New state strategy on Iowa’s most widespread water pollution problem cries out for more accountability, greater citizen input, and stronger solutions

Last month, after a two year effort, an interagency state government team released a 197-page strategy for reducing nitrogen and phosphorous pollution that harms water quality in Iowa and downstream. Here are five key facts you need to know about the document:

1.  The strategy’s approach for addressing agricultural sources of nitrogen and phosphorous pollution (also referred to as non-point source pollution) will fall short of creating significant, sustainable, statewide improvements in Iowa’s waters. The strategy’s approach to engaging farmers is neither substantially different nor better from what is already happening in Iowa.

State officials have proposed replacing Iowa’s current all-voluntary conservation efforts with new “aggressive” all-voluntary conservation efforts.  The strategy does not clearly define how farmers who contribute to Iowa’s nitrogen and phosphorous pollution problem will be held accountable for helping to solve it.  It proposes a range of improvements to current conservation programs, but they are vague and lack timetables and clear goals.

The strategy’s authors emphasize benefits of all-voluntary conservation programs without providing evidence of why these methods, which have fallen short of protecting our waters in the past, will be successful now.

The strategy argues that significant improvements to voluntary conservation programs can be made without any initial increases in state funding—despite noting that existing funds for landowners to implement conservation practices “are often limited and oversubscribed” (p. 19).[i]  The lack of a plan for obtaining additional funding for voluntary conservation efforts with initial costs as high as $1.2 billion to $4 billion (p. 4) raises still more doubts about whether the plan can succeed on a comprehensive, statewide basis.

2. The strategy does not set specific goals for lower nitrogen and phosphorous pollution levels in local lakes and rivers.  These goals are necessary to ensure the strategy solves water pollution problems facing rivers and lakes in Iowa as well as downstream.

The authors of the strategy make clear that Iowa’s nutrient strategy was written to reduce Iowa’s contributions of nitrogen and phosphorous pollution to the Gulf of Mexico by 45%.  However, the strategy fails to list either short-term or long-term goals for water quality improvements for Iowa’s rivers and lakes.

The Environmental Protection Agency’s framework for state nutrient strategies (the “Stoner memo”) calls on states to set numeric goals to limit nitrogen and phosphorous pollution in waterways.  To motivate Iowans to invest in substantial and sustainable improvements in water quality, Iowa needs these goals, which are based on benefits to Iowa waters.  The nutrient strategy evades this responsibility, promising only to “[evaluate] the need for nutrient water quality standards” in the future.

Further, while the strategy describes the challenges of establishing these numeric goals at great length, it does not mention that in 2011, Iowa nearly finished a process to set numeric criteria for recreational lakes which was tabled pending completion of additional research.  Despite the considerable progress Iowa had made when work stopped, the nutrient strategy does not call for resuming this effort now or in the future.

3. The strategy contains useful research about what it will take to clean up Iowa’s waters.

As part of the nutrient strategy, an Iowa State University-led team of researchers examined how successful different practices on agricultural land are at reducing nitrogen and phosphorous pollution. Almost all of their work is on practices already in existence and to some extent followed by a portion of Iowa farmers. Their findings provide important insight on the benefits of greater use of these practices and about how Iowa can focus its limited resources to achieve the best results.  Having this information centralized in one place gives Iowa a good “road map” to make significant progress on nitrogen and phosphorous pollution now.  In addition, continuing research by the team will help make Iowa’s pollution control efforts even more effective over time.

4. The strategy proposes new mandatory standards for how cities treat their wastewater to reduce pollution levels.  However, these improvements will likely not solve Iowa’s larger pollution problem unless they are accompanied by more effective participation by agriculture.

The strategy lays out a plan for reducing the amount of nitrogen and phosphorous released by large municipal and industrial wastewater treatment facilities where it is determined that the additional treatment is technically feasible and affordable.  This new treatment to remove nitrogen and phosphorous would be required, not voluntary, under the Clean Water Act permits that these facilities must currently obtain.  The proposed changes in the strategy could reduce point source nitrogen releases by many wastewater facilities by two thirds and phosphorous releases by three quarters.

At the same time, the strategy recognizes that point source pollution is a much smaller contributor to Iowa’s overall problem than non-point source pollution (Table 1).

Table 1: Sources of nitrogen and phosphorous discharged from Iowa to the Gulf of Mexico
	Wastewater treatment plants and other point sources	Agricultural and other non-point sources
Nitrogen	8%	92%
Phosphorous	20%	80%
Source:  Iowa Nutrient Reduction Strategy, p. 7.

Even if cities add nitrogen and phosphorous treatment to their wastewater plants and raise their customers’ rates to pay for it, the vast majority of the problem will remain unsolved without effective programs and real results on the non-point source/agricultural side.

5. The Iowa Environmental Council is working hard to ensure the voices of Iowans like you who value clean water are heard in this debate.

Most Iowans have not had an adequate opportunity to comment on this strategy, and it appears input has been artificially limited to a select few interest groups.   The Council believes that this plan can only be stronger when all Iowans have the opportunity to contribute to it.

The Iowa Department of Agriculture and Land Stewardship and its partners released the new nutrient strategy with only a short 45 day public comment period.  The Council is preparing comments on additional elements the strategy should include to secure the results for clean water Iowans expect.  In addition, over the next few days, the Council will provide additional guidance to members of the public who wish to submit comments on the strategy via our action alert system.

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[i] According to a Department of Agriculture press release, on December 6, Secretary of Agriculture Northey announced his request that Governor Branstad include $2.4 million in additional funding for agricultural conservation in FY-2014 and $4.4 million in additional funding in FY-2015.  The nutrient strategy (p. 12) identified $15.1 million in state funding for conservation programs the legislature approved for the current fiscal year (FY2013).  Even with the increased funding, the nutrient strategy suggests much more would be needed to achieve its target result of a 45% reduction in pollution reaching the Gulf of Mexico.  According to the strategy, “annual costs” of implementing the strategy “including initial investment and operating cost, range from $77 million per year to $1.2 billion per year” (p. 4).