role of state permitting and agriculture agencies in addressing public health concerns related to industrial food animal production, will provide the context and be the organizing document for our request that the county notify its residents of known “public health threats” due to living in proximity to hog confinements and fields where confinement waste is applied. The Fry study goes into great detail showing and discussing the gap between known public health threats from industrial agriculture and what is being done to protect the public through regulations from those known health threats.

Documents 2 though 9, which discuss new types of MRSA and new pathways into the human community for MRSA colonization of humans, represent the 268 local, state, national, and international studies included in this packet that discuss new types of MRSA (livestock associated MRSA from pigs) and new pathways for that MRSA to colonize humans. Those pathways are hog confinements and fields where hog confinement waste is applied.

Documents 10 and 11, studies conducted in rural Keokuk and Winneshiek counties, discuss some of the human health hazards from living, working, or going to school in proximity to hog confinements, and represent the 192 local, state, national, and international studies included in this packet that are about human diseases caused by hydrogen-sulfide and ammonia that are constantly exhausted from hog confinements; and, about the environmental damage caused by these, and other, gasses coming from confinements.

From the Fry study:

            “Research linking IFAP (Industrial Food Animal Production) to public health concerns and impacts continues to increase. In addition to posing respiratory health risks to those residing near operations [4]-[8] due to emissions that include hydrogen-sulfide [9], particulate matter [9], endotoxins [10], ammonia [11], allergens [12], and volatile organic compounds [13], [14], odor generated by IFAP operations and spray fields has been associated with a broad range of health problems. Public access to information regarding hazardous airborne releases from IFAP operations is hindered due to exemptions in federal laws that require disclosure of such releases [15], despite research linking chronic exposure to odors from IFAP to headaches, nausea, upset stomach, mood disorders, high blood pressure, and sleep problems [16]-[20]. Additionally, there is growing evidence that livestock can transmit methicillen-resistant Staphylococcus aureus (MRSA) to humans [21]-[23].

            …Common across most states, however, is delegating the permitting to an agency without a primary mandate to address public health [31], raising concerns that public health issues may not be adequately monitored or addressed by the agencies tasked with regulating IFAP operations. …

            …No staff member, in permitting or agriculture agencies, said that they provided information regarding potential health issues related to IFAP. …

            …Our study reveals that sampled state permitting and agriculture agencies have taken limited actions to prevent and/or respond to public health concerns arising from IFAP operations. The main barriers identified that prevent further engagement include narrow or inadequate regulations, a lack of public health expertise within the agencies, and limited resources. There was widespread agreement among permitting and agriculture agency interviewees that health departments (HDs) should play a role in regulating IFAP operations, partly due to their own agencies’ limited mandates and available expertise in public health. Yet previously published findings show limited involvement by local and state HDs due to political barriers and a lack of jurisdiction, expertise, and resources [36].

            These results indicate a fragmented system to protect public health where no agency has ownership of monitoring or addressing the impact of IFAP on people’s health. In short, HDs generally lack jurisdiction over IFAP operations [36] and permitting and agriculture agencies generally lack jurisdiction over and the capacity to address public health concerns. A growing divide between environmental and public health agencies was identified in the 1990’s as a trend that threatens public health protections [42]. Research has found that the main foci of environment agencies have shifted to permitting, enforcement, record keeping, and standard setting, and away from public health evaluations [43]. Our findings are consistent with these trends.”

So what can the county do? We know that the county is prohibited by state law from regulating agriculture. But, there is no prohibition against educating the public about these health threats. In fact, since the county, through the County Supervisors, has a mandate to protect the health and general welfare of county residents, there is a responsibility to educate the public so they can protect themselves. The County Board of Health should direct the County Department of Public Health to educate the public about the known “public health threats” from the poison sewer gasses hydrogen-sulfide and ammonia, and MRSA, coming from hog confinements and fields where confinement waste is applied. Since these studies discuss proximity, a one mile radius from existing confinements, or fields that have confinement waste applied to them, should be the guiding distance for notification of these public health threats to county residents.

The request that the county notifies its residents of known “public health threats” due to living in proximity to hog confinements, and fields where confinement waste is applied, will be informative and will operate on a number of levels.

It will:

1. Generally: it will educate the public. By being educated about the dangers coming from industrial hog confinements, the public will be empowered to make informed decisions, rather than working from ignorance.

2. Particularly: it will allow the public to take measures and precautions to protect themselves. Such as:

a. putting correct bio-filters in your HVAC system that will filter out hydrogen-sulfide and ammonia gasses.

b. cancel, or don’t renew, hog waste application contracts you may have signed.

c. ask neighbors to cancel or not renew application contracts.

d. get baseline testing of your well.

e. if you wish to file a nuisance suit, start keeping a log of times and dates, for both inside and outside your house, when odor is present. Nuisance suits have not shut down confinements, but might get you a fair market buyout if you want to move. (include well testing in those logs)

f. keep your children away from confinements and fields where confinement waste has been applied.

g. if hospitalized, make sure you tell your doctor you may be colonized with MRSA due to living in proximity to confinements or fields where confinement waste is applied. If you are already colonized with MRSA, your chances of getting a MRSA infection increases.

h. move.

3. Contextually: it will end the corporate ag apologists’ (they say there is no danger) dominance in the conversation about the dangerous reality of industrial hog confinements. People will have the knowledge to make their own decisions about the relative safety or danger from living in proximity to confinements or fields where confinement waste is spread. And, they can take part in conversations knowing they understand their situation correctly.

One argument against this notification request that you may hear is that this is not credible science, or it is just a few studies. We have given you two sets of studies: 268 studies having to do with MRSA and antibiotic resistance, and 192 studies having to do with the human health and environmental damage caused by hydrogen-sulfide and ammonia being vented 24/7/365 into the neighborhood and the larger environment from industrial hog confinements. Those are published peer-reviewed studies and tell a consistent story of the prevalence and dangers of MRSA, hydrogen-sulfide, and ammonia for human health, animals, and the environment.

Notification can be accomplished with a general statement to the public. Or, it can be targeted to those who live within a mile radius of hog confinements and fields where confinement waste is spread.

Thank you for considering this request to educate the county’s residents.

Bob Watson

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patricia fuller letter.doc

Ugly future may not include antibiotics.

            As a health-care professional, I am deeply troubled about recently disclosed information on MRSA (methicillen-resistant staphylococcus aureus) a potentially dangerous bacteria traced to overuse of antibiotics. This past March, at the International Conference on Emerging Infectious Diseases in Atlanta, Tara Smith, an assistant professor at the University of Iowa Department of Epidemiology reported her findings on MRSA on swine farms, which confirmed the presence of MRSA in both swine and swine-farm workers.

            Smith found MRSA in more than 70 percent of the 209 pigs they tested on 10 farms in Iowa and Illinois. Of the 20 workers tested on swine farms, 45 percent carried the same MRSA bacteria found in pigs.

            MRSA was identified as a potential killer in the early 1960s. In the mid 1900s, the CDC reported that MRSA had broken out of its usual medical institutional setting and was occurring in the young and healthy population.

            It was during this time the prophylactic use of antibiotics in livestock went from rare to commonplace. The similarity between the time line for increased use of antibiotics in livestock and the soaring rate of MRSA in the general population should spark Iowans to demand additional research.

            This increase in antibiotic-resistant bacteria is raising concern that we may be entering the post-antibiotic era, meaning a period where there would be no effective antibiotics available for treating many life-threatening infections. Death due to infection will once again become a very real threat.

Patricia Fuller, Council Bluffs From a letter to the editor of the Des Moines Register.

Bob Watson

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ipp critique comments.doc

Comments on IPP’s critique of the INRS

            Although an adequate recitation of what is known, the Iowa Policy Project (IPP) critique of the Iowa Nutrient Reduction Strategy (INRS) could have used a contextual story, a discussion of the inherent inability of any regime to address some pollution avenues from this recent industrial model of agriculture, and suggestions as to where agriculture needs to go in the future. While pointing out deficiencies like “voluntary only” and no numeric testing, limits, or reporting of nutrient pollution coming off farm fields (in this particular case pollution is being called proprietary trade secrets that supposedly can’t be made public; really? pollution?), IPP’s critique seems to go along with the notion that the future of agriculture is corn and beans, and feedlots and confinements. If one assumes that this recent post WWII industrial model is the future of agriculture, even if agriculture is regulated at some point in the future, we will never get rid of nutrient pollution, erosion, and flooding.

            As Bonnie Blodgett, Minneapolis StarTribune columnist, commented to me: “I do think farmers got fed a line of bull by Big Ag and are now being told it’s their job to correct a problem that can’t be fixed within the current ag model.” As Bonnie alludes to, as long as we use this corn and beans, confinements and feedlot model of agriculture, we will have unsolvable pollution problems.

            There are a number of non-point ag pollution avenues that simply cannot be addressed with either the conservation practices that are in the INRS or even any new future regulations. In fact, some of the INRS anti-pollution conservation practices actually pollute themselves.

            When anhydrous ammonia is applied to crop fields, much of that ammonia volatilizes into the air. That ammonia, along with the ammonia that is blown out of confinements 24/7 365 days a year, make up the Midwest ammonia cloud which is concentrated over Iowa. The Iowa DNR has had conversations about and knows that when it rains and the ammonia precipitates out of the air as ammonium nitrate, that amount of ammonium nitrate is a significant contributor to the EPA imposed limit where ammonia is no longer a nutrient, but becomes a pollutant in our surface waters. What in the INRS, or any new regulation, addresses this pollution avenue?

            With the prevailing winds, that ammonia cloud flows east and is a major contributor to the new acid rain: nitric acid rain. Nitric acid rain is doing the same sort of damage in the eastern US as the original sulfuric acid rain did. How does the INRS, or any new regulation, stop this pollution avenue?

            As the IPP report made clear, nitrogen put on fields that isn’t used by the plants and that doesn’t run off in rain events, still would not be stopped even if buffer strips were used because some of it flows down through the soil profile and into field tiles. That untreated and unused nitrogen flows into Iowa’s 880,000 plus miles of field tile which lead directly to our surface and ground water, and eventually into our aquifers. How does the INRS, or any new regulation, affect this pollution avenue?

            A long-term study of industrial nitrogen uptake, published in the online edition of the Proceedings of the National Academy of Sciences, shows nitrates from agricultural nitrogen-based synthetic fertilizers could continue to leach into groundwater for at least 80 years after initial use. How does the INRS, or any future regulation, affect this time span pollution avenue?

            It is known that organic nitrogen has always been in our surface waters. However, because the Green Revolution uses industrial fertilizers, today’s nitrogen is in the form of nitrate nitrogen rather than the historic organic nitrogen from animal and green manures. Even though organic nitrogen was in the surface waters, organic nitrogen needs to break down to be in a form that is available to plants. But the Green Revolution’s nitrate nitrogen is in a form that is readily available to algae and other biological organisms. This nitrate nitrogen, versus pre WWII organic nitrogen, leads directly to the algae blooms and other problems seen in our surface waters today. What in the INRS, or any new future regulation, addresses this new industrial form of nitrogen and its pollution avenue?

            While the DNR contends confinements don’t need discharge permits for their fecal waste because they are zero discharge buildings, that is not true. Hog confinements actually discharge 100% of their waste (sewage actually) when it is spread on farm fields. And, that waste is no longer “valuable manure” but rather a brew of at least 130 toxic compounds that have cooked up into sewage during six months to a year in a pit directly beneath the animals, in a tank, or in a lagoon. Since this fecal hog waste is five times stronger (more polluting) than untreated human waste, and since there are always at least 15 million hogs in confinement at any one time in Iowa, this is like having 75 million people living in Iowa, collecting their waste, but cooking it instead of treating it, and then just dumping it on fields and calling it manure. That waste can then wash off the fields and into our surface waters during rain events. This is not, and never would be, allowed in the regulated point source sector. What in the INRS, or any new future regulation, addresses this pollution avenue?

            A number of studies have shown that a new form of MRSA (an antibiotic resistant Staph infection) unique to hog confinement pigs, workers, and farm family members, can be acquired by people from simply being in contact with or in proximity to hog confinement waste spread on farm fields. How does the INRS, or any new future regulation, protect us from this harmful to human health pollution avenue?

            The same “flowing down through the soil profile” process that we saw with the nitrogen from anhydrous is at work in field applied confinement waste, too. Because most of our rich organic biologically active topsoil is gone, and because the soil that is left has been drenched with chemicals for the last 50 years, that soil is not capable of treating much of the confinement waste. Hog waste that doesn’t run off in rain events and isn’t treated by the soil travels through field tiles and into our states waters. How can the INRS practices, or any new regulation, affect this untreated hog confinement sewage pollution stream going into tile lines?

            Hog confinements, actually poorly designed and poorly operating wastewater technology, must exhaust the poison sewer gasses that are the continuous products of having anaerobic digestion taking place in their pits. Those sewer gasses, hydrogen-sulfide, ammonia, and methane, must be continuously vented out of the confinements into the surrounding neighborhoods or the pigs inside will die within 20 minutes. The resultant harmful human health effects for neighbors and the environmental damage from these gasses have been well documented. Along with our local lawsuit asking the EPA to regulate those poison sewer gasses through the Clean Air Act, we filed 177 medical and scientific studies showing detrimental human health and environmental effects from these gasses. If we continue to use confinements and feedlots, what in the INRS practices, or any new future regulation, would be able to affect the detrimental effects of these poison gasses?

            Simply using no-till as a practice has resulted in new and expanding dead zones in the Great Lakes (and by extension, the Gulf of Mexico). It turns out that no-till releases “dissolved reactive phosphorus” from the soil. That phosphorus then runs into rivers and streams and then into the lakes leading to the dead zones and other problems we see in our waters (Toledo, Ohio’s drinking water problem in August of 2014). How does the INRS, or any new future regulation, affect this pollution avenue?

            Pollutants from this industrial ag model are considered “externalities” by agricultural entities. The public is expected to bear the brunt of the cost, monetarily, human health wise, and environmentally, that these “externalities” bring. This is the basis of Bill Stowe’s “rate payer’s argument.” Ag pollutes the water and you pay to clean it up through ever higher water and sewer bills. As we have discussed, as long as we use this corn and beans, confinements and feedlot model of agriculture, we will always have unsolvable pollution problems.

            Farmers have only followed what land grant colleges and corporate ag interests have told them, and sold them, to do. Farmers didn’t choose this industrial model. They didn’t understand the flooding, erosion, and nutrient pollution that would be caused by adopting this recent industrial model. And, they shouldn’t be made to bear the cost of transitioning to a new clean agriculture. We all should.

            The IPP critique did not provide any suggestions about what kind of agriculture we could transition to that would mitigate nutrient pollution, erosion, and flooding. Thankfully, there are crops and cropping systems that are available today, that could be adopted today, which would recreate a sponge-like landscape and re-perennialize our agriculture without sacrificing our ability to feed ourselves or provide for our manufacturing needs. Those crops and cropping systems would foster a non-polluting, biologically benign and beneficial, soil building agriculture that would mitigate the flooding, erosion, and nutrient pollution problems caused by this recently adopted industrial model of agriculture. (to see go to www.civandinc.net appendix H)

Bob Watson    

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d-borlaug.doc

The Dark Side of the Green Revolution – II

            In light of the centenary celebration of his birth, we should remember there is a sense in which Norman Borlaug’s Green Revolution can be viewed as one of the most serious and sustained human-caused pollution events in history.

            Similar to US, Midwest, and Iowa farmers, other countries farmers’ use of chemical fertilizers, pesticides and herbicides as part of the Green Revolution has resulted in dead zones, algae blooms and polluted surface and ground waters. Locally, Iowa’s impaired surface waters list is now well over 600. We find agricultural chemicals in the majority of our private wells. And, we have seen recent stories about poison algae blooms and Iowa’s contribution to the continuing dead zone in the Gulf of Mexico.

            Again, like many agricultural areas in the US and around the world, because of drenching soils with chemicals for 50 plus years, the soils in some areas of the Punjab, India’s breadbasket, are now so polluted and bereft of beneficial biological organisms that crops can no longer be grown without the use of chemicals. And similar to what has happened to the Ogallala Aquifer, because of the Green Revolutions’ need for water, the Punjab’s and other water tables have been significantly lowered.

            Although it has been claimed that the Green Revolution has saved millions from starvation, we know that millions of subsistence farmers have been put off the land through not having the capital resources for the machinery, chemicals and hybrid seeds required by the Green Revolution. Millions of people have moved into urban areas contributing to urban problems that come with over-population. Similar to the US’s illegal immigration problem, millions have been forced to migrate to other countries looking for work.

            We have a tendency to pat each other on the back and give each other awards and accolades. Meanwhile, unintended, but very real, consequences are conveniently brushed aside and ignored.

            Borlaug’s admonition that no food revolution will help unless we deal with the problem of over-population is seldom remarked upon. It should be. But, his Green Revolution is not the right agricultural model for the earth or for its people.

Bob Watson

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bill leonard response.doc

Op-ed submission:

            If it were the case that cleaning up industrial agriculture’s inherent pollution was as easy as assigning personal responsibility for “burning leaves”, “second hand smoke”, or “pet poop”, I would agree with Bill Leonard’s letter objecting to the Register editorial calling for taxpayers’ help in paying to clean up ag’s pollution (“Why is it the taxpayers’ obligation, not farmers’”, Register 8-13).

            But that is not the case. Ag’s pollution is a massive problem with millions of acres of row crops and thousands of confinements and feedlots in Iowa alone. And there are avenues of nutrient pollution, erosion, and flooding coming from this recent industrial model that no conservation practices, however well intentioned, can fix.

            Because farmers did not choose this model, I am one who advocates for all of us to share in paying for a “transition” away from this inherently polluting, recent industrial – CAFO – Green Revolution – GMO model of ag that is now dominant.

            There was a perfect storm after WWII consisting of Borlaug’s Green Revolution’s need for nitrogen fertilizer, chemical companies needing a market for their bomb-making explosive material (ammonium nitrate – nitrogen), and land grant colleges and universities being taken over by corporate ag input and output companies. Farmers did not understand the flooding, erosion, and perpetual pollution that would become the hallmark of this kind of agriculture. They simply did what land grant colleges and corporate ag interests told them, and sold them, to do.

            I advocate for a transition to crops and cropping systems that are available today, that could be adopted into the farm bill today, that would recreate a sponge-like landscape (flooding), and re-perennialize our agriculture (erosion) without sacrificing our ability to feed ourselves or provide for our manufacturing needs. And, those crops and cropping systems would foster a non-polluting (no nutrient pollution), biologically benign and beneficial, soil building agriculture that would mitigate the flooding, erosion, and nutrient pollution inherent in this current industrial model of agriculture (see www.civandinc.net appendix H).

            Agriculture is how we as a nation (and the world) feed ourselves. And how, if it is done right, future generations will feed themselves. This is too serious a problem to tell farmers it is up to them to clean up this mess (impossible anyway with this industrial model) when we are all complicit (by our ignorance or silence) in its adoption.

Bob Watson

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gipp northey response.doc

            While a nice story, Bill Northey and Chuck Gipp’s “On The Right Path” (Register 7-3-14) is fiction. Record nitrate levels in rivers are not fiction.

            The Iowa Nutrient Reduction Strategy (INRS) is touted as being the vehicle to clean up Iowa’s and the Gulf’s waters. But the only part of that strategy that is regulated through the Clean Water Act, and therefore required to clean up its discharges, is the point source sector which only includes municipal and industrial wastewater treatment plants. This is Bill Stowe’s “rate payers” argument. Ag pollutes – you pay to clean it up through ever increasing sewer and water rates.

            The courts have held that the Clean Water Act cannot be used to regulate non-point dischargers, which is agriculture. So the agricultural non-point part of the INRS is on a voluntary basis only. And as record high levels of nitrates in rivers show, voluntary is not working so well.

            It is known that nitrogen has always been in our rivers. Before World War II most nitrogen in our waters was from animal and green manure which had to break down before it could be used by plants. Rivers and streams were safe for human use. With the adoption of the Green Revolution and industrial fertilizers, however, that nitrogen is in the form of nitrates, which are readily available for algae and other plants. This nitrate nitrogen, unlike organic nitrogen, leads directly to the algae blooms and some of the other problems we see in our surface waters.

            If we are going to continue mining our soil (two bushels of soil to produce one bushel of corn – the soil will be gone some day) to grow corn and soybeans (that is a debatable future), and if Gipp and Northey are actually serious about stopping nutrient pollution from coming off farm fields through flooding and erosion, then they should work towards getting the INRS’s STRIPS (10% of an annual field in native prairie strips stops 95% of erosion and therefore the nutrients attached to the soil particles) as a mandatory part of the farm bill.

            Also, there are crops and cropping systems that are available today that could be adopted today which would recreate a sponge-like landscape, re-perennialize our agriculture, without sacrificing our ability to feed ourselves or provide for our manufacturing needs. Those crops and cropping systems would foster a non-polluting biologically benign and beneficial, soil building agriculture that would mitigate the flooding and nutrient pollution problems caused by this recent industrial row crop model of agriculture. (to see go to www.civandinc.net appendix H)

            The usual corporate ag apologist myth that is trotted out to justify growing corn and beans in Iowa, and the reason that we supposedly have to put up with this nutrient pollution, is that we feed the world. Hell, Iowa doesn’t even feed itself. We import 85% of our people food. 

            If Gipp and Northey really want to clean up Iowa’s waters, they should lobby Iowa’s US legislators to change the farm bill to adopt existing crops and cropping systems, including the “low hanging fruit” STRIPS (10% prairie gets rid of 95% erosion), that would mitigate pollution and still raise people food.

            Understanding that farmers have only followed what land grant colleges and corporate ag interests have told them, and sold them, to do, prairie seed for that 10% of annual fields should be paid for by the US government. Farmers didn’t choose this industrial model. They didn’t understand the flooding and nutrient pollution that would be caused by adopting this recent industrial model. And, they shouldn’t be made to bear the cost of fixing it. We all should.

            Right now some of us will be paying forever trying to deal with the problem (the Stowe argument). By changing the farm bill, we would all be paying for the solution.

Bob Watson

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sides clash hog dsm letter.doc

Dear Editor,

            It was somewhat disappointing to read the apparent ignorance of Iowa State professors in regard to where our state’s water pollution comes from (Sides clash over hog expansion, Register 6-8-14).

            The accepted numbers are agriculture 92%, wastewater treatment plants 4%, and other 4% – although the “other’s” contribution is from the same chemicals as agriculture.

            It is technically correct to say that “Cities are allowed to discharge treated sewage that still contains nitrates into waterways, under their Clean Water Act Permits. Hog producers, however, are prohibited from letting manure into Iowa waterways.” But it is somewhat disingenuous.

            The relative ammonia/nitrogen pollution numbers for hog confinement waste and treated human waste is 300-400 for hog confinement waste and 1-5 for treated human waste (IDNR numbers). Although confinements are touted as not discharging waste, all of the waste is spread on the land eventually. Because of the relative numbers, it is like having 75 million people living in Iowa, collecting their waste and letting it “cook up toxics” for 6 months to a year in a pit, and then simply dumping it on the land where much of it ends up in our rivers and lakes (the 92% comes from somewhere).

            As a result of treatment of human waste, the cleanest sections of most rivers are directly downstream of wastewater plant discharge pipes. Your water and sewer rates pay to clean and treat water for drinking, and for the treatment of your waste so it is safe to discharge back into the environment. That is mandated by the Clean Water Act.

            There are no regulations or mandates on the 92% of pollution coming from agriculture. Until that changes, (and the completely voluntary Iowa Nutrient Reduction Strategy will not help) you will continue to pay higher and higher water and sewer rates while the waters of Iowa continue to become more and more polluted. Good luck.

Bob Watson

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star tribune gmo letter.doc

Letter to Mpls Star Tribune 5-27-14:

Dear Editor,

        The Star Tribune runs the risk of compromising the integrity of the new “science+health” section by putting in obvious industrial agriculture corporate apologist stories like the “DON’T KNOW MUCH ABOUT GMOS?”, Sunday May 25th.

        Inserting genes (GMO) is the same as cross breeding? We will feed the world with cattle feed, corn oil, cornstarch, high fructose corn syrup and soybean oil?

        In Iowa we hear this same refrain: we feed the world. But, Iowa has to import 85% of its food; and I’m sure Minnesota is similar. How can we claim that we must put up with all the nutrient pollution, erosion, and human health problems (obesity, diabetes, asthma, circulatory problems, etc) that come from this recent industrial model of agriculture, when we can’t even feed our own states’ people?

        For the sake of your readers’ confidence in the veracity of your stories, please leave out the obvious industrial ag apologists’ urban myths.

Bob Watson

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water street ag trucks.doc

Ag trucks traveling Water Street:

            This is an email chain on this issue. The people that I have contacted are Chad Bird and Randy Uhl and they are the people in this email chain.

            Chad recently told me that there is a subcommittee now working on this; the Chief of Police and the City Engineer. So you are getting this email so that you understand where this has come from and the dangers that are being foisted on unsuspecting people using Water Street.

        On the confinement trucks going through town on Water Street, I originally told the city they only needed to make two phone calls to get it to stop. One to the Waukon Feed Ranch, and the other to Lynch Livestock.

        They are the two abusers. I’m not sure what the problem with the city taking some action on this is. Whenever I mention this, to office holders too, people are incredulous, and see the trucks too.

        The city wouldn’t have to prohibit a type, but prohibit any trucks that are not delivering to town. That would catch the trucks coming and going from confinements.

From Randy Uhl:

Not sure what barriers the city may face in addressing the trucking issue. But one thing I wondered about is how to specifically prohibit a “type” of truck content. I can see regulating by size and weight, axles, etc. But that kind of regulation would affect a lot of “clean” deliveries to downtown stores.

I Googled several variations of the regulating issue and didn’t really find anything concrete. (Although one site seemed to have a very helpful article on regulating menstrual cycles, but I couldn’t seem to make that fit into what we are talking about.)

I also went on the Iowa League of Cities site. I would think a member (Decorah/ Chad Bird) could probably e-mail them the question and get an answer.

Randy,

        I recently sent this email (below) to Chad Bird. I thought that this was being discussed and truck routes would be put in place by the city by now, but that was with the old configuration of the City Council.

        I am sending this to you because I don’t know the tourism person and I think this would be important to that person, and important to you in your endeavors, too.

        Chad’s response was:


[Bob,

Thanks for the reminder. We are still discussing and reviewing the truck route scenarios in town. As you may know, we do not have any formal truck route mapping or signage so are starting from scratch on this issue.

We continue to discuss as priorities allow. I will pass this on to council and ramp up the discussion again.

Chad]

        If you look out your front window, there will be Waukon Feed Ranch semi’s driving on Water Street every day, and some times there will be actual pig transports apparently going to Freeport. The health problems discussed below are being carried by those trucks. I am not sure this is something that enhances Decorah. And, it is completely avoidable if the city would enact truck routes.

        I am also sending this to you as you might be a part of the Downtown Betterment group, or at least know who they are. I think they would like to know this, too.

        I would answer questions about this if anyone has any.

        Thanks for your help on this.

Bob

Bob Watson

Hi Bob,

I just talked with Nikki Brevig, Decorah Area Chamber of Commerce director, to see what the latest is. I had mentioned it to her a while back because the DACC administers Downtown Decorah Betterment. I thought Betterment was a good place to have the discussion.

She said Betterment had discussed the issue a while back but felt as though they had reached a dead end. Betterment cited that we have two ag-related businesses — Winneshiek Coop and Thornton Feed & Grain — near the downtown area. Also, they had concerns about funneling ag truck traffic off Water Street onto the narrower Broadway or Main Street.  Or worse, down near Decorah High School and John Cline Elementary.

Bottom line is that they referred the issue to the City of Decorah.

I know this doesn’t help much, but at least now you know it has gone past Betterment.

RU


Chad,

        I originally put this email together for people fighting hog confinement expansions. Among the many other human health problems, hog waste, which is spread on fields and from trucks, can infect people with MRSA, and/or antibiotic resistant infections. Add to that the PED virus, millions of pig deaths so far, that is being spread from confinement to confinement by trucks and waste haulers, and you have an infectious brew that is not pretty.

        With this in mind, it still boggles my mind that Decorah allows semis and trucks that have been hauling to and from hog confinements to continually use Water Street; both feed trucks and actual transports. If Decorah thinks that this is safe, they are highly mistaken. If Decorah thinks this is beneficial to tourism, they are doubly mistaken.

        By allowing these trucks to travel our main street, Water Street, we are endangering ourselves and our children’s health, and we are doing a disservice to those businesses that depend on tourism; including many of the fine restaurants in town.

        I have mentioned this before along with the suggestion that truck routes be labeled and enforced. What ever happened to this discussion?

        The 3 studies and PED virus information is below.

Bob

        Besides the study on Iowa City VA veterans who live in proximity to hog confinements, there are two other studies (among others I assume) on MRSA and confinements.

        I have included the Iowa City VA and Johns Hopkins study articles below.

        The third study, and the original study that found a unique MRSA strain that is only in hog confinement hogs, workers and families, was done by Tara Smith at the University of Iowa. She is listed in the VA study but she was not the lead author on this recent study.

        I worked with Tara by finding her pasture raised hogs, farmers, and farm families to test for MRSA. She found no MRSA in pastured raised settings either in pigs or people.

        I also asked Tara to be on a panel with me when the Iowa Academy of Science asked me to put together on this confinement issue; the other person on the panel was Joel Kline, MD, U of Iowa, who did the North Winn study. After they gave their presentations, I did my presentation that shows confinements are poorly designed and operated wastewater technology anaerobic digesters that create a sewer environment (with the poison sewer gasses) both inside and outside confinements. Tara’s comment to me was that after listening to my presentation, she now understood why they were finding what they were finding. Researchers had no idea these were actually wastewater technology that led to the environments that allowed these pathogens and poisons to be created and exist.

        While they are spreading waste, the haulers will be spreading PEDv if that disease is in the confinement. And the trucks that deliver feed and transport pigs to market will be spreading both the MRSA and the PED virus.

Bob


The Johns Hopkins study article and link:

Researchers from the Johns Hopkins Bloomberg School of Public Health have for the first time found an association between living in proximity to high-density livestock production and community-acquired infections with methicillin-resistant Staphylococcus aureus, commonly known as MRSA. Their analysis concluded that approximately 11 percent of community-acquired MRSA and soft tissue infections in the study population could be attributed to crop fields fertilized with swine manure. The study is the first to examine the association between high-density livestock operations and manure-applied crop fields and MRSA infections in the community. The results were published online September 16 in JAMA Internal Medicine.
The rest of the story can be found at:

<http://www.jhsph.edu/news/news-releases/2013/casey-schwartz-mrsa.html>



The Iowa City VA study article:

Almost 3 times the risk of carrying MRSA from living near a mega-farm

By Marilyn McJenna

1-22-14

In the long fight over antibiotic use in agriculture, one of the most contentious points is whether the resistant bacteria that inevitably arise can move off the farm to affect humans. Most of the illnesses that have been associated with farm antibiotic use ­ resistant foodborne illness, for example ­ occur so far from farms that opponents of antibiotic control find them easy to dismiss. So whenever a research team can link resistant bacteria found in humans with farms that are close to those humans, it is an important contribution to the debate.

A team from the University of Iowa, Iowa City Veterans Affairs, and Kent State University have done just that. In next month’s Infection Control and Hospital Epidemiology, they survey 1,036 VA patients who lived in rural Iowa and were admitted to the Iowa City facility in 2010 and 2011. Overall, among those patients, 6.8 percent were carrying MRSA, drug-resistant staph, in their nostrils. But the patients’ likelihood of carrying MRSA was 2.76 times higher if they lived within one mile of a farm housing 2,500 or more pigs.

They say:

The increasing populations of swine raised in densely populated CAFOs and exposed to antibiotics presents opportunities for drug-resistant pathogens to be transmitted among human populations. Our study indicates that residential proximity to large numbers of swine in CAFOs in Iowa is associated with increased risk of MRSA colonization.

Some important things to unpack here:

MRSA (formally, methicillin-resistant Staphylococcus aureus) often “colonizes” people ­ takes up residence on the skin or in the nostrils ­ before it causes an infection. Studies have shown repeatedly that being colonized with MRSA increases the risk of contracting a difficult-to-treat infection.
Because of that risk, and because MRSA spreads easily in hospitals, the VA since 2006 has required facilities to screen all incoming patients to see whether they are carrying MRSA and thus are posing a risk to other patients.
MRSA is frequently found in the vicinity of pigs: not just MRSA ST398, the specific resistant variety that was first identified in pig farmers in the Netherlands in 2004, but the garden-variety community forms as well.
And Iowa has a lot of pigs: 19 million, according to the US Department of Agriculture, housed in about 7,000 “CAFOs” (for confined or concentrated animal-feeding operations), which the US Environmental Protection Agency defines as a facility of at least 1,000 pigs, though most are many thousands larger.
(If you’d like to know more about MRSA, including the “livestock-associated “pig MRSA” variety, I wrote a book. OK, back to this paper.)

The authors, led by Margaret Carrel, PhD, initially identified 2,996 patient admissions in that 2-year period, and then winnowed out any patients who lived in cities as well as any whose addresses could not be confirmed and plotted using geo-coding. That left them with 1,746 samples taken from 1,036 patients, of which 119 ­ 6.8 percent ­ were positive for MRSA. That was a red flag to begin with, because MRSA colonization in the general population is less than 2 percent.

Using data from the Iowa Department of Natural Resources for the locations of very large pig-raising facilities, they then sorted the patients by the distance of their homes from pig CAFOS. Initially, patients who lived 1 mile or less from a CAFO were 1.8 times more likely to be colonized. When the team cleaned up the data ­ accounting for patients who came into the hospital more than once in that 2-year period, and also adjusting for the known likelihood that elderly patients, who are likely to be in a VA facility, have higher colonization rates ­ they came up with a relative risk of 2.76.

This is not the first time that MRSA has been found in people who work on farms or live in the vicinity of them. Last year, a study found “pig MRSA” in workers from North Carolina hog farms, and another identified it in workers in Iowa and Illinois. Meanwhile, a third study published just in November found MRSA among people who lived in the vicinity of fields where swine manure was being applied. And last year, a group in Germany identified MRSA in people who lived near hog farms but did not have contact with animals.

None of these studies have been able to trace with precision how workers and neighbors are acquiring MRSA. The authors of the newest study say:

Although the exact mechanism by which residential proximity to large swine CAFOs increased risk of MRSA is unknown, it appears that there is potential for drug-resistant strains of S. aureus in animals to transmit to people living at close distances. For example, a 55-pound or greater hog can produce upward of 10 gallons of manure a day. Typically, in Iowa, manure is spread on surrounding fields, and MRSA can be aerosolized from this manure to human food or water sources.

And they add:

Residential proximity to CAFOs could be risky in ways other than simply direct exposure to preexisting livestock-associated S. aureus strains, including via exposure to antibiotic residues via air or water, application of manure containing residues near their homes.

As last year ended, a number of food-policy writers noted that 2013 marked the first time that discussion of agricultural use of antibiotics ­ and the unintended consequences of that use ­ really emerged into mainstream discourse. Papers like this can move that process along. Throughout the decades-long discussion of farm antibiotics, the challenge has been linking the externalized costs of those antibiotics back to their use on the farm. The more those off-farm effects are elucidated, the more complete and transparent the discussion of on-farm use ought to become.

Cite: Carrel M, Schweizer ML, Sarazin MV, Smith TC, Perencevich EN. Residential Proximity to Large Numbers of Swine in Feeding Operations Is Associated with Increased Risk of Methicillin-Resistant Staphylococcus aureus Colonization at Time of Hospital Admission in Rural Iowa Veterans. Infect Control Hosp Epidemiol 2014;35(2).

Maryn McKenna is a journalist for national magazines and a Senior Fellow of the Schuster Institute at Brandeis University. She is the author of SUPERBUG and BEATING BACK THE DEVIL, and is writing a book about food for National Geographic.

Bob Watson

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gazette paying farmers.doc

Paying farmers to not pollute – Gazette letter 5-13-14. Dear Editor,

        According to Tim Smith, “Funding facilitates nitrate reduction” Gazette 5-12-14, we should be paying farmers to reduce their nitrate pollution. Should we also pay farmers to reduce this industrial model’s contribution to the loss of pollinators; pay them to stop their part in the honey bee colony collapse; pay them to stop soil erosion; flooding; dead zones; nutrient pollution to our surface, groundwater and aquifers; pay them to stop the poison sewer gasses, hydrogen-sulfide and ammonia, and the greenhouse and explosive gas methane coming from hog confinements; pay them to stop nitric acid rain from CAFOs and the volatilization of anhydrous ammonia; pay them to stop contributing to human health issues like antibiotic resistant bacteria including MRSA; asthma and other respiratory, digestive and nervous system diseases from CAFOs; pay them to stop contributing to obesity, diabetes and circulatory problems from highly processed foods; pay them to quit plowing up wildlife habitat; pay them to quit drenching soil organisms with chemicals; pay them to foster soil health and soil building; pay them to quit using GMOs, fertilizers, pesticides and herbicides?

        Wouldn’t it be much easier and cheaper to replace this industrial model of agriculture with crops and cropping systems that would foster a non-polluting biologically benign and beneficial, soil building agriculture that doesn’t sacrifice our food and manufacturing needs, and that exists today and can be adopted today?

        If you are curious about these crops and tired of hearing how we should pay farmers to quit polluting, go to www.civandinc.net appendix H. Get your legislators to change the farm bill and you will change agriculture. And, you will once again live in a healthy and non-polluted Iowa.

Bob Watson

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5 Pillars of Sponge Ag.ppt

Bob Watson

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feb 2nd gazette response.doc

            To think that the Iowa Nutrient Reduction Strategy can affect changes that would clean up this particular, recent, post WWII, soil losing, nutrient polluting, flood enhancing, hydrologically short circuiting, human health harming, petro/chemical/industrial, CAFO, Green Revolution, row crop model of agriculture is disingenuous.

            As conservation band-aids these strategies are useless:

1. because there is no implementation instrument – making it a voluntary only program;

2. because of scale – millions of acres of corn and beans versus a few small conservation band-aid projects;

3. because there are practices included in these strategies that actually pollute themselves;

4. because there are practices included that short circuit hydrology contributing to flooding and not recharging our groundwater and aquifers;

5. and, because there is nothing in them that we did not know or could not have implemented years ago, and we haven’t.

            These strategies are needed only if we assume we will continue with this corn – beans – confinement – feedlot model of agriculture.

            We have a choice. We can continue with this inherently polluting, soil losing, petro/chemical/industrial agriculture. Or, we can switch to a non-polluting biologically benign and beneficial, soil building agriculture that doesn’t sacrifice our food and manufacturing needs and that exists today and can be adopted today.

            What this non-polluting agriculture might look like:

1. edible perennial prairie grains for humans and animals – no chemicals, no runoff, no erosion, no yearly tillage, builds soil, provides habitat, exists today – scaled up for sale to farmers by 2020;

2. strips of perennial native prairie in all annual fields – 10% of annual fields in strips stops 95% of soil erosion, builds soil, provides habitat;

3. prairie and grass based animal farming – no chemicals, no runoff, no erosion, builds soil, provides habitat;

4. industrial hemp – cover crop, no chemicals if used in crop rotations, used with strips, provides habitat, provides food and fiber, replaces many oil based manufactured products, revitalizes rural America with factories and processing plants, 350 year history as a crop in North America;

5. small grains, hays, fruits, and vegetables – used with strips, provides habitat, builds soil.

            What is at stake is our continued ability to feed ourselves. This current industrial model of agriculture is unsustainable and polluting. The biological organisms in our soil are being destroyed through years of chemical application. And through unsustainable erosion, even that polluted soil will someday be completely gone.

            We still have a choice. We can switch to a non-polluting, clean, soil building agriculture if we want to.

Bob Watson

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summary of laws lost appendix.doc

Summary of laws lost or not used in the fight against CAFO’s (2013)

            This is a summary of the laws that could be used but are not in relation to protecting the public from the sewer gasses and particulates that are produced by confinements and feedlots; and the laws that were on the books and that could have been used but they were changed or gotten rid of.

1. Agency Discretionary Rule. EPC/DNR doesn’t use (except maybe once).

2. Separation Distance Between Confinements and Sinkholes. Lost when language was changed.

3. “Permit to Operate” laws: Iowa Administrative Code 567.64.3. Under 64.3(1)h.(2) those CAFO’s cannot be excluded from regulation. Lost when moved to Chapter 65 and changed the language.

4. 2008 EPA CAFO Rules. Lost in federal district court in Oklahoma. Cannot regulate CAFO’s using the Clean Water Act.

5. CERCLA provision of Superfund: Community Right to Know. Changed to write a letter once a year to say their CAFO is polluting.

6. OSHA “General Duty Clause” prompts “Confined Spaces Regulations”. No one will use.

7. Home Rule. State laws only allow the DNR to regulate sewer gasses and particulates coming from CAFO’s and they won’t or say the Legislature won’t let them.

8. State denies anaerobic treatment taking place in confinements. The State and the DNR say that confinements are for storage only. That way they don’t have to regulate them as wastewater treatment technology. A DNR construction permit requires confinements which create sewer gasses and particulates that are vented to neighborhoods and the larger environment.

(1). The following will explain how to use the Agency Discretionary Rule:

            Rich Leopold, the new Director of the DNR, has let it be known both inside and outside the DNR that he will rarely use what in the press and public has been known as the Director’s Discretionary Rule, but is really the Agency Discretionary Rule. When I contacted Rich Leopold and told him I was going to write about this issue he emailed me this language to use to explain his position: “I will use it as appropriate. But I will not be quick to use it. The burden of evidence needs to be such that we (the DNR) could defend our decision in court if necessary. This sets the bar high, but does not mean that the rule will not be considered and used when necessary.” To me that is unfortunate because the public has the perception that the rule was put in place to be used more widely.

            There is good news though. The rule still does exist and can still be used to protest those CAFO’s that do not fall under regular DNR rules but pose risks to people and the environment. After an email conversation with a member of the Environmental Protection Commission, this member laid out why the rule can be used and how to get a protested CAFO permit in front of the EPC to ask them to use the rule. Here is the EPC member’s language and direction:

        “Remember it’s the Agency Discretion Rule which means the EPC can invoke the rule itself. That would occur when the commission hears a county appeal. The county would need to request the EPC to use its discretionary authority under the rule, as well as citing any other reasons to deny the permit and then it would be up to the commission. If the county believes that it should appeal the granting of a permit it should do so. The commission will hear the arguments and make its own decisions. It’s not bound by any decision of the DNR director or staff. It takes those positions into account as well as other views including the county’s. The final authority in the agency is with the EPC.”

            So, it is the County Supervisors’ right, even when a confinement has enough matrix points and even when the DNR grants a permit, to protest that permit in front of the Environmental Protection Commission. They simply tell the Commission the reasons they feel a particular confinement, which may pass all the present legal requirements, isn’t a good idea and ask the Commission to deny the permit using the Commissions’ power under the Agency Discretionary Rules. Much of the Agency Discretionary Rules were written with karst in mind.

            So, if your county wants to appeal a permit, they need only appeal it to the EPC, request the EPC use the rule and provide the county’s reason(s) for denying the permit.

(2). In Iowa law there is supposed to be a 1000 foot separation distance between sinkholes and confinements in NE Iowa’s karst topography. That separation distance gives the public some assurance that their public water supply, aquifers, will not be subject to a pollution event from an industrial agricultural confinement. Not so anymore. Because there are so many places a proposed new confinement would be within 1000 feet of a sinkhole, and therefore not allowed, the pork producers asked our local legislators, Chuck Gipp and Mark Zieman, to change the law. In 2002 they did. SF 2293 repealed the section in 455B which had, in part, to do with separation distance from sinkholes. A new provision for “secondary containment structures” allowed building confinements within the 1000 foot minimum and that new language is, I think, found in 459.

            When confinements started being put in next to sinkholes, we asked the DNR how that could be when there was supposed to be a 1000 foot separation. The DNR held an upper level management meeting where this was discussed. At that meeting the DNR lawyers said that because of the way the new law, a variance granted for the 1000 foot minimum if a “secondary containment structure” was put in place, was written, there was “effectively no longer any separation distance between sinkholes and confinements”. A confinement could now be built right next to a sinkhole. Oddly, no one at that DNR meeting seemed to think they might want to look into how or why this change to the safety of the public’s water supply happened.

            The concept of “secondary containment” comes from the EPA’s regulation of the petroleum industry. It originally meant an earthen berm 360 degrees around a set of above ground tanks capable of holding 150% of the largest tank. In karst, for confinements with underground tanks, “secondary containment” means a pit dug on one side of the building big enough to hold 50% of the manure. How this ground level pit is supposed to contain a leak from an underground tank is unknown.  How any spill is supposed to happen on only that one side of the building is unknown.  And, how something illegal in karst for manure storage because of sinkholes, namely an earthen structure (the pit), allows you to build right next to a sinkhole in karst is also unknown.

            We are in real danger when our legislators are unable to understand the effects of laws they pass. And when they, and our regulatory officials, are apprised of those effects and are unwilling to reinsert the provisions which protect the public, we are courting disaster.

(3). Even though Iowa DNR says they can’t regulate confinements and open feed lots like they do other entities with fecal waste and poison gasses, that statement is not true. Because of a snafu by the State of Iowa when originally applying for EPA’s NPDES Permit program in the 1970’s, Iowa wasn’t enrolled in the program and had to create their own “Permit to Operate” laws, which the EPA accepted as a mirror program. Those rules, Iowa Administrative Code 567.64.3, included not only point source wastewater treatment plants, but also included CAFO’s. Under 64.3(1)h.(2) those CAFO’s cannot be excluded from regulation. Those rules are still on the books and could be used immediately to regulate CAFO’s (by a request to do so of the County to the DNR Director) as wastewater facilities thusly (but not limited to):

a: require monitoring wells around storage lagoons, concrete storage tanks, and fields being used for application.

b. testing requirements of waste for, but not limited to, nitrogen, phosphorus, E. coli, antibiotics, hormones, and other pollutants.

c. set rules for manure storage capacity.

d. set minimums for the depth to groundwater under storage facilities.

e. require tests of tile lines and adjacent streams where manure is applied.

f. impose requirements to prevent waste from running off fields.

            (Iowa Code 2003: Section 455E.5 Groundwater protection policies. #3 All persons in the state have the right to have their lawful use of groundwater unimpaired by the activities of any person which render the water unsafe or unpotable. #4 All persons in the state have the duty to conduct their activities so as to prevent the release of contaminants into groundwater.)

            Counties have the authority to enforce existing state and federal laws which address the interface between industrial poisons and the public, if the counties choose to do so. Any enforcement action would be up to the county attorney, with the direction or concurrence of the board of supervisors.

(4). In November of 2008, EPA finalized its new CAFO rule. Under that rule, any CAFO that discharges or proposes to discharge pollutants into waters of the United States must have an NPDES permit. This applies to all CAFOs, confinement operations and open feedlots. Counties can enforce this rule. This rule applies to all confinements regardless of size.

            The Oklahoma Attorney General was using this law in an action against Tyson. The County could use this section to protect neighbors and the watershed from pollution from manure. See (64.3) to see how testing could be done to see whether pollution goes from a confinement property to adjacent properties and/or the larger watershed.

            The EPA lost this suit and lost the ability to use the Clean Water Act in relation to agriculture.

(5). To protect the public from the poison gasses being constantly discharged into the neighborhoods of confinements, the County could enforce the CERCLA provision of Superfund: Community Right to Know. Under this law, monitoring equipment, per EPA regulations, would need to be installed by the owner at each confinement site’s exhaust vents and the owner would need to contact the EPA each day that the facility discharges more than 100 lbs of ammonia and/or 100 lbs of hydrogen-sulfide into the atmosphere. This would apply to most CAFO’s. (This section was changed in the waning days of the Bush administration. It now says a confinement need only send a letter once a year to the EPA stating the confinement is discharging the poison gasses hydrogen-sulfide and ammonia into the neighboring atmosphere. The National Sierra Club has a lawsuit pending to return this section to its original requirements.)

(6). To protect the public from the poison gasses inside and outside confinements, Counties could enforce the federal “Confined Spaces Regulations”. These laws can be enforced by OSHA through their “General Duty Clause”.  This clause comes into effect if a serious hazard is identified.  We know that over 20 Iowans have been killed from poison gasses in confinements, and that many studies show serious health effects to people from the emission of those poison gasses. A recent study from the U. of Iowa shows 55.8% of children on farms with confinements have asthma. These “recognized hazards” trigger OSHA’s “general duty clause” and allow OSHA to regulate these confinements. We are asking the Counties to enforce OSHA’s Confined Spaces Regulations and General Duty Clause. It seems reasonable when all of the wastewater facilities and sewer systems in Iowa are already regulated under these laws.

(7). I am attaching a few items for your consideration.  In essence, the regulation of

animal feeding operations by local jurisdictions is preempted by state regulations.  While this is an oversimplification of an otherwise complicated issue, the attached documents provide some context through Iowa Code citations, Attorney General Opinions, and Court findings.

            1. The attached AG Opinion speaks specifically to city authority over animal feeding operations, however in the document there are several references to county authority being preempted by state authority.  In most citations, the document references the court decision impacting Humboldt County (also attached).

            2. The attached Iowa Code citation is the language that appears to most directly

impact local authority.

            I’ve highlighted the sections of the AG Opinion and Iowa Code documents that appear to be most relevant to the issues and concerns you raised in your original email.

            Furthermore, it has been a long standing practice that State Agencies can act only

within the authorities granted to them under Iowa Code.  The Code of Iowa that establishes the authorities and duties of the Iowa Department of Public Health can be found in Iowa Code Chapter 135.  In this chapter there is an absence of any explicit authority for IDPH to regulate animal feeding operations within the state of Iowa.

            Regarding local board of health authorities, those authorities are spelled out in

Iowa Code 137 (Local Boards of Health) and again there is an absence of any explicit authority to regulate animal feeding operations.  Chapter 137 also specifically requires when local boards of health adopt rules and regulations that those regulations must not be inconsistent with state law.  This would seem to relate to the preemption discussion found in the AG Opinion; in that any attempt by local boards of health to regulate animal feeding operations would be “inconsistent” with state law and preempted by that state law.

            The authorities to regulate animal feeding operations clearly lie with the Iowa

Department of Natural Resources.

            I hope this helps to clarify the authorities around the issues and concerns over

animal feeding operations.

****

            The attachments you sent stating why the County or the State doesn’t have jurisdiction in this, or like, cases, do not address the issue that we contacted you about. The ongoing air quality issue on North Winn’s property is not addressed, nor does our request have anything to do with wanting to regulate cafo’s on their own property.

            As I mentioned originally, we are only interested in the interface between industrial poisons and the public. We are not interested in regulating anyone. We simply don’t think people, children in this case who are mandated to be in school by the State, should be exposed to industrial poisons – in concentration’s which are known to put their health at risk – when they are on public property regardless of origin of those poisons. The question is, does the State have an obligation to protect our most vulnerable citizens from air pollutants that can shorten their life span and leave them suffering from chronic and acute health conditions?

            I am wondering if you would address this more specific issue again with the Assistant Attorney General?

****

And the final word from the DNR on this request and issue:

What follows is the letter that I received from Wayne Gieselman, Administrator IDNR.

March, 28, 2011

RE: Odor, hydrogen-sulfide and ammonia concerns at North Winneshiek School

Dear Bob,

I am responding to your March 2, 2011 e mail to Catharine Fitzsimmons at the Air Quality Bureau. The subject of your e mail is hydrogen sulfide, ammonia, and odors “emanating from multiple hog confinements and one cattle feedlot in proximity to the North Winneshiek School”. In your March 2, 2011 e mail you indicated that you are “not interested in regulating anything or anyone. We are only interested in getting the ongoing air quality issue at North Winn resolved”. That’s good because at this time this department has no regulatory control over odors, hydrogen-sulfide and ammonia from the sources you listed.

In 2002 the Iowa Legislature directed the DNR to perform a field study to determine airborne levels of ammonia, hydrogen-sulfide and odor near animal feeding operations. The outcome of that study was no a new set of rules. It was a report titled “Animal Feeding Operation Technical Workgroup Report On: Air Emissions Characterization , Dispersion Modeling, and Best Management Practices” (12/15/04)/ The full report is available through the Iowa DNR website at http://www.Iowadnr.gov/air/afo/afo.html . Scroll down to “Animal Feeding Operation Technical Workgroup Report” and click on “complete report”. There are also a number of Iowa State University publications available to guide facilities in the reduction of hydrogen-sulfide, ammonia and odor. They are included in the report and individually at the same website. If the confinement and feedlot owners are interested in being good neighbors to the school they can voluntarily implement the practices described in the ISU publications. I would encourage you to work with all the parties to discuss these options. {no reduction methods have been successful – Watson}

I would also like to offer the assistance of the field office at Manchester. {the Manchester office won’t even log odor reports called in from the school – Watson} They could not assist from a regulatory standpoint but they could meet with the school’s neighbors to provide technical assistance. Another option {this organization that Wayne is suggesting to contact is a corporate ag apologist group fully funded by corporate ag – Watson} might be to contact the Coalition to Support Iowa Farmer. Brian Waddingham is the contact person. He can be reached at 800-225-5531. {the irony is too much – Watson} I believe that they might be able to help out with this too in terms of trying to come to some resolution about this.

I hope this is helpful to you. We will do what we can to assist you in this.

Sincerely,

Wayne Gieselman

Administrator

            So, through this email chain you can see that no one in the state of Iowa is responsible for children’s health when they are required by law to be on school property. And, no one at the EPA is very much concerned either.

****

This odyssey was somewhat summarized by an op-ed that Bob Watson wrote:

            Rural school kids are being poisoned – and the bureaucrats refuse to do anything.

            With most of Iowa’s livestock now being raised in factory-like, industrial settings, rural residents and rural schools are being subjected to the poison sewer gasses hydrogen-sulfide and ammonia, to the explosive and greenhouse gas methane, and to particulates.

            Concentrated animal feeding operations (CAFOs), which include both confinements and open feedlots, act like sewers and poorly operating wastewater digesters. They create sewer environments. But unlike carefully monitored industrial or municipal sewers, CAFOs are unregulated. They can and do constantly produce poison gasses, which are blown into the rural neighborhoods 24/7, 365 days a year. This is legal because the state and federal governments have exempted confinements and feedlots from all regulation concerning these poisons and particulates. Rules that normally would protect the public from the harmful health effects of these industrial technologies do not apply to agriculture. Rural schools – and school children – receive no protection from industrial poisons produced by agriculture.

            The essential question we are asking is: “Who is responsible for school children’s health when they are required by law to be on school property?”

            In our effort to find a solution to this problem in our county, we have gone to the Iowa DNR, our local County Board of Health, and the Iowa Department of Public Health – which checked twice with the Attorney General’s office. In each instance, when we asked who might be responsible for these children’s health, we have been told essentially that no one is. Apparently these poisons are not considered poisons when they are coming from industrial agriculture.

            Studies have shown that negative health effects normally associated with exposure to hydrogen-sulfide, ammonia, and particulates are higher in rural Iowa than most anywhere else in the US, as a percentage of population. We used to raise most animals outside on pasture. Up until a few years ago in Iowa, we raised more animals per year outside versus what we raise now in confinements and feedlots. We didn’t have these health problems in rural areas until we started using CAFOs – confinements and feedlots – with their inherent poisons and particulates.

            So, who is responsible for children’s health when their playgrounds and classrooms are inundated with poison sewer gasses and particulates? Do we accept the Orwellian decree from the State that these really aren’t poisons when they come from industrial agriculture, and those children’s health problems don’t really exist?

            We have been amazed and disappointed at this response – or really the non-response – from government officials to our inquiry. The harmful effects to human health and the environment from this modern petro-chemical industrial model of agriculture is probably Iowa’s most urgent peace and justice issue. It is despicable that children can be sacrificed for a model of agriculture that enriches a few corporations and leaves the rest of us living with the shattered remains of a once vibrant farming culture.

(8). It’s not just one bad egg. There are fundamental problems across industrial confinement agriculture. In the last year, both Iowa and Minnesota have seen an ominous increase in foaming in pits beneath hog confinements – like a potentially toxic bubble bath, it rises right through floor slats – exacerbating the already serious problem of dead pigs and flash fires caused by hydrogen-sulfide and methane.

            “I wish we had the answer,” said Angela Rieck-Hinz of ISU, writing in August on the Iowa Manure Management Action Group website, “but at this point in time we still have no answers as to what is causing the foaming or how best to control or manage the foam. If you have information regarding foaming pits you would like to share please contact me. In the meantime, I urge caution when pumping from manure pits. Be aware of safety concerns regarding manure gases, pit fires and explosions. Not all pit fires and explosions have happened in barns with foaming pits.”

            The crux of the problem is that confinement advocates have inappropriately transferred wastewater technology from the highly regulated sector of municipal and industrial wastewater to the unregulated – in terms of wastewater – sector of industrial agriculture. The concern about poison and explosive gasses is not new, and not only in those confinements with the foaming problem. It is simply a consequence of using wastewater technology to raise animals.

            In the wastewater industry, we learned long ago – after workers became ill or died – that we could not put normal workspaces in proximity to areas where fecal waste is decomposing. The constant production of the poison and explosive gasses – hydrogen sulfide, ammonia, and methane – was finally taken into account in designing wastewater facilities and technology that would protect both the workers and the surrounding public. Those protections have been codified in the regulations that control municipal/industrial wastewater technology and design. But industrial agriculture remains exempt.

            There may be many causes for the upswing in foaming problems in confinements. Some potential causes might include: damage to buildings and equipment through the corrosive nature of hydrogen-sulfide, genetically modified crops being fed to animals, different insecticides and herbicides applied to fields as pests and weeds become resistant to chemicals used in the past. Perhaps we will find solutions to somewhat mitigate this new foaming problem. But the bottom line is that as long as you use wastewater technology to store waste in pits below where animals are being raised, you will always have disease and death affecting both people and animals caused by these poisonous and explosive gasses.

            The state Legislature, the Iowa Department of Natural Resources, and corporate industrial agricultural officials steadfastly deny that confinements are a form of wastewater technology. Although seeming illogical, in fact a DNR construction permit requires this type of building, resulting in these problems.

            As a society, we should question what this industrial model of agriculture is doing to us, the animals, and the environment. We have turned most of our hog producers into virtual serfs, with corporations financing and owning the buildings, the pigs, and the feed, and even controlling when the producers market the pigs. Corporations externalize their environmental costs onto the producers and the public by having the producers own the polluting waste and the dead animals. We also expect producers to deal with the unsolvable problems confinement buildings create.

            Confinement technology used to raise animals is a failed model on many levels. It is time to put animals back on the land.

Bob Watson

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iowa, minn nutrient reduction plans.doc

Iowa, Minnesota Nutrient Reduction Plans (10-1-13)

            Minnesota now has its own version of Iowa’s much ballyhooed, but useless, “Iowa Nutrient Reduction Strategy.” (“Minnesota sets goals for fixing Gulf of Mexico dead zone,” Cedar Rapids Gazette 9-26-13)

            These strategies are useless:

1. because there is no implementation instrument – making it a voluntary only program;

2. because of scale – millions of acres of corn and beans versus a few piddling conservation band-aid projects;

3. because there are practices included in these strategies that actually pollute;

4. because there are practices included that short circuit hydrology contributing to flooding and not recharging our groundwater and aquifers;

5. and, because there is nothing in them that we did not know or could not have implemented years ago.

            These strategies are needed only if we assume we will continue with this corn – beans – confinement – feedlot model of agriculture.

            We have a choice: continue with this inherently polluting, soil losing, petro/chemical/industrial agriculture, or switch to a non-polluting biologically benign and beneficial, soil building agriculture.

            What this non-polluting agriculture might look like:

1. edible perennial prairie grains for humans and animals – no chemicals, no runoff, no erosion, no yearly tillage, builds soil, provides habitat, exists today – scaled up for sale to farmers by 2020;

2. strips of perennial native prairie in all annual fields – 10% in strips stops 95% of soil erosion, builds soil, provides habitat;

3. prairie and grass based animal farming – no chemicals, no runoff, no erosion, builds soil, provides habitat;

4. industrial hemp – cover crop, no chemicals if used in crop rotations, used with strips, provides habitat, provides food and fiber, replaces many oil based manufactured products, revitalizes rural America with factories and processing plants, 350 year history as a crop in North America;

5. small grains, hays, fruits, and vegetables – used with strips, provides habitat, builds soil.

            What is at stake here is our continued ability to feed ourselves. This current industrial model of agriculture is unsustainable and polluting. The biological organisms in our soil are being destroyed through years of chemical application. And through unsustainable erosion, even that polluted soil will someday be completely gone.

            We still have a choice.

Bob Watson

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farm bureau letter.doc

Dear Editor,

            Re: “Iowa faces anti-ag attitude problem,” Des Moines Register 12-5-13.

            To be against this particular, recent, post WWII, soil losing, nutrient polluting, flood enhancing, hydrologically short circuiting, human health harming, petro/chemical/industrial, CAFO, Green Revolution, row crop model of agriculture is not to be against agriculture.

            To tell generations of Iowans who have lived and worked on farms that they just don’t understand agriculture is arrogant.

            To call people who speak about this extremely important issue “anti-ag environmental zealots” is ignorant and smacks of right wing politics.

            To lobby for the Renewable Fuels Standard without ever mentioning the massive nutrient pollution and soil erosion that accompanies those millions of acres of corn is unconscionable.

            The Farm Bureau and its keynote speaker should be ashamed of themselves.

            Argue the facts. Bob Watson

rochester talk abstract.doc

            This presentation tells the technical story describing the problems stemming from using this post WWII petro/chemical industrial row crop model of agriculture. It also presents crops and cropping systems, our 5 pillars, that exist today that, if adopted, will mitigate the negative impacts to human health, the air, water, soil, erosion, habitat, and the larger environment that are seen coming from this industrial model. These 5 pillars will return us to a non-polluting biologically benign and beneficial, soil building agriculture which still meets our food and manufacturing needs.

            This recent intensive, petro-chemical, and fossil fuel based model of farming produces pollutants – nitrogen, phosphorus, eroded topsoil, toxic waste from confinements and feedlots – that have made Iowa and Minnesota a toilet for industrial agriculture. But the rest of society, as rate payers of water and wastewater treatment systems, and as people who live with the health effects of this pollution, bears the cost of what this industrial Green Revolution and CAFO agriculture considers “externalities.”

Bob Watson

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borlaug and green revolution letter.doc

The Dark Side of the Green Revolution (10-09 Register)

            There is a sense in which Norman Borlaug’s Green Revolution can be viewed as one of the most serious and sustained human-caused pollution events in history.

            Similar to US, Midwest, and Iowa farmers, other countries farmers’ use of chemical fertilizers, pesticides and herbicides as part of the Green Revolution has resulted in dead zones, algae blooms and polluted surface and ground waters. Locally, Iowa’s impaired surface waters list alone is now well over 400. We find agricultural chemicals in the majority of our private wells. And, we have seen recent stories about poison algae blooms and Iowa’s contribution to the continuing dead zone in the Gulf of Mexico.

            Again, like many agricultural areas in the US and around the world, because of drenching soils with chemicals for 50 plus years, the soils in some areas of the Punjab, India’s breadbasket, are now so polluted and bereft of beneficial biological organisms that crops can no longer be grown without the use of chemicals. And similar to what has happened to the Ogallala Aquifer, because of the Green Revolutions’ need for water, the Punjab’s and other water tables have been significantly lowered.

            Although it has been claimed that the Green Revolution has saved millions from starvation, we know that millions of subsistence farmers have been put off the land through not having the capital resources for the machinery, chemicals, and hybrid seeds required by the Green Revolution. Millions of people have moved into urban areas contributing to urban problems that come with over-population. Similar to the US’s illegal immigration problem, millions have been forced to migrate to other countries looking for work.

            We have a tendency to pat each other on the back and give each other awards and accolades. Meanwhile, unintended, but very real, consequences are conveniently brushed aside and ignored.

            Borlaug’s admonition that no food revolution will help unless we deal with the problem of over-population is seldom remarked upon. It should be. But, his Green Revolution is not the right agricultural model for the earth or for its people.

Bob Watson

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gazette front page with larry.doc

            Kudos to Orlan Love for the Sunday Gazette article, “Farm Fertilizer Runoff Wreaking Havoc.”

            But we will not correct the problem if we continue to assume that “agriculture” means annual row crops, and that farmers will curb runoff if we say “pretty please.”

            The culprit is industrial agriculture, based on petro-chemical inputs and cheap energy. Nitrogen has always been in our rivers. Before World War II, most nitrogen in our waters was from animal and green manure, which had to break down before it could be used by plants.

            With the Green Revolution and industrial fertilizers, however, that nitrogen is in the form of nitrates, which are readily available to algae and other plants. This nitrate nitrogen, unlike organic nitrogen, leads directly to the algae blooms and other problems in our surface waters.

            Our solutions may actually compound the problem. The Great Lakes were becoming much cleaner 20 years ago, in part because of the elimination of phosphorus from detergents. But then, ten years ago, scientists began to see new and expanding dead zones.

            The only obvious difference was the introduction of no-till cropping. Apparently a form of phosphorus – dissolved reactive phosphorus – washes off of no-till fields and into the lakes. Yet, no-till is considered a conservation measure.

            Some try to justify the pollution coming from industrial agriculture with the excuse that “we need to feed the world.” But Pam Johnson, president of the Iowa Corn Growers Association, seemed more concerned about fuel than food when she recently testified before Congress that the ag economy would “be in a deep recession” unless the Renewable Fuels Standard was reauthorized.

            The intensive, petro-chemical, fossil fuel based model of farming produces pollutants – nitrogen, phosphorus, eroded topsoil, and toxic waste from confinements and feedlots – that have made Iowa a toilet for industrial agriculture. But the rest of society, as rate payers of water and wastewater treatment systems, and as people who live with the health effects of this pollution, bears the cost of what this Green Revolution agriculture considers “externalities.”

            Do we need an agriculture that pollutes in order to feed ourselves and supply our manufacturing goods? No. 

            We could reduce pollution by using crops and cropping systems that exist today, which don’t need industrial fertilizers, herbicides or pesticides, that don’t need annual tillage or inputs, that hold water and soil on the land, and that still meet our food and manufacturing needs.

            We have a choice: continue with this inherently polluting, soil losing, petro/chemical/industrial agriculture; or, switch to a non-polluting, biologically benign and beneficial, soil building agriculture.  

            The political process could help make that choice. Cities and counties can use their political capital to push for changes in the Farm Bill to promote sustainable cropping systems – rather than policies that encourage all-out commodity production and subsidize clearing of fragile lands. To see those cropping systems and how to go about changing the Farm Bill, go to http://www.civandinc.net/  appendices D and G.

            As people who put up with, and pay for, industrial ag’s pollution and flooding, we all have a dog in this fight. Through our joint and individual efforts, we can clean up Iowa.

Bob Watson                               

Larry Stone

——————————————————————————–

gazette front page nutrient response.doc

            It is known that nitrogen was in our rivers in the early 1900’s. However, because the Green Revolution uses industrial fertilizers (West, Texas explosion), today’s nitrogen is in the form of nitrate nitrogen rather than the historic organic nitrogen from animal and green manures.

            Even though organic nitrogen was in the rivers, organic nitrogen needs to break down to be in a form that is available to plants. But the Green Revolution’s nitrate nitrogen is in a form that is readily available to algae and other biological organisms. This nitrate nitrogen, versus pre WWII organic nitrogen, leads directly to the algae blooms and other problems seen in our surface waters today.

            The Great Lakes were becoming much cleaner 20 years ago in part because of the elimination of phosphorus from detergents. But, 10 years ago scientists noticed that the lakes were once again seeing new and expanding dead zones.

            The only obvious difference in the watersheds was the introduction of no-till cropping. It turns out there is a form of phosphorus, dissolved reactive phosphorus, coming from no-till acres that washes off fields and into the lakes. Yet, no-till is considered a conservation measure.

            Pam Johnson, president of the Iowa Corn Growers Association, testifying in front of Congress said that unless the Renewable Fuels Standard was reauthorized Iowa’s ag economy would crash. So much for the canard “we feed the world” as an excuse for putting up with pollution from industrial agriculture.

            Because of petro/chemical/industrial ag’s pollution, nitrogen – phosphorus – toxic waste from confinements and feedlots, Iowa has become a toilet for rich people in the world. And you, as rate payers of water and wastewater treatment systems, bare the cost of what this Green Revolution agriculture considers externalities.

            Do we need an agriculture that pollutes in order to feed ourselves and supply our manufacturing goods? No. 

            Pollution reduction is attained by using crops and cropping systems which don’t need industrial fertilizers, herbicides or pesticides, that don’t need to be worked up every year, hold water and soil on the land, and still meet our food and manufacturing needs.

            We have a choice; continue with this inherently polluting, soil losing, petro/chemical/industrial agriculture; or, switch to a non-polluting biologically benign and beneficial soil building agriculture, which exists today. As a nation, we choose through the political process.

            Cities and counties can use their political capital to push for changes in the farm bill which will put those crops and cropping systems in the farm bill. To see those crops and how to go about changing the farm bill, go to www.civandinc.net appendices D and G.

            As people who put up with, and pay for, this industrial ag’s pollution and flooding, you do have a dog in this fight. Through your efforts, you can clean up Iowa.

Bob Watson   

Larry Stone

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millennium ag expansion.doc

Name, (this is going to all of the Supervisors)

        Millennium Ag is now proposing a 3 building expansion instead of the original 2 building expansion. I have included my comments below protesting this expansion. I have also included information on the “Agency Discretionary Rule” which allows the County, through the Supervisors, to ask that this expansion, even if it meets all the rules and permits, be denied.

        I hope you and the other Supervisors will consider this option for stopping the expansion of this facility. This option exists for those times when no one else’s objections are taken into consideration.

        Thanks.

Bob

Bob Watson

Protest comments on Millennium Ag 3 building expansion:

DNR Director Chuck Gipp,

        I am going to use this email as my protest comments on the expansion discussed below.

        Brad Herman is “expanding” the confinements called Millennium Ag now by 3 buildings, at 3740 Locust Rd, Decorah. The original expansion called for 2 new confinements.

        The animal unit number that triggers having to pass a Matrix for a new facility is 1000. Ironically and illogically the animal unit number that triggers a new Matrix for expansion of an existing facility is 1666 which is more than 50% larger than what is required for a new facility. This seems to say that a facility that may end up being 2 1/2 times bigger than the original is less dangerous. The expansion at Millennium Ag is being allowed without the safety that is built into the matrix; it is happening without public input; it is happening without the County Supervisors having any say in an “expansion” which can be larger than the original confinements; it is going through no public process whatever.

        This expansion should be put on hold until these public and government body processes are put back in. Neighbors are not happy with this now 3 confinement buildings “expansion”. The public is confused at how something larger than an original plan can be built without the normal public input.

        In this case, the DNR is failing in its responsibility to protect the natural resources, including our children, of Iowa. Gasses from Winneshiek County confinements are already at a scale that affect human health (Kline study – appendix E), affect neighbor’s right to be free from industrial poisons, affect neighbor’s ability to enjoy their property, affect property values, etc. We don’t need more. (see www.civandinc.net appendix E for a discussion of the technology; the inherent production from confinements of poison sewer gasses (on the EPA’s toxic list), greenhouse gasses, and particulates; water pollution including fecal material and antibiotics from runoff, spills and leaks; and the laws and regulations which have been changed or gotten rid of that used to protect the public).

        Appendix E also lists the 177 medical and scientific studies (tip of the iceberg) that we have included in our EPA lawsuit, and which show clearly the negative human health and environmental damage from confinements. E also shows that confinements are poorly designed and poorly operating anaerobic digesters inappropriately transferred from the highly regulated wastewater industry to the unregulated area of industrial agriculture. Without those regulations, the public is left with NO PROTECTIONS from the poisons coming from these confinements. The public IS PROTECTED from these poisons in all other sectors of the US where these gasses and technologies exist.

        This is an abomination of the process of public input. I know that you have the authority to put this on hold until these normal public processes are put back in so that neighbors, Supervisors, and affected county residents have a say in what happens to the air they breathe and the water they drink.

        I highly oppose this “expansion”. Please use your authority in regard to the Director/Agency Discretionary Rule (see below) to put this expansion on hold while real public processes are again in place to give people a say about what happens in their lives.

        Thanks.

Bob

Bob Watson

            The following will explain how to use the Agency Discretionary Rule:

            Rich Leopold, the new Director of the DNR, has let it be known both inside and outside the DNR that he will rarely use what in the press and public has been known as the Director’s Discretionary Rule, but is really the Agency Discretionary Rule. When I contacted Rich Leopold and told him I was going to write about this issue he emailed me this language to use to explain his position: “I will use it as appropriate. But I will not be quick to use it. The burden of evidence needs to be such that we (the DNR) could defend our decision in court if necessary. This sets the bar high, but does not mean that the rule will not be considered and used when necessary.” To me that is unfortunate because the public has the perception that the rule was put in place to be used more widely.

            There is good news though. The rule still does exist and can still be used to protest those CAFO’s that do not fall under regular DNR rules but pose risks to people and the environment. After an email conversation with a member of the Environmental Protection Commission, this member laid out why the rule can be used and how to get a protested CAFO permit in front of the EPC to ask them to use the rule. Here is the EPC member’s language and direction:

        “Remember it’s the Agency Discretion Rule which means the EPC can invoke the rule itself. That would occur when the commission hears a county appeal. The county would need to request the EPC to use its discretionary authority under the rule, as well as citing any other reasons to deny the permit and then it would be up to the commission. If the county believes that it should appeal the granting of a permit it should do so. The commission will hear the arguments and make its own decisions. It’s not bound by any decision of the DNR director or staff. It takes those positions into account as well as other views including the county’s. The final authority in the agency is with the EPC.”

            So, it is the County Supervisors’ right, even when a confinement has enough matrix points and even when the DNR grants a permit, to protest that permit in front of the Environmental Protection Commission. They simply tell the Commission the reasons they feel a particular confinement, which may pass all the present legal requirements, isn’t a good idea and ask the Commission to deny the permit using the Commissions’ power under the Agency Discretionary Rules. Much of the Agency Discretionary Rules were written with karst in mind.

            So, if your county wants to appeal a permit, they need only appeal it to the EPC, request the EPC use the rule and provide the county’s reason(s) for denying the permit.

Bob Watson

——————————————————————————–

iawea hybrid presentation.doc

(IAWEA) Hybrid PowerPoint Presentation

            This is a combination of our two PowerPoint presentations into a hybrid which deals with two important agricultural issues – confinements and non-point ag pollution.

            Through giving the “watershed” PowerPoint at my annual wastewater conference (IAWEA), I developed a very easily understandable model of what is happening (description) and what can happen (prescription) with these two issues.

            This IAWEA presentation came about because the EPA, DNR, IDALS, USDA, ISU, etc., come to our conference each year and tell us we have to clean up Iowa’s water because it is too complicated and expensive for ag to clean up their 90% contribution. This presentation was my response to that notion and it gave our members language and context to discuss, or become involved in, these issues. We hope it will do the same for you.

            In recent years at the Annual Wastewater Conference the EPA, DNR, IDALS, USDA, ISU and others have presented the notion that point source emitters (that would be you, the rate payers of water and wastewater fees) must bear the brunt of cleaning up our waters because fixing the pollution coming from non-point ag was too complicated and expensive to be undertaken. At this years conference Bob Watson presented a response to that notion. This presentation gives a language and context that our members can use when responding to that claim.

Bob Watson Presentation IAWEA Annual Conference June 5, 2013

Presentation title: Alternate Cropping Systems to Reduce Non-point Pollution

Original title: Conservation Band-Aids or Real Watershed Changes

            For cities and counties this presentation is about reducing flooding. For you, and for our purposes today, this is about agricultural non-point pollution reduction.

            Pollution reduction is attained by using crops and cropping systems which don’t need industrial fertilizers, herbicides or pesticides, that don’t need to be worked up every year, hold water and soil on the land, and still meet our food and manufacturing needs.

            The “Iowa Nutrient Reduction Strategy” is needed only if we assume we will continue with this corn – beans – confinement – feedlot model of agriculture. We have a choice; continue with this inherently polluting, soil losing, petro/chemical/industrial agriculture; or, switch to a non-polluting biologically benign and beneficial soil building agriculture. As a nation, we choose through the political process.

            What is new about this approach is that we are taking this directly to cities whose people, through flooding and polluted rivers, are affected and who have political capital to spend on correcting that problem through changing the farm bill.

            Listening to the public conversation, you would think non-point nutrient reduction is complicated. It is not. But, most of the conversation today is a description of the problem. Our presentation will provide you with a prescription for solving the problem. We will give you a language and contextual story about agricultural based non-point nutrient reduction that you can use when discussing, or becoming involved, in this issue.

            We know that the two pollutants most responsible for our surface waters being classified impaired are phosphorus and nitrogen. And, we know that the majority of those pollutants come from agricultural practices.

            The Great Lakes were becoming much cleaner 20 years ago in part because of the elimination of phosphorus from detergents. But, 10 years ago scientists noticed that the lakes were once again seeing new and expanding dead zones.

            The only obvious difference in the watersheds was the introduction of no-till cropping. It turns out there is a form of phosphorus, dissolved reactive phosphorus, coming from no-till acres that washes off fields and into the lakes. Yet, no-till is considered a conservation measure.

            It is known that nitrogen was in our rivers in the early 1900’s. Because the Green Revolution uses industrial fertilizers, today’s nitrogen is in the form of nitrate nitrogen rather than the historic organic nitrogen from animal and green manures. Even though organic nitrogen was in the rivers, organic nitrogen needs to break down to be in a form that is available to plants. But nitrate nitrogen is in a form that is readily available to algae and other biological organisms. This nitrate nitrogen, versus pre WWII organic nitrogen, leads directly to the algae blooms and other problems seen in our surface waters today.

            This presentation serves two functions; it informs and it requests.

            Research tells us that prior to sod-busting in the 1830’s, rain and snow stayed on the land where it fell because of the sponge-like landscape of prairies, savannahs, forests, and wetlands.

            There was a spring melt consisting of 10% of the year’s total rain and snow amount. But that happened over days and/or weeks. The melt’s volume was 3 to 4 inches of the annual rainfall of approximately 36 inches, and instead of flooding, the spring melt gently raised river volumes for a short time.

            This presentation is about adopting crops and cropping systems that exist today that will, to the extent possible, recreate that sponge landscape without sacrificing our ability to feed ourselves.

            We originally prepared this presentation with the floods of 2008 in mind. But, because of the crops and cropping systems we discuss, it’s become obvious that these ideas inform us about and speak to several other agricultural issues besides flooding. We hope you’ll see the implications relating to the drought, pollution and the “Iowa Nutrient Reduction Strategy,” the link between food and fracking, and the revitalization of rural America.

            The request is that you work to change the farm bill. Most farmers have to farm the farm bill in order to make money. Change the farm bill and you will change agriculture. Change agriculture and you will change flooding and pollution.

            To see this presentation and the accompanying documents, go to www.civandinc.com appendix D.

 Bio:

            Bob Watson is an environmental activist who makes his living in the wastewater industry. Bob has been presenting on the unintended consequences of the adoption of industrial agricultural models for 20 years. His work is the basis of the recently filed lawsuit asking the EPA to regulate the poison sewer gasses hydrogen-sulfide and ammonia in agriculture the same as they regulate them in other sectors of the US.

            To see a related presentation on the unintended consequences of CAFO agriculture, see www.civandinc.net appendix E. This work is the basis of our recent lawsuit trying to get the EPA to regulate poison sewer gasses coming from confinements the same as they regulate those gasses in other sectors of the US.

Bob Watson

——————————————————————————–

new nutrient language.doc

This language will speak directly to phosphorus and nitrogen:

            We know that the two pollutants most responsible for our surface waters being classified impaired are phosphorus and nitrogen. And, we know that the majority of those pollutants come from agricultural practices.

            The Great Lakes were becoming much cleaner 20 years ago in part because of elimination of phosphorus from detergents. But, 10 years ago scientists noticed that the lakes were once again seeing new and expanding dead zones.

            The only obvious difference in the watersheds was the introduction of no-till cropping. It turns out there is a form of phosphorus, dissolved reactive phosphorus, coming from no-till acres that washes off fields and into the lakes. Yet, no-till is considered a conservation measure.

            It is known that nitrogen was in our rivers in the early 1900’s. Because the Green Revolution uses industrial fertilizers, today’s nitrogen is in the form of nitrate nitrogen rather than the historic organic nitrogen from animal and green manures. Even though organic nitrogen was in the rivers, organic nitrogen needs to break down to be in a form that is available to plants. But nitrate nitrogen is in a form that is readily available to algae and other biological organisms. This nitrate nitrogen, versus pre WWII organic nitrogen, leads directly to the algae blooms and other problems seen in our surface waters today.

Bob Watson

——————————————————————————–

Gazette op-ed.doc

Conservation Band-Aids or Real Watershed Changes

            We know that the two pollutants most responsible for our surface waters being classified impaired are phosphorus and nitrogen. And, we know that the majority of those pollutants come from agricultural practices.

            The Great Lakes were becoming much cleaner 20 years ago in part because of the elimination of phosphorus from detergents. But, 10 years ago scientists noticed that the lakes were once again seeing new and expanding dead zones.

            The only obvious difference in the watersheds was the introduction of no-till cropping. It turns out there is a form of phosphorus, dissolved reactive phosphorus, coming from no-till acres that washes off fields and into the lakes. Yet, no-till is considered a conservation measure.

            It is known that nitrogen was in our rivers in the early 1900’s. Because the Green Revolution uses industrial fertilizers, today’s nitrogen is in the form of nitrate nitrogen rather than the historic organic nitrogen from animal and green manures. Even though organic nitrogen was in the rivers, organic nitrogen needs to break down to be in a form that is available to plants. But nitrate nitrogen is in a form that is readily available to algae and other biological organisms. This nitrate nitrogen, versus pre WWII organic nitrogen, leads directly to the algae blooms and other problems seen in our surface waters today.

            Research tells us that prior to sod-busting in the 1830’s, rain and snow stayed on the land where it fell because of the sponge-like landscape of prairies, savannahs, forests, and wetlands.

            There was a spring melt consisting of 10% of the year’s total rain and snow amount. But that happened over days and/or weeks. The melt’s volume was 3 to 4 inches of the annual rainfall of approximately 36 inches, and instead of flooding, the spring melt gently raised river volumes for a short time.

            We could start to recreate that sponge landscape without sacrificing our ability to feed ourselves by adopting crops and cropping systems that exist today. This “sponge” could help hold needed water and reduce the impacts of drought and floods. It could slow runoff and nutrient loss, as we supposedly are trying to do through the “Iowa Nutrient Reduction Strategy.” It could reduce the need for industrial nitrogen fertilizer, which has become even more pervasive with the abundance of natural gas due to the controversial process of “fracking.” Alternative crops and cropping systems also could help revitalize rural America.

            All Iowans, and their city and county governments, could help simply by working to change the farm bill to encourage these alternatives. Most farmers have to farm the farm bill in order to make money. Change the farm bill and you will change agriculture. Change agriculture and you will reduce flooding and ease the impacts of drought.

            For details, go to  www.civandinc.com appendix D.

Bob Watson 

Larry Stone

——————————————————————————–

new intro language.doc

New introductory language:

This presentation serves two functions; it informs and it requests.

Research tells us that prior to sod-busting in the 1830’s, rain and snow stayed on the land where it fell because of the sponge-like landscape of prairies, savannahs, forests, and wetlands.

There was a spring melt consisting of 10% of the year’s total rain and snow amount. But that happened over days and/or weeks. The melt’s volume was 3 to 4 inches of the annual rainfall of approximately 36 inches, and instead of flooding, the spring melt gently raised river volumes for a short time.

This presentation is about adopting crops and cropping systems that exist today that will, to the extent possible, recreate that sponge landscape without sacrificing our ability to feed ourselves.

We originally prepared this presentation with the floods of 2008 in mind. But, because of the crops and cropping systems we discuss, it’s become obvious that these ideas inform us about and speak to several other agricultural issues besides flooding. We hope you’ll see the implications relating to the drought, pollution and the “Iowa Nutrient Reduction Strategy,” the link between food and fracking, and the revitalization of rural America.

The request is that you work to change the farm bill. Most farmers have to farm the farm bill in order to make money. Change the farm bill and you will change agriculture. Change agriculture and you will change flooding.

Bob Watson

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dead zone and IDALS doc.doc

Iowa and the Gulf’s Dead Zone (12-2-12)

            In the Des Moines Register’s series on the dead zone in the Gulf, corporate agriculture apologists repeated their excuses for not addressing agriculture’s major role in the pollution causing that dead zone. According to apologists, most erosion and pollution from Iowa may not really be from the 30 million acres of farmland in Iowa. That pollution might be from a few hundred golf courses, some urban lawns, and regulated wastewater treatment plants. We also heard that regulations don’t work in agriculture, and that farmers should be allowed to pollute because they ‘feed the world’. Further, we were told farmers are conservationists who already work to limit runoff, erosion, and pollution.    

            Pollution from wastewater plants (point source pollution) has actually declined due to ever more stringent regulations. Meanwhile the waters of Iowa and the Gulf continue to become more polluted with each passing year due to non-point source pollution from agriculture. Understanding this phenomenon, the EPA directed states to come up with strategies to reduce that pollution.

            After some years of study, Iowa’s strategy is contained in the IDALS “Iowa Nutrient Reduction Strategy” document. The extent to which corporations have taken over our government, as shown by this document, should give us pause. Technically, many of the promoted practices have little real ability to deal with runoff, erosion, and pollution on the scale that is seen. And, this strategy ends up being just another “we wish the farmers would do” list because the document contains no “implementation instrument” to ensure adoption.

            The question whether any strategy can fix this recently adopted petro/chemical/industrial model of agriculture is not even asked. This recent model is extraction based, petroleum based, and inherently polluting (because of how it works, it has to pollute). Research presented at this year’s US and Canadian Great Lakes Conference suggests no-till may be causing new dead zones in the Great Lakes. If so, this would be a major blow to this model’s no-till being promoted as a conservation method.

            An “Iowa Nutrient Reduction Strategy” is necessary only if we assume we will keep using this inherently polluting petro/chemical/industrial model of agriculture. We don’t need to. There are models of agriculture which exist today (edible perennial prairie, forage crops, prairie buffer strips, etc), that can clean up our water, reduce erosion, runoff, and pollution, and that are biologically benign and clean. Go to www.civandinc.net and click on appendix D to see models that exist today, that can be adopted wholesale today, and that will return agriculture to a non-polluting, non-flooding, soil building system adaptable to both a future of intense rain events and major droughts.

Bob Watson

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wes jackson quote externality.doc

This quote speaks to a question I put to Neal Harl some years back. He had been speaking all morning on Iowa’s agricultural economics and had never mentioned soil. After lunch I asked him why he had never mentioned soil, which after all is the basis of all ag economics. His answer was that economists considered soil an externality. I got up and left.

Wes Jackson:

            “We live off of what comes out of the soil, not what’s in the bank. If we squander the ecological capital of the soil, the capital on paper won’t much matter….For the past 50 or 60 years, we have followed industrialized agricultural policies that have increased the rate of destruction of productive farmland. For those 50 or 60 years, we have let ourselves believe the absurd notion that as long as we have money we will have food. If we continue our offenses against the land and the labor by which we are fed, the food supply will decline, and we will have a problem far more complex than the failure of our paper economy. Remember, if our agriculture is not sustainable then our food supply is not sustainable….Either we pay attention or we pay a huge price, not so far down the road. When we face the fact that civilizations have destroyed themselves by destroying their farmland, it’s clear that we don’t really have a choice.”

This quote was taken from Erik Sessions/Sara Peterson’s Patchwork Green CSA newsletter, Winter 2009.

Bob Watson

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watershed approach to floods discussion.doc

Watershed Approach to Floods Discussion

In the recent historical past, Iowa was covered with forests, prairies, wetlands, thick sod, streams and rivers. Rain that fell to the earth was retained, cleansed, used and slowly passed through the state. That changed with the coming of settlers who broke the sod of the prairies for cultivation agriculture. The historic hydrology of the state was altered with the need to drain fields. To accomplish that draining, we now have some 880,000 miles of field tile in Iowa. Records show a doubling and even tripling of the flow of some rivers over the last 100 years. Also, because tile lines provide a direct conduit to surface and ground waters, we have lost the water’s contact with the cleansing soil and surface flora, resulting in streams and rivers that are in many cases contaminated with silt, fecal waste and chemicals.

This discussion includes changes to the watershed and to the agricultural cropping systems which could end floods as we know them and would cost cities no money for flood control. This discussion will include pre-settlement vegetation cover before we turned the landscape upside down and put the soil on the top; the differences in rain infiltration of historic vegetation and current row crops; agricultural systems available today which mimic the rain infiltration rates of presettlement vegetation; and the goal of returning the landscape to a system with soil beneath vegetation. Also discussed is what using those perennial cropping systems would mean for cleaning up water, holding and creating soil, cleaning our air, and reducing our contribution to the Dead Zone in the Gulf of Mexico.

*From Connie Mutel’s “A Watershed Year”, Wayne Petersen’s chapter 9, “The Hydrology of Urban Landscapes”, pages 87-89:

“…Prior to the 1830’s, when native prairies and savannas dominated Iowa, not more that about 10 percent of the annual precipitation became surface runoff. Most of this 10 percent would have been snowmelt or runoff from rain on frozen ground. The other 90 percent was held by vegetation or entered the soil. When rain falls on vegetation, some of it evaporates back into the atmosphere. Some drops to the ground and infiltrates the soil, where it is taken up by plant roots and ‘breathed’ back into the atmosphere (through the process of transpiration). About 40 percent of all rainfall would never have flowed into a stream, because it would have been evaporated or transpired directly back into the atmosphere.

The remaining 50 percent or so of annual rainfall would have infiltrated the soil and slowly percolated downward to feed deep aquifers or become part of the groundwater flow. Because runoff was minimal before the 1830s, surface waters were fed primarily through this slow, steady groundwater flow. Because groundwater generally discharges at a constant rate, fluctuations in water levels would have been minimal.

The ancient cycling of water’s flow through native prairies and savannas was stable and sustainable. It was infiltration-based and groundwater-driven. The land evaporated, transpired, and infiltrated more rainfall and shed less runoff, certainly compared to today’s urban landscapes. Consequently, the land was far more flood-resistant, with water levels in surface waters remaining relatively stable (as well as clean). …”

*Briefly discussed is an end to toxic and greenhouse gasses contributed by industrial agriculture; an end to antibiotic resistant diseases; and an end to untreated confinement and feedlot waste washing into our streams and rivers. Along with bacteria from this waste, the other non-point pollution contributors to our water quality problems are nitrogen, phosphorus and sediment (soil). As long as our model of agriculture is corn and beans, and livestock confinements and feedlots, we will continue to have this non-point pollution and surface runoff contributing to flooding and water quality. Change the federal farm programs and you will affect quantity and quality of water in the state.

This discussion includes manufacturing and processing which would need to be done locally from new cropping systems and new crops being raised in Iowa, with a bio-regional and sustainable approach. And we will touch on the multitude of new products from these crops. We will discuss humans becoming healthier by not eating processed corn and soybeans, and a reduction of obesity, heart disease, and type II diabetes, which have exploded since we changed to a diet of processed foods.

We will talk about the need to modernize our transportation system because of new crops and more people living in rural areas. This includes roads and rail.

We will talk about what city dwellers can do to help make these changes; what it will cost you in political capital instead of in dollars; and how you as cities can change the watershed cropping systems to protect yourselves from flooding in the future.

Surprisingly, the floods of ’08 have provided an opportunity to test Wendell Berry’s axiom that “the problem of agriculture is an urban problem.” By that I take it he meant the ignorance of urban people to what our agricultural system has become. This can be tested by saying to Cedar Rapids, Des Moines and other flood damaged cities that you can prevent floods by changing cropping practices in agriculture instead of spending billions (CR) and millions (DSM) on flood control infrastructure. We are corn and bean farmers, because that is what the federal programs pay for. A change in those programs will lead to changes in the hydrology of the state.

This discussion shows the means to stop flood damage to towns and cities; clean up our water, soil, and air; provide more jobs in farming and manufacturing; encourage people to have healthier diets; and  save towns and cities money otherwise spent on flood control projects.

*Estimated Cost of Flood Control for Cities using Levees and Pumps:

With a watershed approach to control flooding, cities wouldn’t need to spend millions of dollars on levees and pumping systems. The original Cedar Rapids estimate for levees and pumps was $1 Billion dollars. Des Moines’ ballpark figure was a $250 Million dollar project.

*Vegetation covers and their relation to infiltration and storage:

Land Management Options                            Infiltration Rates (in./hr.)

Pasture and Row Crops                                              1 – 3

Rotational Grazing, Alfalfas                                       3 – 7

Un-Pastured Native Grasses                                       7 – 13

Mature Trees                                                               10 – 14

*From the Jackson/Keeney chapter “Perennial Farming Systems That Resist Flooding” (pp. 216-225) in the Connie Mutel edited 2010 book, “A Watershed Year: Anatomy of the Iowa Floods of 2008” we have the following discussion:

“To prevent rains from flowing rapidly into channels and raising water levels, some of their moisture must be returned directly to the atmosphere or discharged steadily and slowly (not in flashy gushes) into drainage ways. Agriculture can help achieve these ends and thus make the land more flood-resilient if it can:

            1. Minimize runoff by increasing the speed at which water soaks into the soil and the quantity of water the soil can hold.

            2. Store an abundance of water in healthy soils that are high in organic matter, instead of immediately draining it into streams.

            3. Increase the amount of time that growing crops are pumping water back into the atmosphere.

            4. Intercept any runoff from intense rainfall, passing it into nearby wetlands or through buffer strips that protect streams.

The truth is, the corn and soybeans that now dominate Iowa’s agriculture (…92% of planted acres are row crops. Only 50% in the 1950’s…) It would be difficult to find two crops that do a worse job of handling Iowa’s rainfall. In conjunction, these croplands pollute our waterways by their release of sediment, fertilizers, and pesticides. [The fourth non-point pollutant, non-soil bacteria, comes mainly from the untreated waste from feedlots and confinements; Watson] Scientists studying the problems of surface and groundwater contamination, the Dead Zone in the Gulf of Mexico, and flooding have arrived at the same conclusion: we need to re-perennialize the landscape. Quite literally, we have to rediscover and cultivate our deepest roots.

Before the coming of European Americans in the mid-1800s, the prairie soils of Iowa were filled with a dense and deep underground network of perennial plant roots. These roots filled the soil year round, not just in July and August. They made the soil more crumbly, porous, and spongy. They shielded it from the destructive power of raindrops. Year in and year out, perennial plant roots added humus to the soil, built pores, and supported a rich community of arthropods, fungi, and bacteria. The perennial sod could absorb tremendous quantities of rain without producing runoff. Perennials active in early spring began using water in April, and the diversity of plant growth ensured that soil water was used through October. Excess water not used by plants steadily percolated into the shallow groundwater and onto wetlands and streams, or it recharged deeper aquifers. Many features made this landscape flood-resistant. It is no wonder that Know (2006) describes the agricultural conversion of prairie and forest in the upper Mississippi River basin as ‘the most important environmental change that influenced fluvial {river and stream} activity in this region during the last 10,000 years’ [emphasis added, Stone & Watson].

Agriculture can increase perennial plant cover and contribute to Iowa’s hydro-logical health in a variety of ways. Corn and soybeans could become part of four-to-five year crop rotations that include small grains, hay and pasture. Long crop rotations were in wide use up until the 1950’s…Today we can improve on the farming of the 1950’s by implementing conservation tillage, better options for pest control, intensively managed rotational grazing, and cover crops to protect the soil before the row crops are well established. …we need to critically examine subsurface water (tile) drainage. Farmlands are tiled to dry out the root zone as fast as possible. This has caused more water to flow into our rivers in the spring, instead of lingering in the soils (Schilling and Helmers 2008). Thus, as happened in 2008, rivers are often running full when a really big early summer storm arrives.

Researchers at Iowa State University are modifying strip-cropping practices (which now alternate row crops with European pasture grasses or legumes, such as alfalfa, in strips along the contour) by using deeper-rooted native prairie strips instead. Preliminary results indicate that prairie strips covering just 10 to 20 percent of the total field area were able to reduce sediment loss by 95 percent. Prairie strips should also be able to draw down soil moisture earlier in the spring and later in the fall. By occasionally moving these strips, better soil structure could be restored throughout a field.

Taking the use of perennials one step further, they could be incorporated directly into grain production. Farmers in Australia have pioneered a new method to grow their winter grains (oats, wheat, and barley) in the same field with perennial warm-season pasture grasses. And for over 25 years, researchers at The Land Institute in Kansas have worked to develop high-yielding mixtures of perennial grains (Cox et al. 2006). Recently they have made rapid progress by hybridizing wheat, sorghum, and sunflower with their wild perennial relatives. Perennial grains could revolutionize our whole way of doing agriculture, but a great deal more research will be required to develop crops with economic yields. [The time needed for this research and the time it will take to make political changes to the federal farm programs and implementation of this model should coincide. In other words by the time we change the programs, the perennial crops will be ready; Watson.]

Although cropland runoff can be decreased, some will remain. This should flow into a wetland or buffer strip before reaching a stream. Buffer strips of prairie grasses, shrubs, and trees along streams will trap sediments, improve soil quality, remove some nitrogen and phosphorus and increase water infiltration into the soil. By breaking selected field tiles as they meet the buffer strip, we could further slow the movement of water into streams.

As flood damages increase, the need for hydrological resilience grows more urgent. A re-perennialized agricultural landscape will still produce food but also will restore community values and ecosystem services that have been lost. This landscape will once again regulate and purify water, sustain soil fertility, replenish the groundwater supply, support wildlife and pollinators, and carry forward the ancient heritage of our native prairies, woodlands, and wetlands. The challenge will be to incorporate these very real ecosystem services into a market that has until now neglected and nearly destroyed them. An agricultural economy modeled on natural perennial systems will shoulder its share of the responsibility for a healthy, resilient landscape.”

*Wes Jackson’s Perennial Polyculture/ Natural Systems Agriculture http://www.landinstitute.org : rain infiltration rates of 7 to 13 inches per hour. 12 to 15 foot deep roots restoring the life of our soils. Replanted only every 6 or 7 years. Native cover cropping system rather than row crop monoculture of corn and beans that needs millions of pounds of fertilizers, pesticides and herbicides annually.

I recently, July 2011, emailed Wes with this question: “I heard you say, or read somewhere, that you had “copywrited” one variety of prairie grass. Did I hear that correctly? If so, what does that mean? Is that variety ready to be scaled up?” This is Wes’s response: “We have one species being domesticated. We call it Kernza™ and have used the name we made up as a trademark name. We still have lots of breeding – probably another 9 years before farm ready and then with agronomists assisting.”

So, by 2020, probably the same amount of time that it will take to change the farm bill, Wes’s prairie crops could be in fields.

*10% of annual field planted to native prairie strips leads to a 95% reduction in erosion. This email is from Matt Liebman, H.A. Wallace Chair for Sustainable Agriculture / Professor of Agronomy Iowa State University, in response to my question about an article that described up to a 95% reduction in erosion using prairie strips as part of row crops:

“This web site shows graphs of the reduction in soil erosion in the experiment.

http://www.nrem.iastate.edu/research/STRIPs/research/index.php?page=Ecohydrological

To my knowledge, Wes Jackson’s concept of perennial polycultures for seed production has not been used for the soil, water, and wildlife conservation purposes in working lands for which we’re using the prairie strips at Neal Smith NWR.

The farmer who operates our experimental site baled the prairie strips for bedding for his cattle after he harvested the corn and soybean crops that grew among the strips. There are several farmers in SE MN who are pelleting prairie vegetation and burning it to heat greenhouses.”

If you asked if there is one aspect of our presentation that you could work on first, it would be to require native prairie strips covering 10% of all annual fields.

*Hemp: http://www.lumes.lu.se/database/alumni/04.05/theses/erin_young.pdf      

This pdf is a Masters Thesis describing the world wide hemp market and discusses the inclusion of hemp in a sustainable rotation model of agriculture. The US is only one of 2 or 3 countries in the world which prohibits the growing of hemp. There are thousands of products available from hemp. Next to soybeans, hemp is the second highest plant in percent protein content, and has the correct essential fatty acids in the correct percentages for humans. It is a cover crop which needs little or no commercial help to grow, especially when used in crop rotations, and is good for rain infiltration.

The economics for rural farming communities is dependant largely on transport and proximity to processing and manufacturing facilities. The bulk nature of hemp crops requires that processing facilities are located nearby hemp fields. The decentralization of hemp production will reduce transport costs and hence product manufacturing costs. Bioregional production and processing of hemp would be beneficial to rural commerce and contribute to rural community self sufficiency.

For more on hemp see these two links:

http://www.treehugger.com/environmental-policy/perfect-plant-7-great-uses-for-industrial-hemp.html

and http://www.hort.purdue.edu/newcrop/ncnu02/v5-284.html/

Hemp can also be a reseeding annual that supplies its own nutrients through decomposition: http://www.finola.com/ : “The FINOLA oilseed hemp variety is an excellent source of sustainable food and fiber. The exceptional fatty acid profile in Finola hempseed oil offers a rich source of the essential fatty acids (EFAs); omega-3 ALA and omega-6 LA, in addition to significant amounts of GLA and SDA. The human body can’t make the EFAs, so we have to get them from the daily diet. The EFAs are needed to produce many important things in our bodies, including optimal nerve functions throughout the brain and central nervous system. Finola hempseed oil is a safe and nutritious way to consume our dietary EFAs, to better our somatic health already at the neuronal level.” (from the Finola website)

*Hays and Alfalfas: cover crops which can be cropped for years and then turned under for green manure. 3 to 7 inches per hour rain infiltration.

*Pastures and Rotational Grazing: provides feed for livestock and holds water during rain events. This becomes important as all CAFOs, confinements and open feedlots are phased out. All animals would be raised on the land.

*Woodlands: provides traditional forest products, plus 10 to 14 inches per hour of rain infiltration.

*Vegetables and Fruits: provide nutrition lacking in the modern processed food diet.

*Small grains such as oats, barley, wheat, etc. Cover type crops for both human and animal consumption. Can be grown with other cover crops.

*Prairie strips, constructed wetlands and other soil saving and runoff mitigation efforts: Federal programs could include “continuously shifting through the field” prairie strips as a necessary part of any row crop system for obvious benefits. (see also above in Wes Jackson’s section)

*This is a graph and discussion showing Iowa River data over time, and changing crops and cropping systems. This data shows that if we adopt a land use model more similar to what we had earlier in our history, our flooding will more than likely decrease:

“The Raccoon River at Fleur has crested above flood stage 62 times since 1903 according to the Van Meter record.

There have been four separate crests above flood stage in 2010. That has happened only three other times: 1973 (5 times), 1983 (4), and 1984 (4).

By looking at the Van Meter gauge, it is doubted the Raccoon ever left its banks a single time at Fleur from March of 1929 until May of 1944. To look at the most recent 15-year period, the Raccoon has gone out of its banks 16 times since 1995.  It can’t be said for certain that the table below is exactly accurate, but it is pretty close to what has been observed at Fleur:”

DecadesCrests above flood stage
2010-194
2000-097
1990-998
1980-8911
1970-798
1960-697
1950-598
1940-496
1930-390
1920-292
1910-190
1900-091

*Some advantages of phasing out certain crops, cropping systems and industrial animal systems:

By phasing out most row crops and all confinements and feedlots, we would end most pollution of our soil, water, and air. This would result in fewer fertilizers, pesticides, herbicides, and nitrogen and phosphorus being put into our soil, running into our water, and evaporating into our air.

Toxic sewer and greenhouse gasses from confinements and feedlots would no longer be produced and vented into our air. Diseases from proximity to hydrogen-sulfide and ammonia (asthma, etc.) would no longer be a problem in rural areas.

Antibiotics, hormones, and endocrine disruptors would no longer be put into our soil, water and air from confinement and feedlot waste. Antibiotic resistant diseases would slowly be eliminated.

Infectious diseases such as MRSA, and Ebola would no longer be living in confinement herds or in the people who work with those confined animals. Integrons, which are the vehicle for antibiotic resistance being passed from one organism to another, would not be living in confinement conditions ripe for spreading that resistance to germs which infect people.

*Manufacturing and Processing:

Products from Hemp: see pdf’s and links above. Because of bulk, the manufacturing and processing of this crop would need to stay local therefore encouraging bio-regional systems.

Food preserving and processing:

Unlike the highly processed foods essentially made from corn and soybeans, these grains, vegetables, and fruits would be preserved and processed locally.

Animal processing plants would be smaller and more wide spread with the capability to process a variety of species and size of animals.

*Federal Farm Programs:

Subsidy per acre only, regardless of use.

Subsidy ($) to the farmer who is actually working the land; not to the owner (takes land out of investment category and returns it to working land).  

Rent limited to 100% of actual tax per acre.

Farmers today are corn and bean farmers because those are the programs. Change the programs and you will change how farmers farm.

*2nd Clean Water Act:

Regulate non-point source pollution. If we are ever to truly get a handle on water pollution in America, we need a new “Clean Water Act” to regulate non-point pollution, which primarily comes from this model of agriculture now in use.

*Repopulate and Revitalize Rural America:

By growing crops that need to be processed and made into products locally, you will need to have a greater population base in rural America. These cropping and animal raising models would need labor and management (farmers) instead of inputs (structures, chemicals and energy) and would therefore require many more farmers and laborers in rural areas.

This would enhance the prosperity of larger cities, which are regional engines of commerce.

*Rail and Road Infrastructure:

Because of the bulk of hemp, processing and manufacturing will need to be local and there will be a need to return rail transportation to the rural areas.

Farm to market roads will attain higher use and as a result will be built and maintained with higher use in mind.

Bob Watson

and kind argument deconstruction.doc

“and kind argument deconstruction” (1-10)

            This will talk about what happened to our anti-degradation op-ed when one of two parallel arguments, our “and kind” argument, is left out. And, what happens further when those sentences which are a part of the “and kind” argument are left out.

            The anti-degradation op-ed that we submitted to the Register for publication contained not one, but two parallel arguments. One was about the “amount” of sewage, our quantity argument, which was left in. The other was about the “kinds” of sewage, our quality argument, which was left out. Right at the outset then, the Register narrowed the scope of our argument by taking out the “kind” argument by leaving out the words, “and kind.” We are left making the much narrower argument about quantity, and having a less complex discussion by not addressing the quality argument (what is this stuff?). The Register version becomes a one dimensional beginner’s version of what we are actually talking about. And, still allows the argument that “this is just manure” to be made by industrial ag apologists.

            The set of “and kind” sentences left out contain explanatory factual statements that add depth and clarity to the understanding of the technology and the waste, talk about the connections to multiple levels, connect the different parts of our conversation, inserts this issue into the larger issue of the petro-chemical/industrial row crop model of agriculture, explains why and how this waste (through its intersection with the row crop model soils) affects the larger environment, talk about why soils can’t treat this waste and why soils can’t treat some waste no matter what, and contains language which tells you why you should care about this issue.

            The “and kind” argument and sentences are our “justification arguments”. They provide the information which allows us to make the assertions that we make. These details also connect our conversation’s logical progression. They justify what we have said and then allow us to make new arguments based on those truths. The op-ed is laid out in an “if then, therefore” form of argument. The “and kind” argument and sentences are the “if then” portion of that form. That form of argument gives a firm basis for believing the assertions that we make. With the Register version, we seem to be making assertions which you have no basis for believing except that we told you to.

            Our originally submitted argument has more depth, is more complex, is a larger multi-level conversation about how this issue fits in to the current petro-chemical/industrial ag model; and, how this waste affects, through the current ag model, the larger environment. If the “and kind” quality argument is left in our op-ed, instead of the Register’s one dimensional discussion, we have a conversation on multiple levels talking about a whole host of issues; which is what we intended and what our original op-ed did.  

Bob Watson

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ossian ethanol plant and taxes.doc

Why not lower our taxes by $20 million? (11-29-01)

Dear Editor,

            The county supervisors were not elected to be financial investors. If even one voter doesn’t want their hard-earned tax money gambled on a private venture whose profits will go to private investors, the county supervisors should not be able to risk that tax money.

            If the supervisors think they have $20 million to risk losing, thin I say they should lower our taxes by $20 million instead.

            Our taxes already subsidize corn. Our taxes subsidize ethanol, too. Why should we then have to subsidize a private industrial venture which already benefits from our tax dollars?

            If we actually have any extra tax money, I would just as soon it went for school buildings, educational costs and the like.

            I will be voting “no” on Dec 11th.

Bob Watson

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response to Dugger.doc

Dear Editor,

            I agree with Tim Dugger and the North Winneshiek School Board. They have had nothing to do with the EPA lawsuit.

            That suit has been filed and funded by mothers, teachers, former students, parents, grandparents, relatives, friends, and community members.

            177 medical and scientific studies (one of which was actually done on North Winn) were filed along with the lawsuit as evidence corroborating the lawsuit’s position that children’s health is being harmed by poison sewer gasses coming from confinements and feedlots. See www.civandinc.net , appendix E, # 2 “CAFO Research Studies and Articles”.

            There was a time when country kids were healthier than city kids; it was known as the “Hygiene Hypotheses”. Now, under the current industrial model, country kids, because of confinements and feedlots, are less healthy than city kids (see appendix E, #3 “Traditional vs. Industrial Farm Children’s Health Studies”).

            Why these gasses are being produced, and why children’s health is being harmed as a result, is made clear from the discussion of what CAFO technology is (see appendix E, #1 “Unintended Consequences of CAFOs” ), and what happens when you use that technology in agriculture.

            We’ve explored many avenues in trying to resolve these North Winn air quality issues including the current EPA lawsuit and my candidacy for county supervisor. The air quality issue is not one that North Winn has had any control over. A new county funded HVAC system for North Winn, with the correct filters, would allow the kids to have clean and safe air to breathe at least while they are inside the building. That doesn’t seem too much to ask.

Bob Watson

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formal cover letter.doc

There’s more than one way to mitigate flooding.

Although building expensive levees, dams, and other structures often seems to be the first approach, we also should look at a parallel course of action to reduce the causes of the high water those structures are expected to contain.

As we discussed in our recent “Cedar Rapids Gazette” op-ed, we could address the causes of floods by promoting a long-term move toward perennial agriculture. That eventually would re-create the “sponge” that historically absorbed rainwater and held it on and in the land, rather than rushing it away to flood downstream neighbors. This sponge model of agriculture, with a complex of perennial vegetation that may reach 30 feet from the deepest roots to the above-ground tops, would mimic the historic prairie, woodland, savannah, and wetland landscape of Iowa.

Changes in the federal farm bill could help accomplish that goal. We propose that this body use its political capital to help begin that process. Since this doesn’t involve the expenditure of money, you could start without waiting for some new tax vehicle, as you must do with pumps and levees.

With that in mind, we have formalized and expanded our op-ed. The package we hope you’ll consider includes our op-ed and a PowerPoint based on the op-ed. We also asked a retired city administrator to prepare an outline/guideline that translates our op-ed into a form and language that this body might use in contemplating action on our proposal.

The package contains documents explaining elements of the op-ed. We have included several academic and scientific studies, along with materials putting the op-ed in context. We hope this information will encourage you to adopt the suggested parallel course of action toward flood reduction.

We believe it’s in your self-interest to consider measures to help change the farm bill to encourage a move toward agricultural practices that can store water in place in the watershed, rather than sending that water downstream to you and your neighbors.

We would urge you to contact your Senators and Congressmen to support those changes:

Senator Charles Grassley: 319-363-6832

Senator Tom Harkin: 202-224-3254

Representative Dave Loebsack: 202-225-6576

Representative Bruce Braley: 202-225-2911

Representative Tom Latham: 202-225-5476

Representative Steve King: 202-225-4426

Representative Leonard Boswell: 202-225-3806

Although you may be asking Congressional support because of your direct concerns about protecting your city and county from flooding, there are many other positive benefits that could result from farm bill incentives to promote perennial agriculture:

For example:

* Reduced soil erosion.

* Restoring the soil’s water storage capacity and soil organisms.

* Less water pollution from soil erosion carrying sediment, nitrogen, phosphorus,

fecal bacteria.

* Reduction of the Dead Zone in the Gulf of Mexico, because of less agricultural

run-off.

* Aid State of Iowa regulators in antidegradation efforts for our surface waters.

*Less air pollution from wind erosion of soil; from volatilization of fertilizers, pesticides

and herbicides; from confinements and feedlots.

*Reduced Nitric acid rain, which is from the volatilization of anhydrous ammonia

fertilizer and from ammonia produced in confinements and feedlots.

*Human health benefits from fewer particulates and poison gases – hydrogen sulfide,

ammonia, methane – which now are coming from feedlots and confinements 24/7, 365 days a year.

*Reduced use of antibiotics and hormones in livestock when the animals are removed

from confinements. This would decrease potential water pollution and help prevent antibiotic resistance and endocrine disruption in humans.

*Additional human health benefits – less obesity, diabetes and heart disease – from an

improved diet with fewer highly-processed corn and soybean products, and less meat from grain-fed animals.

* Improved wildlife habitat from maintaining permanent cover.

* Perennial vegetation would act as a carbon sink to help slow climate change.

* Revitalization of our rural communities through the need for more farmers, local

processing and manufacturing of bulk crops; and because we would replace industrial ag’s inputs and structures with management and labor (farmers).

*A rebuilding of our transportation infrastructure, roads and rail, to facilitate local

manufacturing and processing of crops.

These advantages, and problems solved, also would be important benefits of changing the farm bill to give farmers incentives to re-perennializing our agriculture.

Thank you very much for allowing us time to make this formal request. We would be pleased to return to continue this dialogue, to present the PowerPoint, or discuss possible courses of action that you may want to consider.

Bob Watson                                                                           

Larry Stone

——————————————————————————–

watershed approach op-ed, shorter, 1-16, LS-RW edits.doc

A Watershed Approach to Reducing Floods

Cedar Rapids Gazette, January 22, 2012

Following the 2008 floods, the Army Corps of Engineers estimate of levee and pumping structures to “protect” Cedar Rapids from floods was $1 billion. More recent estimates for smaller systems have been substantially less, but still in the hundreds of millions. These efforts would protect only parts of Cedar Rapids, while creating worse conditions for other residents of the watershed. Also, these so-called “protective” systems would do nothing to alleviate the causes of floods.

Another solution, and a parallel course of action, would be for the people of Cedar Rapids, and other flood prone cities, to focus on changes in watershed practices to reduce flooding. This can be accomplished through the spending of political capital on a new farm bill, rather than wasting monetary capital.

Historically, Iowa was covered by deep-rooted forests, prairies, savannahs, and wetlands. This floral/hydrological system created a vast sponge ranging some 15 to 30 feet in depth both below and above the surface. This sponge allowed rainwater to infiltrate at 7 to 14 inches per hour, while purifying and slowly releasing the stored water for plant uptake and recharging groundwater and aquifers.

Today’s intensive, row-crop agriculture has virtually destroyed that sponge. Modern floods, although made worse by climate change’s extreme rain events, are mostly caused because industrial agriculture has turned the historic landscape on its head and put bare soil at the surface. With this unprotected soil reaching saturation after as little as one inch of rainfall, rainwater simply sluices off the surface on its way into our waterways.

But other innovative, alternative agricultural systems – which are available now – would allow us to re-perennialize agriculture and rebuild the topsoil “sponge,” with its flood mitigating capabilities. An Iowa State University study has shown that interspersing annual crop fields with strips of native prairie, which can soak up 7 to 13 inches of rain per hour, can eliminate up to 95% of erosion.

“The Land Institute” is breeding prairie plants to have large seed heads for human and animal consumption. The first of these should be ready for sale to farmers by 2020. We will be able to eat the prairie, and these crops would help rebuild Iowa’s historic sponge.

We also should take livestock out of confinement buildings, which are really dangerous sewage collection facilities. Confinements create untreated sewage, hydrogen-sulfide, ammonia, methane and particulates that damage human health and pollute the environment. And we should remove livestock from feedlots, which often are little more than open sewers. If we put animals on the land, fields now used for row crops could be converted to pasture. Utilizing intensive rotational grazing, that pastureland could store up to 7 inches of rain per hour.

Another important part of a rotational cropping system could be industrial hemp, which can need little or no commercial fertilizers, herbicides or pesticides. Hemp was important for food and fiber in early America, but its cultivation now is prohibited in the United States. (We are the only developed country to ban hemp.) Yet hemp ranks second only to soybeans in its protein content, and it can be used to produce food, fiber, textiles, paper, essential fatty acids, and other products. Other crops which would feed people and animals could include small grains, hays, vegetables, and fruits.

The declining supply of petroleum eventually will require a change from petro/chemical-dependent industrial/row crop agriculture to more sustainable crop rotations. That could mean the need for 40 to 60 million smaller, sustainable farmers. And that could revitalize our rural communities.

A more diverse, sustainable sponge agriculture would go a long way toward reducing future flooding for Cedar Rapids and the Cedar River watershed.

A farm bill that spends political capital to promote watershed changes to reduce floods. A levee and pump system to attempt to control the next “500 year” flood. These are parallel courses of action.

Bob Watson                              

Larry Stone

——————————————————————————–

agrinews foam article.doc

Agri News Op-ed

Re the Jan 26 article on foaming (3-12)

            With all the discussion and puzzlement over foam and flash fires in CAFO manure pits, researchers and CAFO operators may be overlooking the obvious. A CAFO manure pit is a de-facto anaerobic digester that produces methane, hydrogen-sulfide, phosphine, ammonia, and other toxic and poison gasses and compounds. There is no way around that situation when manure decomposes in a pit for months at a time.

            Many variables could affect why foam forms on top of the waste in the pit, however: the animals’ diet; the proportional increase in the amount of manure being deposited in relation to the total volume of the pit as the pigs get bigger; the age of the waste; the water-manure ratio; the amount and kind of ventilation; barn cleaning chemicals; and other factors. But, the explosive methane and other gasses are created and present, whether they are in the waste, entrapped by foam, in the air of the building, or vented out into the surrounding neighborhood.

            These facts were made clear in a 2009 study prepared for the National Pork Board by the Iowa State University Dept. of Agricultural and Biosystems Engineering. The report reviewed literature that cited CAFO fires from as long ago as 1969. Thus, it’s disturbing that no research has questioned the confinement technology that may lead to these explosions.

            That 2009 study also noted a correlation between the feeding of DDGs and the apparent increase in foaming. Some studies show a higher manure output from animals fed DDGs, which have fewer available nutrients for the pigs to digest than unprocessed grain. This results in more waste being deposited in the pit over time (the proportional problem), and that waste will have a higher organic loading. Both issues can lead to foaming, and both are realities that wastewater industry operators have dealt with for years.

            There may be no easy answer to the inherent CAFO problems of toxic emissions, fires, and foaming until we acknowledge that the technology being used is inappropriate. CAFOs mimic municipal/industrial wastewater facilities by collecting waste. But CAFOs, which are virtually exempt from regulations governing this fecal waste technology, do not treat the waste or contain the resulting gasses and pollutants. And, unlike the wastewater industry, CAFOs routinely place workers and animals in proximity to the hazards of anaerobic digestion.

            Methane can cause fires. Methane and other toxins are vented into the surrounding neighborhood. Untreated sewage is spread on the land. An attempt to suppress foaming does not address the issue that confinements are anaerobic digesters. Decomposing fecal waste in a closed space always creates these poison and explosive gasses. If you use this technology, you will get these problems. You simply can’t get around that fact.

Bob Watson                                  

Larry Stone

——————————————————————————–

nw history and current efforts.doc

This is the history and current effort in trying to get the North Winn air quality issues resolved. 3-6-12.

A. The foul air coming from confinements and feedlots, first confinements built SW of the school in 1995, was so bad during the 2009-10 school year that Birgitta Meade started keeping a log. She also talked with Steve McCargar and Bob Watson about this. They had been involved with the original group, “We Live Here Too”, that had been put together to try to stop these confinements from being built.

B. We went to a meeting of the North Winn School Board to discuss the issue and possible avenues for help, Oct 18th , 2010.

North Winn School Board meeting Monday Oct 18th, 2010.

1. All CAFO’s produce similar gasses and particulate matter which result in health problems for neighbors.

2. Merchant and Kline studies. MRSA studies.

3. These studies and some German studies have led the EPA to conduct their own studies over the next two years; according to Peter Thorne who is the head of the U of I Health research school. You might ask him how you could be considered to take part in that EPA study.

4. HVAC information.

5. Who might help you if you wish to pursue mitigating this issue:

            Public Health Dept both county and state,

            EPA, (has already taken over eight feedlots in Iowa)

            OSHA, (I wonder who they would enforce against since the employer and employee are both affected in this case)

            EPC/DNR.

Contact me if you have any questions or would like my help.

Bob Watson

            At this meeting it was asked that Birgitta continue to see what might be done to address the air issue. She asked Steve and Bob to continue helping her with this process.

C. A meeting was set up with the Winneshiek County Board of Health. The North Winn issue was brought up and discussed. The Board, due to prior requests of this kind in regard to confinements, said that they could do nothing about the situation. We asked them to contact the State Epidemiologist, Dr. Patricia Quinlisk, and the Iowa Dept of Public Health, to see what they might be able to do to address the issue.

This is the text of the letter that the County Board sent to me about the response they received from the Dept of Public Health:

Dec 22, 2010

Dear Mr. Watson,

            Thank you for presenting information to the Board of Health at the November meeting. It was interesting to learn of confinement odor issues/concerns at North Winneshiek School.

            We would like you to know what we have done to follow-up your visit. The Iowa Department of Public Health was contacted. Conversations were held with Dr. Patricia Quinlisk, state epidemiologist and Ken Sharp, bureau Chief of Environmental Health. Unfortunately, the legal hands of the local and state Boards of Health are tied. It was explained to us that the contaminants most likely to cause an issue are going to be at a nuisance level and determined not high enough to cause a risk to be considered as an imminent health threat. It was also share with us that Iowa Law Statute distinctly states that no one other than the DNR can regulate farming operations. The farming industry has been a powerful lobby and in so doing, restricted any health regulations from being imposed upon the farming industry.

            It was suggested that if the North Winneshiek School administration and board wish to alleviate the odor, an HVAC system be purchased that will filter out the smell. If an employee of the school wishes to contact OSHA to lobby a complaint, it is between the employee and the employer (school board), in which case the Board of Health still does not have legal authority to do anything.

            While we empathize with you, we are limited by the law, as you realize. We will continue to monitor and regulations or legislation that may be imposed and will continue discussions at future Board of Health meeting.

            Again, thank you for your ongoing concern on this and other local and regional concerns, and taking time to research and present them to us.

Sincerely,

Thomas Shroyer, DVM

Chairman, Winneshiek County Board of Health

D. We expected something like this response, but we were not satisfied with this nor did we wish to stop this line of attacking the NW air issue. What follows is an email chain continuing this attempt at resolving NW’s air issue. This email chain involves the Iowa Dept of Health, EPA, DNR, and the Iowa Attorney General’s Office. Steve McCargar sent a letter to the EPA (region 7, Kansas City) and that is how we ended up contacting Sue Casteel.

{this first email exchange is with Ken Sharp, IDPH. Dr. Quinlisk never responded}

North Winneshiek School email chain:

From: Bob and Linda [mailto:bobandlinda@civandinc.net]
Sent: Wednesday, January 05, 2011 9:35 AM
To: Sharp, Ken
Subject: Winneshiek County Board of Health

Dear Dr. Quinlisk and Mr. Sharp,

            I received a follow-up letter from Tom Shroyer, Chairman of the Winneshiek County Board of Health, about my and Steve McCargar’s presentation to them about the North Winneshiek School air quality issues. This concerned poison industrial gasses, hydrogen-sulfide and ammonia, emanating from multiple hog confinements and one cattle feedlot in proximity to the North Winneshiek School. In his letter, Tom indicated that he had spoken to, or contacted, both of you in getting answers to our questions and in finding out what might be possible in order to alleviate this ongoing problem; fifteen years and counting. That is why I am sending this follow-up email to you.

            As I’m sure you are aware, recent studies, including the Merchant and Kline studies as well as some German studies, find that health problems for people in proximity to confinements, and by extension feedlots, are no longer in the nuisance category but are recognized as leading to real health consequences. These studies have proven so convincing that the EPA has recently started their own two year study using those studies as guides. We actually contacted Peter Thorne to see if the North Winneshiek school could be included in the new EPA study, but the sites had already been decided upon.

            Our perspective relating to industrial agricultural issues has been, and remains, simply addressing the interface between industrial poisons and the public. This perspective shows how the County can enforce existing federal and state laws that protect the public from these industrial poisons, and do in all other sectors of America except agriculture. We do not care where the poisons are coming from. We simply want our children to have the protections afforded to all other children from these industrial poisons.

            We identified, for the North Winn School Board, filters that could be installed in their HVAC system to control hydrogen-sulfide and ammonia; at least inside their building. For various reasons, they have not decided to do that yet. But, being that the heat needed to be shut off in the nurse’s room recently because of the stench, that may have greater urgency.

            Because of computer problems, I am not able to attached documents to this email. But, what I am sharing with you here is available at:
http://www.civandinc.net/Stone-Watson%20CAFO%202007.htm . If you scroll down to the “Rural Schools, Confinements, and Poison Gasses” section, the Merchant and Kline studies are there. The HVAC information is there. And, the situation North Winn is in is
generally outlined there. As well, the first two pieces in that appendix outline our perspective and what might be done to address this issue.

            Thank you for taking the time to read this email and to look at the information proffered in considering whether or not the state Board of Health might actually have jurisdiction in this, and like, situations.

Bob Watson

Mr. Watson –

            I wanted to acknowledge receipt of your email regarding your concerns about the air quality surrounding North Winneshiek School.  We are reviewing the material in detail, however the preliminary review seems to indicate the concerns you have raised fall more appropriately under regulations of the DNR.  The Iowa Dept of Public Health has little or no explicit authority to regulate animal agriculture in Iowa.  This is also true for Local Boards of Health in Iowa.

            I will be reviewing this material with the Department’s Assistant Attorney General next week during our regular meeting with her and hope to be able to provide you with a more detailed response in terms of legal authorities soon after that meeting.

Thank you,

Ken Sharp, MPA, RS
Director, Division of Environmental Health
Iowa Department of Public Health
321 E. 12th Street
Des Moines, IA  50319

phone: 515/281-5099
fax: 515/281-4529
email: Ken.Sharp@idph.iowa.gov

Mr. Watson –

            I am attaching a few items for your consideration.  In essence, the regulation of

animal feeding operations by local jurisdictions is preempted by state regulations.  While this is an oversimplification of an otherwise complicated issue, the attached documents provide some context through Iowa Code citations, Attorney General Opinions, and Court findings.

            1. The attached AG Opinion speaks specifically to city authority over animal feeding operations, however in the document there are several references to county authority being preempted by state authority.  In most citations, the document references the court decision impacting Humboldt County (also attached).

            2. The attached Iowa Code citation is the language that appears to most directly

impact local authority.

            I’ve highlighted the sections of the AG Opinion and Iowa Code documents that appear to be most relevant to the issues and concerns you raised in your original email.

            Furthermore, it has been a long standing practice that State Agencies can act only

within the authorities granted to them under Iowa Code.  The Code of Iowa that establishes the authorities and duties of the Iowa Department of Public Health can be found in Iowa Code Chapter 135.  In this chapter there is an absence of any explicit authority for IDPH to regulate animal feeding operations within the state of Iowa.

            Regarding local board of health authorities, those authorities are spelled out in

Iowa Code 137 (Local Boards of Health) and again there is an absence of any explicit authority to regulate animal feeding operations.  Chapter 137 also specifically requires when local boards of health adopt rules and regulations that those regulations must not be inconsistent with state law.  This would seem to relate to the preemption discussion found in the AG Opinion; in that any attempt by local boards of health to regulate animal feeding operations would be “inconsistent” with state law and preempted by that state law.

            The authorities to regulate animal feeding operations clearly lie with the Iowa

Department of Natural Resources.

            I hope this helps to clarify the authorities around the issues and concerns over

animal feeding operations.

Thank you,

Ken Sharp, MPA, RS

Director, Division of Environmental Health

Iowa Department of Public Health

321 E. 12th Street

Des Moines, IA  50319

phone: 515/281-5099

fax: 515/281-4529

email: Ken.Sharp@idph.iowa.gov

            Please see the email with attachments for these highlighted documents.

Mr. Sharp,

            Thank you very much for the attachments you sent. I was able to read through them when I went to the library in town.

            The attachments you sent stating why the County or the State doesn’t have jurisdiction in this, or like, cases, do not address the issue that we contacted you about. The ongoing air quality issue on North Winn’s property is not addressed, nor does our request have anything to do with wanting to regulate cafo’s on their own property.

            As I mentioned originally, we are only interested in the interface between industrial poisons and the public. We are not interested in regulating anyone. We simply don’t think people, children in this case who are mandated to be in school by the State, should be exposed to industrial poisons – in concentration’s which are known to put their health at risk – when they are on public property regardless of origin of those poisons. The question is, does the State have an obligation to protect our most vulnerable citizens from air pollutants that can shorten their life span and leave them suffering from chronic and acute health conditions?

            I am wondering if you would address this more specific issue again with the Assistant Attorney General?

            Again, thank you for taking the time to consider this issue.

Bob

Bob Watson

Mr. Watson –

            I was able to speak with the AG’s Office yesterday regarding your concern.  Your questions regarding legal authority and obligations the State of Iowa has over air pollutants fall under the authority of the Iowa Dept of Natural Resources (IDNR).  Iowa Code 455B contains the relevant information, and in more specific detail it appears your concerns are addressed under sections 455B.131 through 455B.152.

            The Iowa Dept of Public Health has no similar authority as it related to air pollutants.  It would be more appropriate to discuss these concerns with the IDNR.  I recommend you start by contacting the Air Quality Bureau of IDNR.  Their website can be found here: http://www.iowadnr.gov/air/index.html

Thank you,

Ken Sharp, MPA, RS

Director, Division of Environmental Health

Iowa Department of Public Health

321 E. 12th Street

Des Moines, IA  50319

phone: 515/281-5099

fax: 515/281-4529

email: Ken.Sharp@idph.iowa.gov

End of email chain with Ken Sharp. Start of email chain with Catherine Fitzsimmons.

Ms. Fitzsimmons,

        Attached with this email is an email exchange chain that I had with Ken Sharp, Dept of Health, concerning the ongoing air quality issue at North Winneshiek School.

        Mr. Sharp in the end indicated that this conversation should be had with the Air Quality Section of the DNR. Hence this email to you.

        The attached document, ‘north winn email chain’, will lay out the issue, and explain why we contacted the Dept of Health. A second email with attachments will be sent to you also. Those attachments are too large for me to download, so I am sending them from my website. The text of that email is in this email chain also.

        As will become clear to you as you read the email chain, we are not interested in regulating anything or anyone. We are only interested in getting the ongoing air quality issue at North Winn resolved. Hopefully you can shed some light for us on how that may be accomplished.

        Thank you very much for taking the time to read these two emails and this email chain. I look forward to your thoughts on this issue.

Bob

Mr. Watson,

Thank you for sending me this information.  I will review this and respond as soon as I can.  I am also consulting with our Field offices and our division administrator’s office since this issue relates to a number of areas.

– Catharine

Catharine,

        I have included below the air quality log that has been kept by Birgitta Meade, science teacher at North Winneshiek School.

        Taken along with the other information I have sent you, and our request for action on this issue, I would be interested to know what has happened in this regard since our last email interchange. And, I would be interested to know what this log adds to your ability to secure a resolution to this issue. You will note that heat had to be turned off on one of the days this winter.

        Thanks.

Bob

Bob Watson



Days on Which Manure Odor is Detectable at North Winneshiek School 2010

 January 4,5,15,19,25

February 26

March 2, 12, 15 (very strong) 24,25

April 8,20,26,27

May 19

June 2 (extremely strong), 4

Total 18% of school days during spring semester 2010

 

July 7,11,21 (extremely strong), 22 (extremely strong)

August 4,16,18,24 (extremely strong), 25


September 1,8,10,14,25,28,30 (extremely strong)

October 1,4,5,6,7,11 (extremely strong), 12,13,14,15,19,20, 28,29

November 2 (extremely strong on Election Day), 3,8,17,30

December 10 (had to turn off heaters on NE side of building to avoid “fresh air” intake)

2011

January 2, 3, 5 (extremely strong),6, 7, 3, 14, 20, 25, 26

February 14,16,17, 24 (extremely strong), 28

March 1,2, 15 (extremely strong), 16 (extremely strong), 21

On 37% of school days (51 of 136) so far in the 2010/2011 school year, the odor was detectable on the playground.  On 9 school days the odor permeated the interior of the building.

Dear Mr. Watson,

Wayne Gieselman, Administrator of the Environmental Services Division, DNR, will be responding to your e-mail shortly.  I have shared with him all of the materials you have forwarded.

Catharine Fitzsimmons

515-281-8034

Bob,

Good morning.  Please find attached a correspondence from Wayne Gieselman, Division Administrator for Iowa DNR Environmental Programs in relation to your inquiry for air quality at North Winneshiek School. A hard copy will also arrive in the US Postal mail.

Thanks (pdf nw dnr letter, attach this pdf)

Jerah Sheets

Iowa DNR

502 East 9th Street

Des Moines, IA 50319

Phone:  515-313-8909

Ken,

        As you suggested, I sent the email chain to Catharine Fitzsimmons, Bureau Chief for the Air Quality Section of the DNR. She apparently kicked it upstairs. This is what I received from the DNR this week.

        I am wondering if you might be interested in talking with the Attorney General’s office again and see if they don’t think someone might be responsible for the poison gasses on the North Winn property affecting children who are required to be there. Or, could you tell me who I might contact at the AG’s office?

        I have also attached the log of air problems for the last 15 months or so that might interest you.

        Thank you for any help or suggestions you might give me/us.

Bob

E. This is the email chain with the CDC/EPA on getting their air quality testing trailer to North Winn.

Sue, (Sue Casteel, CDC)

        I am attaching the document with the email chain that I have had with the State Dept of Health’s Ken Sharp and the more recent with Catharine Fitzsimmons, Bureau Chief, Air Qaulity Section, IDNR. I am also attaching the ‘rural schools’ document so that you can see some of the background for our position.

        I will also try to send an email with legal and regulatory language that was sent to me by Ken Sharp. I am hoping this email with its three attachments will make it to you.

        Thank you for taking the time to look into this for us. Please contact me if you have questions or wish more information from us.

Bob

Bob,

I just received your e-mails.  I am out of the office the rest of the week, and part of next week on travel, so it may be a few weeks before you hear from me again, but I will be contacting you to discuss how I would like to proceed forward.

In the interim, please feel free to give me a call on my cell phone at the number listed below if you would like to discuss the site.

Sue Casteel

Regional Representative

ATSDR

(913) 551-1312 – Office

(913) 669-2589 – Mobile

(913) 551-1315 – Fax

Dear Sue Casteel,

Thank you for your call one week ago regarding the emissions from confined animal feeding operations surrounding North Winneshiek School in rural Decorah, Iowa.

I know that you already received a list of odor impacted school days, but I wanted to let you know about last Friday April 1st.

The stench was already strong on the playground when the school day started, by lunchtime it had permeated the school, and by 2:30 five adults had told me they experienced symptoms such as: headache, mild nausea, sinus pain, itchy eyes, and sore throat.  All of them said that the inescapable smell of manure was troubling them.  This is the tenth school day so far this school year that the odor has permeated the school building.  (On thirty-eight percent of school days so far this year CAFO emissions have hung over our playground.)   I have not asked students about their responses to the odor because this issue is so highly politicized in segments of this community.  I did notice however that middle schoolers had sprayed perfume in the hallways – which of course made the problem even worse.  An overheard comment from one of them was that, “The whole place smells gagatrocious.”

So far I have:

  • recorded data regarding odor events- starting January 1, 2010
  • spoken with my superintendent and the school board- they are supportive of my efforts
  • called the Department of Natural Resources- they said nothing could be done-suggested planting trees and closing windows
  • called my state legislators last fall- no help
  • written the Department of Public Health- no help
  • written to the Environmental Protection Agency- they forwarded my letter to you
  • spoken at public meetings held by my legislators- no help
  • conversed with local farmers who raise livestock- each of them blames someone else


What should I do next?  This problem is getting worse and worse.  A teaching colleague who grew up close to this school, comes from a farming family, and attended this school all the way through grade twelve said to me on Friday, “It was NEVER like this when I was growing up and going to school here.  This is disgusting.”

We have a wonderful school.  We have great families, great teachers, and great facilities.  Can you please help us do something so that the air inside and outside isn’t toxic?

Thanks for your work,
Birgitta Meade
Middle School Science Teacher
North Winneshiek Community School

            Sue Casteel put our request in for having the air quality testing trailer to be used at North Winn. She then sent us an email stating the trailer was still in Joplin, MO and that we should request this again in the spring; this spring 2012. When we did in Feb, this was the response:

Bob,

I just spoke with Dr. Metcalf.  She stated that at this time the air monitoring equipment has been committed to other site work until October, 2013.  However, she asked that you contact ATSDR then to determine if they will have the resources to conduct air sampling at that time.

I am moving to Atlanta, Georgia in June, 2012 so will no longer be in this office at that time.  I would therefore like to provide you with the name and contact information for the ATSDR Regional Director for this region.  She is Denise Jordan-Izaguirre, and she can be reached at 913-551-1310, or via email at ddj2@cdc.gov.  I have talked to her about this site, and hope that you will follow up with her next October.  In the interim, feel free to contact me if you would like to discuss this project.

It has been a pleasure to work with you.

Sue Casteel

Regional Representative

ATSDR

(913) 551-1312 – Office

(913) 669-2589 – Mobile

(913) 551-1315 – Fax

            So much for working with the EPA/ATSDR.

F. What follows is the letter that I received from Wayne Gieselman, Administrator IDNR.

March, 28, 2011

RE: Odor, hydrogen-sulfide and ammonia concerns at North Winneshiek School

Dear Bob,

I am responding to your March 2, 2011 e mail to Catharine Fitzsimmons at the Air Quality Bureau. The subject of your e mail is hydrogen sulfide, ammonia, and odors “emanating from multiple hog confinements and one cattle feedlot in proximity to the North Winneshiek School”. In your March 2, 2011 e mail you indicated that you are “not interested in regulating anything or anyone. We are only interested in getting the ongoing air quality issue at North Winn resolved”. That’s good because at this time this department has no regulatory control over odors, hydrogen-sulfide and ammonia from the sources you listed.

In 2002 the Iowa Legislature directed the DNR to perform a field study to determine airborne levels of ammonia, hydrogen-sulfide and odor near animal feeding operations. The outcome of that study was no a new set of rules. It was a report titled “Animal Feeding Operation Technical Workgroup Report On: Air Emissions Characterization , Dispersion Modeling, and Best Management Practices” (12/15/04)/ The full report is available through the Iowa DNR website at http://www.Iowadnr.gov/air/afo/afo.html . Scroll down to “Animal Feeding Operation Technical Workgroup Report” and click on “complete report”. There are also a number of Iowa State University publications available to guide facilities in the reduction of hydrogen-sulfide, ammonia and odor. They are included in the report and individually at the same website. If the confinement and feedlot owners are interested in being good neighbors to the school they can voluntarily implement the practices described in the ISU publications. I would encourage you to work with all the parties to discuss these options. {no reduction methods have been successful – Watson}

I would also like to offer the assistance of the field office at Manchester. {the Manchester office won’t even log odor reports called in from the school – Watson} They could not assist from a regulatory standpoint but they could meet with the school’s neighbors to provide technical assistance. Another option {this organization that Wayne is suggesting to contact is a corporate ag apologist group fully funded by corporate ag – Watson} might be to contact the Coalition to Support Iowa Farmer. Brian Waddingham is the contact person. He can be reached at 800-225-5531. {the irony is too much – Watson} I believe that they might be able to help out with this too in terms of trying to come to some resolution about this.

I hope this is helpful to you. We will do what we can to assist you in this.

Sincerely,

Wayne Gieselman

Administrator

            So, through this email chain you can see that no one in the state of Iowa is responsible for children’s health when they are required by law to be on school property. And, no one at the EPA is very much concerned either.

G. This odyssey was somewhat summarized by an op-ed that Bob Watson wrote:

            Rural school kids are being poisoned – and the bureaucrats refuse to do anything.

            With most of Iowa’s livestock now being raised in factory-like, industrial settings, rural residents and rural schools are being subjected to the poison sewer gasses hydrogen-sulfide and ammonia, to the explosive and greenhouse gas methane, and to particulates.

            Concentrated animal feeding operations (CAFOs), which include both confinements and open feedlots, act like sewers and poorly operating wastewater digesters. They create sewer environments. But unlike carefully monitored industrial or municipal sewers, CAFOs are unregulated. They can and do constantly produce poison gasses, which are blown into the rural neighborhoods 24/7, 365 days a year. This is legal because the state and federal governments have exempted confinements and feedlots from all regulation concerning these poisons and particulates. Rules that normally would protect the public from the harmful health effects of these industrial technologies do not apply to agriculture. Rural schools – and school children – receive no protection from industrial poisons produced by agriculture.

            The essential question we are asking is: “Who is responsible for school children’s health when they are required by law to be on school property?”

            In our effort to find a solution to this problem in our county, we have gone to the Iowa DNR, our local County Board of Health, and the Iowa Department of Public Health – which checked twice with the Attorney General’s office. In each instance, when we asked who might be responsible for these children’s health, we have been told essentially that no one is. Apparently these poisons are not considered poisons when they are coming from industrial agriculture.

            Studies have shown that negative health effects normally associated with exposure to hydrogen-sulfide, ammonia, and particulates are higher in rural Iowa than most anywhere else in the US, as a percentage of population. We used to raise most animals outside on pasture. Up until a few years ago in Iowa, we raised more animals per year outside versus what we raise now in confinements and feedlots. We didn’t have these health problems in rural areas until we started using CAFOs – confinements and feedlots – with their inherent poisons and particulates.

            So, who is responsible for children’s health when their playgrounds and classrooms are inundated with poison sewer gasses and particulates? Do we accept the Orwellian decree from the State that these really aren’t poisons when they come from industrial agriculture, and those children’s health problems don’t really exist?

            We have been amazed and disappointed at this response – or really the non-response – from government officials to our inquiry. The harmful effects to human health and the environment from this modern petro-chemical industrial model of agriculture is probably Iowa’s most urgent peace and justice issue. It is despicable that children can be sacrificed for a model of agriculture that enriches a few corporations and leaves the rest of us living with the shattered remains of a once vibrant farming culture.

H. Where we are at this evening at this meeting.

            We have given you a brief history. We will now present a short powerpoint explaining the technology and the poisons that are created by using that technology. Then Wally Taylor will give an explanation of a lawsuit that he believes has a chance at success in this issue.

Bob Watson

——————————————————————————–

ag gag and baudler.doc

Dear Editor,

            The ag gag legislation would make it a crime to get a job at a confinement farm if you lie about belonging to an organization which has making public animal abuse as one of its aims.

            But, we have a sitting representative in the Iowa Legislature, Republican Clel Baudler of Greenfield, who went to California and lied to get a prescription for medical marijuana.

            What, pray tell, is the difference?

Bob Watson

——————————————————————————–

lower taxes by $20million.doc

Why not lower our taxes by $20million?

            The county supervisors were not elected to be financial investors. If even one voter doesn’t want their hard-earned tax money gambled on a private venture whose profits will go to private investors, the county supervisors should not be able to risk that tax money.

            If the supervisors think they have $20million to risk losing, than I say they should lower our taxes by $20million instead.

            Our taxes already subsidize corn. Our taxes subsidize ethanol, too. Why should we then have to subsidize a private industrial venture which already benefits from our tax dollars?

            If we actually have any extra tax money, I would just as soon it went for school buildings, educational costs and the like.

            I will be voting “no” on December 11.

Bob Watson

——————————————————————————–

j-rural schools, confinements and poison gasses.doc

Rural Schools, Confinements and Poison Gasses.

            This talk will explore the relationship between rural schools, confinements (with their constantly exhausting poison gasses), and the incidence of airborne diseases in children due to their proximity to these confinements. It will give you an understanding of the technology which creates ammonia and hydrogen-sulfide, and how you can at least protect children when they are inside your school buildings.

            What follows is an important argument in that it gives a structure to understand generally all the particular community problems when a confinement moves into the neighborhood.  It becomes not an argument about farming, but about industrial processes and their resultant poisons and how the community is affected by them.

            Recognizing the larger ecological problem being that we have adopted industrial technologies for agricultural use, it is a shame that petro-chemical/industrial agriculture is portrayed by corporate agricultural entities and some politicians as nothing more than what farming has always been.  Any defense of industrial agriculture, based on the notion that this is how agriculture has always operated in the past, is rendered moot because industrial processes, new to agriculture and never intended for use outside of strict regulation, have only recently been adopted for use in the unregulated area of agriculture.  In today’s confinements, versus farms of 50 years ago, we see diseases and deaths to both animals and humans because we are no longer dealing with composted manure spread to fertilize the soil, but are instead dealing with a poison liquid which has been made toxic through cooking for months in a septic tank, lagoon or pit. The poison gases hydrogen-sulfide and ammonia are constantly generated from this untreated fecal waste and are continuously blown into the air of the neighborhood from the inside of the confinement building. We have people working in a hazardous workplace ignorant of the dangers because agriculture has been, by law, exempted from the regulations which would educate and protect them.  People in the neighborhoods of confinements are in a similar situation as they are repeatedly told this is only a nuisance and they do not have the protections from these poisons afforded all other citizens where similar circumstances exist.

            Confinements and city sewers have the same poison gasses and are the same technology. Confinements and sewers both are closed structures. They both have untreated fecal waste in them. That waste constantly generates the poison gases hydrogen-sulfide and ammonia in both confinements and sewers. People and animals need constant ventilation to survive in either a confinement or a sewer. The diseases and causes of deaths from those gasses are the same in sewers and confinements. Confinements and sewers are the same technology.

            There are two major management differences. First, city sewers are designed to contain their poison gasses while confinements, having literally turned sewers on their head, are designed to constantly blow those poison gasses out into the surrounding neighborhood. Think of confinements as upside down sewers that exhaust their poisons so that the pigs or chickens inside can stay alive, which people in the neighborhood then have to breathe.

            The second major difference is that city sewers are regulated by law, the federal “Confined Spaces Regulations”. By not regulating these gasses in agriculture there is no education and training about, and protection from, a hazardous work place; and there are no regulations protecting the public from these poisons from confinements as there are everywhere else in America where fecal waste producing hydrogen-sulfide and ammonia gases exist in a closed structure.

            All international, national and state health regulatory agencies – World Health Organization, Environmental Protection Agency, Occupational Health and Safety Administration to name some – know that hydrogen-sulfide and ammonia are dangerous to people. The science is settled on this issue, and we have understood the toxicology of those gasses since the 1950’s. In fact, it is an irony that one of the first studies to set an 8 hour limit for human exposure to ammonia was a 1960 OSHA study done on pigs.

            Among many confinement studies over the last 30 years, a study in Utah simply looked at hospital records pre- and post-confinement introduction into a community. Those records show clearly a tripling of illnesses generally associated with exposure to hydrogen-sulfide and ammonia.  These illnesses are a direct result of the constant venting by those confinements of the poison gasses hydrogen-sulfide and ammonia into the neighborhoods around those confinements, and the contamination of the neighborhoods’ sources of drinking water by those confinements.

            “Proximity of children to confinements” studies (University of Iowa’s Dr. Joel Kline http://www.chestjournal.org/cgi/content/full/129/6/1486 proximity to rural schools, James Merchant of the University of Iowa on asthma in children who live on a farm with a confinement http://www.ehponline.org/members/2004/7240/7240.pdf ) done since 2004 show even more alarming results. Iowa’s overall rate of asthma is about 6.7%. To generalize, it has been found that if a rural school has a confinement within 10 miles, 11.7% of the children have asthma – nearly twice the state rate. If a confinement is ½ mile away from a school, 24.6% of children have asthma – four times the state rate. And if you are a kid unlucky enough to live on a farm with a confinement, there is a 55.8% chance you will have asthma – nine times the state rate.

            We have been raising pigs for between 7000 and 9000 years. We know how to raise animals in a manner benign to human health and the environment. It is unconscionable to do it otherwise. But, we seem to live in a state where even though we know it is immoral to poison our children, it is not illegal.

            So what can be done to at least protect rural school children while they are in school buildings? In speaking with a civil engineer about this problem he pointed me to Koch Filter information. Page 2 talks about “Specialized Carbon Media” for ammonia and hydrogen sulfide, http://www.kochfilter.com/pdf/detailed/d_prod_12.pdf . I have included the link so that you can give this information to a local HVAC business so that they can adapt your schools ventilation system to accept this carbon filter. In that way you will at least protect the children from poison gasses while they are inside your buildings.

Bob Watson

For further information about this issue, go to www.civandinc.com and click on the appendices A and B.

——————————————————————————–

foam op-ed.doc

Fundamental Problems (Sept 2010)

            It’s not just one bad egg. There are fundamental problems across industrial confinement agriculture. In the last year, both Iowa and Minnesota have seen an ominous increase in foaming in pits beneath hog confinements – like a potentially toxic bubble bath, it rises right through floor slats – exacerbating the already serious problem of dead pigs and flash fires caused by hydrogen-sulfide and methane.

            “I wish we had the answer,” said Angela Rieck-Hinz of ISU, writing in August on the Iowa Manure Management Action Group website, “but at this point in time we still have no answers as to what is causing the foaming or how best to control or manage the foam. If you have information regarding foaming pits you would like to share please contact me. In the meantime, I urge caution when pumping from manure pits. Be aware of safety concerns regarding manure gases, pit fires and explosions. Not all pit fires and explosions have happened in barns with foaming pits.”

            The crux of the problem is that confinement advocates have inappropriately transferred wastewater technology from the highly regulated sector of municipal and industrial wastewater to the unregulated – in terms of wastewater – sector of industrial agriculture. The concern about poison and explosive gasses is not new, and not only in those confinements with the foaming problem. It is simply a consequence of using wastewater technology to raise animals.

            In the wastewater industry, we learned long ago – after workers became ill or died – that we could not put normal workspaces in proximity to areas where fecal waste is decomposing. The constant production of the poison and explosive gasses – hydrogen sulfide, ammonia, and methane – was finally taken into account in designing wastewater facilities and technology that would protect both the workers and the surrounding public. Those protections have been codified in the regulations that control municipal/industrial wastewater technology and design. But industrial agriculture remains exempt.

            There may be many causes for the upswing in foaming problems in confinements. Some potential causes might include: damage to buildings and equipment through the corrosive nature of hydrogen-sulfide, genetically modified crops being fed to animals, different insecticides and herbicides applied to fields as pests and weeds become resistant to chemicals used in the past. Perhaps we will find solutions to somewhat mitigate this new foaming problem. But the bottom line is that as long as you use wastewater technology to store waste in pits below where animals are being raised, you will always have disease and death affecting both people and animals caused by these poisonous and explosive gasses.

            The state Legislature, the Iowa Department of Natural Resources, and corporate industrial agricultural officials steadfastly deny that confinements are a form of wastewater technology. Although seeming illogical, in fact a DNR construction permit requires this type of building, resulting in these problems.

            As a society, we should question what this industrial model of agriculture is doing to us, the animals, and the environment. We have turned most of our hog producers into virtual serfs, with corporations financing and owning the buildings, the pigs, and the feed, and even controlling when the producers market the pigs. Corporations externalize their environmental costs onto the producers and the public by having the producers own the polluting waste and the dead animals. We also expect producers to deal with the unsolvable problems confinement buildings create.

            Confinement technology used to raise animals is a failed model on many levels. It is time to put animals back on the land.

Bob Watson

——————————————————————————–

a-tile line op-ed.doc

Tile Line/Constructed Wetlands Op-Ed (1-10)

            In the recent historical past, Iowa was covered with forests, prairies, wetlands, thick sod, streams and rivers. Rain that fell to the earth was retained, cleansed, used and slowly passed through the state. That changed with the coming of settlers who broke the sod of the prairies for cultivation agriculture. The historic hydrology of the state was altered with the need to drain fields. To accomplish that draining, we now have some 880,000 miles of field tile in Iowa. Records show a doubling and even tripling of the flow of some rivers over the last 100 years. Also, because tile lines provide a direct conduit to surface and ground waters, we have lost the water’s contact with the cleansing soil and surface flora resulting in streams and rivers that are, in many cases, little more than silt, fecal and chemical filled canals.

            Last November, the Water Resources Coordinating Council (WRCC) submitted flood plain management policy recommendations and funding options to Governor Culver and state legislators. The recommendations are intended to help the state rebuild safer, stronger and smarter in the wake of the historic 2008 floods.

            House File 756, passed by the legislature in 2009, required the WRCC to submit policy and funding recommendations that promote “a watershed management approach to reduce the adverse impact of future flooding on this state’s residents, businesses, communities, and soil and water quality.”

            One proposal from the Iowa Department of Agriculture and Land Stewardship (IDALS) is counter intuitive and scientifically questionable.  IDALS proposes to further enhance artificial drainage of Iowa farmland. The proposal has morphed between an implementation plan and a feasibility study. The plan appears to be moving rapidly from concept to expensive experiment, in spite of serious questions raised by scientists and knowledgeable water resource professionals. What has been called the “Iowa Plan” redesigns and enlarges existing drainage systems and directs water flow to constructed wetlands. These wetlands may reduce nutrient loads delivered to Iowa lakes and streams. Restoring Iowa’s wetlands sounds appealing because this could benefit the hydrology and water quality that has been disturbed by – ironically – artificial drainage. The arguments supporting accelerated drainage are the same that resulted in the elimination of Iowa’s wetland ecosystem in the first place – increased agricultural production. Producers and commodity consumers tout the benefits of expanded production efficiency, but what about those of us who want to use the streams and lakes destined to receive more water, nutrients and pollution from accelerated drainage? If increased production efficiency resulted in the cultivation of less land, then this is a noble objective. History shows, however, that this has not been the case in Iowa.

            The downstream consequences of accelerated drainage need to be carefully examined beyond the proposed token wetland band-aid. There are several things we know for certain: “improved” artificial drainage in Iowa has increased stream flow in quantity and duration over the last 100+ years; artificial drainage flushes nitrogen and phosphorus from soil into lakes and streams, impairing those waters for drinking, recreation, and aquatic life; wetlands have the potential to reduce stream flow and nutrient loads. What we don’t know: how much will stream flow and nutrient levels increase if drainage is further enhanced? What will be the effect of constructed wetlands on downstream flows and nutrient loads? And, are producers willing to designate enough acreage to a constructed wetland such that it can function effectively? Furthermore, there is the risk that these constructed wetlands, which will be receiving enormous nutrient loads, will have deleterious effects on downstream water quality. 

            Under current Iowa law, producers can construct drainage systems for their land using their own funds. If the negative environmental effects of accelerated drainage are only balanced out by a wetland system, how will the taxpayers of Iowa and the U.S. benefit by subsidizing this activity? Will the water leaving these drainage systems be required to meet some quality and quantity objectives? Discussion of these questions and a discussion of further modifying Iowa’s hydrology at taxpayer expense need to be addressed. A specific, scientifically sound project plan needs to be developed and reviewed. This will best be accomplished by assembling some of the best Iowa scientists familiar with the issues. A transparent planning and funding process should lead to evaluating competitive ideas rather than the process of directing taxpayer funds to a limited number IDALS’ friends. Such a review is generally required for competitive research funding and Iowa should expect no less before embarking on a potentially expensive adventure in further (mis)managing its water resources.

            If we learned nothing more from the Floods of ’08, let’s remember that accelerated drainage creates significant risks for downstream property owners and communities. We hope IDALS will propose changes in land practices that result in less flow and less nutrient pollution to the waters of the state of Iowa, rather than more.

Bob Watson

Bill Stowe

Mike Burkart

——————————————————————————–

who is responsible for children.doc

            Rural school kids are being poisoned – and the bureaucrats refuse to do anything.

            With most of Iowa’s livestock now being raised in factory-like, industrial settings, rural residents and rural schools are being subjected to the poison sewer gasses hydrogen-sulfide and ammonia, to the explosive and greenhouse gas methane, and to particulates.

            Concentrated animal feeding operations (CAFOs), which include both confinements and open feedlots, act like sewers and poorly operating wastewater digesters. They create sewer environments. But unlike carefully monitored industrial or municipal sewers, CAFOs are unregulated. They can and do constantly produce poison gasses, which are blown into the rural neighborhoods 24/7, 365 days a year. This is legal because the state and federal governments have exempted confinements and feedlots from all regulation concerning these poisons and particulates. Rules that normally would protect the public from the harmful health effects of these industrial technologies do not apply to agriculture. Rural schools – and school children – receive no protection from industrial poisons produced by agriculture.

            The essential question we are asking is: “Who is responsible for school children’s health when they are required by law to be on school property?”

            In our effort to find a solution to this problem in our county, we have gone to the Iowa DNR, our local County Board of Health, and the Iowa Department of Public Health – which checked twice with the Attorney General’s office. In each instance, when we asked who might be responsible for these children’s health, we have been told essentially that no one is. Apparently these poisons are not considered poisons when they are coming from industrial agriculture.

            Studies have shown that negative health effects normally associated with exposure to hydrogen-sulfide, ammonia, and particulates are higher in rural Iowa than most anywhere else in the US, as a percentage of population. We used to raise most animals outside on pasture. Up until a few years ago in Iowa, we raised more animals per year outside versus what we raise now in confinements and feedlots. We didn’t have these health problems in rural areas until we started using CAFOs – confinements and feedlots – with their inherent poisons and particulates.

            So, who is responsible for children’s health when their playgrounds and classrooms are inundated with poison sewer gasses and particulates? Do we accept the Orwellian decree from the State that these really aren’t poisons when they come from industrial agriculture, and those children’s health problems don’t really exist?

            We have been amazed and disappointed at this response – or really the non-response – from government officials to our inquiry. The harmful effects to human health and the environment from this modern petro-chemical industrial model of agriculture is probably Iowa’s most urgent peace and justice issue. It is despicable that children can be sacrificed for a model of agriculture that enriches a few corporations and leaves the rest of us living with the shattered remains of a once vibrant farming culture.

Bob Watson

——————————————————————————————————

cheap food.doc

Cheap Food:

            There is a statement/question/accusation/suggestion/assumption/argument that is made when discussing changing the model of agriculture to a more environmentally benign model for raising our food, namely that we can’t do without cheap food which this system has brought us. That suggestion is more a result of corporate spin than fact. These are some of the factors which give the lie to that assumption.

1. Subsidies: we would consider that the billions of dollars of subsidies that are now in the Federal Farm Program and contribute to the ability to have cheap food would remain in a non-chemical model of agriculture. These subsidies were originally intended to pull farmers through those tough years where the growing season did not turn out enough profit to get that farmer to the next year. We rely on food for life. We wouldn’t want that system of raising food to end simply because the weather didn’t cooperate for a particular year.

2. We would assume that people would be eating lower on the food chain in a non-chemical agriculture versus the propensity for processed foods in the current industrial model.

3. There is a moral/ethical question that is not readily reduced to monetary considerations when one looks at the health impacts to humans from the current industrial model of agriculture. – But, to this non-monetized question, one must add those costs we can associate with the health impacts from the current industrial model; whether those costs are considered inside or outside the Natural Capitalism analysis.

4. If one were to apply a Natural Capitalism analysis and account for the externalities of industrial agriculture (pollution of our air, water and soil; human and animal health; loss of soil leading to no agriculture), food is not cheap.

5. The current petro-chemical/industrial model of agriculture is a zero sum model in consideration of soil. Natural replenishment of soil is .5 ton/year if one has in place those systems which can replenish soil, ergo prairie, etc. We will run out of soil in the near future with this model since even the vaunted no-till system loses 5 ton/year, and every other system has much greater soil loss per year.

Bob Watson

———————————————————————————————-

ias 2011.doc

IAS 2011 Presentation

Unintended Health and Environmental

Consequences of Confinement Agriculture

Why Confinement Technology

Creates Unintended Consequences

Bob Watson

Slide 1 

One of the major reasons that accounts for the increase in life expectancy and quality of life has been the adoption of good water treatment design, technology, and practices; and the adoption of good wastewater treatment design, technology, and practices. It seems with the coming of industrial agriculture, we may be in danger of going backwards.

I will be talking about confinement technology and what it actually is. Confinement agriculture will be shown to be a closed sewer environment. By analogy, feedlots, which I will not discuss, can be seen as open sewers. I will use an expanded version of an op-ed I wrote to show where we are today with this maturing technology. I will then mention a new unintended consequence, nitric acid rain, before I end on a positive note about models that exist, and could be used today, that could alleviate many of the problems discussed by Joel and Tara and me.

Slide 2 – For the purpose of this talk, sewer – closed space – and anaerobic digester can be considered interchangeable. Specifically in the op-ed portion of this talk, consider the confinement as an anaerobic digester; which means it contains decomposing fecal waste. And, as it will turn out, a poorly designed and poorly operating anaerobic digester.

Similarities: what a confinement and sewer/digester have in common.

Both are closed spaces.

Both have untreated fecal waste in them.

That waste constantly generates the poison and explosive gasses hydrogen-sulfide, ammonia and methane – this gas production is inherent in the use of this technology.

Causes of diseases and death from those gasses are the same in both sewers and confinements.

Constant ventilation is needed to survive in either.

(whenever and wherever these conditions exist, the controlling regulations are the Federal Confined Spaces Regulations, except in agriculture)

Differences: how confinements and sewer/digesters are different.

Sewers are designed to contain the poison gasses while confinements are designed to blow them into the surrounding neighborhood; 24/7 365 days a year – with consequences for the public such as those discussed by Joel and Tara.

The waste in sewers is ultimately treated, confinement waste is not treated. But, poison gas problems are prior to and would remain a problem even if the waste was treated. So for those who might think that treatment would be a solution to these problems, it isn’t. The problems remain regardless of treatment.

There are no regulations for confinements providing for education and training about, and protections from, a hazardous work place.

There are no regulations protecting the public from the poisons from confinements, as there is from sewers and anywhere in America where there is fecal waste producing hydrogen-sulfide, ammonia and methane gasses in a closed structure. Those regulations would be the afore mentioned Federal Confined Spaces Regulations.

Slide 3

Hydrogen-Sulfide:  (look at slide and read) Kelley Dunham, a veterinarian who is in the same organization as Joel and Tara, and I were keeping an unofficial count of deaths from hydrogen-sulfide in agriculture. It was unofficial because confinements aren’t regulated and therefore no government department keeps records from agriculture as they do from the wastewater industry. We simply looked at newspapers. We found that there were four times as many deaths from hydrogen-sulfide in confinements as in wastewater.

Summary of toxicology – Hydrogen-sulfide gas is a rapidly acting systemic poison which causes respiratory paralysis with consequent asphyxia at high concentrations.  It irritates the eyes and respiratory tract at low concentrations.  Inhalation of high concentrations of hydrogen-sulfide, 1000 to 2000 ppm, may cause coma after a single breath and may be rapidly fatal; convulsions may also occur.  Exposure to concentrations of hydrogen-sulfide above 50 ppm for one hour may produce acute conjunctivitis with pain, lacrimation, and photophobia; in severe form this may progress to keratoconjunctivitis and vesiculation of the corneal epithelium.  In low concentrations, hydrogen-sulfide may cause headache, fatigue, irritability, insomnia, and gastrointestinal disturbances; in somewhat higher concentrations it affects the central nervous system, causing excitement and dizziness.  Prolonged exposure to 250 ppm of hydrogen-sulfide may cause pulmonary edema.  Prolonged exposure to concentrations of  hydrogen-sulfide as low as 50 ppm may cause rhinitis, pharyngitis, bronchitis, and pnuemonitis.  Repeated exposure to hydrogen sulfide results in systemic effects that may result from concentrations previously tolerated without any effect.  Rapid olfactory fatigue can occur at high concentrations.

Slide 4

Ammonia:  (Joel’s talk – look at slide and read) There was a study done in a Utah town which simply looked at hospital records pre and post confinement introduction into that community. Illnesses normally associated with ammonia tripled. And illnesses normally associated with hydrogen-sulfide quadrupled.

Summary of toxicology- Ammonia vapor is a severe irritant of the eyes, especially the cornea, the respiratory tract, and skin.  Inhalation of concentrations of 2500 to 6500 ppm causes dyspnea, bronchospasm, chest pain and pulmonary edema which may be fatal; production of pink frothy sputum often occurs.  Consequences can include bronchitis or pneumonia; some residual reduction in pulmonary function has been reported.  In a human experimental study which exposed 10 subjects to various vapor concentrations for 5 minutes, 134 ppm caused irritation of the eyes, nose, and throat in most subjects and 1 person complained of chest irritation; at 72 ppm, several reported the same symptoms; at 50 ppm, 2 reported nasal dryness and at 32 ppm only 1 reported nasal dryness.

Slide 5

            There are fundamental problems across industrial confinement agriculture. In the last year, both Iowa and Minnesota have seen an ominous increase in foaming in pits beneath hog confinements – like a potentially toxic bubble bath, it rises right through floor slats – exacerbating the already serious problem of dead pigs and flash fires caused by hydrogen-sulfide and methane.

            “I wish we had the answer,” said Angela Rieck-Hinz of ISU, writing in August on the Iowa Manure Management Action Group website, “but at this point in time we still have no answers as to what is causing the foaming or how best to control or manage the foam. If you have information regarding foaming pits you would like to share please contact me. In the meantime, I urge caution when pumping from manure pits. Be aware of safety concerns regarding manure gases, pit fires and explosions. Not all pit fires and explosions have happened in barns with foaming pits.”

            The crux of the problem is that confinement advocates have inappropriately transferred wastewater technology from the highly regulated sector of municipal and industrial wastewater to the unregulated – in terms of wastewater – sector of industrial agriculture. The concern about poison and explosive gasses is not new, and not only in those confinements with the foaming problem. It is simply a consequence of using wastewater technology to raise animals.

            In the wastewater industry, we learned long ago – after workers became ill or died – that we could not put normal workspaces in proximity to areas where fecal waste is decomposing. The constant production of the poison and explosive gasses – hydrogen sulfide, ammonia, and methane – was finally taken into account in designing wastewater facilities and technology that would protect both the workers and the surrounding public. Those protections have been codified in the regulations that control municipal/industrial wastewater technology and design. But industrial agriculture remains exempt.

            There may be many causes for the upswing in foaming problems in confinements. Some potential causes might include: damage to buildings and equipment through the corrosive nature of hydrogen-sulfide, genetically modified crops being fed to animals, different insecticides and herbicides applied to fields as pests and weeds become resistant to chemicals used in the past. Perhaps we will find solutions to somewhat mitigate this new foaming problem. But the bottom line is that as long as you use wastewater technology to store waste in pits below where animals are being raised, you will always have disease and death affecting both people and animals caused by these poisonous and explosive gasses.

Slide 6

Actually the wastewater industry understands these causes:

1. Old fecal stock leads to foaming. Anything 3 weeks to 2 months is considered old in the wastewater industry. Fecal waste sits in confinements for 5 months to 1 year.

2. The volume of waste being deposited into the pit over time versus the total volume that the pit can hold leads to foaming. As the volume of waste that is generated increases (as the pigs get bigger) and is deposited as a percentage of the total volume of the pit, foaming increases.

3. Because of the way confinements are required to be built, there is no ability for the confinement operator to control the foaming problem because they can’t mix the pit. If the pit was mixed, the gasses would escape into the level containing the pigs and kill them.

Slide 7 

Consequences of foaming:

Normally gasses tend to stay in suspension in a liquid and to get out they must somehow break the surface tension. (wind or wave action, or some type of agitation)

1. Foaming increases the surface area increasing the chances of gasses escaping the liquid.

2. Foaming provides a direct path to the pigs for the gasses. The gas does not have to disperse and travel through air to get to the pigs.

3. The pigs bite/eat the foam, or the foam breaks down, and the pigs breathe the gasses and die.

4. The methane also has a direct path to the pig area increasing the chances of flash fires and explosions. (4800 pigs died a couple weeks ago in a fire in Rowley which is some 40 miles from here.)

            The state Legislature, the Iowa Department of Natural Resources, and corporate industrial agricultural officials steadfastly deny that confinements are a form of wastewater technology. Although seeming illogical, in fact a DNR construction permit requires this type of building, resulting in these problems.

            As a society, we should question what this industrial model of agriculture is doing to us, the animals, and the environment. We have turned most of our hog producers into virtual serfs, with corporations financing and owning the buildings, the pigs, and the feed, and even controlling when the producers market the pigs. Corporations externalize their environmental costs onto the producers and the public by having the producers own the polluting waste and the dead animals. We also expect producers to deal with the unsolvable problems confinement buildings create.

            So we know the problems that lead to foaming. And, in the wastewater industry at least, we know how to fix them. But because this technology has been adopted by confinement agriculture without the historic understanding of design engineers, wastewater operators, or regulators, it is used incorrectly and dangerously and without the ability to fix operational problems. We are raising animals in, and subjecting neighbors to, a sewer environment.

            Confinement technology used to raise animals is a failed model on many levels. It is time to put animals back on the land.

Slide 8 – I would like to briefly move on to a new unintended consequence, nitric acid rain: from the September 2010 Scientific American article “Sour Showers” by Michael Tennesen.

“Acid rain is back – this time triggered by nitrogen emissions. The acid rain scourge of the 1970s and 1980s that killed trees and fish and even dissolved statues on Washington, D.C.’s National Mall has returned with a twist. Rather than being sulfuric acid derived from industrial sulfur emissions, the corrosive liquid is nitric acid, which has resulted not just from smokestacks but also from farming.”

Slide 9 – this slide shows the ammonia cloud over the Midwest and the U.S., concentrated over Iowa.

Slide 10 – this is a slide showing the sampling sites for a study that is being done by the DMWW. That study, in part, is looking at ammonia content in snow.

Slide 11

Slide 12 – Sour Showers: 

September 2010 Scientific American, “Sour Showers”. The people or organizations you mention include: Viney P. Aneja, professor of air quality and environmental technology at North Carolina State University; the Hubbard Brook Experimental Forest in New Hampshire’s White Mountain National Forest; William H. Schlesinger president of the Cary Institute for Ecosystem Studies in Millbrook, NY; the 1999 Gothenburg Protocol in a 2009 paper in Environmental Science & Technology; and the Integrated Nitrogen Committee of the EPA’s science advisory board has generated a draft report that lays out the details, including management options for nitric acid rain. It also discusses ways to monitor atmospheric emissions, currently the weak link in the nitrogen-control picture.

Slide 13 – Papers sent to me by Bill Schlesinger: after a phone conversation we had, Bill sent these papers that he has done and that he thought would be pertinent to this presentation. “Schlesinger thinks that national arguments over climate change have allowed the U.S. to ignore the nitrogen problem, which he predicts will be the next big environmental issue.”

Effects of Agriculture upon the Air Quality and Climate: Research, Policy, and Regulations.

Farming pollution. From that paper: “Agriculture is a significant source of ammonia and particulate matter: approximately 90% of ammonia emissions in the United States and in many European countries result from animal and crop agriculture.” So that 90% comes from confinements, feedlots, and the volatilization of anhydrous ammonia applied to crops.

On the fate of anthropogenic nitrogen.

On fertilizer-induced soil carbon sequestration in China’s croplands.

Slide 14 – Watershed Approach to Floods: I would like to end my portion of this panel on an upbeat note. You can go to my website: www.civandinc.net to read this discussion in its entirety.

This discussion includes changes to the watershed and to the agricultural cropping systems which would end floods as we know them, and would end many of the problems that Joel, Tara, and I have been discussing; and would cost cities no money what-so-ever for flood control. This discussion will include presettlement vegetation cover before we turned the landscape upside down and put the soil on the top; what rain infiltration amounts historic and recent vegetation permits; and, agricultural systems available today which mimic that presettlement vegetation as far as rain infiltration rates and returning the landscape to a system with soil beneath vegetation. Also discussed is what using those perennial cropping systems would mean for cleaning up water, holding and creating soil, cleaning our air, and ending our contribution to the Dead Zone in the Gulf of Mexico.

Slide 15 – the topics discussed include:

Land Practices: Perennial Farming Systems That Resist Flooding, Laura Jackson/Dennis Keeney.

Wes Jackson’s Perennial Polyculture/Natural Systems Agriculture

Hemp – the inclusion of hemp in a sustainable model of agriculture.

Hay and Alfalfas.

Pastures and Rotational Grazing. Animals back on the land.

Woodlands.

Vegetables and Fruits.

Small Grains.

Prairie Strips.

Manufacturing and Processing.

Federal Farm Programs. Farmers farm the federal farm program. Change the program and you will change farming.

2nd Clean Water Act for agriculture. Ag is exempt from the current Clean Water Act.

Repopulate and Revitalize Rural America.

http://www.civandinc.net/watershedapproachtofloods.htm

Thank you and Questions.

Bob Watson

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foam op-ed fundamental problems.doc

Fundamental Problems (Sept 2010)

            It’s not just one bad egg. There are fundamental problems across industrial confinement agriculture. In the last year, both Iowa and Minnesota have seen an ominous increase in foaming in pits beneath hog confinements – like a potentially toxic bubble bath, it rises right through floor slats – exacerbating the already serious problem of dead pigs and flash fires caused by hydrogen-sulfide and methane.

            “I wish we had the answer,” said Angela Rieck-Hinz of ISU, writing in August on the Iowa Manure Management Action Group website, “but at this point in time we still have no answers as to what is causing the foaming or how best to control or manage the foam. If you have information regarding foaming pits you would like to share please contact me. In the meantime, I urge caution when pumping from manure pits. Be aware of safety concerns regarding manure gases, pit fires and explosions. Not all pit fires and explosions have happened in barns with foaming pits.”

            The crux of the problem is that confinement advocates have inappropriately transferred wastewater technology from the highly regulated sector of municipal and industrial wastewater to the unregulated – in terms of wastewater – sector of industrial agriculture. The concern about poison and explosive gasses is not new, and not only in those confinements with the foaming problem. It is simply a consequence of using wastewater technology to raise animals.

            In the wastewater industry, we learned long ago – after workers became ill or died – that we could not put normal workspaces in proximity to areas where fecal waste is decomposing. The constant production of the poison and explosive gasses – hydrogen sulfide, ammonia, and methane – was finally taken into account in designing wastewater facilities and technology that would protect both the workers and the surrounding public. Those protections have been codified in the regulations that control municipal/industrial wastewater technology and design. But industrial agriculture remains exempt.

            There may be many causes for the upswing in foaming problems in confinements. Some potential causes might include: damage to buildings and equipment through the corrosive nature of hydrogen-sulfide, genetically modified crops being fed to animals, different insecticides and herbicides applied to fields as pests and weeds become resistant to chemicals used in the past. Perhaps we will find solutions to somewhat mitigate this new foaming problem. But the bottom line is that as long as you use wastewater technology to store waste in pits below where animals are being raised, you will always have disease and death affecting both people and animals caused by these poisonous and explosive gasses.

            The state Legislature, the Iowa Department of Natural Resources, and corporate industrial agricultural officials steadfastly deny that confinements are a form of wastewater technology. Although seeming illogical, in fact a DNR construction permit requires this type of building, resulting in these problems.

            As a society, we should question what this industrial model of agriculture is doing to us, the animals, and the environment. We have turned most of our hog producers into virtual serfs, with corporations financing and owning the buildings, the pigs, and the feed, and even controlling when the producers market the pigs. Corporations externalize their environmental costs onto the producers and the public by having the producers own the polluting waste and the dead animals. We also expect producers to deal with the unsolvable problems confinement buildings create.

            Confinement technology used to raise animals is a failed model on many levels. It is time to put animals back on the land.

Bob Watson

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register version tile line op-ed.doc

Tile Line/Constructed Wetlands Op-Ed (1-10)

            Last November, the Water Resources Coordinating Council (WRCC) submitted flood plain management policy recommendations and funding options to Governor Culver and state legislators. The recommendations are intended to help the state rebuild safer, stronger and smarter in the wake of the historic 2008 floods.

            House File 756, passed by the legislature in 2009, required the WRCC to submit policy and funding recommendations that promote “a watershed management approach to reduce the adverse impact of future flooding on this state’s residents, businesses, communities, and soil and water quality.”

            One proposal from the Iowa Department of Agriculture and Land Stewardship (IDALS) is counter intuitive and scientifically questionable.  IDALS proposes to further enhance artificial drainage of Iowa farmland. The proposal has morphed between an implementation plan and a feasibility study. The plan appears to be moving rapidly from concept to expensive experiment, in spite of serious questions raised by scientists and knowledgeable water resource professionals. What has been called the “Iowa Plan” redesigns and enlarges existing drainage systems and directs water flow to constructed wetlands. These wetlands may reduce nutrient loads delivered to Iowa lakes and streams. Restoring Iowa’s wetlands sounds appealing because this could benefit the hydrology and water quality that has been disturbed by – ironically – artificial drainage. The arguments supporting accelerated drainage are the same that resulted in the elimination of Iowa’s wetland ecosystem in the first place – increased agricultural production. Producers and commodity consumers tout the benefits of expanded production efficiency, but what about those of us who want to use the streams and lakes destined to receive more water, nutrients and pollution from accelerated drainage? If increased production efficiency resulted in the cultivation of less land, then this is a noble objective. History shows, however, that this has not been the case in Iowa.

            The downstream consequences of accelerated drainage need to be carefully examined beyond the proposed token wetland band-aid. There are several things we know for certain: “improved” artificial drainage in Iowa has increased stream flow in quantity and duration over the last 100+ years; artificial drainage flushes nitrogen and phosphorus from soil into lakes and streams, impairing those waters for drinking, recreation, and aquatic life; wetlands have the potential to reduce stream flow and nutrient loads. What we don’t know: how much will stream flow and nutrient levels increase if drainage is further enhanced?; what will be the effect of constructed wetlands on downstream flows and nutrient loads?; and are producers willing to designate enough acreage to a constructed wetland such that it can function effectively? Furthermore, there is the risk that these constructed wetlands, which will be receiving enormous nutrient loads, will have deleterious effects on downstream water quality. 

            Under current Iowa law, producers can construct drainage systems for their land using their own funds. If the negative environmental effects of accelerated drainage are only balanced out by a wetland system, how will the taxpayers of Iowa and the U.S. benefit by subsidizing this activity? Will the water leaving these drainage systems be required to meet some quality and quantity objectives? Discussion of these questions and a discussion of further modifying Iowa’s hydrology at taxpayer expense need to be addressed. A specific, scientifically sound project plan needs to be developed and reviewed. This will best be accomplished by assembling some of the best Iowa scientists familiar with the issues. A transparent planning and funding process should lead to evaluating competitive ideas rather than the process of directing taxpayer funds to a limited number IDALS’ friends. Such a review is generally required for competitive research funding and Iowa should expect no less before embarking on a potentially expensive adventure in further (mis)managing its water resources.

            If we learned nothing more from the Floods of ’08, let’s remember that accelerated drainage creates significant risks for downstream property owners and communities. We hope IDALS will propose changes in land practices that result in less flow and less nutrient pollution to the waters of the state of Iowa, rather than more.

William Stowe, Assistant City Manager–Public Works Director, City of Des Moines, IA <wgstowe@dmgov.org>

Michael Burkart, Hydrologist, Ames, IA 

Bob Watson

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nw sch bd.doc

North Winn School Board meeting Monday Oct 18th.

1. All CAFO’s produce similar gasses and particulate matter which result in health problems for neighbors.

2. Merchant and Kline studies. MRSA studies.

3. These studies and some German studies have led the EPA to conduct their own studies over the next two years; according to Peter Thorne who is the head of the U of I Health research school. You might ask him how you could be considered to take part in that EPA study.

4. HVAC information.

5. Who might help you if you wish to pursue mitigating this issue:

            Public Health Dept both county and state,

            EPA, (has already taken over eight feedlots in Iowa)

            OSHA, (I wonder who they would enforce against since the employer and employee are both affected in this case)

            EPC/DNR.

Contact me if you have any questions or would like my help.

Bob Watson

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an-rotary chamber talk.doc

Sinkholes and hog confinements in karst topography.  (a talk)  2-27-05

            We live in a state where even though we know it is immoral to poison your neighbor, it is not illegal.

Geologic within Ecologic Argument (11-22-04)

The specific geologic argument:

            Sinkholes, a major feature of karst topography, besides appearing out of the blue, are a direct conduit to underground streams, rivers, springs and aquifers (which are our public source of clean drinking water).  Think of sinkholes as enablers of environmental disaster if there were a hog confinement pollution event close by.  Now, imagine our utter disbelief at finding out what the Iowa Legislature has done to the minimum separation distance laws in karst topography between hog confinements and sinkholes.

            Whether through stupidity or sheer malice the Legislature has trumped the original separation distances thusly:

        -“earthen structures” for manure storage at hog confinements (CAFO’s) are not allowed in karst topography because of sinkholes, so you must use an underground concrete pit beneath the building for manure storage.

        -if your confinement site is too close to a sinkhole in karst (minimum separation distance-1000 feet), you simply can’t build it.

        -unless(!) you put an “earthen structure” above the ground next to your building, and then you can build right next to a sinkhole in karst topography.

            Huh?  The absurdities are:

            -an “earthen structure” not allowed in karst because of sinkholes, can be used in karst to build right next to a sinkhole if you are too close to that sinkhole.

            -an above ground berm will contain any spills from an underground tank.

            Much to the consternation of DNR upper level management, when apprised of this situation and upon deciding to enforce the original separation distances, their lawyers told them that because of the way HF 2494 (or 2493) was written, they could not enforce those separation distances.  The lawyers said the DNR would lose any suit brought by an operator denied the berm option.  Effectively there are no longer any separation distances between hog confinements and sinkholes in karst topography.  THE MOST SENSITIVE GEOLOGIC AREA OF IOWA IS NOW THE LEAST PROTECTED FROM POLLUTION CAUSED BY UNTREATED MANURE SPILLED OR LEAKING FROM HOG CONFINEMENTS.  Make no mistake, there is no biological remediation available in aquifers if there is a pollution event, and OUR PUBLIC WATER IS AT RISK. 

            It gets even worse when the berm option is actually played out in construction.  The law for calculating how big an earthen berm (secondary containment) needs to be around a confinement building is:

            “65.15(17)  Secondary containment barriers for manure storage structures.

Secondary containment barriers used to qualify any operation for the exemption provision in subrule 65.12(5) {the minimum separation distances-author} shall meet the following:

            a.  A secondary containment barrier shall consist of a structure surrounding or downslope of a manure storage structure that is designed to contain 120 percent of the volume of manure stored above the manure storage structure’s final grade.  If the containment barrier does not surround the manure storage structure, upland drainage must be diverted.”

            By law, the berm must contain 120% capacity of an above grade (above ground) storage structure.  Somehow in karst, not only have we lost minimum separation distance to sinkholes, but the berm calculation is based on above ground storage, which is not allowed in karst, and 120% has become 50%.  If you carry out the calculation, because there is no above grade storage to multiply out, the answer always turns out to be zero. Again, this is a clearly absurd situation.

            What really happens is even more bizarre and Orwellian.  The concept of “secondary containment” originally comes from the EPA’s regulation of the petroleum industry.  As originally understood, secondary containment meant ‘an earthen berm completely surrounding a set of tanks, large enough to contain 150% of the contents of the largest tank’.  That is what anyone historically associated with secondary containment will tell you it means.  Somehow when this was translated to hog confinements in karst, secondary containment now means a pit dug on one side of a building.  How this above ground pit is supposed to contain a spill from an underground tank is unknown.  How any spill is supposed to happen on only that one side of the building is unknown.  And, how something illegal in karst for manure storage because of sinkholes, namely an earthen structure, allows you to build right next to a sinkhole in karst is unknown.

            Am I being Chicken Little crying that the sky is going to fall?  No.  If we know what has happened when we build waste storage in karst topography when no sinkholes are apparent (show pictures), then why would we be so stupid as to risk ruining our public water by sighting waste storage right next to a known sinkhole?

The general ecologic argument:

            Recognizing the larger ecological problem being that we have adopted industrial technologies for agricultural use, it is a shame that petro-chemical/industrial agriculture is portrayed by corporate entities and some politicians as nothing more that what farming has always been.  Any defense of industrial agriculture, based on the notion that this is how agriculture has always operated in the past, is rendered moot because industrial processes, new to agriculture and never intended for use outside of strict regulation, have only recently been adopted for use in the unregulated area of agriculture.  In today’s confinements, versus farms of 50 years ago, we see diseases and deaths to both animals and humans because we are no longer dealing with manure spread to fertilize the soil, but are instead dealing with the poison gases hydrogen-sulfide and ammonia which are constantly generated from untreated fecal waste both in the confinement and in the storage pit or lagoon.  We have people working in a hazardous workplace ignorant of the dangers because agriculture has been, by law, exempted from the regulations which would educate and protect them.  People in the neighborhoods of confinements are in a similar situation as they are repeatedly told this is only a nuisance and do not have the protections from these poisons afforded all other citizens where similar circumstances exist.

            I call your attention to the most recent studies on asthma in children where it was found that a shocking 55.8% of children living on a farm with a hog confinement had asthma.  And, to the recent measurements of ammonia haze in Iowa, where explanations of the sources of that ammonia conveniently left out the over 10,000 CAFO’s and open feedlots which constantly (24/7) spew ammonia into the atmosphere.  In pig-human equivalency only (without counting chickens, turkeys or cattle), it is like having 36 million Iowans shit in open trenches with no treatment required.  The ammonia haze in Iowa is truly a ‘haze of shit’.

            There are hundreds of studies that have been done on the effects of hog confinements on people and animals over the last 45 years.  Ironically, because some studies to set human limits for gases were done on pigs, we know that animals are susceptible to the same diseases from confinements as people.  There may be an argument by some about the “good science” of those studies, but there can be no argument about the government’s own studies culling hospital records, pre- and post-confinement introduction into a community, which show clearly a tripling of those illnesses generally associated with exposure to hydrogen-sulfide and ammonia.  These are a direct result of the constant venting of those poison gasses into the neighborhood and the contamination of the sources of water.  Add to that, records which show human mortality from hydrogen-sulfide poisoning four times higher in Iowa in agriculture than in the wastewater industry, and a need for public health protection from confinements becomes obvious.

            In logic, there is an argument: if a=b and b=c, then a=c.  If hog confinements and sewer pipes both are closed structures, if they both have untreated fecal waste in them, if that waste constantly generates the poison gases hydrogen-sulfide and ammonia, if the causes of diseases and deaths from those gasses are the same, if you need constant ventilation to survive in either a confinement or a sewer pipe, then confinements and sewer pipes are the same.  People are essentially eating pork raised in a sewer, and neighbors of confinements are living next to an unregulated poison producing technology.

Author’s note:

            The above gives you the specific argument with regard to the Bluffton South confinement site.  This is the site which is next to the 125 year old St. Bridget’s Catholic Church, and which was originally denied because it was too close to a sinkhole.  This specific geological argument also has general applications.  All of karst will be like this.

            In addition to St Bridget’s and its cemetery being downslope and downwind of this confinement, there are further watershed issues.  The subsurface tiles, that drain the land to the east of the confinement site, surface and run into a creek on a neighbor’s land.  The confinement’s surrounding fields surface drainage also runs into that creek.  That creek is joined by another creek which has its beginning in Falcon Spring, reputed to be one of the most pristine springs left in Iowa.  That spring’s watershed, because of the 380 acres being used to apply manure from this confinement, will also be impacted.  Those creeks end up in the Upper Iowa River.

            The three general argument paragraphs lay out the larger general ecological argument that “it is not just farming as usual that people are dealing with, but with the transference of industrial technology (specifically in the case of CAFO’s wastewater technology), unregulated into agriculture.”  That argument can be found in greater detail if you go to www.oneota.net/~watsoncampaign and click on chapter 6, public writings agriculture.  This is an important argument in that it gives a structure to understand generally all the particular community problems when a confinement moves into the neighborhood.  It becomes not an argument about farming, but about industrial processes and their resultant poisons and how the community is affected by them.

            With the above Iowa law and the resultant absurd conditions they create, let me welcome you to the world of CAFO’s in karst topography.  It would be nice once in awhile if the DNR would make people sue them in order to win the right to pollute, instead of private citizens having to sue to try to stop pollution, or after a pollution event has already occurred.  It would be even better if the DNR would admit the absurdities brought about by the berm option being applied in karst, and just enforce the original separation distances.  Actually, because of the dangers posed, the DNR and the Iowa Legislature should simply outlaw any CAFO’s in karst topography.

            In every sector of America where fecal waste, constantly generating the poison gasses hydrogen-sulfide and ammonia, exists in a closed structure the federal “Confined Spaces Regulations” are the controlling laws, except in agriculture.  It is my contention and belief that if the federal “Confined Spaces Regulations” were applied to CAFO’s, as they should be, then, because of the conditions inside the confinement building, CAFO’s would not be allowed to be used in agriculture.  And, the environmental problems that CAFO’s now cause would cease to exist.  There are existing technologies available to raise chickens, turkeys, pigs and cattle besides CAFO’s and open feedlots; and wider use of those technologies would clean up our environment and coincidentally put many more farmers back on the land.  To make that happen is simply a matter of seeing the problems and solutions clearly, and political will.

Bob Watson

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world pork op-ed.doc

            At the World Pork Expo I was intrigued, but not surprised, to be answering questions from hog confinement operators that had to do with wastewater anaerobic digestion problems. This is intriguing because the State Legislature, the DNR, and pork industry officials do not recognize or admit that confinements are wastewater technology; that confinements need to be built to wastewater treatment specifications; or that confinement operators need to have a wastewater education. They don’t admit that confinements should be covered by wastewater regulations so that the operators and neighbors of these confinements will be educated and protected from these structures’ inherent poisons.

            The anaerobic digestion problems described to me included foam containing hydrogen-sulfide, ammonia and methane bubbling up through the slatted floor from the waste pit, resulting in dead pigs and flash fires. This was happening to multiple confinements regardless of builder, corporate ownership, or feed content.

            I contacted a wastewater operator, described the problems, and asked if he could suggest ways to alleviate those issues. He said yes. After receiving certain test results, he could balance out the waste in the pit to mitigate those issues. But, because these buildings were not built to accommodate anaerobic digestion, his solutions could not be implemented. The waste in the pit needed to be mixed in order to balance it out. This was impossible because mixing would cause even more hydrogen-sulfide, ammonia and methane to bubble out and be pulled up through the slatted floor by the exhaust fans into the level containing the pigs and on out into the neighborhood. So, because we have steadfastly denied that these structures are wastewater structures and because the DNR specifically details how they are to be built, operators have no way to deal with the problems caused by poorly operating anaerobic digestion; the end result being dead pigs and flash fires.

            If you call the Iowa Department of Agriculture and ask them if they regulate confinements they will tell you they don’t regulate any animal agriculture in Iowa. If you then call the Iowa DNR and ask them if they regulate confinements they will tell you yes they do, but that is somewhat of a misnomer. The DNR requires a Manure Management Plan from confinement operators but this only describes how they plan to spread the waste. The DNR also requires a Construction Permit which specifies how a confinement is to be built. But these specifications give rise to the problems mentioned above and do not result in a structure which allows anaerobic digestion problems to be resolved.

            The DNR will defend themselves at this point by stating that these facilities are designed for storage of waste only and not for treatment. But the DNR cannot suspend the laws of nature. Decomposition of this waste, generating poison and flammable gasses, will happen in these confinements just as it does in an anaerobic digester. Treatment problems in these confinements will be the same treatment problems found in the wastewater industry. This puts operators, pigs and neighbors in constant threat from poison gasses inside and outside the confinement.

            If you ask a wastewater engineer if he could design a workshop or office complex on top of an anaerobic digester at a wastewater plant complete with an open slatted floor above the digester with fans pulling up all of the poison gasses through the floor into the workshop or office and then out into the neighborhood, that engineer will tell you no. There are federal regulations, NFPA 820, which cite ventilation requirements to protect against fire and explosions which would not allow that to happen. Further, there are public health and safety liability constraints on the engineer which would not allow that to happen. And, there are the ‘OSHA Regulations’ which proscribe how long, under what conditions, and with what safety equipment and training people can be in a space containing those poison gasses. But that is exactly the structure proscribed to be built by the DNR in the case of hog confinements. And that is the exact structure which results in the problems brought to me by operators at the World Pork Expo. The DNR’s proscribed confinement structure endangers operators, pigs and neighbors; and does not allow for effective treatment strategies when gasses get out of hand. Because it is not regulated as a wastewater structure, the operators have no required education which would allow them to deal with these problems even if the buildings were designed correctly.

            We need to begin to call a spade a spade. We need the DNR to stop specifying structures which will inherently cause disease, death, polluted neighborhoods and waste filled streams and rivers from poorly or completely untreated waste spread on fields.

            As a society, we should question what this industrial model of agriculture is doing to us, the animals, and the environment. We have turned most of our hog producers into virtual serfs through corporations financing and owning the buildings, the pigs, the feed, and even telling the producers when to market the pigs. Corporations externalize their environmental costs onto the farmers and the public by having the farmers own the polluting waste and the dead animals. We also expect producers to be wastewater operators even though they are saddled with wrongly designed buildings and no education as to how to deal with the inherent treatment problems these buildings engender.

            This is a starkly different reality from the World Pork Expo corporate spin trumpeting an environmentally friendly industry full of happy and successful producers.

Bob Watson

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b-register updated op-ed 12-09 dnr anti deg comments.doc

Anti-degradation Regulations (1-10 Register Op-Ed)

            Iowa has a double standard about sewage.

            The state’s inconsistent rules for waste from cities and industries, compared with the regulations that apply to industrial agriculture, are jeopardizing our water quality and punishing the citizens of our communities.

            State laws and agency regulations require municipal and industrial wastewater treatment plants to collect and treat their sewage, and to obtain permits to discharge effluent from their treatment facilities. We know who these “point source” polluters are, and we strive to keep them in check.

            Industrial livestock confinements also produce sewage, but these operations have escaped the point source restrictions because they have been defined as “agriculture.” With today’s industrial scale, however, these confinements are no different than cities or industries in terms of the amount and kind of waste produced. Although confinement waste is produced by agricultural animals, it is not what most people would describe as “manure.” Confinement animal waste sits in a pit, tank or lagoon and “cooks” for several months, turning into a toxic sewage. That confinement waste generates hydrogen-sulfide and ammonia – poison sewer gasses that are constantly vented into the air that neighbors must breathe. Confinements also produce and discharge methane, which is a toxic greenhouse gas that contributes to global warming.

            Cities and industries must collect and treat their waste before discharging it. In contrast, industrial confinements only collect and store their waste, but then are allowed to dispose of it on farm fields without treating it. That untreated sewage often enters our rivers, streams, tile lines and groundwater.

            In recent years Iowa has adopted stricter discharge permits for point source municipal/industrial wastewater facilities. The DNR is now considering further restrictions on point source dischargers: so-called anti-degradation regulations. With the adoption of anti-degradation rules, today’s permits would be a baseline and no increase in discharge limits would be allowed in the future. It is an attempt to keep the waters of the state from degrading any further due to increased pollution from dischargers. Yet the State has no documentation to show there would be a significant decrease in the ongoing degradation of Iowa waters if anti-degradation rules are adopted for point source dischargers.

            To meet this new municipal/industrial anti-degradation regulation, the DNR is suggesting alternatives to discharging treated liquid effluent to a stream or river. One alternative would be applying the treated liquid effluent onto the land. The DNR has strict rules for land applying treated effluent from municipal and industrial systems, which makes land application more expensive than discharging their treated effluent into a stream. Small communities, with a high proportion of senior citizens and young people, would especially feel the financial pinch.

            Contrast this proposed extra regulation and more expense for municipal/industrial waste with what happens to the completely untreated waste from an industrial livestock confinement. The pig to people equivalent amount of waste from confined pigs in this state would be like having 30 million Iowans spreading their “untreated” waste directly on Iowa’s farmland. Remember, the manure from a confinement sits for months in a pit, tank or lagoon, where it becomes a toxic brew that spews poisons into the air. Eventually, both the liquids and solids from the untreated confinement waste – which is more polluting than raw human sewage – are simply spread on cropland. The waste can seep into the state’s 880,000 miles of field tiles or run into adjacent streams, then quickly enter our rivers. Worse yet, it can enter groundwater through sinkholes or losing streams. Because many of the microorganisms in the soil have been lost to erosion and heavy application of chemical pesticides and fertilizers, there is only minimal biological breakdown of the waste. Likewise, the antibiotics and hormones commonly used by industrial livestock producers can enter our water without treatment.

            If state officials hope to stop the degradation of Iowa’s waters, it does not make sense to ignore the agricultural component, which accounts for at least 90% of our water pollution. To be sure, it’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while continuing to allow industrial agriculture to spread untreated sewage onto the land?

            It’s time to require the agricultural community to pay its share of the clean-up. If livestock producers wish to use industrial confinements, which produce sewage instead of manure, we should apply the same standards to the wastewater from those confinement operations as we do to municipal/industrial wastewater treatment facilities. We should require them to build a treatment facility, just as we impose that requirement on Iowa communities. If producers of livestock “sewage” don’t want this regulation, they should adopt sustainable models of agriculture that return manure to the land as fertilizer, rather than convert it to a toxic waste.

            Whatever the source, untreated “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same strict environmental rules. Until this happens, it is pointless to impose any further regulations – including these anti-degradation regulations – on point source dischargers.

.

Bob Watson                                 

Larry Stone

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i-city council request.doc

Request for Rural/Urban Cooperation

To: City Council.

Re: Request for Rural/Urban Cooperation.

Dear Council,

            My name is Bob Watson. Because I would like a written response from the Council to the request I am making today, this request will be in written form. After reading it to you, I will give it to you.

            We hear much about rural and urban Iowans working together to solve problems that we have in Iowa. It is in that spirit of cooperation that I am here today. Many times it is necessary to experience something to actually understand it. I am going to ask that you and your children share with rural Iowan’s and their children an ongoing rural experience. Hopefully, once you share that experience, we can work together in resolving this issue.  

            I will briefly describe the experience and its’ effects on rural people and their children. I will then talk about what technology is in operation in your city which would allow you to share this experience. I will mention how you can easily modify that technology so that you can share the experience. And, finally, I will formally ask you to share in that experience.

            Among many confinement studies over the last 30 years, a study in Utah simply looked at hospital records pre- and post-confinement introduction into a community. Those records show clearly a tripling of illnesses generally associated with exposure to hydrogen-sulfide and ammonia.  These illnesses are a direct result of the constant venting by those confinements of the poison gasses hydrogen-sulfide and ammonia into the neighborhoods around those confinements, and the contamination of the neighborhoods’ sources of drinking water by those confinements.

            A study concerning proximity of confinements to rural schools in Iowa and the incidence of asthma among those schools students was conducted by the University of Iowa’s Dr. Joel Kline http://www.chestjournal.org/cgi/content/full/129/6/1486 . The overall rate of physician-diagnosed asthma in Iowa is about 6.7%. Two rural schools were in the study. One school had no confinement closer than 10 miles, and the other, a NE Iowa school, was ½ mile from a confinement. In the school which was 10 miles away from a confinement, 11.7% of the students were found to have asthma, double the Iowa rate. In the school which was only a ½ mile from a confinement, 24.6% of the students were found to have asthma, four times the Iowa rate.  

            In a recent study by James Merchant of the University of Iowa on asthma in children who live on a farm with a confinement http://www.ehponline.org/members/2004/7240/7240.pdf , it was found that after all other factors were accounted for, a shocking 55.8% of those children had asthma as a direct result of living on that farm with that confinement, nine times the Iowa rate for asthma. This study also found that antibiotics from the confinements are particularized and blown into the air along with the poison gases. We are constantly breathing not only poison gases from confinements but also antibiotics.

            These are astounding rates of asthma, 11.7%-24.6%-55.8%, and increases of other illnesses for people, especially children, in rural Iowa who are in proximity to confinements.

            All international, national and state health regulatory agencies, World Health Organization – Environmental Protection Agency – Occupational Health and Safety Agency to name some, know that hydrogen-sulfide and ammonia are dangerous to people. There is no argument about that danger; the science is settled on this issue. We see the dangerous results of exposure to those gasses in the rates of asthma and other illnesses in people in the rural areas of Iowa.

            Now, how is it that you and your children have the capability to share in this experience? What technology exists in a city which constantly creates the poison gasses hydrogen-sulfide and ammonia? The answer is – your sewers.

            How do we know confinements and sewers are the same technology? Confinements and sewers both are closed structures. They both have untreated fecal waste in them. That waste constantly generates the poison gases hydrogen-sulfide and ammonia in both confinements and sewers. People and animals need constant ventilation to survive in either a confinement or a sewer. The diseases and causes of deaths from those gasses are the same in sewers and confinements. That is how we know confinements and sewers are the same technology.

            There are two major management differences. City sewers are designed to contain their poison gasses while confinements, having literally turned sewers on their head, are designed to constantly blow those poison gasses out into the surrounding neighborhood. Think of confinements as upside down sewers that exhaust their poisons, which people in the neighborhood then have to breathe, so that the pigs or chickens inside can stay alive. The second major difference is that your sewers are regulated by law.

            So, how can you modify your sewers so that you and your children can share in the experience of having poison sewer gasses in your neighborhoods? And, this is my formal request of you today: Take the manhole covers off your sewers, put blowers down in those sewers and blow the poison sewer gasses out into your neighborhoods. After experiencing those poison sewer gasses and their health effects, hopefully, in the spirit of rural/urban cooperation, you will then want to work with your rural neighbors to resolve this issue.

            Because part of what I am doing is documenting who can and cannot have these gasses in their neighborhoods, if you think sewer gasses in your neighborhoods might not be a good idea, or, if you think there might be some law, or other reasons, prohibiting you from blowing poison gasses into your neighborhoods, I would ask that you include what those reasons might be in your written response to my request. There are professionals employed by this city who work with these poisons on a daily basis. Your Wastewater Superintendent, Collection System Supervisor, or whoever keeps you in OSHA compliance, could tell you why my request should or shouldn’t be granted.

            Thank you very much for your time and for considering my request that you and your children share in the continuing rural experience of breathing poison sewer gasses. (I will answer any questions you may have.)

Bob Watson

—————————————————————————————————————

watershed approach to floods.doc

Outline for the “Watershed Approach to Floods”.

            Today I would like to have a conversation with you about floods. How much damage you have incurred so far from them. What you as cities can do to protect yourselves from flooding now and in the future. And, how much it may cost you for new flood control systems.

            We will also discuss changes to the watershed and agricultural cropping systems which would end floods as we know them and would cost cities no money what-so-ever. We will discuss presettlement vegetation cover before we turned the landscape upside down and put the soil on the top, what rain infiltration amounts that historic and recent vegetation permitted, and systems today which mimic that presettlement vegetation as far as rain infiltration rates. We will also discuss what those cropping systems use would mean for cleaning up water, and ending our contribution to the Dead Zone in the Gulf of Mexico.

            We will briefly discuss an end to toxic and greenhouse gasses contributed by industrial agriculture, an end to antibiotic resistant diseases, and an end to untreated confinement and feedlot waste washing into our streams and rivers. Along with bacteria from this waste, the other non-point pollution contributors to our water quality problems are nitrogen, phosphorus and sediment (soil). As long as we are corn and bean, and confinement and feedlot farmers, we will continue to have this non-point pollution and surface runoff contributing to flooding and water quality. Change the federal farm programs and you will affect quantity and quality of water in the state.

            We will discuss manufacturing and processing which would need to be done locally from new cropping systems and crops being raised in Iowa. And, we will touch on the thousands of new products from these new crops. We will discuss humans becoming healthier by not eating processed corn and soybeans and an end to obesity, heart disease, and type II diabetes which have exploded since we changed to a diet of processed foods.

            We will talk about the need to modernize our transportation system because of new crops and more people living in rural areas. This includes roads and rail.

            We will talk about what city dwellers can do to help make these changes. What it will cost you in political capital instead of in dollars, and how you as cities can change the watershed cropping systems to protect yourselves from flooding in the future.

            Surprisingly, the floods of ’08 have provided an opportunity to test Wendell Berry’s axiom that “the problem of agriculture is an urban problem”; by that I take it he meant ignorance of what our agricultural system has become. This can be tested by saying to Cedar Rapids, Des Moines and other flood damaged cities that you can prevent floods by changing cropping practices in agriculture instead of spending billions (CR) and millions (DSM) on flood control infrastructure. We are corn and bean farmers, because that is what the federal programs pay for. A change in those programs will lead to changes in the hydrology of the state.

            This outline shows the means to stop flood damage to towns and cities; clean up our water, soil, and air; provide more jobs in farming and manufacturing; get people eating healthy; and, save towns and cities money otherwise spent on flood control projects.

1. Flood Control for Cities:

            A. Cities wouldn’t need to spend billions of dollars on levees and pumping systems with a watershed approach to control flooding in place.

                        (1) Cedar Rapids $1 Billion dollar project.

                        (2) Des Moines $250 Million dollar project.

2. Discussion of vegetation covers and their relation to water flow:

Land Management Options                            Infiltration Rates (in./hr.)

Pasture and Row Crops                                              1 – 3

Rotational Grazing, Alfalfas                                       3 – 7

Un-Pastured Native Grasses                                       7 – 13

Mature Trees                                                               10 – 14

3. Land Practices:

            From the Jackson/Keeney chapter “Perennial Farming Systems That Resist Flooding” in the Connie Mutel edited 2010 book, “A Watershed Year: Anatomy of the Iowa Floods of 2008” we have the following discussion:

            “To prevent rains from flowing rapidly into channels and raising water levels, some of their moisture must be returned directly to the atmosphere or discharged steadily and slowly into drainage ways. Agriculture can help achieve these ends and thus make the land more flood-resilient if it can:

            1. Minimize runoff by increasing the speed at which water soaks into the soil and the quantity of water the soil can hold.

            2. Store an abundance of water in healthy soils that are high in organic matter, instead of immediately draining it into streams.

            3. Increase the amount of time that growing crops are pumping water back into the atmosphere.

            4. Intercept any runoff from intense rainfall, passing it into nearby wetlands or through buffer strips that protect streams.

            The truth is, the corn and soybeans that now dominate Iowa’s agriculture [92% of planted acres are row crops. Only 50% in the 1950’s.] It would be difficult to find two crops that do a worse job of handling Iowa’s rainfall. In conjunction, these croplands pollute our waterways by their release of sediment, fertilizers, and pesticides. [The fourth non-point pollutant, non-soil bacteria, comes mainly from the untreated waste from feedlots and confinements; Watson] Scientists studying the problems of surface and groundwater contamination, the Dead Zone in the Gulf of Mexico, and flooding have arrived at the same conclusion: we need to re-perennialize the landscape. Quite literally, we have to rediscover and cultivate our deepest roots.

            Before the coming of European Americans in the mid-1800s, the prairie soils of Iowa were filled with a dense and deep underground network of perennial plant roots. These roots filled the soil year round, not just in July and August. They made the soil more crumbly, porous, and spongy. They shielded it from the destructive power of raindrops. Year in and year out, perennial plant roots added humus to the soil, built pores, and supported a rich community of arthropods, fungi, and bacteria. The perennial sod could absorb tremendous quantities of rain without producing runoff. Perennials active in early spring began using water in April, and the diversity of plant growth ensured that soil water was used through October. Excess water not used by plants steadily percolated into the shallow groundwater and onto wetlands and streams, or it recharged deeper aquifers. Many features made this landscape flood-resistant. It is no wonder that Know (2006) describes the agricultural conversion of prairie and forest in the upper Mississippi River basin as “the most important environmental change that influenced fluvial {river and stream} activity in this region during the last 10,000 years.”

            Agriculture can increase perennial plant cover and contribute to Iowa’s hydro-logical health in a variety of ways. Corn and soybeans could become part of four-to-five year crop rotations that include small grains, hay and pasture; …and by implementing conservation tillage, better options for pest control, intensively managed rotational grazing, and cover crops to protect the soil before the row crops are well established. …we need to critically examine subsurface water (tile) drainage. Farmlands are tiled to dry out the root zone as fast as possible. This has caused more water to flow into our rivers in the spring, instead of lingering in the soils (Schilling and Helmers 2008). Thus, as happened in 2008, rivers are often running full when a really big early summer storm arrives.

            Researchers at Iowa State University are modifying strip-cropping practices (which now alternate row crops with European pasture grasses or legumes, such as alfalfa, in strips along the contour) by using deeper-rooted native prairie strips instead. Preliminary results indicate that prairie strips covering just 10 to 20 percent of the total field area were able to reduce sediment loss by 95 percent. Prairie strips should also be able to draw down soil moisture earlier in the spring and later in the fall. By occasionally moving these strips, better soil structure could be restored throughout a field.

            Taking the use of perennials one step further, they could be incorporated directly into grain production. Farmers in Australia have pioneered a new method to grow their winter grains (oats, wheat, and barley) in the same field with perennial warm-season pasture grasses. And for over 25 years, researchers at The Land Institute in Kansas have worked to develop high-yielding mixtures of perennial grains (Cox et al. 2006). Recently they have made rapid progress by hybridizing wheat, sorghum, and sunflower with their wild perennial relatives. Perennial grains could revolutionize our whole way of doing agriculture, but a great deal more research will be required to develop crops with economic yields. [The time needed for this research and the time it will take to make political changes to the federal farm programs and implementation of this model should coincide. In other words by the time we change the programs, the perennial crops will be ready; Watson.]

            Although cropland runoff can be decreased, some will remain. This should flow into a wetland or buffer strip before reaching a stream. Buffer strips of prairie grasses, shrubs, and trees along streams will trap sediments, improve soil quality, remove some nitrogen and phosphorus and increase water infiltration into the soil. By breaking selected field tiles as they meet the buffer strip, we could further slow the movement of water into streams.

            As flood damages increase, the need for hydrological resilience grows more urgent. A re-perennialized agricultural landscape will still produce food but also will restore community values and ecosystem services that have been lost. This landscape will once again regulate and purify water, sustain soil fertility, replenish the groundwater supply, support wildlife and pollinators, and carry forward the ancient heritage of our native prairies, woodlands, and wetlands. The challenge will be to incorporate these very real ecosystem services into a market that has until now neglected and nearly destroyed them. An agricultural economy modeled on natural perennial systems will shoulder its share of the responsibility for a healthy, resilient landscape.”

            A. Wes Jackson’s Perennial Polycrop System: rain infiltration rates of 7 to 13 inches per hour. 12 to 15 foot deep roots restoring the life of our soils. Replanted only every 6 or 7 years. Native cover cropping system rather than row crop monoculture of corn and beans and needing millions of pounds of fertilizers, pesticides and herbicides annually.

            B. Hemp: http://www.lumes.lu.se/database/alumni/04.05/theses/erin_young.pdf  This discusses the inclusion of hemp in a sustainable model of agriculture. The US is only one of 2 or 3 countries in the world which prohibits the growing of hemp. There are some 4000 products available from hemp. Hemp is the second highest plant in protein content, next to soybeans, and has many of the correct essential oils. It is a cover crop which needs little or no help to grow. Good for rain infiltration.

            C. Hays and Alfalfas: cover crops which can be cropped for years and then turned under for green manure. 3 to 7 inches per hour rain infiltration.

            D. Pastures and Rotational Grazing: provides feed for livestock and holds water during rain events.

            E. Woodlands: provides feed for livestock along with all of the traditional uses. 10 to 14 inches per hour of rain infiltration.

            F. Vegetables and Fruits: provide nutrition lacking in the modern processed food diet.

            G. Small grains such as oats, barley, wheat, etc. Cover type crops for both human and animal consumption.

            H. Prairie strips, constructed wetlands and other soil saving and runoff mitigation efforts: Federal programs could include continuously shifting through the field prairie strips as a necessary part of any row crop system for obvious benefits.

This is some data which shows that if we adopt a land use model more similar to what we had earlier in our history, our flooding will more than likely decrease:

“The Raccoon River at Fleur has crested above flood stage 62 times since 1903 according to the Van Meter record.

 There have been four separate crests above flood stage in 2010. That has happened only three other times: 1973 (5 times), 1983 (4), and 1984 (4).

 By looking at the Van Meter gauge, it is doubted the Raccoon ever left its banks a single time at Fleur from March of 1929 until May of 1944. To look at the most recent 15-year period, the Raccoon has gone out of its banks 16 times since 1995.  It can’t be said for certain that the table below is exactly accurate, but it is pretty close to what has been observed at Fleur:”

DecadesCrests above flood stage
2010-194
2000-097
1990-998
1980-8911
1970-798
1960-697
1950-598
1940-496
1930-390
1920-292
1910-190
1900-091

            I. Phase out:

                        (1) most row crops

                        (2) all confinements and feedlots

                                    a. Would end most pollution of our soil, water, and air

                                                1. Fewer fertilizers, pesticides, herbicides, nitrogen and phosphorus being put into our soil, running into our water, and evaporating into our air.

                                                2. Toxic and poison sewer and greenhouse gasses from confinements and feedlots would no longer be produced and vented into our air. Diseases from proximity to hydrogen-sulfide and ammonia (asthma, etc.) would no longer be a problem in rural areas.

                                                3. Antibiotics, hormones, endocrine disruptors would no longer be put into our soil, water and air from confinement and feedlot waste. Antibiotic resistant diseases would slowly be eliminated.

                                                4. Infectious diseases such as MRSA, and Ebola would no longer be living in confinement herds or in the people who work with those confined animals. Integrons, which are the vehicle for antibiotic resistance being passed from one organism to another, would not be living in conditions ripe for spreading that resistance to germs which infect people.

4. Manufacturing and Processing:

            A. Products from Hemp: see above.

                        (1) Because of bulk, the manufacturing and processing of this crop would need to stay local.

            B. Food preserving and processing:

                        (1) Unlike the highly processed foods essentially made from corn and soybeans, these grains, vegetables, and fruits would preserved and processed locally.

                        (2) Animal processing plants would be smaller and more wide spread with the capability to process unlike animals.

5. Federal Farm Programs:

            A. Subsidy per acre only regardless of use..

                        (1) Subsidy ($) to the farmer who is actually working the land; not to the owner (takes land out of investment category and returns it to working land).  

            B. Rent limited to 100% of actual tax per acre.

            C. Farmers today are corn and bean farmers because those are the programs. Change the programs and you will change how farmers farm.

6. 2nd Clean Water Act:

            A. Regulate non-point source pollution.

7. Repopulate and Revitalize Rural America:

            A. By growing crops that need to be processed and made into products locally, you will need to have a greater population base in rural America. These cropping and animal raising models would need labor and management (farmers) instead of inputs (structures and energy) and would therefore require many more farmers and laborers in rural areas.

            B. This would enhance the larger cities prosperity as regional engines of commerce.

8. Rail and Road Infrastructure:

            A. Because of the bulk of hemp, processing and manufacturing will need to be local and there will be a need to return rail transportation to the rural areas.

            B. Farm to market roads will attain higher use and as a result will be built and maintained with higher use in mind.

Bob Watson

———————————————————————————————————–

actual submitted register updated op-ed 12-09 dnr anti deg comments.doc

Anti-degradation Regulations (1-10 Register Op-Ed)

            Iowa has a double standard about sewage.

            The state’s inconsistent rules for waste from cities and industries, compared with the regulations that apply to industrial agriculture, are jeopardizing our water quality and punishing the citizens of our communities.

            State laws and agency regulations require municipal and industrial wastewater treatment plants to collect and treat their sewage, and to obtain permits to discharge effluent from their treatment facilities. We know who these “point source” polluters are, and we strive to keep them in check.

            Industrial livestock confinements also produce sewage, but these operations have escaped the point source restrictions because they have been defined as “agriculture.” With today’s industrial scale, however, these confinements are no different than cities or industries in terms of the amount and kind of waste produced. Although confinement waste is produced by agricultural animals, it is not what most people would describe as “manure.” Confinement animal waste sits in a pit, tank or lagoon and “cooks” for several months, turning into a toxic sewage. That confinement waste generates hydrogen-sulfide and ammonia – poison sewer gasses that are constantly vented into the air that neighbors must breathe. Confinements also produce and discharge methane, which is a toxic greenhouse gas that contributes to global warming.

            Cities and industries must collect and treat their waste before discharging it. In contrast, industrial confinements only collect and store their waste, but then are allowed to dispose of it on farm fields without treating it. That untreated sewage often enters our rivers, streams, tile lines and groundwater.

            In recent years Iowa has adopted stricter discharge permits for point source municipal/industrial wastewater facilities. The DNR is now considering further restrictions on point source dischargers: so-called anti-degradation regulations. With the adoption of anti-degradation rules, today’s permits would be a baseline and no increase in discharge limits would be allowed in the future. It is an attempt to keep the waters of the state from degrading any further due to increased pollution from dischargers. Yet the State has no documentation to show there would be a significant decrease in the ongoing degradation of Iowa waters if anti-degradation rules are adopted for point source dischargers.

            To meet this new municipal/industrial anti-degradation regulation, the DNR is suggesting alternatives to discharging treated liquid effluent to a stream or river. One alternative would be applying the treated liquid effluent onto the land. The DNR has strict rules for land applying treated effluent from municipal and industrial systems, which makes land application more expensive than discharging their treated effluent into a stream. Small communities, with a high proportion of senior citizens and young people, would especially feel the financial pinch.

            Contrast this proposed extra regulation and more expense for municipal/industrial waste with what happens to the completely untreated waste from an industrial livestock confinement. The pig to people equivalent amount of waste from confined pigs in this state would be like having 30 million Iowans spreading their “untreated” waste directly on Iowa’s farmland. Remember, the manure from a confinement sits for months in a pit, tank or lagoon, where it becomes a toxic brew that spews poisons into the air. Eventually, both the liquids and solids from the untreated confinement waste – which is more polluting than raw human sewage – are simply spread on cropland. The waste can seep into the state’s 880,000 miles of field tiles or run into adjacent streams, then quickly enter our rivers. Worse yet, it can enter groundwater through sinkholes or losing streams. Because many of the microorganisms in the soil have been lost to erosion and heavy application of chemical pesticides and fertilizers, there is only minimal biological breakdown of the waste. Likewise, the antibiotics and hormones commonly used by industrial livestock producers can enter our water without treatment.

            If state officials hope to stop the degradation of Iowa’s waters, it does not make sense to ignore the agricultural component, which accounts for at least 90% of our water pollution. To be sure, it’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while continuing to allow industrial agriculture to spread untreated sewage onto the land?

            It’s time to require the agricultural community to pay its share of the clean-up. If livestock producers wish to use industrial confinements, which produce sewage instead of manure, we should apply the same standards to the wastewater from those confinement operations as we do to municipal/industrial wastewater treatment facilities. We should require them to build a treatment facility, just as we impose that requirement on Iowa communities. If producers of livestock “sewage” don’t want this regulation, they should adopt sustainable models of agriculture that return manure to the land as fertilizer, rather than convert it to a toxic waste.

            Whatever the source, untreated “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same strict environmental rules. Until this happens, it is pointless to impose any further regulations – including these anti-degradation regulations – on point source dischargers.

.

Bob Watson                                 

Larry Stone

———————————————————————————————————–

and kind actual submitted register updated op-ed 12-09 dnr anti deg comments.doc

Anti-degradation Regulations (1-10 Register Op-Ed)

            Iowa has a double standard about sewage.

            The state’s inconsistent rules for waste from cities and industries, compared with the regulations that apply to industrial agriculture, are jeopardizing our water quality and punishing the citizens of our communities.

            State laws and agency regulations require municipal and industrial wastewater treatment plants to collect and treat their sewage, and to obtain permits to discharge effluent from their treatment facilities. We know who these “point source” polluters are, and we strive to keep them in check.

            Industrial livestock confinements also produce sewage, but these operations have escaped the point source restrictions because they have been defined as “agriculture.” With today’s industrial scale, however, these confinements are no different than cities or industries in terms of the amount and kind of waste produced. Although confinement waste is produced by agricultural animals, it is not what most people would describe as “manure.” Confinement animal waste sits in a pit, tank or lagoon and “cooks” for several months, turning into a toxic sewage. That confinement waste generates hydrogen-sulfide and ammonia – poison sewer gasses that are constantly vented into the air that neighbors must breathe. Confinements also produce and discharge methane, which is a toxic greenhouse gas that contributes to global warming.

            Cities and industries must collect and treat their waste before discharging it. In contrast, industrial confinements only collect and store their waste, but then are allowed to dispose of it on farm fields without treating it. That untreated sewage often enters our rivers, streams, tile lines and groundwater.

            In recent years Iowa has adopted stricter discharge permits for point source municipal/industrial wastewater facilities. The DNR is now considering further restrictions on point source dischargers: so-called anti-degradation regulations. With the adoption of anti-degradation rules, today’s permits would be a baseline and no increase in discharge limits would be allowed in the future. It is an attempt to keep the waters of the state from degrading any further due to increased pollution from dischargers. Yet the State has no documentation to show there would be a significant decrease in the ongoing degradation of Iowa waters if anti-degradation rules are adopted for point source dischargers.

            To meet this new municipal/industrial anti-degradation regulation, the DNR is suggesting alternatives to discharging treated liquid effluent to a stream or river. One alternative would be applying the treated liquid effluent onto the land. The DNR has strict rules for land applying treated effluent from municipal and industrial systems, which makes land application more expensive than discharging their treated effluent into a stream. Small communities, with a high proportion of senior citizens and young people, would especially feel the financial pinch.

            Contrast this proposed extra regulation and more expense for municipal/industrial waste with what happens to the completely untreated waste from an industrial livestock confinement. The pig to people equivalent amount of waste from confined pigs in this state would be like having 30 million Iowans spreading their “untreated” waste directly on Iowa’s farmland. Remember, the manure from a confinement sits for months in a pit, tank or lagoon, where it becomes a toxic brew that spews poisons into the air. Eventually, both the liquids and solids from the untreated confinement waste – which is more polluting than raw human sewage – are simply spread on cropland. The waste can seep into the state’s 880,000 miles of field tiles or run into adjacent streams, then quickly enter our rivers. Worse yet, it can enter groundwater through sinkholes or losing streams. Because many of the microorganisms in the soil have been lost to erosion and heavy application of chemical pesticides and fertilizers, there is only minimal biological breakdown of the waste. Likewise, the antibiotics and hormones commonly used by industrial livestock producers can enter our water without treatment.

            If state officials hope to stop the degradation of Iowa’s waters, it does not make sense to ignore the agricultural component, which accounts for at least 90% of our water pollution. To be sure, it’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while continuing to allow industrial agriculture to spread untreated sewage onto the land?

            It’s time to require the agricultural community to pay its share of the clean-up. If livestock producers wish to use industrial confinements, which produce sewage instead of manure, we should apply the same standards to the wastewater from those confinement operations as we do to municipal/industrial wastewater treatment facilities. We should require them to build a treatment facility, just as we impose that requirement on Iowa communities. If producers of livestock “sewage” don’t want this regulation, they should adopt sustainable models of agriculture that return manure to the land as fertilizer, rather than convert it to a toxic waste.

            Whatever the source, untreated “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same strict environmental rules. Until this happens, it is pointless to impose any further regulations – including these anti-degradation regulations – on point source dischargers.

.

Bob Watson                                 

Larry Stone

———————————————————————————————————–

hunter response.doc

Dear Editor, (12-08)

            Unless you confine your information to what the Farm Bureau or other “corporate agriculture apologists” have to say, anyone who pays attention to what subsidized American agriculture has done to indigenous farmers around the world certainly knows Steve Jacobson knew what he was talking about. Guatemala’s historical problems with the US go much further than farmers losing their farms because of the US exporting subsidized corn to their country. It started when the US, through the CIA, overthrew a democratically elected government there in 1954 and hasn’t stopped since.

            Paul Hunter should get a clue from the recent elections. Mouthing talking points will no longer work when discussing our country’s unfortunate effects on other countries in the world. Petro-chemical/industrial agriculture, as a model of agriculture, is not only bad for others around the world but it is also slowly killing our environment and ourselves.

            Some weeks ago I gave information to the County Health Board which talked about a U of Iowa study showing MRSA being found in 70% of confinement pigs and 45% of the workers in those confinements. Whether it was a case of ignorance or confusion, no one at that meeting seems to have thought this might be something to worry about. In 2005 alone MRSA caused nearly 19,000 deaths in the US and more than 94,000 life threatening infections.

            Another recent study done out of Johns Hopkins showed just driving down a highway behind a truck full of confinement chickens being taken to a processing plant resulted in high levels of bacteria, some of which were resistant to antibiotics like MRSA, in the car, in the car’s air, and on items in the car. The U of Iowa MRSA pig study was recently expanded to non-confinement pastured-raised pigs and no MRSA was found in pigs or people on those farms.

            Because of subsidized American grain being dumped in Guatemala, many farmers and farm workers lost their livelihoods and some ended up working at Agri in Postville. It is a good thing for our local environment and our local social service providers that Agri has finally gone under; for good, I hope. Kosher meat industry prices were kept unduly low because Agri scrimped on environmental costs of raising and butchering meat animals, and by hiring illegal immigrants and paying them wages far below what most people could live on. We and our neighborhoods paid a high price for Agri’s low priced meat.

            We continue to pay a high price for using this inherently poisonous petro-chemical/industrial model of agriculture. With the recent rejection of right wing jingoism, there may be a chance of having a conversation filled with good science, fairness and justice, resulting in a cleaner form of agriculture, and a clearer conscience when it comes to dealing with our international neighbors.

Bob Watson

———————————————————————————————————–

updated op-ed 12-09 dnr anti deg comments.doc

            Iowa has a double standard about sewage.

            The state’s inconsistent rules for waste from cities and industries, compared with the regulations that apply to industrial agriculture, are jeopardizing our water quality and punishing the citizens of our communities.

            State laws and agency regulations require municipal and industrial wastewater treatment plants to collect and treat their sewage, and to obtain permits to discharge effluent from their treatment facilities. We know who these “point source” polluters are, and we strive to keep them in check.

            We also know that municipal/industrial wastewater technology and industrial agricultural confinement technology are the same technologies with the same potential pollution problems. We know these technologies are the same by description, by their inherent poison byproducts, and by Iowa Code. Unfortunately, when this technology is used by industrial agriculture, we turn what would have been biologically benign beneficial manure, broken down by soil, sun and microorganisms, into a toxic sewage. To compound the problem, industrial agriculture adopted only the first half of wastewater technology – collection and storage – without adopting the second half – treatment, regulation, protection, and education. Thus, agricultural waste is collected and stored for months without treatment, meanwhile “cooking” and turning into a toxic soup, which constantly generates the poison sewer gasses, hydrogen-sulfide and ammonia; and the greenhouse gas, methane.

           But, as it stands today, if several hundred/thousand hogs, cows, chickens, or turkeys are confined in a building, their excrement, ­amounting to the waste from a small city, is considered to be agricultural and therefore exempt from most regulation. It’s legal to allow that “agricultural” sewage to ferment for months, all the while venting the resulting toxic gasses into the atmosphere. Neighbors breathe those emissions, and scientific studies show that their health often suffers. Eventually, the untreated sewage is spread on the land, where it becomes “non-point pollution” that often enters our rivers, streams, tile lines, and groundwater.

            In recent years Iowa has adopted stricter discharge permits for point source municipal/industrial wastewater facilities. The DNR is now considering further restrictions on point source dischargers: so-called anti-degradation regulations. With the adoption of anti-degradation rules, today’s permits would be a baseline and no increase in discharge limits would be allowed in the future. It is an attempt to keep the waters of the state from degrading any further due to increased pollution from dischargers. Yet the State has no documentation to show there would be a significant decrease in the ongoing degradation of Iowa waters if anti-degradation rules are adopted for point source dischargers.

            To meet this new municipal/industrial anti-degradation regulation, the DNR is suggesting alternatives to discharging treated liquid effluent to a stream or river. One alternative would be applying the treated liquid effluent onto the land. The DNR has strict rules for land applying treated effluent from municipal and industrial systems, which makes land application more expensive than discharging their treated effluent into a stream. Small communities, with a high proportion of senior citizens and young people, would especially feel the financial pinch.

            Contrast this proposed extra regulation and more expense for municipal/industrial waste with what happens to the completely untreated waste from an industrial livestock confinement. The pig to people equivalent amount of waste from confined pigs in this state would be like having 30 million Iowans spreading their “untreated” waste directly on Iowa’s farmland. Remember, the manure from a confinement sits for months in a pit, tank or lagoon, where it becomes a toxic brew that spews poisons into the air. Eventually, both the liquids and solids from the untreated confinement waste – which is more polluting than raw human sewage – are simply spread on cropland. The waste can seep into the state’s 880,000 miles of field tiles or run into adjacent streams, then quickly enter our rivers. Worse yet, it can enter groundwater through sinkholes or losing streams. Because many of the microorganisms in the soil have been lost to erosion and heavy application of chemical pesticides and fertilizers, there is only minimal biological breakdown of the waste. Likewise, the antibiotics and hormones commonly used by industrial livestock producers can enter our water without treatment.

            If state officials hope to stop the degradation of Iowa’s waters, it does not make sense to ignore the agricultural component, which accounts for at least 90% of our water pollution. To be sure, it’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while continuing to allow industrial agriculture to spread untreated sewage onto the land?

            It’s time to require the agricultural community to pay its share of the clean-up. If livestock producers wish to use industrial confinements, which produce sewage instead of manure, we should apply the same standards to the wastewater from those confinement operations as we do to municipal/industrial wastewater treatment facilities. We should require them to build a treatment facility, just as we impose that requirement on Iowa communities. If producers of livestock “sewage” don’t want this regulation, they should adopt sustainable models of agriculture that return manure to the land as fertilizer, rather than convert it to a toxic waste.

            Whatever the source, untreated “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same strict environmental rules. Until this happens, it is pointless to impose any further regulations – including these anti-degradation regulations – on point source dischargers.

.

Bob Watson                                 

Larry Stone

———————————————————————————————————–

z-laws only presentation.doc

Laws only presentation:

Dear Supervisors,

            I am scheduled to meet with you to have a conversation with you about laws and regulations, addressing the interface between industrial poisons and the public, which exist that can help protect neighbors from poisons emanating from confinements. In this email I will list those laws and regulations and at the bottom add an op-ed piece that Larry Stone and I did that puts industrial confinement technology in a larger context. If you are inclined to read further about this, at the bottom of that op-ed piece will be a link to the complete Supervisor’s presentation materials. For this time I would like to limit the conversation to the actual laws that you can use.

            Counties already have the authority to enforce existing state and federal laws, if the counties choose to do so. Any enforcement action would be up to the county attorney, with the direction or concurrence of the board of supervisors. In the larger presentation materials there is an ordinance from Lake County Indiana which the county could use as a template for enforcement action.

1. To protect the public from the poison gasses being constantly discharged into the neighborhoods of confinements, the County could enforce the CERCLA provision of Superfund: Community Right to Know. Under this law, monitoring equipment, per EPA regulations, would need to be installed by the owner at each confinement site’s exhaust vents and the owner would need to contact the EPA each day that the facility discharges more than 100 lbs of ammonia and/or 100 lbs of hydrogen-sulfide into the atmosphere. (This section was changed in the waning days of the Bush administration. It now says a confinement need only send a letter once a year to the EPA stating the confinement is discharging the poison gasses hydrogen-sulfide and ammonia into the neighboring atmosphere. The National Sierra Club has a lawsuit pending to return this section to its original requirements.)

Another section of this law prohibits the pollution of a watershed from pollutants in manure. The Oklahoma Attorney General is already using this law in an action against Tyson. The County could use this section to protect neighbors and the watershed from pollution from manure. See number 3 below (64.3) to see how testing could be done to see whether pollution goes from a confinement property to adjacent properties and/or the larger watershed. 

2. To protect the public from the poison gasses inside and outside confinements, Counties could enforce the federal “Confined Spaces Regulations”. These laws can be enforced by OSHA through their “General Duty Clause”.  This clause comes into effect if a serious hazard is identified.  We know that over 20 Iowans have been killed from poison gasses in confinements, and that many studies show serious health effects to people from the emission of those poison gasses. A recent study from the U. of Iowa shows 55.8% of children on farms with confinements have asthma. These “recognized hazards” trigger OSHA’s “general duty clause” and allow OSHA to regulate these confinements. We are asking the Counties to enforce OSHA’s Confined Spaces Regulations and General Duty Clause. It seems reasonable when all of the wastewater facilities and sewer systems in Iowa are already regulated under these laws.

3. Even though Iowa DNR says they can’t regulate confinements and open feed lots like they do other entities with fecal waste and poison gasses, that statement is not true. Because of a snafu by the State of Iowa when originally applying for EPA’s NPDES Permit program in the 1970’s, Iowa wasn’t enrolled in the program and had to create their own “Permit to Operate” laws, which the EPA accepted as a mirror program. Those rules, Iowa Administrative Code 567.64.3, included not only point source wastewater treatment plants, but also included CAFO’s. Under 64.3(1)h.(2) those CAFO’s cannot be excluded from regulation. Those rules are still on the books and could be used immediately to regulate CAFO’s (by a request to do so of the County to the DNR Director) as wastewater facilities thusly (but not limited to):

a: require monitoring wells around storage lagoons, concrete storage tanks, and fields being used for application.

b. testing requirements of waste for, but not limited to, nitrogen, phosphorus, E. coli, antibiotics, hormones, and other pollutants.

c. set rules for manure storage capacity.

d. set minimums for the depth to groundwater under storage facilities.
 
e. require tests of tile lines and adjacent streams where manure is applied.

f. impose requirements to prevent waste from running off fields.

(64.3 was recently moved to a different section. The rule amendment adopted by the EPC in February amended Section 64.4 to require NPDES permits for CAFOs to discharge pollutants into navigable waters, and refers to provisions of Chapter 65. But Chapter 65 of the rules does not require NPDES permits for confinement feeding operations. The requirement applies only to open feedlots. The Clean Water Act and EPA rules require that the requirement for NPDES permits apply to confinement operations. A Petition has been filed to return the original 64.3 language.)

4. In November of 2008, EPA finalized its new CAFO rule. Under that rule, any CAFO that discharges or proposes to discharge pollutants into waters (this means confinements with manure piled outside and not in a storage facility, and manure being spread on frozen ground) of the United States must have an NPDES permit. This applies to all CAFOs, confinement operations and open feedlots. Counties can enforce this rule. This rule applies to all confinements regardless of size.

            So, these are the laws and rules which exist that the county can use to help protect neighbors of confinements from the inherent poisons coming from using that technology. The op-ed piece below will put this technology perspective in a larger context.

            I look forward to our upcoming conversation about the county’s ability to use these laws.

Bob Watson

2736 Lannon Hill Rd
Decorah, IA 52101
563-382-5848
mob 563-379-4147
bobandlinda@oneota.net

Op-Ed:

            Iowa has a double standard about sewage.

            Inconsistent rules for waste from cities and industries, compared with regulations for industrial agriculture, jeopardize water quality and punish our citizens.

            State laws and regulations require municipal and industrial wastewater plants to collect and treat their sewage, and to obtain permits to discharge effluent. We closely monitor these “point source” polluters.

            Technology used by industrial agriculture creates the same potential problems as municipal/industrial wastewater treatment. Unfortunately, industrial agriculture has adopted only part of the technology – collection and storage – without including treatment and regulated disposal. This industrialization of animal waste converts what would have been beneficial manure, broken down by soil, sun and microorganisms, into toxic sewage. When manure is collected and stored for months without treatment, it becomes a noxious soup, producing the poison gases hydrogen sulfide and ammonia.

            Yet if several hundred/thousand hogs, cattle, chickens, or turkeys are confined, their excrement – amounting to the waste from a small city – is considered to be agricultural and therefore exempt from most regulation. It’s legal to allow that “agricultural” sewage to ferment for months, venting toxic gases into the atmosphere. Neighbors breathe those emissions, and their health often suffers. Eventually, the untreated sewage is spread on the land, where it becomes “non-point pollution” that often enters our rivers, tile lines, and groundwater.

            Iowa sets strict discharge permits for municipal/industrial wastewater facilities, and the DNR is considering further restrictions: so-called anti-degradation regulations. These rules would make today’s permits a baseline, with no increase in discharge allowed. Yet the State has no studies to show that the proposed rules would significantly improve water quality.

            One alternative to meet new municipal/industrial anti-degradation regulations, the DNR suggests, is to apply treated wastewater onto the land, instead of discharging it to a stream. But current DNR rules for municipal/ industrial systems make that option more expensive than discharging into a stream.

            Contrast this proposed extra regulation and expense for treated municipal/industrial waste with what happens to the untreated, air polluting, waste from industrial livestock confinements. Both the liquids and solids from confinement waste which is more polluting than raw human sewage are simply spread on cropland. The waste can seep into Iowa’s 880,000 miles of field tiles, run into streams, and enter groundwater through sinkholes or losing streams. Many of the microorganisms in the soil have been lost to erosion and agricultural chemicals, so there is minimal biological breakdown of the waste. Antibiotics and hormones used by industrial livestock producers also can enter our water without treatment.

            If we hope to protect Iowa’s waters, we can not ignore the agricultural component, which accounts for perhaps 90% of water pollution. It’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while industrial agriculture continues to spread untreated sewage onto the land?

            The agricultural community should pay its share of the sewage treatment. Livestock producers who use industrial confinements, which produce sewage instead of manure, should meet the same wastewater standards as cities and other industries. Require them to build a treatment facility, just as we do Iowa communities. If producers of livestock “sewage” can’t accept this regulation, they should adopt sustainable agriculture methods that return manure to the land as fertilizer, rather than convert it to toxic waste.

            Whatever the source, “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage whether cities, or industries, or industrial confinements should follow the same environmental rules.


Bob Watson                                 

Larry Stone

———————————————————————————————————–

op ed final.doc

            Iowa has a double standard about sewage.

            Inconsistent rules for waste from cities and industries, compared with regulations for industrial agriculture, jeopardize water quality and punish our citizens.

            State laws and regulations require municipal and industrial wastewater plants to collect and treat their sewage, and to obtain permits to discharge effluent. We closely monitor these “point source” polluters.

            Technology used by industrial agriculture creates the same potential problems as municipal/industrial wastewater treatment. Unfortunately, industrial agriculture has adopted only part of the technology – collection and storage – without including treatment and regulated disposal. This industrialization of animal waste converts what would have been beneficial manure, broken down by soil, sun and microorganisms, into toxic sewage. When manure is collected and stored for months without treatment, it becomes a noxious soup, producing the poison gases hydrogen sulfide and ammonia.

            Yet if several hundred/thousand hogs, cattle, chickens, or turkeys are confined, their excrement –  ­amounting to the waste from a small city – is considered to be agricultural and therefore exempt from most regulation. It’s legal to allow that “agricultural” sewage to ferment for months, venting toxic gases into the atmosphere. Neighbors breathe those emissions, and their health often suffers. Eventually, the untreated sewage is spread on the land, where it becomes “non-point pollution” that often enters our rivers, tile lines, and groundwater.

            Iowa sets strict discharge permits for municipal/industrial wastewater facilities, and the DNR is considering further restrictions: so-called anti-degradation regulations. These rules would make today’s permits a baseline, with no increase in discharge allowed. Yet the State has no studies to show that the proposed rules would significantly improve water quality.

            One alternative to meet new municipal/industrial anti-degradation regulations, the DNR suggests, is to apply treated wastewater onto the land, instead of discharging it to a stream. But current DNR rules for municipal/ industrial systems make that option more expensive than discharging into a stream.

            Contrast this proposed extra regulation and expense for treated municipal/industrial waste with what happens to the untreated, air polluting, waste from industrial livestock confinements. Both the liquids and solids from confinement waste – which is more polluting than raw human sewage – are simply spread on cropland. The waste can seep into Iowa’s 880,000 miles of field tiles, run into streams, and enter groundwater through sinkholes or losing streams. Many of the microorganisms in the soil have been lost to erosion and agricultural chemicals, so there is minimal biological breakdown of the waste. Antibiotics and hormones used by industrial livestock producers also can enter our water without treatment.

            If we hope to protect Iowa’s waters, we can not ignore the agricultural component, which accounts for perhaps 90% of water pollution. It’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while industrial agriculture continues to spread untreated sewage onto the land?

            The agricultural community should pay its share of the sewage treatment. Livestock producers who use industrial confinements, which produce sewage instead of manure, should meet the same wastewater standards as cities and other industries. Require them to build a treatment facility, just as we do Iowa communities. If producers of livestock “sewage” can’t accept this regulation, they should adopt sustainable agriculture methods that return manure to the land as fertilizer, rather than convert it to toxic waste.

            Whatever the source, “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same environmental rules.

Bob Watson                                 

Larry Stone

———————————————————————————————————–

orignial anti-deg.doc

I want to add the “no auditing of mmp’s”, “confinements as100% dischargers instead of 0%”, and “15 going up to 20 million pigs in the last 5 years to assure us of continued degradation no matter what we do to point source dischargers” to the national op ed.

And we need to decide what is the main point: Is it to argue against the anti-deg rules OR to point out that CAFOs are wastewater treatment plants that should not be allowed to escape regulation because we define them as agriculture?

I’m not sure that it works to try to weave the two together so much.

My thought is to hit the CAFO argument hard, then use that to conclude that the proposed anti-deg rules are missing the point.

*******

            Iowa has a double standard about sewage.

            The state’s inconsistent rules for waste from cities and industries, compared with the regulations that apply to industrial agriculture, are jeopardizing our water quality and punishing the citizens of our communities.

            State laws and agency regulations require municipal and industrial wastewater treatment plants to collect and treat their sewage, and to obtain a permit to discharge effluent from their treatment facilities. We know who these “point source” polluters are, and we strive to keep them in check. We also know that municipal/industrial wastewater technology and agricultural industrial confinement technology are the same technologies. We know this by description, by their inherent poison byproducts, and by Iowa Code.

            But if several hundred/thousand hogs, cattle, chickens, or turkeys are confined in a building, their excrement, ­amounting to the waste from a small city, is considered to be agricultural and therefore exempt from most regulation. It’s legal to allow that “agricultural” sewage to ferment for months, all the while venting the resulting toxic gases (including ammonia and hydrogen sulfide) into the atmosphere. Neighbors breathe those emissions, and their health may suffer. Eventually, the sewage is spread on the land, where it becomes “non-point pollution” that often enters our rivers, streams, tile lines, and groundwater.

            In recent years Iowa has adopted fishable/swimable discharge permits for point source municipal/industrial wastewater facilities. The DNR is now considering further restrictions on point source dischargers with what is called anti-degradation regulations. Simply put this means today’s permits would be a baseline and no increase in discharge limits will be allowed in the future. It is an attempt to keep the waters of the state from degrading any further due to increased pollution from dischargers. An alternative to discharging to a receiving stream or river being proposed for these permit holders is land applying the effluent (liquid portion) from their facilities. Even though this liquid effluent has been treated to at least secondary levels (primary, secondary, tertiary), land applying this effluent has more regulations to be followed and is more expensive than to simply discharge it to the receiving stream. This will result in an extra financial burden to the population of communities in Iowa. This will be exceptionally burdensome for smaller communities which, because of demographics, we know include many fixed income older people and young working class families who call ill afford more financial stresses.

            Contrast this extra regulation and more expense with what happens to the completely untreated waste from industrial confinements. Waste from agricultural industrial confinements is never treated even to the primary level. As stated above, this waste sits for months in a pit, tank or lagoon fermenting a toxic brew spewing poisons into the air of the surrounding neighborhood. Unlike the treated liquid waste from highly regulated wastewater plants, untreated confinement waste, not just the liquid but all of the waste, is simply spread on cropland. Even if this waste is knifed into the soil, because of 880,000 miles of field tiles, because of adjacent streams, and because of sinkholes and losing streams, this untreated waste ends up in our streams and rivers in no time. Because of wind and water erosion, much of the soil we farm today is technically subsoil and what topsoil that is left has been drenched by 60 years of chemical application. The treatment element of soil’s bacterial life is today minimal. Hence the higher level of cost and regulation even for secondarily treated liquid effluent from wastewater facilities being land applied. The soil has no capacity to properly treat this agricultural waste before it reaches the states waters.

            If it is the State’s desire to put together regulation which will stop the degradation of the states waters, not including agricultures 90% contribution to that degradation does not make sense. Disregarding for the moment that the State has no documentation showing the states waters will be even minimally cleaned up if anti-degradation rules are adopted for point source dischargers, why would we impose the huge financial burden on communities to upgrade their systems to meet these limits if we allow agriculture to not only continue applying their untreated waste to the watershed, but to allow them to continue to build more and larger confinements at the same time?

            Agricultural industrial confinements and municipal/industrial wastewater systems are the same technology. Iowa cannot expect to clean up its waters if it concentrates its efforts on the wastewater sector which contributes 10% of the pollution while disregarding the 90% which comes from using the same technology in the agricultural sector of the state. 

            Whatever the source – isn’t it all “sewage?” And doesn’t it all pollute our waters, kill aquatic organisms, affect the health of our citizens, and impact the quality of life?

********

            Our argument is that because the same wastewater technology is being used by both industrial confinement agriculture and municipal/industrial wastewater systems, unless those systems are regulated the same in both sectors we can lower the effluent limits, using anti-degradation rules on the municipal/industrial systems, all we want and yet we will see no statistically significant change to the purity of Iowa’s waters. In effect, we will be constricting the discharge of municipal/industrial systems at a significant cost to those served by those systems, understanding that that sector accounts for only 10% of the overall pollution going into the waters of the state. We are then saying to industrial agriculture, which accounts for 90% of pollution going to the waters of the state, go ahead and continue to pollute and continue to build new systems. Because we know that the demographics show a high number of fixed income older people and young working class families living in the small towns most likely impacted by this anti-degradation rule, we are putting a financial burden on those least able to stand that burden all the while knowing that there will be no change to the good in the purity of the water even if this anti-degradation regulation is adopted. What is the story here?

            We know that industrial confinements and wastewater systems are the same technology by description, by inherent poison byproducts and by Iowa Code. There are differences though. Wastewater systems ultimately treat their waste to at least secondary levels (primary, secondary, tertiary). Confinements not only do not treat their waste but that waste cooks for months in a pit, lagoon or tank, turning into a toxic soup constantly off-gassing the poisons hydrogen-sulfide and ammonia into the surrounding neighborhood.

            The preliminary wording for the anti-degradation rules says that because municipal/industrial dischargers will not be allowed to expand or add anymore pollution to the stream they will have to land apply the additional flow or pump it to a different watershed. The anti-deg wording goes on to say that these can be more expensive and sometimes cost prohibitive options.

            In fact, looking at the “Iowa Wastewater Facilities Design Standards”, Chapter 21: Land Application of Wastewater, we can see that even though this effluent is treated to secondary levels there are more regulations pertaining to land application than if this effluent was simply discharged into a receiving stream. And, because the extra processes needed to land apply this treated waste incur greater cost to the systems operation, that option is not one that is generally adopted.

            Contrast this municipal/industrial regulatory environment with what is happening to the waste put out by industrial confinements. We are saying to the municipal/industrial dischargers you must do all of this to land apply your treated waste, which you have to do because though anti-degradation rules we are going to clean up Iowa’s waters; meanwhile we are saying to industrial confinement operators, using the same wastewater technology and with untreated cooked waste, land apply all the untreated waste you have in the same watershed as the municipal/industrial plants are in. And, in fact, build as many of these industrial confinements in this same watershed as you want. What? How do we expect to ever clean up the waters of the state if we restrict treated waste from being land applied and yet at the same time have ever greater amounts of untreated cooked waste being applied in the same watershed?

            The state has no testing documentation that can be given to these municipal/industrial dischargers that show that if they adhere to these new proposed anti-degradation rules, the waters of the state will be statistically significantly purer because of it. In fact, the documentation that does exist, both formal and anecdotal, show that in many or most cases, because of the background pollution of the receiving waters of the state, in many cases the cleanest place in these receiving waters is that part just below the effluent discharge pipe.

            The state has yet to produce a program showing the testing of waste effluent from industrial confinements on the tile lines and adjacent streams from fields where waste from confinements has been spread. With the ever expanding 880,000 miles of tile lines under the farm fields of the state of Iowa and the thousands of miles of adjacent streams and rivers, with, because of the summer’s floods, the ever increasing number of sink holes and losing streams going directly into our groundwater, we know where the background pollution of our states waters comes from.

            With one hand we have the state promulgating new stricter and more expensive anti-degradation regulations with no testing documentation showing that there would be any difference in the waters of the state; and with the other hand telling those in the agricultural sector who use the same technology but don’t even treat their waste, just go ahead and dump all this you want on the land and, by the way, keep building as many of these pollution factories as you want.

            Unless and until we include the agricultural sector in our anti-degradation rule making, we will never begin to clean up any of the waters of the state in any statistically significant way.

*******

Synopsis: The DNR is proposing anti-deg rules which would limit NPDES permit holders being able to expand their discharges. Kind of a baseline discharge that they can’t go beyond. At the same time the DNR is allowing building multiple (as many as anyone wants) confinements in the same watershed as the anti-deg rules would apply to.

            This is ridiculous. We know that confinement and wastewater technologies are the same technologies. We know that wastewater treats its waste before discharging the effluent. We know that confinements don’t treat any of their waste. In fact, that waste is allowed to cook for months continuously creating the poison sewer gasses, hydrogen-sulfide and ammonia, which are constantly blown into the surrounding neighborhood. We know that if you want to land apply wastewaters’ treated effluent, the State has made that process more expensive and regulated than just discharging that effluent to a receiving stream or river. We know that the confinements’ untreated total waste is simply put on ground. We know that that waste makes it to and through tile lines and adjacent streams into those same receiving streams or into the aquifer via losing streams and sinkholes (because of the flood of ’08, many more sinkholes have opened up and losing streams are losing even more flow, the Yellow River is dry in stretches now because of this).

            So we have the State proposing new anti-deg rules which will cost towns (because of demographics, many towns are now made up of fixed income elderly and young poor working class families who don’t have money for this) money they don’t have. We know that this higher quality discharge will not make a statistically significant difference in the quality of Iowa’s waters because we are not including agricultures contribution to the pollution going into the waters. We know that 90% of the pollution in the waters is from agriculture.

            We know that the State has no testing documentation that says adopting anti-deg rules will clean up the waters in any statistically significant way. We know from background testing (Friest) and from anecdotal evidence that the cleanest part of receiving streams and rivers is just below the wastewater plant effluent discharge pipes.

            So what we have is the State wanting to implement rules which will cost lots of money to people who don’t have it; while leaving out the sector (ag) which accounts for 90% of the pollution. The justification for this seems to be that because we can regulate point source dischargers, we will even though the consensus is that it will make no difference to the overall quality of the waters of the state.

TMDL and Anti-degradation op-ed piece:

            We would like to discuss what effect, if any, the TMDL and anti-degradation regulations being put forth for adoption by the DNR for point source dischargers will have on the overall purity of Iowa’s waters. It is our thesis that because agriculture is not included in the TMDL and anti-degradation proposals there will be no statistically significant difference in Iowa’s water quality even if these proposed regulations for point source dischargers are adopted.

            Our perspective will be guided by our understanding that agricultural confinement technology and wastewater technology are the same technologies. That becomes obvious in three ways: by description, by the inherent poisonous by-products, and through Iowa Code 64.3.

By description: Confinements and sewers are both closed spaces. Both have untreated fecal waste in them. That untreated waste constantly produces the poison gasses hydrogen-sulfide and ammonia. The diseases and causes of death from those gasses are the same in sewers and confinements. Confinements must ventilate the poison gasses; otherwise all people and animals inside would die. Sewers are regulated to protect both workers and the public, while confinements, with the same industrial pollutants and poisons, are not regulated in the same ways, thereby subjecting workers and the public to those industrial poisons.

By inherent poisonous byproducts: The poison gasses hydrogen-sulfide and ammonia are constantly created by this untreated fecal soup. A difference between wastewater technology and confinements is that sewers are designed to keep those poison gasses in, and confinements, literally turning sewers on their head, are designed to constantly blow those poison gasses into the surrounding neighborhoods. Wastewater technology as part of its process treats its waste; while confinement technology has no treatment as part of its process. Confinements store waste while allowing that waste to “cook” for months.

Iowa Code Chapter 64.3: 567-64.3(455B) Permit to operate.

64.3 (1) Except as provided otherwise in this subrule and in 567-Chapter 65 , no person shall operate any wastewater disposal system or part thereof without, or contrary to any condition of, an operation permit issued by the directorAn operation permit is not required for the following: ….

h. Water pollution from agricultural and silvicultural activities, runoff from orchards, cultivated crops, pastures, rangelands, and forestlands, except that this exclusion shall not apply to the following: ….

(2) Discharges from concentrated animal feeding operations as defined in 40 CFR §122.23 (eff. 12-18-84);

All confinements, regardless of size, use the same technology, are inherently poisonous, and constantly pollute the immediate neighborhood and the larger environment. Size distinctions are arbitrary and meaningless from this perspective.

            The State has put forth no testing documentation that if these TMDL and anti-degradation rules are adopted for point source dischargers that there would be an increase to the quality of Iowa’s waters. In fact, there is no documentation that this would be the case. There is though ample documentation and anecdotal information that right now the cleanest part of receiving streams and rivers is that portion of the river directly downstream of the effluent discharge pipes.

Bob Watson

———————————————————————————————————–

national op ed final.doc

            Iowa and the nation have a double standard about sewage.

            Inconsistent rules for waste from cities and industries, compared with regulations for industrial agriculture, jeopardize water quality and punish our citizens.

            State laws and regulations require municipal and industrial wastewater plants to collect and treat their sewage, and to obtain permits to discharge effluent. We closely monitor these “point source” polluters.

            Technology used by industrial agriculture creates the same potential problems as municipal/industrial wastewater treatment. Unfortunately, industrial agriculture has adopted only part of the technology – collection and storage – without including treatment and regulated disposal. This industrialization of animal waste converts what would have been beneficial manure, broken down by soil, sun and microorganisms, into toxic sewage. When manure is collected and stored for months without treatment, it becomes a noxious soup, producing the poison gases hydrogen sulfide and ammonia.

            Yet if several hundred/thousand hogs, cattle, chickens, or turkeys are confined, their excrement –  ­amounting to the waste from a small city – is considered to be agricultural and therefore exempt from most regulation. It’s legal to allow that “agricultural” sewage to ferment for months, venting toxic gases into the atmosphere. Neighbors breathe those emissions, and their health often suffers. Eventually, the untreated sewage is spread on the land, where it becomes “non-point pollution” that often enters our rivers, tile lines, and groundwater.

            Iowa and other states set strict discharge permits for municipal/industrial wastewater facilities, and the Iowa DNR is considering further restrictions: so-called anti-degradation regulations. These rules would make today’s permits a baseline, with no increase in discharge allowed. Yet the State has no studies to show that the proposed rules would significantly improve water quality.

            One alternative to meet new municipal/industrial anti-degradation regulations, the Iowa DNR suggests, is to apply treated wastewater onto the land, instead of discharging it to a stream. But current Iowa DNR rules for municipal/ industrial systems make that option more expensive than discharging into a stream.

            Contrast this proposed extra regulation and expense for treated municipal/industrial waste with what happens to the untreated, air polluting, waste from industrial livestock confinements. Both the liquids and solids from confinement waste – which is more polluting than raw human sewage – are simply spread on cropland. The waste can seep into Iowa’s 880,000 miles of field tiles, run into streams, and enter groundwater through sinkholes or losing streams. Many of the microorganisms in the soil have been lost to erosion and agricultural chemicals, so there is minimal biological breakdown of the waste. Antibiotics and hormones used by industrial livestock producers also can enter our water without treatment.

            If we hope to protect Iowa’s and the nation’s waters, we can not ignore the agricultural component, which accounts for perhaps 90% of water pollution in agricultural states such as Iowa. It’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while industrial agriculture continues to spread untreated sewage onto the land?

            The agricultural community should pay its share of the sewage treatment. Livestock producers who use industrial confinements, which produce sewage instead of manure, should meet the same wastewater standards as cities and other industries. Require them to build a treatment facility, just as we do communities. If producers of livestock “sewage” can’t accept this regulation, they should adopt sustainable agriculture methods that return manure to the land as fertilizer, rather than convert it to toxic waste.

            Whatever the source, “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same environmental rules.

Bob Watson                                 

Larry Stone

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b-overview and explanation.doc

            This is an overview of what the County Supervisor Boards in Iowa could do. Northeast Iowa has the added worry of karst, but most of this will apply to the whole state.

            What Supervisors could do:

1. It is the County Supervisors’ right, even when a confinement has enough matrix points and even when the DNR grants a permit, to protest that permit in front of the Environmental Protection Commission. Supervisors simply tell the Commission the reasons they feel a particular confinement, which may pass all the present legal requirements, isn’t a good idea and ask the Commission to deny the permit using the Commission’s power under the Agency Discretionary Rules.

2. In 2002, SF 2293 repealed the section in 455B which had, in part, to do with separation distance between confinements and sinkholes. A new provision for “secondary containment structures” allowed building confinements within the original 1000 foot minimum distance away from sinkholes. That new language is found in 459. The Supervisors could ask that the new language be repealed. By repealing that new language, the original separation distance would again be law and no confinements could be built within 1000’ of a sinkhole.

3. We know there is a cumulative negative effect on the air and water and human health in Iowa because of all the new confinements, the expansion of existing confinements, and new ethanol plants. The County Supervisors and the County Boards of Health in all the Iowa counties therefore should ask the State for a moratorium on any further confinement or ethanol plant building, or expansion, until a federal Environmental Impact Statement, or a similar State of Iowa study, is completed. If nothing is done, this leaves the rural areas of Iowa having an environmental experiment carried out on them with no control being exerted or allowed. This environmental experiment should require an EIS or State of Iowa equivalent.

4. Even though Iowa DNR says they can’t regulate confinements and open feed lots like they do other entities with fecal waste and poison gasses, that statement is not true. Because of a snafu by the State of Iowa when originally applying for EPA’s NPDES Permit program in the 1970’s, Iowa wasn’t enrolled in the program and had to create their own “Permit to Operate” laws, which the EPA accepted as a mirror program. Those rules, Iowa Administrative Code 567.64.3, included not only point source wastewater treatment plants, but also included CAFO’s. Under 64.3(1)h.(2) those CAFO’s cannot be excluded from regulation. Those rules are still on the books and could be used immediately to regulate CAFO’s (by a request to do so of the County to the DNR Director) as wastewater facilities thusly (but not limited to):

a: require monitoring wells around storage lagoons, concrete storage tanks, and fields being used for application.

b. testing requirements of waste for, but not limited to, nitrogen, phosphorus, E. coli, antibiotics, hormones, and other pollutants.

c. set rules for manure storage capacity.

d. set minimums for the depth to groundwater under storage facilities.

e. require tests of tile lines and adjacent streams where manure is applied.

f. impose requirements to prevent waste from running off fields.

            (Iowa Code 2003: Section 455E.5 Groundwater protection policies. #3 All persons in the state have the right to have their lawful use of groundwater unimpaired by the activities of any person which render the water unsafe or unpotable. #4 All persons in the state have the duty to conduct their activities so as to prevent the release of contaminants into groundwater.)

            Counties have the authority to enforce existing state and federal laws which address the interface between industrial poisons and the public, if the counties choose to do so. Any enforcement action would be up to the county attorney, with the direction or concurrence of the board of supervisors. Items 5 and 6 are some of the laws which could be enforced by the county.

            Iowa counties do not need to adopt an ordinance in order to enforce these laws. But, we have included the Lake County Ordinance (pdf file in this appendix) to show counties how enforcement and funding has been accomplished elsewhere.

5. To protect the public from the poison gasses being constantly discharged into the neighborhoods of confinements, the County could enforce the CERCLA provision of Superfund: Community Right to Know. Under this law, monitoring equipment, per EPA regulations, would need to be installed by the owner at each confinement site’s exhaust vents and the owner would need to contact the EPA each day that the facility discharges more than 100 lbs of ammonia and/or 100 lbs of hydrogen-sulfide into the atmosphere.

Another section of this law prohibits the pollution of a watershed from pollutants in manure. The Oklahoma Attorney General is already using this law in an action against Tyson. The County could use this section to protect neighbors and the watershed from pollution from manure. See number 6 below (64.3) to see how testing could be done to see whether pollution goes from a confinement property to adjacent properties and/or the larger watershed.  

6. To protect the public from the poison gasses inside and outside confinements, Counties could enforce the federal “Confined Spaces Regulations”. These laws can be enforced by OSHA through their “General Duty Clause”.  This clause comes into effect if a serious hazard is identified.  We know that over 20 Iowans have been killed from poison gasses in confinements, and that many studies show serious health effects to people from the emission of those poison gasses. A recent study from the U. of Iowa shows 55.8% of children on farms with confinements have asthma. These “recognized hazards” trigger OSHA’s “general duty clause” and allow OSHA to regulate these confinements. We are asking the Counties to enforce OSHA’s Confined Spaces Regulations and General Duty Clause. It seems reasonable when all of the wastewater facilities and sewer systems in Iowa are already regulated under these laws.

            In this package, we also include documents about:

1. “Air problems from ethanol” gives you the information from the Iowa DNR on what pollutants to expect from ethanol plants.

2. “Rural Schools, Confinements and Poison Gasses” tells about poison gasses and their effects on the rural population from confinements which already exist, and what rural schools need to do in order for their students to have air free from poison gasses inside their schools.

3. “Urban Partners” is a version of a request to get cities to share in what rural people must live with when poison sewer gasses are constantly blown into their neighborhoods by confinements.

4. “Loss of separation distance and public safety” tells how the law was changed to eliminate the separation distance between confinements and sinkholes. This change has allowed confinements to be built in karst where they otherwise would not have been allowed.

5. “ias6 – Stressing Iowa’s Environment” and the jpeg pictures is a discussion of the whole problem of confinements from the perspective of wastewater technology being transferred from the regulated environment where it matured to the unregulated environment of agriculture.

6. We also include medical studies done on the health of Iowa’s rural population taking into account their proximity to confinements. Also included is an industrial agriculture primer, an explanation of an EIS, and three documents about chapter Iowa Administrative Code 567.64.3.

            This information only reinforces the need for action on your part to safeguard the health of your constituents and the environment.

Bob Watson                                                   

Larry Stone

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op ed magazine.doc

            Iowa has a double standard about sewage.

            The state’s inconsistent rules for waste from cities and industries, compared with the regulations that apply to industrial agriculture, are jeopardizing our water quality and punishing the citizens of our communities.

            State laws and agency regulations require municipal and industrial wastewater treatment plants to collect and treat their sewage, and to obtain permits to discharge effluent from their treatment facilities. We know who these “point source” polluters are, and we strive to keep them in check.

            We also know that municipal/industrial wastewater technology and industrial agricultural confinement technology are the same technologies with the same potential pollution problems. Unfortunately, when this technology is used by industrial agriculture, we turn what would have been biologically benign beneficial manure, broken down by soil, sun and microorganisms, into a toxic sewage. To compound the problem, industrial agriculture adopted only the first half of wastewater technology – collection and storage – without adopting the second half – treatment, regulation, protection, and education. Thus, agricultural waste is collected and stored for months without treatment, meanwhile “cooking” and turning into a toxic soup, which constantly generates the poison sewer gasses hydrogen-sulfide and ammonia.

            But, as it stands today, if several hundred/thousand hogs, cattle, chickens, or turkeys are confined in a building, their excrement, ­amounting to the waste from a small city, is considered to be agricultural and therefore exempt from most regulation. It’s legal to allow that “agricultural” sewage to ferment for months, all the while venting the resulting toxic gases into the atmosphere. Neighbors breathe those emissions, and scientific studies show that their health often suffers. Eventually, the untreated sewage is spread on the land, where it becomes “non-point pollution” that often enters our rivers, streams, tile lines, and groundwater.

            In recent years Iowa has adopted stricter discharge permits for point source municipal/industrial wastewater facilities. The DNR is now considering further restrictions on point source dischargers: so-called anti-degradation regulations. With the adoption of anti-degradation rules, today’s permits would be a baseline and no increase in discharge limits would be allowed in the future. It is an attempt to keep the waters of the state from degrading any further due to increased pollution from dischargers. Yet the State has no documentation to show there would be a significant increase in the purity of Iowa waters if anti-degradation rules are adopted for point source dischargers.

            To meet this new municipal/industrial anti-degradation regulation, the DNR is suggesting alternatives to discharging liquid effluent to a stream or river. One alternative would be applying the treated liquid effluent onto the land. The DNR has strict rules for land applying effluent from municipal and industrial systems, which makes land application more expensive than discharging their effluent into a stream. Small communities, with a high proportion of senior citizens and young people, would especially feel the financial pinch.

            Contrast this proposed extra regulation and more expense for municipal/industrial waste with what happens to the completely untreated waste from an industrial livestock confinement. Remember, the manure from a confinement sits for months in a pit, tank or lagoon, where it becomes a toxic brew that spews poisons into the air. Eventually, both the liquids and solids from the untreated confinement waste – which is more polluting than raw human sewage – is simply spread on cropland. The waste can seep into the state’s 880,000 miles of field tiles or run into adjacent streams, then quickly enter our rivers. Worse yet, it can enter groundwater through sinkholes or losing streams. Because many of the microorganisms in the soil have been lost to erosion and heavy application of chemical pesticides and fertilizers, there is only minimal biological breakdown of the waste. Likewise, the antibiotics and hormones commonly used by industrial livestock producers can enter our water without treatment.

            If state officials hope to stop the degradation of Iowa’s waters, it does not make sense to ignore the component of agriculture, which accounts for perhaps 90% of our water pollution. To be sure, it’s hard to argue against cleaner water. But is it fair to impose a new regulatory and financial burden on cities and urban industries, while continuing to allow industrial agriculture to spread untreated sewage onto the land?

            It’s time to require the agricultural community to pay its share of the clean-up. If livestock producers wish to use industrial confinements, which produce sewage instead of manure, we should apply the same standards to the wastewater from those confinement operations as we do to municipal/industrial wastewater treatment facilities. We should require them to build a treatment facility, just as we impose that requirement on Iowa communities. If producers of livestock “sewage” don’t want this regulation, they should adopt sustainable models of agriculture that return manure to the land as fertilizer, rather than convert it to a toxic waste.

            Whatever the source, “sewage” pollutes our waters, kills aquatic organisms, affects the health of our citizens, and impacts the quality of life. Those who produce sewage – whether cities, or industries, or industrial confinements – should follow the same environmental rules.

Bob Watson

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