Comments from Craig Hill, president of the Iowa Farm Bureau Federation on the Iowa Nutrient Reduction Strategy

1/7/2013 9:22:28 AM
Craig Hill

The Honorable Bill Northey
January 4, 2013
Page 3 - Comments from Craig Hill, president of the Iowa Farm Bureau Federation on the Iowa Nutrient Reduction Strategy

January 4, 2013
The Honorable Bill Northey
Iowa Secretary of Agriculture
Nutrient Reduction Strategy
ANR Program Services
2101 Agronomy Hall
Ames, Iowa 50011-1010

RE: Iowa Draft Nutrient Reduction Strategy Comments

Dear Secretary Northey:

EPA has asked states to establish a strategy to reduce nutrients in surface water. This is because EPA has recognized that restrictive, unachievable numeric water quality standards is not an effective option for further nonpoint and point source reductions.  The Iowa Farm Bureau Federation, the state’s largest general farm organization with more than 153,000 members, agrees with the EPA that a state strategy is best near-term and long-term option. The IFBF supports the draft Iowa Nutrient Strategy and will work with the Iowa Department of Agriculture and other agencies to help implement it by prioritizing resources and programs for effectiveness, and communicating to our members and the public about the strategy so that it can be successful.

The numeric water quality standard approach that results in labeling people, farmers and businesses as “polluters” has real financial consequences.  The current science behind developing more restrictive numeric water quality standards for nutrients in surface water is flawed, and the ability to adjust them as new science is developed is limited. Iowa shouldn’t set arbitrary numbers to address nutrients. Arbitrary numeric standards only lead to more Total Maximum Daily Loads (TMDLs) or restrictive watershed plans that limit economic growth of businesses and communities, like in the Chesapeake Bay, resulting in more pressure on Congress to regulate agriculture through the Clean Water Act, and the opportunity for more activist lawsuits.  These regulatory approaches have not been effective at reducing nutrient impairments, but have merely redefined the definition of pollution and labeled partners as “polluters.”

That’s why a different approach, as described in the draft Iowa Nutrient Strategy, is necessary to address nonpoint sources, including farms.  EPA, as evidenced in its 2011 “Stoner memo,” allowed for this new path forward, and specifically for state-federal partnerships to address nutrients as an alternative approach.  These targeted, focused voluntary water quality efforts have been successful in Iowa when they have been tried.  We believe these successes should be duplicated using the tools we know will work, such as strategically targeted conservation measures.  While the state has supported these efforts to some degree, the state has not put its full efforts in a comprehensive way behind this approach to maximize progress.

IDALS and DNR have now put its full support behind this realistic approach – the Iowa Nutrient Strategy - that will prioritize the top watersheds and focus resources to make improvements in cooperation with landowners, long before numeric standards are necessary.  Iowa State University has developed a comprehensive, peer-reviewed science and technical assessment of the best management practices available to reduce nutrients, their effectiveness and implementation cost. Because IDALS has experience in working with farmers and using their knowledge to gain trust, IDALS is taking the lead in establishing and implementing the nutrient strategy with nonpoint sources. The DNR is working with the point sources to determine the cities and industries that will use new, effective biological nutrient removal treatment processes.

The IFBF supports the strategy and the process used to develop it. It was refreshing to see point sources and nonpoint sources working together with the state agencies to develop it. We appreciate the leadership provided by Iowa Secretary of Agriculture Bill Northey and Iowa DNR Director Chuck Gipp in developing this strategy.

Since the EPA did not dictate how to move forward with the strategy development process, the state reviewed what worked and what didn’t for other states. Clearly, states that had too many advocacy groups at the table right in the beginning became mired down in politics and reached a stalemate without any progress or pathway forward to show for their efforts.  It is unfortunate that some groups, after calling on agriculture to do more, have already made a decision to support the scientifically-challenged numeric criteria approach. The negative, regulatory rhetoric expressed regarding the draft strategy is unfortunate, but not unexpected. It should, however, be rejected by the State of Iowa in establishing its policy on this issue.  The Clean Water Act does not provide the government with regulatory authority over agricultural stormwater for good reason.  Nonpoint source issues, which are heavily influenced by variable weather conditions, are not best resolved with mandating a specific practice on every acre.  The science assessment demonstrates this would be a huge waste of financial resources.  Rather an adaptive management approach that encourages innovation for new methods of addressing problems is what Iowans do best.

The Iowa strategy outlines how the state will make real, additional, meaningful progress with better coordination and synchronization of our current state and federal conservation programs. This is the first ‘real-world’ comprehensive state assessment that will lead to prioritized watersheds and the best use of our limited state and federal resources. The scientific assessment by Iowa State University reinforces that conservation is not a ‘one-size fits all’ approach. To be the effective, and to avoid a Chesapeake Bay situation in Iowa and the Midwest, conservation choices should suit the soil, terrain, crops and the demands for food, energy and fiber. What works on one farm in Northwest Iowa may not be as effective (and could cost more) on a farm in Southeast Iowa, for example. Understanding the differences in conservation methods will help save the state and Iowans money, but most importantly, increase the likelihood of success.

Right now, farmers are using their own funds to match with limited cost-share dollars for conservation. The demand for these funds exceeded funds available by more than $100 million last year, proof that farmers are willing to do more.  But those additional actions need to be guided by this comprehensive nutrient strategy to be as effective as possible.  

Thank you for the opportunity to comment. The IFBF looks forward to working with the Water Resources Coordinating Council, state and federal conservation partners, and other organizations to further develop this dynamic strategy into more detailed implementation plans as new scientific information comes forward in the future.

Craig Hill