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What’s in the rule:
- A “health effects” standard
of 30 parts per billion which is weaker than the 15 ppb recommended
in the joint University of Iowa/ Iowa State University CAFO air
quality study.
- Seven “grace days”
annually that factory farms could exceed the standard.
- The standard is a 60-minute average (12
readings taken every five minutes and averaged together has to
exceed 30 ppb before an exceedance could occur)
- Monitoring only at a nearby residence
or other “separated location.”
What’s NOT in the rule:
- A standard for ammonia or odor.
- Any enforcement action.
- Any economic cost for factory farms.
- An “ambient” standard that
would allow the state to monitor anywhere the pollution leaves
the factory farm property. Minnesota, Missouri, Nebraska, and
California all have an ambient air standard.
- A 30 ppb standard averaged over 30 minutes
like that of Minnesota, Missouri, California and Wyoming which
is significantly stronger than Iowa’s 60 min. averaging
period.
What factory farm supporters are
arguing:
Factory
Farm supporter argument #1:
Factory farm supporters argue that the DNR monitors, which are allowed
to be within 100 meters of a neighbor's home, is too far
from the house.
The TRUTH is:
-The DNR has said that 100 meters is as
practical as they can be. This is to allow the DNR room to place
the monitor at a house but keep it away from any obstacles (trees,
bushes, right behind the house) that might block the air flow
and alter the monitoring data.
-In the first draft of their rule, the DNR proposed having monitors
within 300 meters of a house but has since changed this number
to a more restrictive distance of 100 meters. Factory farm supporters
are still opposed to even 100 meters.
Factory
Farm supporter argument #2:
Factory farm supporters argue that the DNR should use the Agency
for Toxic Substances and Disease Registry’s (ATSDR) recommendation
of 30 ppb for an average of up to 364 days rather than the DNR’s
standard of 30 ppb for a one hour average not to be exceeded more
than seven times a year.
The TRUTH is:
-ATSDR position on their recommendation
is “It is important to note that MRLs are not intended to
define clean-up or action levels for ATSDR or other Agencies.”
They also state that “These values are not a regulatory
value and are not intended for use as a 'yes or no' adverse health
impact indicator.”
-ATSDR scientists recent peer-reviewed research (March 2004) has
documented there is an association between increased hospital
visits for respiratory diseases among residents the day after
exceedances of 30 ppb for a 30-min. average were recorded (a level
much lower than ATSDR’s recommendation and the Iowa DNR’s
standard.)
-The ATSDR’s recommendation is
based on one study conducted 21 years ago! on laboratory
mice.
-ATSDR’s top hydrogen sulfide expert
developed a new hydrogen sulfide standard for the World Health
Organization that recommends 14 ppb to prevent health impacts
and five ppb for 30-minute exposure to prevent headaches and nausea.
For more information, contact Iowa Citizens
for Community Improvement at 515-282-0484.
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