United States Environmental
Protection Agency Region 7
2024 Response to Comments for EPA's Partial
Approval/Partial Disapproval of
Iowa's Clean Water Act Section 303(d) List of Water
Quality Limited Segments Still Requiring TMDLs
irrrrny RORIf~l—IAI I P| Digitally signed by JEFFERY ROBICHAUD
JLrrLrvY nUDIL-rlMUU Date: 202412.30 11:59:24 -06'00'
Jeffery Robichaud
Director
Water Division
Date
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Table of Contents
1. Responses to Comments on the EPA's Partial Approval/Partial Disapproval of Iowa's 2024 303(d) List 4
A. Conclusion 4
B. Summary of responses received 5
i. Comments that support adding the seven WQLSs 5
ii. Comments that oppose adding the seven WQLSs 5
iii. General comments 8
2. Appendix A: Original Public Comments Received 10
A. Index 10
B. Public comments 12
3. Appendix B: The EPA-approved Iowa 2024 CWA Section 303(d) List 167
4. Appendix C: Data Exceedances 207
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1. Responses to Comments on the EPA's Partial Approval/Partial Disapproval of
Iowa's 2024 303(d) List
A. Conclusion
On November 13, 2024, through December 19, 2024, the U.S. Environmental Protection Agency Region 7
provided an opportunity for public comment on its decision to add seven Water Quality Limited Segments
(WQLSs) to Iowa's 2024 Clean Water Act (CWA) Section 303(d) list of impaired waters, pursuant to CWA
Section 303(d) and 40 Code of Federal Regulation Section 130.7(d)(2). Regulations implementing CWA Section
303(d) at 40 C.F.R. 130.7(b) and (d)(1) require that states submit, every two (2) years, a list of WQLSs still
requiring Total Maximum Daily Loads (TMDLs) within their boundaries for which effluent limitations required
by CWA Section 301(b)(1)(A) and (B) are not stringent enough to implement any applicable water quality
standard. The EPA must approve or disapprove each list, referred to as a 303(d) list of impaired waters. 33
U.S.C. 1313(d)(2); 40 C.F.R. 130.7(d)(2).
The EPA partially approved Iowa's 2024 303(d) list, approving the state's identification of 705 WQLSs and the
removal of 84 WQLSs. However, the EPA disapproved the exclusion of seven WQLSs that the EPA determined
are not attaining applicable water quality standards due to exceedance of the nitrate as Nitrogen (N) and
nitrate plus nitrite as N criteria, based on the existing and readily available water quality data and
information. The seven WQLSs include sections of the Cedar, Des Moines, Iowa, Raccoon, and South Skunk
rivers (Table 1). The EPA identified these seven WQLSs for inclusion in Iowa's list pursuant to CWA Section
303(d)(2) and 40 C.F.R. 130.7(d)(2) in its decision document issued on November 12, 2024.
Table 1. Water quality limited segments and parameters added to Iowa's 2024 Clean Water Act Section 303(d)
list of impaired waters.
Assessment ID
IA 02-CED-456
IA 04-LDM-1011
IA 04-UDM-1211
IA 02-IOW-628
IA 02-IOW-628
IA 04-RAC-1116
IA 03-SSK-927
The EPA promptly issued public notice on the addition of the identified WQLSs, pursuant to 40 C.F.R.
130.7(d)(2), on November 13, 2024, and received 83 responses during the public comment period occurring
through December 19, 2024 (Appendix A). A summary of the comments received and the EPA's response to
the comments are provided below. The EPA has considered all comments received and hereby affirms its
November 12, 2024, addition of seven WQLSs to Iowa's 2024 303(d) list. The seven WQLSs added to Iowa's
2024 303(d) list by the EPA are identified in Table 1. The complete and final Iowa 2024 303(d) list, including
the added seven WQLSs, is available in Appendix B and is to be included in the state's water quality
management plan. 40 C.F.R. 130.7(d)(2). The rationale for the addition of the seven WQLSs to Iowa's 2024
303(d) list is provided in the EPA's November 12, 2024, decision document for Iowa's 2024 303(d) list.
Assessment Name
Cedar River
Des Moines River
Des Moines River
Iowa River
Iowa River
Raccoon River
South Skunk River
Parameter
Nitrate plus nitrite as N
Nitrate plus nitrite as N
Nitrate plus nitrite as N
Nitrate as N
Nitrate plus nitrite as N
Nitrate plus nitrite as N
Nitrate plus nitrite as N
Data Range
2020-2022
2012-2014
2020-2022
2020-2022
2020-2022
2020-2022
2020-2022
Number or Samples
Exceeding 10 mg/L
4
2
8
13
3
8
2
4
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B. Summary of responses received
Of the comments received, 72 expressed support for the EPA's action adding the WQLSs, three expressed
opposition to the EPA's action adding the WQLSs, and eight provided general comments requesting
information regarding the EPA's action or not specific to the EPA's action adding the WQLSs. All comments can
be found in the Index and Public Comments sections provided in Appendix A.
The EPA thanks the commentors for their time and comments. It is important to note that the EPA only
requested comments regarding the addition of the seven WQLSs in Table 1 during the public comment period.
Public comments and concerns outside of the purview of the seven WQLSs for this public comment period are
acknowledged but not substantively addressed in this response; however, they are noted by the agency and
will be transmitted to relevant parties for consideration.
i. Comments that support adding the seven WQLSs
The EPA received numerous comments that expressed support for the listing of the seven WQLSs. In total, 72
of the 83 comments received expressed support for the EPA's action adding the seven WQLSs. Commentors
that support the listing of the seven WQLSs include residents of Iowa; public water suppliers, including Des
Moines Water Works and Central Iowa Water Works; and environmental and agricultural groups, including
Sierra Club, Southeast Iowa Sierra Club, Iowa Alliance for Responsible Ag, Iowa Environmental Council and
Environmental Law & Policy Center, Prairie Rivers of Iowa, Expert Tree Consulting, Inc., Jefferson County
Farmers & Neighbors, Inc., Technologies of World Peace, and Iowa Citizens for Community Improvement. The
Iowa Citizens for Community Improvement comment included over 500 individual names; however, as this
was submitted as one comment, the EPA treated it as a single comment.
ii. Comments that oppose adding the seven WQLSs
The EPA received three comments that expressed opposition to the listing of the seven WQLSs. Commentors
that oppose the listing of the seven WQLSs include Iowa Farm Bureau Federation (IFBF), Iowa Department of
Natural Resources (Iowa DNR), and The Fertilizer Institute (TFI). The IFBF and TFI refer to comments made by
Iowa DNR, and all three comment letters oppose the listing based on similar concerns. Therefore, the EPA has
considered each of the three comment letters and addresses them below collectively and comprehensively.
The EPA also refers the commentors to its April 2, 2024, public comment to Iowa DNR; November 12, 2024,
decision document; and November 13, 2024, public notice.
The EPA identified the seven specified WQLSs for inclusion in Iowa's 2024 303(d) list based on its evaluation of
existing and readily available data and information, which demonstrates these WQLSs are not attaining Iowa's
EPA-approved water quality standards. The EPA acknowledges that state water quality standards, monitoring
programs, and assessment approaches vary across states with regard to nitrate as N, nitrate plus nitrite as N,
and nitrite as N. Iowa DNR's EPA-approved water quality standards state in Subrule 61.3(3)(c)(2), Specific
water quality criteria, that "all substances toxic or detrimental to humans or detrimental to treatment process
shall be limited to nontoxic or nondetrimental concentrations in the surface water" for streams designated for
drinking water use. Of note, nitrate as N, nitrate plus nitrite as N, and nitrite as N are not removed by
conventional drinking water treatment processes and are thus detrimental to conventional treatment
processes' ability to meet the requirements of the Safe Drinking Water Act without additional treatment when
surface water concentrations exceed the Maximum Contaminant Level (MCL). Iowa DNR's EPA-approved
water quality standards provide numeric criteria in Subrule 61.3(3) Specific water quality criteria, Table 1.
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Criteria for Chemical Constituents, for Class "C" protection for nitrate as N at 10 milligrams per liter (mg/L),
nitrate plus nitrite as N at 10 mg/L, and nitrite as N at 1 mg/L. These criteria were established by using the
EPA's nitrate, nitrate plus nitrite, and nitrite Maximum Contaminant Level Goals.
In identifying the seven specified WQLSs for inclusion in Iowa's 2024 303(d) list, the EPA applied these existing
and EPA-approved water quality standards to assess the WQLSs. The EPA's identification of waters pursuant to
CWA Section 303(d)(2) and 40 C.F.R. 130.7(d)(2) notably did not establish new water quality standards or
impose additional assessment requirements on the state.
As described above, the EPA identified the seven WQLSs by applying these applicable water quality standards
to the existing and readily available water quality information and data, including the data collected and
assembled by Iowa DNR and publicly available data from the Pes Moines Water Works for nitrite. The EPA did
not include data in the November 12, 2024, decision document as the data sources the EPA used to identify
the seven specified WQLSs are the same sources used and summarized by Iowa DNR in its 2024 303(d) list
submission. For all data collected by Iowa DNR, raw data is available through Iowa DNR's AQulA. For external
data assembled and considered by Iowa DNR, the 2024 state submission to the EPA is available to the public
through How's My Waterway under the file named '2024 External Data'. Iowa DNR provides data sources,
summaries, and statistics to the public on its ADBNet for all 303(d) assessments.
While Iowa DNR cited Des Moines Water Works as the data source it used to assess the Des Moines River (IA
04-UDM-1211; sample location number 99990015) and Raccoon River (IA 04-RAC-1116; sample location
number 99990003), it only provided data from Des Moines Water Works for nitrate for these sites in its 2024
303(d) list submission. For its analysis, the EPA also used publicly available nitrite data from the Des Moines
Water Works for these same sites. This data is available through the Des Moines Water Works Water Quality
Data website. The EPA has provided data that indicates exceedances of Iowa DNR's EPA-approved water
quality standards for the identified seven WQLSs in Appendix C of this document. The EPA notes that the
regulatory requirements in 40 C.F.R. 130.7(b) and 130.7(b)(6)(ii) referenced by IFBF as the requirements
applicable to the EPA's decision to add the seven WQLSs to Iowa's 2024 303(d) list generally outline the
regulatory framework for the state's listing submission.
Applying the existing and EPA-approved water quality standards to this data, the EPA determined that the
seven identified WQLSs are not attaining the applicable water quality standards associated with the drinking
water use, as the data reflect exceedances of nitrate as N and nitrate plus nitrite as N criteria for this use. As
noted in Table 1, each of the seven WQLSs included by the EPA in Iowa's 2024 303(d) list demonstrate
multiple nitrate as N and nitrate plus nitrite as N exceedances of Iowa's EPA-approved water quality
standards.
In acting on Iowa's 2024 303(d) list and identifying the seven specified WQLSs for inclusion in this list, the EPA
did not take action to approve or disapprove Iowa's assessment methodology. Rather, the EPA found that the
existing and readily available water quality data demonstrate that the seven specified WQLSs are not attaining
applicable water quality standards, and the state did not provide a technically defensible rationale in its
assessment.
The EPA has routinely, consistently, and clearly indicated the following in its approval of previous Iowa 303(d)
lists:
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'While the guidelines, protocols, and requirements in state statute and the IDNR [Iowa DNR]
listing methodology might be useful tools for the IDNR to use in identifying impaired waters,
they are not part of the EPA approved standards. Hence, the EPA did not rely solely on the
State's statute or the methodology in reviewing Iowa's list. Instead, the EPA reviewed all
available information including any information excluded under the state's methodology, to
determine if the state's list was developed consistent with the state's underlying EPA-approved
water quality standards. The EPA's review process generally followed a two-step analysis:
1. The EPA reviewed the state's listing methodology, including data collection and data
assessment requirements, to determine whether, based on Iowa's EPA-approved water
quality standards, the methodology was a reasonable method for identifying water quality
limited segments; and
2. Where the EPA was unsure whether the methodology was a reasonable method for
identifying water quality limited segments, the Region requested additional information
from the IDNR to conduct further water body and data analysis.1'
In its April 29, 2022, decision document for Iowa's 2022 303(d) list, the EPA specifically shared the listing issue
related to nitrate as N and nitrate plus nitrite as N:
'The EPA had no comments for the changes made to the Iowa DNR's methodology. However, during its
review, the EPA determined the methodology and assessment for nitrate in water bodies designated
with a Class C drinking water use is not consistent with the Iowa DNR's EPA-approved 1/1/QS [Water
Quality Standard]. Despite this discrepancy, the EPA verified that this did not impact the listing or
removal of water bodies from the Iowa DNR's 2022 CWA Section 303(d) List. In order to comply with
their EPA-approved WQS, the Iowa DNR should assess nitrate as a toxic and apply the prescribed
maximum.'
As the EPA explained in its November 12, 2024, decision document, it determined that the state did not use
existing and readily available data to assess all pollutants with toxic effects with reasonable consideration of
the individual pollutant, endpoints, and adverse effects being considered. Pursuant to 40 C.F.R. 130.7(b),
states must provide documentation to support their list determinations in their 303(d) list submission,
including any decision to not use any existing and readily available data and information. Iowa DNR's
application of its 10% binomial exceedance statistical approach does not supply a technically supported
rationale for not identifying the seven specified WQLSs on the 303(d) list when the existing and readily
available data demonstrate exceedances of applicable criteria for nitrate as N and nitrate plus nitrite as N, as
described above. As Iowa DNR's adoption of a 10% binomial exceedance statistical approach appears to be
premised on past EPA guidance relating to conventional pollutants,2 the EPA's discussion of this approach in
comments submitted to Iowa DNR on its draft 303(d) list and in the decision document addressed how the
Iowa DNR's application of such an approach to nitrate as N, nitrite as N, and nitrate plus nitrite as N is not
1 EPA approval of the 2016 (January 16, 2018), 2018 (March 24, 2020), 2020 (May 14, 2021), and 2022 (April 29, 2022) Iowa 303(d)
lists.
2 A complete list of conventional pollutants designated pursuant to CWA section 304(a)(4) includes biochemical oxygen demand,
total suspended solids, pH, fecal coliform, and oil and grease. 40 C.F.R. 401.16. Pollutants not designated otherwise are categorized
as nonconventional pollutants.
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consistent with the EPA's aforementioned guidance.3 However, in noting this, the EPA was not creating
assessment requirements based on EPA guidance. Additionally, by acknowledging the human health toxicity of
nitrate4 to evaluate attainment of Iowa DNR's EPA-approved water quality standards in the decision
document, the EPA was not taking regulatory action classifying nitrate or changing its status under the CWA,
as suggested by the IFBF.
The EPA adhered to all legally applicable requirements in its review of and action on Iowa's 2024 303(d) list
and its addition of seven WQLSs to the list, including promptly providing public notice of the addition of the
seven WQLSs and seeking and considering comment on this addition pursuant to 40 C.F.R. 130.7(d)(2). As the
EPA partially disapproved Iowa's 2024 303(d) list for the exclusion of the seven identified WQLSs that it
determined, based on existing and readily available water quality data and information, are not attaining
applicable water quality standards, it properly identified these waters for inclusion in Iowa's 2024 303(d) list in
accordance with CWA Section 303(d)(2) and 40 C.F.R. 130.7(d)(2). In its action on Iowa's 2024 303(d) list, the
EPA did not disapprove any loadings for these waters, and therefore is not required to establish such loadings
pursuant to CWA Section 303(d)(2) and 40 C.F.R. 130.7(d)(2).
iii. General comments
The EPA received eight general comments during this public notice. Each is addressed individually due to the
varied topics covered. The comments received were from Denise Mathis; Iowa DNR; Iowa Farm Bureau
Federation; Matthew McAndrew; Elaine St. Clair; Zita Cashin; Jaiden Shahan; and Mary Johannsen.
Denise Mathis
Denise Mathis provided a phone call received on November 20, 2024. In the call, the commentor requests that
the EPA review information for the English River Watershed. As this is not one of the seven WQLSs added to
Iowa's 2024 Section 303(d) list, the EPA has no additional comment for this watershed at this time. However,
any additional information provided will be considered during the 2026 submission.
Iowa DNR
Iowa DNR requested that the EPA provide information regarding the data sources, data used, list of violations,
and methodology used. The data sources used by the EPA in its action are the same as those used by Iowa
DNR in its assessment of the waterbodies. The EPA provided a list summarizing violations in its decision
document transmitted to the state and has provided additional information in its response to comments.
Iowa Farm Bureau Federation
The Iowa Farm Bureau Federation requested the EPA to extend the public comment period by 30 days. The
EPA extended the public comment period by six days, re-scheduling the public comment period to end on
December 19, 2024.
Matthew McAndrew
Matthew McAndrew, a resident of Iowa, provides a methodology for nitrate sampling in tile drains and articles
regarding nitrate toxicity. The commentor notes that many nitrates come from agricultural sources and
3 EPA Region 7's 2024 Decision Document for Iowa's Clean Water Act Section 303(d) List of Water Quality Limited Segments Still
Requiring TMDLs, November 12, 2024, and Public Comment for Iowa's Draft 303(d) List Submission, April 2, 2024.
4 40 C.F.R. Parts 141,142, and 143, EPA's National Primary Drinking Water Regulations: Final Rule, 1991.
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nitrates are toxic to humans. The commentor is concerned about the public's exposure to nitrates and the
impact of nitrates in private and public wells. The commentor advocates for source water protection for
drinking water supplies.
Elaine St. Clair
Elaine St. Clair, a resident of Iowa, thanks the EPA for its regulatory enforcement and advocates for the use of
correct data in protecting the health of lowans.
Zita Cashin
Zita Cashin, a resident of Iowa, advocates for clean water in Iowa and acknowledges the EPA's action to
improve the evaluation of waters in Iowa.
Jaiden Shahan
Jaiden Shahan, a resident of Iowa, advocates for stronger EPA enforcement of the Clean Water Act.
Mary Johannsen
Mary Johannsen, a resident of Iowa, urges the EPA to require Iowa DNR to protect its citizens from polluted
waterways.
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2. Appendix A: Original Public Comments Received
A. Index
Comment
Number
Date
Received
Commentor
Affiliation
Page
Number
1
11/15/2024
Shannon Dox
12
2
11/15/2024
Gaylen Wobeter
13
3
11/18/2024
Harvey Sollberger
14
4
11/19/2024
Patrick Bosold
15
5
11/19/2024
Margaret Dwyer
16
6
11/19/2024
Gail Bishop
17
7
11/19/2024
Steven Monk
18
8
11/19/2024
Virginia Severns
19
9
11/19/2024
Sharon Moss
20
10
11/19/2024
Trish Nelson
21
11
11/20/2024
Zack Jones
22
12
11/20/2024
Mia Morarie
23
13
11/20/2024
Billy Hunter
24
14
11/20/2024
Ryan Reynolds
25
15
11/20/2024
Abigail Bohle
26
16
11/20/2024
RogerJohanson
27
17
11/20/2024
Carl Osterhoudt
28
18
11/20/2024
Anne Zepeski
29
19
11/20/2024
John Norwood
30
20
11/20/2024
Maribeth Newman
32
21
11/20/2024
Greg Nepstad
33
22
11/20/2024
Denise Mathis
34
23
11/21/2024
Peggy Eherenman
35
24
11/21/2024
Dhyana Kaufman
36
25
11/21/2024
Ken Krier
Iowa Department of Natural Resources
37
26
11/21/2024
Melanie Tipton
38
27
11/22/2024
Shawn Richmond
Iowa Farm Bureau Federation
39
28
11/22/2024
Gloria Foster
41
29
11/23/2024
Ed Fischer
42
30
12/02/2024
Matthew McAndrew
43
31
12/02/2024
Pamela Mackey Taylor
Sierra Club
44
32
12/03/2024
Mike Tramontina
47
33
12/03/2024
Bridget McNerny
50
34
12/03/2024
Maria LaFrance
51
35
12/03/2024
Robert Riley
52
36
12/05/2024
Anne Walton
Southeast Iowa Sierra Club
53
37
12/07/2024
Ryan Koch
57
38
12/08/2024
Elaine St. Clair
58
39
12/08/2024
Richard Dietz
59
40
12/09/2024
Ned McPartland
61
41
12/09/2024
Chris Lish
62
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Comment
Number
Date
Received
Commentor
Affiliation
Page
Number
42
12
10/2024
Zita Cashin
64
43
12
11/2024
Jaiden Shahan
65
44
12
13/2024
Patrick Bosold
66
45
12
13/2024
David and Jeannie Rose
68
46
12
13/2024
Larry Mueller
70
47
12
13/2024
Melissa Walker/Ted
Corrigan
Des Moines Water Works
72
48
12
13/2024
Ed Brocksmith
76
49
12
13/2024
Robert and Cynthia
Swan son
77
50
12
13/2024
Jan Corderman
Iowa Alliance for Responsible Ag
79
51
12
13/2024
Paula Mohr
82
52
12
13/2024
Lori Lohman
84
53
12
13/2024
Fonziba Koster
85
54
12
13/2024
Roger Leahy
87
55
12
13/2024
Patricia Timmens
89
56
12
13/2024
Michael Schmidt
Iowa Environmental Council and Environmental
Law & Policy Center
91
57
12
13/2024
Mary Johannsen
97
58
12
13/2024
Pamela Karll Slowick
98
59
12
13/2024
Dan Haug
Prairie Rivers of Iowa
100
60
12
13/2024
Steven Paulsrud
102
61
12
13/2024
Murray Foster
104
62
12
14/2024
Diane James
106
63
12
14/2024
Nancy Leahy
108
64
12
14/2024
Susan Johnson and
Frances Burmeister
110
65
12
14/2024
Jennifer Fishback
112
66
12
15/2024
Jim Karpen
113
67
12
15/2024
Bob Koczela
Expert Tree Consulting, Inc.
114
68
12
16/2024
Sheila Gregan
117
69
12
16/2024
Linda Egenes
119
70
12
16/2024
Diane Rosenberg
Jefferson County Farmers & Neighbors, Inc.
120
71
12
16/2024
Richard Sims
124
72
12
17/2024
Camie Walker
126
73
12
17/2024
Moni Hayne
128
74
12
17/2024
Lisa Ashelman
Technologies of World Peace
130
75
12
18/2024
Shawn Richmond
Iowa Farm Bureau Federation
132
76
12
18/2024
Maralyn Schulze
136
77
12
18/2024
Jo Ann Sadler
138
78
12
18/2024
Linda Quinn
139
79
12
19/2024
Tamara Mcintosh
Iowa Department of Natural Resources
140
80
12
19/2024
Caitlin Golle
Iowa Citizens for Community Improvement
143
81
12
19/2024
June Oliver
159
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Comment
Number
82
83
12/19/2024 Reagan Giesenschlag
12/19/2024 Tami Madsen
The Fertilizer Institute
Central Iowa Water Works
Affiliation
Page
Number
161
164
B. Public comments
From:
Shannon Pox
To:
R7-WaterDivision
Subject:
Nitrate watch
Date:
Friday, November 15, 2024 7:32:22 AM
I Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to
open attachments or click on provided links.
greetings! Im a long time resident of des moines and ive been tracking nitrate levels on the des moines river
all summer on the Clean Water Hub website. I support the EPA adding more sections of iowa rivers to the list
of gross rivers, and any mitigation techniques the EPA suggests. Thank you for supporting clean water.
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From:
To:
Subject:
Date:
Gavlen Wobeter
R7-WaterDivision
water quality in Iowa
Friday, November 15, 2024 3:38:36 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
I am a lifelong lowan and I see how our water quality has deteriorated in my lifetime. Thank
you EPA for helping guide Iowa to improvement. I am not a scientist but an educated person,
and I do understand some of the particular challenges Iowa has faced with so much
agriculture that dominates our state. We need clean water for the health of all living things,
including we humans.
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From:
To:
Subject:
Date;
Harvey Sotlberoer
R?-WaterDivision: Harvey SoHbemer
Rivers of Iowa decision by the EPA
Monday, November 18, 21)24 §:54:59 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
To the United States Environmental Protection Agency:
I am writing to indicate my very strong support for the EPA's recent actions regarding the
nitrate threat to be found in Iowa's rivers. The problem, in fact, extends far beyond the five
central Iowa rivers identified by the EPA (the Cedar, Des Moines, Iowa, Racoon, and South
Skunk Rivers). I live in northeast Iowa where manure, fertilizer, and pesticide runoff from
fanners' uncontrolled activities have compromised a number of our beautiful streams and
rivers that ran southeast and feed into the Mississippi River (from north to south those rivers
are: the Upper Iowa, Yellow, Turkey, Volga, Maquoketa, and Wapsipimcon Rivers).
Iowa's rivers are The uuv»t polluted in the country, and as concerns giow regaiding the viability
of our drinking-water supply and the preservation of our rivers' acquatic life Iowa's state
government and its Depart mem of Natural Resources have had their head in the sand for years.
Many citizens care - and despair - over the despoilment of our environment for private gain,
but our state government and DNR have hardly been guardians of our natural resources. As
has been apparent for years, they are in the pocket of monolithic industrial fanning, fertilizer
and meat-packing interests.
Please, please hold the Iowa DNR's feet to the fire and help our state's many citizens and
environmental groups that heretofore have been outgunned by local (and beyond) tnonied
interests that treat our forests, rivers, and soil as if they are their private plantation.
People live here. We live here, and we breathe the air, drink, the water, and want to enjoy and
protect nature's bounty that we have inherited. Not unrelated to the present despoilment is the
fact that the state of Iowa has the highest per capita rate of cancer in the United States. Only
connect the dots and see where they lead .... back. I think, to the need for action 111 protecting
our environment and minimi resoiucev
I'm 86 years old. My grandfather came to Iowa from Europe hi 1892 and was a fanner here his
whole life, supporting himself and his family oil 30 acres of farmland. It's a whole new
ballgame today, and we are losing. Please know that there are many Iowaus who share the
concerns I've raised in this e-mail, and please help us.
Sincerely,
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From: Patrick Bosold
To: R?~WatefDi¥ision
Cc; "MMlfertC
Subject; Public comment on Iowa's 2024 303(d) list - add more rivets to t
Date: Tuesday, November 19, 2024 10:11:20 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links,
>ear EPA Region 7 Watei Division leans.
I support the EPA's proposal to add the Cedar River, Des Moines River, Iowa River, Raccoon
River, and South Skunk River to Iowa's 2024 303(d) list of impaired waters. Iowa's Dept. of
Natural Resources hasn't been doing its job. These rivers have nitrate and nitrite levels that are
hazardous to Iranian health, particularly since waters from these rivers are used for drinking
water. The EPA is right to point this out and require the Iowa DNR to add these rivers to its
impaired waters list.
If the DNR continues to fail in its responsibilities to Iowans under the Clean Water Act, I ask
that the EPA remove Iowa's authority to administer the Clean Water Act,
Thank you.
Patrick Bosold
15
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From: Margaret Dwver
To: R7-WaterDivision
Subject: Water Quality issues
Date: Tuesday, November 19, 2024 10:34:22 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
To whom it may concern:
I support adding the Cedar River, Des Moines River, Iowa River, Raccoon River, and South Skunk River
to Iowa's 2024 303(d) list. It is high time this happened!
Sincerely,
Margaret Dwyer
16
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From:
To:
Subject:
Date:
Bishop. Gail A
R7-WaterDivision
I approve
Tuesday, November 19, 2024 11:09:14 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Please note that I'm writing to you as a private citizen, not in any official capacity as a University
employee. As an Iowa resident, I'm very concerned about Iowa's new status as #2 in the nation for
cancer incidence. While I know multiple factors surely contribute to this, our overall poor water
quality may be one - and it's one we could do something about. I've long been dismayed that in
Iowa compliance with guidelines for agriculture for permitting nitrate and nitrite to enter waterways
is entirely voluntary. This is to my mind flagrant disregard for the health of lowans.
Please do what you can to get our state leaders to act responsibly 11 We urgently need and deserve
better water quality, and the protection of our waterways for future generations.
Gail A. Bishop, PhD
Professor of Microbiology & Immunology
Holden Chair of Cancer Biology
Assoc. Director for Basic Research, Holden Comprehensive Cancer Center
, The University of Iowa
Senior Research Career Scientist, Iowa City VA Medical Center
Iowa City, IA 52242
17
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From:
To:
Subject:
Date:
Monk. Steven G
R7-WaterDivision
comments concerning the decision to add seven water quality-limited segments to Iowa's 2024 303(d) list
Tuesday, November 19, 2024 11:37:39 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
I agree that these segments should be added. I have already given up swimming and fishing in
Iowa waters. I still use these waters (after some treatment) to wash dishes and clothes, to
bathe, and to drink. And I'd rather keep Iowa's rise in cancer rates from rising further.
Thanks, Steve
18
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From: Severns. Virginia G
To: R7-WaterDivision
Subject: EPA"s Decision on Iowa's 2024 List of Water Quality-Limited Segments Requiring a Total Maximum Daily Load
Date: Tuesday, November 19, 2024 11:59:59 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Hello,
Above all else, thank you all for what you do.
As an Iowa resident whose drinking water is affected by this thank you for asking them to add
these waters to their list. Please continue to hold us accountable for improving our water
conditions and making the public aware. I know this requires a lot of work and resources for our
DNR but public safety is a necessity not a luxury. Of course we do not know that this has any
relation to water quality and I am not placing blame anywhere, but I have lost 2 friends under
35 to cancer already and 2 others in the same age bracket have recently had surgery for thyroid
cancer. We should be doing what we can to limit the risk of cancer and other illness for
everyone.
Thank you,
Ginny Severns
Research Associate, BHRL
University of Iowa
19
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From:
To:
Subject:
Date:
Sharon Moss
R7-WaterDivision
Iowa s 2024 303(d) list
Tuesday, November 19, 2024 3:58:21 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
recommend adding the Cedar River, Des Moines River, Iowa River, Raccoon River, and
South Skunk River to Iowa s 2024 303(d) list. I am very concerned about Iowa s high cancer
rates.
Sharon Moss
20
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From:
To:
Subject:
Date:
trish nelson
R7-WaterDivision
Add the 7 segments to Iowa"s 2024 303(d) list
Tuesday, November 19, 2024 8:40:26 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear EPA:
Please add the 7 segments to Iowa's 2024 303(d) list:
• Cedar River for nitrate plus nitrite as N
• Des Moines River - 2 segments - for nitrate plus nitrite as N
• Iowa River - 1 segment for nitrate plus nitrite as N
• Iowa River - 1 segment for nitrite as N
• Raccoon River for nitrate plus nitrite as N
• South Skunk River for nitrate plus nitrite as N
Trish Nelson
21
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From:
To:
Subject:
Date:
Zack Jones
R7-WaterDivision
Water quality
Wednesday, November 20, 2024 8:11:32 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
'm becoming conscious about taking a hard stance on information that comes from social
media. There are always 2 sides to a story. However, when it comes to
Iowa's water quality it seems very believable that our water is polluted. I say this because of
how many water trails we have, how much ground is farmed, lack of buffer strips along water
ways, and year after year application of chemicals. I can see this with my own eyes.
I believe run off is a problem especially in wet conditions. If the chemicals persist at the
current rate there should be more incentive to reduce run off and continued efforts for better
methods. This is in every living beings interest.
22
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From:
To:
Subject:
Date:
Mia Morarie
R7-WaterDivision
Clean water
Wednesday, November 20, 2024 8:14:14 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
support adding any and all waterways that qualify to the 2024 303(d) list. I find it shocking
that so many people who live off the land, treat it so abhorrently, bending and twisting laws
and regulations until they are unrecognizable and go unenforced and violations go unpunished,
or get a slap in the wrist for major violations. It's downright shameful.
Red Oak, IA
23
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From:
To:
Subject:
Date;
Billv Hunter
R7 Water Divcaon
polluted creels and rivers here in Iowa
Wednesday, November 20, 2024 10:20:02 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
We live next to the Cedar River (creek here in Center Township Jefferson County IA),
and because of all the significant agricultural effluent from farm chemicals and
manure runoff, the river (creek) is a dead zone, and disgusting.
Therefore, we support adding the Cedar River, Des Moines River, Iowa River,
Raccoon River, and South Skunk River to Iowa's 2024 303(d) list.
24
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From:
To:
Subject:
Date;
Ryan Reynolds
R7 WaterOiviswfi
Iowa Rivers
Wednesday, November 20, 2024 i:4S:51 PM
Caution: TWs email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
)ear EPA,
I live along the Iowa River so I heartily support adding the Cedar River, Des Monies River,
Iowa River, Raccoon River, and South Skunk River to Iowa's 2024 303(d) list of impaired
waters.
All people deserv e clean water and what the Iowa DNR is doing is immoral. Please help us
stand up to Big Ag and a eomplieit state government.
Thank you.
25
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From:
To:
Subject:
Date:
Abigail Bohle
R7-WaterDivision
Iowa waters 303
Wednesday, November 20, 2024 1:49:21 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
To whom it may concern:
As an Iowan for my whole life, I am devastated by how lax the DNR has become with our
drinking water. Please add those rivers to the list. They need to be called out and made to
enforce laws that have been in place for years. They need to do better, especially with the high
cancer rates for Iowa.
Thank you,
Abigail Bohle
26
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From:
To:
Subject:
Date:
Johanson. Roger
R7-WaterDivision
Iowa Rivers
Wednesday, November 20, 2024 3:35:56 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
We are drinking dirty water. Please add these rivers in Iowa's 2024 303(d) list the Cedar
River, Des Moines River, Iowa River, Raccoon River, and South Skunk River.
Thank you. Water is everyone's lifeline.
Roger
Roger Johanson
27
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From:
To:
Subject:
Date:
Carl Osterhoudt
R7-WaterDivision
Iowa impaired waterways
Wednesday, November 20, 2024 6:25:12 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
To whom it may concern,
I am writing to express my support for adding the Cedar River, Des Moines River, South
Skunk River, and Raccoon River to Iowa's 303d list. Without intervention, these waterways
will continue to decline. Please do what you can to help address this issue.
Thank you,
Carl J Osterhoudt
Iowa native since 1987
28
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From: Zepeski. Anne E
To: R7-WaterDivision
Subject: Iowa"s 2024 303(d) list of impaired waters
Date: Wednesday, November 20, 2024 6:44:58 PM
Attachments: imaaeOOl.pna
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Hello,
As a resident of Iowa, parent, and health care provider, I support adding the Cedar River, Des Moines
River, Iowa River, Raccoon River, and South Skunk River to Iowa's 2024 303(d) list of impaired
waters.
Thank you,
Anne Zepeski
Anne Zepeski, PharmD, BCPS
Clinical Assistant Professor, Emergency Medicine
Clinical Assistant Professor, Pharmacy Practice
University of Iowa Health Care
¦
29
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From:
To:
Subject:
Date:
iohn Norwood
R7-WaterDivision
Decision to Add 7 water quality segments to Iowa's 2024 303(d) List
Wednesday, November 20, 2024 9:05:55 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear EPA:
I am a West Des Moines resident and frequent paddler on central Iowa rivers
including the Des Moines and Raccoon Rivers. My drinking water provider draws
source water from these two rivers.
I am supportive of the EPA decision to add these seven water quality-limited
segments to Iowa's 2024 303(d) list.
It is clear the existing state Nutrient Reduction strategy is not working. The primary
reason is the scale of activities necessary to mitigate the increase in nutrient loads is
far to slow and far too small to account for the nitrate and nitrite levels resulting from
millions of corn acres and the manure from millions of livestock.
We need a serious plan which includes establishing carrying capacities for crops and
livestock by river segments with robust river level monitoring and management. We
also need mandatory buffer setbacks along streams and waterways and crop rotation
and cover crops tied to crop insurance eligibility. Previously the state's soil and water
commissioners recommended such setbacks, but the current Agriculture Secretary
Mike Naig used his administrative power to block such action either administratively
or legislatively.
Corn-on-corn rotations should be penalized by eliminating eligibility for crop insurance
for fields using this practice. Third crop rotation like small grains, such as food grade
oats should be rewarded. These crops require less fertilizer than corn, can utilize
manure during warmer growing season months, and build soil health- perhaps the
fastest and best way to reduce nutrient loss and retain soil moisture.
EPA should work closely with the USDA and state level IDALS to develop strategies,
timelines, goals and identify resources to protect these rivers and vital sources of
drinking water, biodiversity, groundwater recharge and flood protection.
Thank you,
John Norwood
30
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West Des Moines, Iowa
31
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From: maribeth newman
To: R7-WaterDivision
Subject: Nitrates in Rivers
Date: Wednesday, November 20, 2024 10:28:58 PM
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
Thank you for insisting that Iowa finally address the high nitrates in our rivers. Our corporate agricultural system
makes it difficult for farmers to operate without excess nitrogen application. The numbers of CAFOS create an
obscene amount of animal waste, thus more nitrogen .The entire state is laced with a drainage pipeline system that
deprives the land of natural water retention and recharging. Our increasing cancer rate is the canary in the coal mine
of Iowans' health related to our sick land and water management. Our state government is not functioning to protect
Iowans but to serve corporate agriculture, some international. Thank you for standing up for us.
Maribeth Newman
Sent from my iPhone
32
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From: Greg Nepstad
To: R7-WaterDivision
Subject: PLEASE DO ADD THEM
Date: Wednesday, November 20, 2024 11:33:32 PM
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
Add the Cedar, Des Moines, Iowa, Raccoon, & South Skunk to Iowa's 2024 303(d) list. They are basically sewers.
Greg Nepstad, Stuart, Iowa
33
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From:
To:
Subject:
Date:
Attachments:
Pratt. David
Paxson. Chelsea fshe/her/hersl
Iowa Voice Message
Thursday, November 21, 2024 8:59:15 AM
13194306557 17634801764020413025.amr
Did Amy forward this to you? I received a voice message and not sure if we should call back now or
wait until all are received. Either way, they bring up a point that we'll need to look in to. Thanks
(11/20/24, 7:54 PM) Hi Mister Pratt, this is Denise Mathis, and I am from Iowa. I had read the letter
that you had that your office had sent to Iowa's DNR, and I would ask that you also look at the
English River watershed. Um, the English River watershed was also part of an NIH grant. That um we
were awarded. Several years ago, and they did have money, we were able to test the English river at
that particular time. And uh if you check out the English River watershed. Uh, website, you will see
the conclusion of a lot of the water tests that we did all the way through the river from Grinnell all the
way to English Valley. Um, I am also going to send an email regarding how bad I think the DNR in
Iowa is doing fighting the nitrate levels in Iowa, um, but if you want to call me back, I can put you in
touch with the administrator for the English River watershed. Um, her name isJody. And Her phone
number? I, um, let me find it really quick. I'm so sorry I didn't have it ready. Um, her name is Jody
Bailey and her phone number She was the administrator on the English River
watershed, and if you want to get in touch with me, my number I just wanted you
guys to know that um we had also done. Some water testing and how bad our water testing turned
out. OK, thank you.
'Davtoi'Pratt, Section Supervisor
U.S. TnvironmentaCTrotection JKgency, Region 7
IVater "Division
Standards andWater QuaCity 'Branch
IVater QuaCity Section
Office: 913-551-7552
34
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From: Peaav Eherenman
To: R7-WaterDivision
Date: Thursday, November 21, 2024 3:39:08 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
3lease add the Cedar River, in Iowa, and some other rivers to your list of rivers that need to be
cleaned of nitrites and nitrates. Little has been accomplished toward this end in many, man\
ears and we need EPA to step in. PLEASE! Thank you, - Peggy Eherenman,
35
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From:
To:
Subject:
Date;
Dlwaoa Kauftnan
BZ-WatefOivision
Iowa RiVers
Thursday, November 21, 2024 10:29:43 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
' strongly support the adding of the: Iowa, Cedar, Des Moines. South Skunk, and
Raccoon Rivers to the EPA's list of Impaired Rivers and to direct the Iowa DNR to
follow the regulations set forth in the Clean Waters Act to protect these vital
waterways in our state. It is shameful that the DNR has failed ar its job to protect
these waters (and others) for the abuses of Big Ag and Big Meat. Action must be
taken.
36
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From: Krier. Ken
To: Paxson. Chelsea fshe/her/hersl: Pratt. David
Cc: Kendall. Daniel: Moeller. Mark TDNR1
Subject: Fwd: FW: Partial Approval/Partial Disapproval of Iowa's 2024 Section 303(d) List
Date: Thursday, November 21, 2024 1:42:23 PM
Attachments: IA2024.303d.PartialDisapprovalLetter DecisionDocumentll.l2.2024.pdf
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
VIr Pratt,
It is Iowa DNR's intention to comment on the six segments (seven impairments) EPA R7
intends to add to Iowa's 2024 Section 303(d) List by December 12, 2024. To facilitate Iowa
DNR's response/comment, please provide the following information to Iowa DNR as soon as
possible:
• the data sources (agency, database, etc.) for the data used to assess the
Class C designated uses from the six segments/assessment units
• all the data used to assess the Class C designated uses from the six
segments/assessment units
o the data should include: sample date, site number, site
name, method, laboratory, parameter name, result, unit, latitude, and
longitude
• list of violations calculated from the data
• methodology used for assessment determination
Thanks in advance for your prompt attention to this request.
Regards,
Ken
Ken Krier
Environmental Specialist Senior
Water Quality Monitoring and Assessment Section
Department of Natural Resources
6200 Park Ave, Suite 200
Des Moines, IA 50321
https://www.iowadnr.gov/
DNR logo
Forwarded message
37
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From:
To:
Subject:
Date:
Melanie T
R7-WaterDivision
Iowa Rivers
Thursday, November 21, 2024 8:29:20 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
)ear Environmental Protection Agency:
Please ensure the Department of Natural Resources includes the following Iowa
rivers on the 2024 303(d) list: Cedar. Des Moines, Raccoon. Iowa. South Skunk. It
is no wonder, since so many poor pigs and chickens are crammed in buildings on
Iowa lands, that the waste produced gets into our drinking water. The DNR needs to
correctly report these rivers on this year's list based on the evidence, and as an
lowan. I would greatly appreciate your help in facilitating this.
Thank you so much for your assistance!
Melanie Tipton
38
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From: Shawn Richmond
To: Pratt. David: Paxson. Chelsea fshe/her/hersl
Cc: Robichaud. Jefferv: Christina Gruenhaaen: Matt Steinfeldt: R7-WaterDivision
Subject: FW: Comment period extension request
Date: Friday, November 22, 2024 9:47:36 AM
Attachments: imaaeOOl.ipg
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Hello David and Chelsea - I'm forwarding you the request below from Iowa Farm Bureau for a 30-day
extension on the comment period for the seven water segments EPA has proposed for addition to
Iowa's 2024 impaired waters list.
Please let me know that you have received our request and advise at your earliest convenience if the
extension request will be granted.
Thank You
Shawn Richmond
Conservation & Natural Resources Policy Advisor
Iowa Farm Bureau Federation
5400 University Avenue | West Des Moines, IA 50266
From: Shawn Richmond
Sent: Monday, November 18, 2024 1:42 PM
To: robichaud.jeffery@epa.gov
Subject: Comment period extension request
Hi Jeff - It was good to see you on the tour with Bruno back in September, hope things have been
going well since.
I see that EPA has opened a public comment period regarding EPA's partially approve/partially
disapprove decision on Iowa's 2024 303(d) list. Given the time needed to go through the decision in
detail and the comment period overlapping Thanksgiving, Iowa Farm Bureau requests that the
comment period be extended by 30 days to provide sufficient time for public comment on this
matter. Please advise if this email will suffice for a formal request to extend the comment period, and
if not please advise how to proceed with a formal request.
39
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Thanks!
Shawn Richmond
Conservation & Natural Resources Policy Advisor
Iowa Farm Bureau Federation
5400 University Avenue | West Des Moines, IA 50266
40
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From: Gloria foster
To: R7 WaterPrviSKm
Subject! Adding the Cedar River, Des Manes River, Iowa River, Rac coon River and South Skunk River to Iawas's 2024
303(d) list
Date; Friday, November 22, 2©24 7:23:56 PM
Caution: TMs email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
. support adding the Cedar River, Des Moines River. Iowa River, Raccoon. River and South
Skunk River to Iowa's 2024 303(d) list. I fervently hope this will actually lead to getting
something done about all our impaired lakes and rivers.
Thank you.
Gloria Foster
Gloria W. Foster
41
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From:
To:
Subject:
Date;
H Fischer
R7-WaterDi¥ision
EPA"s Decision on Iowa's 2(124 list of Water Quality-Limited Segments Reqinrjng a Total Maximum Daily Load
Saturday, November 23, 2024 3:58:53 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
To whom it may concern.
I agree with the EPA's assessment that the river segments listed in Table I (letter to the Iowa
Department of Natural Resources, https:'''www.epa.gov-system 'files-documents,-'2024-
1 l/ia2024.303d.particialdisapprovalletter_ decisiondocunientl 1.12.2024.pdf) be included in
Iowa's 2024 303(d) list. Four of the segments are drinking water sources for 3 of Iowa's large
population centers sDes Moines. Cedar Rapids, and Iowa City. The water suppliers for these
centers must go to great expense to keep nitrate/nitrite levels low in their potable water.
Thank you.
Ed Fischer
42
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from:
To: n-WMmnrnkm
Subject: Put* cotnmert to EPA i uimq >n regarfs to nitrates in fives in Iowa
Oate; Monday, Decanter 2» 2024 8:54:10 AM
MTRATC TOXICITY AITOES AMD WEBSITES .(too
water-jualHy-Kgit (3jjf
mammMEasmjaMEmsmmMmMittSmiaa&M^s
CnOn: TMs email originated from outside EPA. please exercise additional caution when deciding whether to
open attachments or click on provided links.
To Whom it may concern:
This email will not address river surface water nitrates alone but more so in a wbolistie sense. 1 monitor nitrates in tiles
and have perfected a process to determine nitrates in tie field using Hach nitrate/nitrite strips and colonmetnc cards
and phone app from Deltares of the Netherlands, (see Monitoring Nitrates in Tiles attached)
The monitoring of tile water is only an indicator of nitrate levels since it is only for a day. But to realize the levels and
act upon them the producer can better regulate and apply any other nitrates in the field.
To reduce the levels of nitrates in Iowa Rivers we need to address agriculture contributions (45% fertilizer and 14%
from manure and 27° o from legumes). These numbers come from estimates from IDNR several years ago as part, of a
water restoration plan for the Cedar River, The plan was abandoned two years ago.
Nitrates are water soluble and thus they move through the soil profile quickly and easily. These chemicals are
necessary for the growth of cultivated plants such as corn.
Yet, as beneficial as nitrate to the plant this nutrient is toxic to humans. A number of articles indicating the toxic
conditions of nitrates are found on the attached ("Nitrate Toxicity Articles and websites")...Exposure to nitrates in
drinking water can be harmful.
In a report done several years ago, findings of the effects of fertilizer applications on draw down areas of small town
public wells indicate that the protection of these areas was not being done successfully, (see water quality report)
nitrate-nitrite-background-docnment.pdf
In the World Health Organizations report on nitrates there are health issues sited with blue baby syndrome or
Methaemoglobinaemia and thyroid tumors and birth defects. Hie chronic effects if allowed will act as an insidious
disease for the population consuming nitrates at variable levels. Not enough research has been done to determine the
long term effects of nitrates. In Iowa, private and public well water is at risk of some level of nitrate unless certain
restrictions, regulations are put in place. Small towns must be given .support to put these controls in place, Source water
protections are absolute.
We must attempt to regulate/measure nitrates in the environment. TWs would include urban as well as rural sources. All
landowners should be educated of the ills of nitrates and held responsible to monitor nitrate levels, (use the Oeltares
method).
I hope this is helpful in your work to limit toxins in the environment.
Peace,
Matthew Mc Andrew
Owner Manager
MB Water
43
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From:
To:
Subject:
Date:
Attachments:
Pamela Mackev Tavlor
R7-WaterDivision
Iowa"s 2024 303(d) list comments
Monday, December 2, 2024 3:19:05 PM
imDairedH20.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Attached are comments from the Iowa Chapter of the Sierra Club about the 2024 Section
303(d) list and adding 7 water quality limited segments to the list.
Thank you for considering these comments.
Pam Mackey Taylor
Iowa Chapter Director
44
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# SIERRA CLUB
IOWA CHAPTER
December 2, 2024
Environmental Protection Agency, Region 7
Water Division
Via email to R7-WaterDivision@epa.gov
Re: Comments concerning Iowa's 2024 Section 303(d) list and 7 water segments being added to the list
Dear Water Division Staff:
Sierra Club Iowa Chapter is the oldest and largest grassroots environmental organization in Iowa. We
have approximately 7,000 members throughout the state. Sierra Club has been a leader in Iowa on
addressing issues surrounding water quality. So we appreciate the opportunity to comment on the
proposed revisions to the 2024 Section 303(d) list.
The Sierra Club supports adding the 7 water quality limited segments to the 303(d) list identified in your
November 12, 2024, letter to Ed Tormey at the Iowa Department of Natural Resources (DNR). The 7
segments include portions of the following rivers and involve nitrate and nitrite pollution:
• Cedar River
• Des Moines River
• Iowa River
• Raccoon River
• South Skunk River
We also support the EPA's analysis of the Iowa Department of Natural Resources processes and methods
of determining whether a water should be listed on the Section 303(d) list, including:
• The DNR did not use the Iowa Water Quality Information System data, including information
from the U.S. Geological Survey and the University of Iowa's Iowa Institute for Hydrologic
Research monitors. This data is credible and collected by professionals dealing with water
quality issues. Iowa DNR should be required to use the information in formulating the 303(d)
list.
• The DNR did not use information in the Clean Water Hub. This information is collected by
trained volunteers. Iowa DNR should be required to use the information in formulating the
303(d) list.
• We support the EPA's analysis that says that "data excluded from the state's analysis must be
based on a technical, science-based rationale and not rely solely upon Iowa's 'Credible Data
Law'". DNR has been able to use the credible data law to hide the fact that some waters is Iowa
are polluted and need to be put on the 303(d) list. The Credible Data Law has allowed DNR to
keep the 303(d) list shorter than it should be. It therefore allows polluters to keep polluting.
• We support EPA's analysis that the DNR should not be using the 10% rule to determine if a water
body is polluted with nitrate and N, nitrite as N, and nitrate plus nitrite as N. Given that excess
amounts of nitrate and nitrite can be injurious to human health, the toxic levels of those
substances should force a water body of the 303(d) list.
• In the letter to Ed Tormey and the decision document, EPA noted that they alerted the DNR that
the DNR is "not assessing all pollutants with toxic effects with reasonable consideration of the
Sierra Club Iowa Chapter, PO Box 1058, Marion, IA 52302
3839 Merle Hay Road, Suite 280, Des Moines, Iowa, 50310. 515-277-8868
Email: iowa.chapter@sierraclub.org Web: www.sierraclub.org/iowa Facebook: Iowa Chapter Sierra Club
45
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# SIERRA CLUB
IOWA CHAPTER
individual pollutant, endpoints, and adverse effects being considered" in their comment letter
about the draft 303(d) list. It is disappointing to know that DNR chose to ignore those comments
and did not list the 7 water quality limited segments on the 303(d) list submitted to DNR.
• We support the EPA looking into how the DNR is prioritizing those waters on the 303(d) list for
development of TMDLs. We have concerns about how long waters are on the list without a
TMDL. We are concerned with the Outstanding Iowa Waters being given lower priority on
TMDL development.
o On the current 303(d) list are numerous water segments that have been on the list since
2006 and 2008, with no TMDL having been prepared.
o Some of those waters on the list since 2006 and 2008 are designated as Outstanding Iowa
Waters pursuant to Iowa's Antidegradation Policy. These waters are entitled to extra
protection.
o Just as troubling as the many years these Outstanding Iowa Waters have been on the list
is the fact that DNR has designated them as low priority for preparing TMDLs. They
have been designated as Tier III and Tier IV, putting them at the bottom of the priority
list, essentially condemning them to perhaps never having a TMDL prepared. This is a
clear violation of the intent, if not the specific language, of the Clean Water Act. Section
303(d) says the priority ranking must be made "taking into account the severity of the
pollution and the uses to be made of such waters." 33 U.S.C. § 1313(d)(1)(A).
• Finally we are concerned that the DNR is not fully implementing the plans to improve water
quality that have been identified as part of the TMDL process. Given efforts by the state to
reduce income taxes and the programs supported by those taxes, it appears that the TMDLs will
not be implemented any time in the near future. The process of listing a water on the 303(d) list
should result in water quality improvement in the near future. The 303(d) list and the TMDLs
mean nothing if the TMDLs are not implemented.
The state of Iowa needs to come to grips with the excessive amounts of nitrate and nitrite that are entering
the water bodies in the state. Along with that, efforts need to begin for setting water quality standards for
nutrients. Plus the state needs to undertake serious efforts to reduce the nutrients entering water bodies,
through the TMDL process. Iowa's voluntary Nutrient Reduction Strategy is not working in reducing
nutrients in the state's waters.
As I said above, the Sierra Club supports adding the 7 water quality limited segments to the 2024 303(d)
list.
Sincerely,
/s/ Pamela Mackey Taylor
Pamela Mackey Taylor
Iowa Chapter Director
PO Box 1058
Marion, IA 52302
Sierra Club Iowa Chapter, PO Box 1058, Marion, IA 52302
3839 Merle Hay Road, Suite 280, Des Moines, Iowa, 50310.
Email: iowa.chapter@sierraclub.org Web: www.sierraclub.org/iowa Facebook: Iowa Chapter Sierra Club
46
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From: Mike Tramontina
To: R7-WaterDivision
Subject: Iowa Impaired Waters List 2024
Date: Tuesday, December 3, 2024 9:55:58 AM
Attachments: 2024-12-03 Letter on Impaired Waters.docx
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Environmental Protection Agency, Region 7
Water Division
Mike Tramontina
"Some white people hate black people, and some white people love black people, some
black people hate white people, and some black people love white people. So you see it's
not an issue of black and white, it's an issue of Lovers and Haters."
eden ahbez
47
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December 2, 2024
Environmental Protection Agency, Region 7
Water Division
Via email to R7-WaterDivision@epa.gov
Re: Iowa's 2024 Section 303(d) list and 7 water segments being added
Pear Water Pivision Staff,
I appreciate the opportunity to comment on the proposed revisions to the 2024 Section 303(d) list.
I support adding the 7 water quality limited segments to the 303(d) list identified in your
November 12, 2024, letter to EdTormey at the Iowa Pepartment of Natural Resources (PNR). The 7
segments include portions of the following rivers and involve nitrate and nitrite pollution: • Cedar
River • Pes Moines River • Iowa River • Raccoon River • South Skunk River.
I support the EPA's analysis of the Iowa Pepartment of Natural Resources processes and methods of
determining whether a water should be listed on the Section 303(d) list, including:
• The PNR did not use the Iowa Water Quality Information System data, including information from
the U.S. Geological Survey and the University of Iowa's Iowa Institute for Hydrologic Research
monitors. This data is credible and collected by professionals dealing with water quality issues.
Iowa PNR should be required to use the information in formulating the 303(d) list.
• The PNR did not use information in the Clean Water Hub. This information is collected by trained
volunteers. Iowa PNR should be required to use the information in formulating the 303(d) list. • We
support the EPA's analysis that says that "data excluded from the state's analysis must be based on a
technical, science-based rationale and not rely solely upon Iowa's 'Credible Pata Law'". PNR has
been able to use the credible data law to hide the fact that some waters is Iowa are polluted and
need to be put on the 303(d) list. The Credible Pata Law has allowed PNR to keep the 303(d) list
shorter than it should be. It therefore allows polluters to keep polluting.
• I support EPA's analysis that the PNR should not be using the 10% rule to determine if a water
body is polluted with nitrate and N, nitrite as N, and nitrate plus nitrite as N. Given that excess
amounts of nitrate and nitrite can be injurious to human health, the toxic levels of those substances
should force a water body of the 303 (d) list.
• In the letter to Ed Tormey and the decision document, EPA noted that they alerted the PNR that
the PNR is "not assessing all pollutants with toxic effects with reasonable consideration of the
individual pollutant, endpoints, and adverse effects being considered" in their comment letter about
the draft 303(d) list. It makes me angry that PNR chose to ignore those comments and did not list
the 7 water quality limited segments on the 303(d) list submitted to PNR.
• I support the EPA looking into how the PNR is prioritizing those waters on the 303(d) list for
development of TMPLs. I am concerned about how long waters are on the list without a TMPL. I am
concerned with the Outstanding Iowa Waters being given lower priority on TMPL development. On
the current 303(d) list are numerous water segments that have been on the list since 2006 and
2008, with no TMPL having been prepared. Some of those waters on the list since 2006 and 2008
are designated as Outstanding Iowa Waters pursuant to Iowa's Antidegradation Policy. These waters
are entitled to extra protection.
Just as troubling as the many years these Outstanding Iowa Waters have been on the list is the fact
that PNR has designated them as low priority for preparing TMPLs. They have been designated as
Tier III and Tier IV, putting them at the bottom of the priority list, essentially condemning them to
48
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perhaps never having a TMDL prepared. This is a clear violation of the intent, if not the specific
language, of the Clean Water Act. Section 303(d) says the priority ranking must be made "taking
into account the severity of the pollution and the uses to be made of such waters." 33 U.S.C. §
1313(d)(1)(A).
• I am concerned that the DNR is not fully implementing the plans to improve water quality that
have been identified as part of the TMDL process. Given efforts by the state to reduce income taxes
and the programs supported by those taxes, it appears that the TMDLs will not be implemented any
time in the near future. The process of listing a water on the 303(d) list should result in water
quality improvement in the near future. The 303(d) list and the TMDLs mean nothing if the TMDLs
are not implemented.
The state of Iowa needs to come to grips with the excessive amounts of nitrate and nitrite that are
entering the water bodies in the state. Along with that, efforts need to begin for setting water
quality standards for nutrients. Plus, the state needs to undertake serious efforts to reduce the
nutrients entering water bodies, through the TMDL process. Iowa's voluntary Nutrient Reduction
Strategy is not working in reducing nutrients in the state's waters.
Finally, I support adding the 7 water quality limited segments to the 2024 303(d).
Mike Tramontina
-------
From:
To:
Subject:
Date:
Bridget McNernev
R7-WaterDivision
Iowa Impaired waterways
Tuesday, December 3, 2024 1:31:46 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
'lease retain the additional 7 waterways that Iowa DNR neglected to include in the impaired
waterways inventory. The citizens have no voice in the process and our requests to clean up
the water go without state action. We voted as a state to fund conservation and clean up
through a sales tax increase and the Legislature has thus far failed to use the dollars designated
for this purpose to be placed into the fund.
While you are at it, have Region 7 air reject the states newly imposed 40% opacity standard on
the locals and force them to rewrite their code to embrace the 20% opacity that we have now
had to give up in Polk and Lynn Counties.
Thank you
Bridget McNerney
50
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From:
To:
Subject:
Date:
Maria La france
R7-WaterDivision
Please add 7 waterways to Iowa"s Impaired Waters List 2024
Tuesday, December 3, 2024 8:05:21 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Please add the 7 Iowa water ways to the 2024 303(d) List of Iowa
Impaired Waters that the Iowa DNR reported in 2024. The
waterways include key segments of the Des Moines, Cedar, Iowa,
Raccoon and South Skunk rivers from which hundreds of thousands
of lowans draw drinking water.
Maria La France
51
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From: Robert Rilev
To: R7-WaterDivision
Subject: iowa Impaired Waters
Date: Tuesday, December 3, 2024 9:08:52 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
I would encourage you to list the 7 additional river sections in the impaired
water List.
The sooner we can name and identify the issues, the sooner we can attempt to
fixe them.
It is apparent that Iowa DNR has no interest in naming or fixing any of our
impaired waters.
Therefore, should EPA take over enforcement of Iowa environmental
protection? YES
R G Riley, Jr
Stay safe, let's be careful out there, keep your distance!
Brevity is worth the effort.
52
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From:
To:
Subject:
Date:
Attachments:
Anne Walton
R7-WaterDivision
Comment on Decision Document for Ipwa"s 2024 Impaired Waters List
Thursday, December 5, 2024 4:58:24 PM
SEISC's Comments on Impaired Waters.docx
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
TO: EPA-R7, Water Division
FROM: SE Iowa Sierra Club, Fairfield, Iowa
RE: Iowa Impaired Waters, Clean Water Section 303d List
DATE: December 02, 2024
To Whom it May Concern:
Please record this as a public comment on The EPA's Decision Document on Iowa's 2024 List
of Impaired Waters, comment period open until December 13, 2024.
on behalf of the Executive Committee of the SE Iowa Sierra Club (SEISC) group, whose
geographic range includes eight counties in SE Iowa, we support the EPA's decision to add five
water bodies to Iowa Department of Natural Resources (DNR) 2024 list of Impaired Waters.
The addition of the Cedar River, Des Moines River, Iowa River, Racoon River and the South
Skunk River would better reflect a complete list of Iowa's Impaired Waters due to the fact that
numerous water samples show these water bodies to exceed the federal water quality
standard for surface waters used for drinking water. This deficit in the list of Iowa's Impaired
Waters is a significant finding on behalf of EPA, and even more so, a finding that leads to the
need to develop and execute a pollutant reduction plan that will take specific action to reduce
the nitrate and nitrite loads of each of these five rivers.
The development of a Total Maximum Daily Load (TMDL) and any meaningful restoration plan
for each of these water bodies will require DNR to address the source of the problem. With
95% of Iowa's total land mass under agricultural production, the largest contributing factors to
the Impaired Waters in our state are manure and commercial fertilizer that is transported
through different forms of precipitation from our agricultural lands to surface water (and likely
ground water) systems. This will require DNR to work closely with Iowa's largest economic
driver to address their farming practices. It will also require DNR, as EPA suggested, to change
their water quality monitoring interpretation of the data. Instead of using a statistical method
that amortizes pollutant levels across a series of data points, DNR must evaluate and report
the results of each test of nitrate, nitrite, or nitrate plus nitrite that exceeds the water quality
standard established by EPA. Additionally, the test data source (e.g. volunteer data) needs to
be sorted from the scientific data.
All of this leads to another issue cited in the Iowa Sierra Club's De-delegation Petition in which
they requested that Iowa DNR's public trust authority to administer the Clean Water Act be
rescinded. The Executive Committee of the SE Iowa Sierra Club concurs with this request as
supported by the earlier statements made in this public comment document. Although our
comments above speak to what is happening in 2024, DNR's history of negligence actually
53
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goes back to at least 2006 and 2008, the time span for which some of the water bodies have
been on the Impaired Waters list, and DNR still has yet to establish TMDLs. Worth noting is the
fact that some of these water bodies are designated as Outstanding Iowa Waters, which
actually entitles them to extra levels of protection.
In conclusion, the SE Iowa Sierra Club group's Executive Committee kindly requests that EPA
ensure that Iowa's DNR completes its 2024 List of Impaired Waters to include at least five
polluted water bodies mentioned above. And, with these additions, provide oversight to
ensure that TMDLs are established for all of Iowa's Impaired Waters, along with restoration
plans. If the Iowa DNR cannot follow through with its public trust responsibilities in regards to
the Clean Water Act, then that delegated authority should be taken back by the EPA and
reassigned appropriately.
Thank you for your consideration of our comments.
Kind regards
Anne Walton, Chair
On Behalf of the SE Iowa Sierra Club group Executive Committee
54
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TO: EPA-R7, Water Division
FROM: SE Iowa Sierra Club, Fairfield, Iowa
RE: Iowa Impaired Waters, Clean Water Section 303d List
DATE: December 02, 2024
To Whom it May Concern:
Please record this as a public comment on The EPA's Decision Document on Iowa's 2024 List of
Impaired Waters, comment period open until December 13, 2024.
On behalf of the Executive Committee of the SE Iowa Sierra Club (SEISC) group, whose
geographic range includes eight counties in SE Iowa, we support the EPA's decision to add five
water bodies to Iowa Department of Natural Resources (DNR) 2024 list of Impaired Waters. The
addition of the Cedar River, Des Moines River, Iowa River, Racoon River and the South Skunk
River would better reflect a complete list of Iowa's Impaired Waters due to the fact that
numerous water samples show these water bodies to exceed the federal water quality standard
for surface waters used for drinking water. This deficit in the list of Iowa's Impaired Waters is a
significant finding on behalf of EPA, and even more so, a finding that leads to the need to
develop and execute a pollutant reduction plan that will take specific action to reduce the
nitrate and nitrite loads of each of these five rivers.
The development of a Total Maximum Daily Load (TMDL) and any meaningful restoration plan
for each of these water bodies will require DNR to address the source of the problem. With 95%
of Iowa's total land mass under agricultural production, the largest contributing factors to the
Impaired Waters in our state are manure and commercial fertilizer that is transported through
different forms of precipitation from our agricultural lands to surface water (and likely ground
water) systems. This will require DNR to work closely with Iowa's largest economic driver to
address their farming practices. It will also require DNR, as EPA suggested, to change their
water quality monitoring interpretation of the data. Instead of using a statistical method that
amortizes pollutant levels across a series of data points, DNR must evaluate and report the
results of each test of nitrate, nitrite, or nitrate plus nitrite that exceeds the water quality
standard established by EPA. Additionally, the test data source (e.g. volunteer data) needs to be
sorted from the scientific data.
All of this leads to another issue cited in the Iowa Sierra Club's De-delegation Petition in which
they requested that Iowa DNR's public trust authority to administer the Clean Water Act be
rescinded. The Executive Committee of the SE Iowa Sierra Club concurs with this request as
supported by the earlier statements made in this public comment document. Although our
comments above speak to what is happening in 2024, DNR's history of negligence actually goes
back to at least 2006 and 2008, the time span for which some of the water bodies have been on
the Impaired Waters list, and DNR still has yet to establish TMDLs. Worth noting is the fact that
some of these water bodies are designated as Outstanding Iowa Waters, which actually entitles
them to extra levels of protection.
55
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In conclusion, the SE Iowa Sierra Club group's Executive Committee kindly requests that EPA
ensure that Iowa's DNR completes its 2024 List of Impaired Waters to include at least five
polluted water bodies mentioned above. And, with these additions, provide oversight to ensure
that TMDLs are established for all of Iowa's Impaired Waters, along with restoration plans. If
the Iowa DNR cannot follow through with its public trust responsibilities in regards to the Clean
Water Act, then that delegated authority should be taken back by the EPA and reassigned
appropriately.
Thank you for your consideration of our comments.
Kind regards
Anne Walton, Chair
On Behalf of the SE Iowa Sierra Club group Executive Committee
56
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From: Ryan Koch
To: R7 WatwI>VTS
-------
From: Elaine StClair
To: R7-WaterDivision
Subject: Iowa DNR must be held to the regulations
Date: Sunday, December 8, 2024 9:31:54 AM
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
Thank you for being the enforcement of regulations for safe water in Iowa and the country. The health of citizens of
Iowa depends on EPA's ability to enforce the rules to provide correct data on which decisions are made.
Elaine St Clair
58
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From:
To:
Subject:
Date:
Richard Dietz
R7-WaterDivision
Re: Iowa's 2024 Section 303(d) list
Sunday, December 8, 2024 11:22:38 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
December 8, 2024
Environmental Protection Agency, Region 7
Water Division
Via email to R 7 - Wa te r D ivisi o n @ e pagov
Re: Iowa's 2024 Section 303(d] list
Dear Water Division Staff,
Thank you for the opportunity to comment on Iowa's 2024 Section 303(d] list. I strongly
support the addition of seven river segments to the 303(d] list that are identified in your
November 12 letter to the Iowa Department of Natural Resources (DNR]. Those segments
(parts of the Cedar, Des Moines, Iowa, Raccoon and South Skunk Rivers] serve as drinking
water sources for hundreds of thousands of Iowan's while having levels of Nitrate that exceed
the drinking water standard.
I support the EPA's analysis of the Iowa Department of Natural Resources processes and
methods of determining whether a water should be listed on the Section 303(d] list, including:
¦ The DNR did not use the Iowa Water Quality Information System data, including information
from the U.S. Geological Survey and the University of Iowa's Iowa Institute for Hydrologic
Research monitors. This data is credible and collected by professionals dealing with water
quality issues. Iowa DNR should be required to use the information in formulating the 303(d]
¦ The DNR did not use information in the Clean Water Hub. This information is collected by
trained volunteers. Iowa DNR should be required to use the information in formulating the
303(d] list. ¦ We support the EPA's analysis that says that "data excluded from the state's
analysis must be based on a technical, science-based rationale and not rely solely upon Iowa's
'Credible Data Law'". DNR has been able to use the credible data law to hide the fact that some
waters in Iowa are polluted and need to be put on the 303(d] list. The Credible Data Law has
allowed DNR to keep the 303(d] list shorter than it should be. It therefore allows polluters to
keep polluting.
¦ I support EPA's analysis that the DNR should not be using the 10% rule to determine if a
water body is polluted with nitrate and N, nitrite as N, and nitrate plus nitrite as N. Given that
excess amounts of nitrate and nitrite can be injurious to human health, the toxic levels of those
substances should force a water body of the 303(d] list.
¦ In the letter to Ed Tormey and the decision document, EPA noted that they alerted the DNR
that the DNR is "not assessing all pollutants with toxic effects with reasonable consideration of
the individual pollutant, endpoints, and adverse effects being considered" in their comment
letter about the draft 303(d] list. It makes me angry that DNR chose to ignore those comments
and did not list the 7 water quality limited segments on the 303(d] list submitted to DNR.
¦ I support the EPA looking into how the DNR is prioritizing those waters on the 303(d] list for
development of TMDLs. I am concerned about how long waters are on the list without a TMDL.
list.
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I am concerned with the Outstanding Iowa Waters being given lower priority on TMDL
development. On the current 303(d] list are numerous water segments that have been on the
list since 2006 and 2008, with no TMDL having been prepared. Some of those waters on the list
since 2006 and 2008 are designated as Outstanding Iowa Waters pursuant to Iowa's
Antidegradation Policy. These waters are entitled to extra protection.
Just as troubling as the many years these Outstanding Iowa Waters have been on the list is the
fact that DNR has designated them as low priority for preparing TMDLs. They have been
designated as Tier III and Tier IV, putting them at the bottom of the priority list, essentially
condemning them to perhaps never having a TMDL prepared. This is a clear violation of the
intent, if not the specific language, of the Clean Water Act. Section 303(d] says the priority
ranking must be made "taking into account the severity of the pollution and the uses to be
made of such waters." 33 U.S.C. § 1313(d](l](A],
¦ I am concerned that the DNR is not fully implementing the plans to improve water quality that
have been identified as part of the TMDL process. Given efforts by the state to reduce income
taxes and the programs supported by those taxes, it appears that the TMDLs will not be
implemented any time in the near future. The process of listing a water on the 303(d] list
should result in water quality improvement in the near future. The 303(d] list and the TMDLs
mean nothing if the TMDLs are not implemented.
The state of Iowa needs to come to grips with the excessive amounts of nitrate and nitrite that
are entering the water bodies in the state. Along with that, efforts need to begin for setting
water quality standards for nutrients. Plus, the state needs to undertake serious efforts to
reduce the nutrients entering water bodies, through the TMDL process.
Iowa's voluntary Nutrient Reduction Strategy is not working in reducing nutrients in the
state's waters.
Richard Dietz
-------
From:
To:
Subject:
Date:
Ned McPartland
R7-WaterDivision
Impaired Iowa Waters
Monday, December 9, 2024 9:03:51 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
support adding the Des Moines, Raccoon, Skunk and other Iowa rivers on this list to the
impaired water's list. My drinking water depends on the Raccoon and Des Moines rivers
whose nitrate levels are high. Also, I have paddled these two rivers which have other types of
pollution as well. Thank you.
Edward McPartland
61
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From: Chris Lish
To: R7-WaterDivision
Subject: Iowans deserve transparent water quality information — EPA"s Decision on Iowa's 2024 List of Water Quality-
Limited Segments Requiring a Total Maximum Daily Load
Date: Monday, December 9, 2024 12:01:24 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Monday, December 9, 2024
Subject: Iowans deserve transparent water quality information - EPA's Decision on
Iowa's 2024 List of Water Quality-Limited Segments Requiring a Total Maximum Daily
Load
Dear Environmental Protection Agency,
EPA R7 Water Quality Section Supervisor David Pratt, EPA R7 TMDL and IR
Coordinator Chelsea Paxson, and EPA R7 Standards and Water Quality Branch
Supervisor Amy Shields,
Concerning the decision to add seven water quality-limited segments to Iowa's 2024
303(d) list.
My mother's family as deep roots in Iowa and I grew up playing in Iowa's waterways
during summer vacations. I have many relatives who live in Iowa and who continue to
enjoy Iowa's waterways this day. The Cedar, Des Moines, Iowa, Racoon, and South
Skunk Rivers are places of importance to us.
Any water in Iowa that is impaired should be recognized as such, especially for nitrate
pollution and contamination. Nitrates in our water pose a very serious problem in
Iowa, with consequences to our health. We should have the right to clear and
transparent water quality reporting data if there is any hope to improve. That means
that the Iowa Department of Natural Resources (DNR) must hold themselves to the
highest standard and adapt their methodology on ethics and worst-case impact to
human health and drinking water supplies.
We want the water quality in Iowa to improve. It will not if we continue to allow for lax
regulations and loopholes.
Please enforce the addition of these seven water quality-limited segments to Iowa's
2024 303(d) list so that it may reflect 712 impaired water segments for 581 water
bodies listed.
Based on ethics and the security of our health and environment, I support the
Environmental Protection Agency's request for the Iowa DNR to revise assessment of
class "C" waters, remove the non-defensible use of the 10% rule in relation to nitrate
and any other pollutants with toxic effects treated as conventional pollutants. To
assess pollutants with toxic effects with reasonable consideration of the individual
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pollutant and potential adverse effects.
Without strong enforcement, Iowa's waters and communities bear the burden of
unacknowledged risk and a false sense of improvement.
I want the best for Iowa, our environment, water and people—and upholding the Iowa
DNR to high standards is an important step to moving towards a healthier Iowa.
Thank you for your consideration of my comments and for standing up for our water.
Please do NOT add my name to your mailing list. I will learn about future
developments on this issue from other sources.
Sincerely,
Christopher Lish
San Rafael, CA
63
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From:
To:
Subject:
Date:
Zita Cashin
R7-WaterDivision
Iowa water quality is NOT improving
Tuesday, December 10, 2024 8:39:23 AM
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
The current administration leadership in Iowa is not being effective to establish real measures to improve our
sources of clean water and waterways.
I appreciate the EPA's effort to evaluate our current water conditions and suggest more realistic ways to improve
Iowa's water.
Agricultural manure spills into waterways occur too frequently in our state! Iowan is ranked 2nd in new cases of
cancer being diagnosed! We need clean sources of water and the current administration is not serious to take the
steps for meaningful water quality improvement.
Zita Cashin, resident in rural Iowa
Sent from my iPhone
64
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From:
To:
Subject:
Date:
Jaiden Shahan
R7-WaterDivision
Iowa Impaired Waters Public Comment
Wednesday, December 11, 2024 6:56:54 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
was told the public comment period for the issue of question classifications for segments of
waters in Iowa ends December 13, so I am submitting a public comment on that.
Iowa, as part of the United States, has the EPA to secure environmental rights for its citizens,
even if the state is against it. As a concerned Iowan, I hope the EPA considers stronger
enforcement of the Clean Water Act in Iowa to protect Iowa citizens.
Thank you,
Jaiden Shahan
Hardin County, Iowa
65
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From:
To:
Cc:
Subject:
Date:
Patrick Bosold
R7-WaterDivision
"Patrick Bosold"
Public comment on Iowa DNR"s list of impaired waterways
Friday, December 13, 2024 7:20:26 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Environmental Protection Agency, Region 7
Water Division
Via email to R 7- WaterDi vi si on @epa. gov
Re: Comment concerning Iowa's 2024 Section 303(d) list and EPA's request to
add 7 water segments to the Iowa Dept. of Natural Resources 2024 draft list of
Iowa's impaired waterways
Dear EPA Region 7 Water Division Staff,
Thank you for taking public comments on the Iowa Department of Natural
Resources (DNR) list of impaired waterways in our state. I'm specifically
referring to the DNR's 2024 draft list of Iowa's impaired waterways. Your
agency directed the DNR to add seven segments of five Iowa rivers to the list
because of high nitrate levels in those waters. The DNR has resisted adding
those waters, and I appreciate that your agency is now seeking public
comments on this matter.
Every two years the DNR is required to submit a draft 303d list of Iowa's
impaired waterways to the EPA for its approval. Water segments that don't
fully support all their designated uses (drinking water, recreation, protection of
all aquatic life, etc.) require a plan to reduce and remove the pollutants called a
total maximum daily load (TMDL).
This year's assessment found 577 water segments are polluted enough to
require a TMDL. There are a total of 712 waterbodies categorized as impaired
in Iowa, but not all of them have pollutant levels reaching the threshold
requiring a TMDL.
The EPA is calling for the DNR to add segments of the Des Moines, Raccoon,
Cedar, Iowa and South Skunk Rivers to their list and require a TMDL for each.
These water segments were found to have nitrate levels exceeding the EPA's
limits of 10 mg/L.
But the DNR has disputed the EPA's findings and says it won't change its
methods to measure nitrates. Many water quality advocates and experts here in
Iowa consider the DNR's methods faulty and inconsistent. I am one of those
advocates.
High levels of nitrates are a danger to human health. Levels over 10 mg/L can
cause fatal blue baby syndrome and have been linked to a variety of cancers
66
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including colorectal, kidney, ovarian, stomach and thyroid cancers as well as
birth defects.
The DNR should add these seven water body segments to their list, and then
create and execute a plan to mitigate these high nitrate levels in order to protect
public health.
It is evident that the Iowa DNR has failed to cany out its duties and
responsibilities under its delegated authority under the Federal Clean Water
Act. The DNR's failure to add these seven additional water segments to their
2024 draft list of Iowa's impaired waterways is further proof of this. If the
DNR does not promptly comply with the EPA's request, I urge the EPA to
withdraw the state's delegated authority under the Clean Water Act, and to
require the state to comply with the requirements of the Clean Water Act.
Sincerely,
Patrick Bosold
67
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From:
To:
Subject:
Date:
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their inclusion.
To protect the public health of all lowans, each segment should be assigned
a Category 5 impairment and require a TMDL for the following reasons:
( 1) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
R7-WaterDivision
DNR Must Be Accountable for Dirty Water
Friday, December 13, 2024 7:25:12 AM
68
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During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to lowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling state
of affairs. At the very least, the Iowa DNR should add these waterbodies to
the 2024 list and do a better job protecting public health.
Sincerely yours,
David &Jeannie Rose
Fairfield, Iowa
69
-------
From:
To:
Subject:
Date:
Larrv Mueller
R7-WaterDivision
clean water standards
Friday, December 13, 2024 8:32:45 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I live in southwest Missouri and I am concerned about water quality in the
midwest states...primarily due to poor regulation of waste from confined
animal feeding operations.
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the
following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
70
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levels using the 10% rule is faulty and irresponsible.
(2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these water
bodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
Larry Mueller
Springfield, MO I
71
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From:
To:
Cc:
Subject:
Date:
Attachments:
Walker. Melissa
R7-WaterDivision
Corriaan. Ted
Iowa Impaired Waters public comment
Friday, December 13, 2024 8:34:08 AM
imaaeOOl.pna
Iowa Impaired Waters Public Comment Pes Moines Water Works.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Good morning,
Please see the attached public comment regarding proposed action on Iowa's list of
Section 303 (d) impaired waters. The letter is also provided below.
December 13, 2024
Jeffrey Robichaud
Water Division
U.S. EPA Region 7
11201 RennerBlvd.
Lenexa, KS 66219
Email: vision@epa.gov
RE: 2024 List of Iowa Impaired Waters
Dear Mr. Robichaud,
On behalf of Des Moines Waterworks (DMWW), I would like to thankthe U.S.
Environmental Protection Agency foryour attention to Iowa's impaired water lists and for
the proposed additions of two segments that are part of the drinking water source for
central Iowa.
DMWW has served as a regional drinking water utility for more than 100 years. We provide
clean, safe, reliable drinkingwaterto 600,000 central lowans - one-fifth of the state's
population - but that mission is becoming increasingly difficult with the source water
quality issues in the state of Iowa.
DMWW offers the following comments on the action proposed by the EPA on Iowa's 2024
list of Section 303 (d) impaired waters.
Two of the seven proposed additions to the impaired waters list directly affect central
Iowa water users:
1- Des Moines Rive -a 6.53-mile segment of the river, which
includes DMWW's intake at Prospect Parkin Des Moines.
2. Raccc - a 15.59-mile segment of the river, including the
entire section that runs through Des Moines Waterworks Park and includes the
intake at the Fleur Drive Treatment Plant in Des Moines.
DMWW has raised concerns about nitrate in raw source waters foryears. We built our
nitrate removal facility in 1992 to combat the issue, and since that time nitrate
concentrations in the riverflowing past the intake at our Fleur Drive Treatment Plant have
72
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not improved. (See chart).
phartffli Description automatically generated
Monthly average nitrate concentrations show significant volatility, but the trend line in
both rivers continues to increase. This year, nitrate concentrations in the Raccoon River
were among the highest we have seen, reaching a peak of 18.23 mg/L on June 24, nearly
doubling the drinking water standard of 10 mg/L. In the Des Moines River, nitrate
concentrations reached 15.56 mg/L on May 16, also higher than the drinking water
standard.
Des Moines Water Works supports EPA's proposed additions to the 2024 impaired waters
list, as it is our hope that the creation of Total Maximum Daily Loads (TMDLs) will allow for
more sustainable drinking water sources well into the future. Thank you for the
opportunity to comment.
Please feel free to contact me if you have any questions or need additional information.
Sincerely,
Ted Corrigan,
CEO and General Manager
Des Moines Water Works
Des Moines, Iowa
MELISSA WALKER | Office of the CEO | Communications and Outreach Manager
Des Moines Water Works | WATER YOU CAN TRUST FOR IIFE
220^»ra^ag^artwa^^e^oines^^^®321
www.dmww.com I Follow us on Facebook and Twitter
73
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Des Moines =
Water W^rks
Water You CwiTrwt for Lite
2201 George Ftagg Parkway | Des Moines, Iowa 50321 | (515)283-8700 | www.dmww.com
December 13,2024
Jeffrey Robichaud
Water Division
U.S. ("PA Region 7
11201 Renner Blvd.
tenexa, KS 66219
Email:
RE: 2024 List of Iowa Impaired Waters
Dear Mr. Robichaud,
On behalf of Des Moines Water Works (DMWW), I would like to thank the U.S. Environmental
Protection Agency for your attention to Iowa's impaired water lists and for the proposed
additions of two segments that are part of the drinking water source for central Iowa.
DMWW has served as a regional drinking water utility for more than 100 years. We provide
clean, safo, reliable drinking water to 600,000 central lowans - one fifth of the state's
population - but that mission is becoming increasingly difficult witi the source water quality
issues in the state of Iowa,
DMWW offers the following comments on the action proposed by the EPA on Iowa's 2024 list of
Section 303 (d) impaired waters.
Two of the seven proposed additions to the impaired waters list directly affect central Iowa
water users:
1. Des Moines River 1A Q4-UOM-1211 - a 6.53-mile segment of the river, which includes
DMWW's intake at Prospect Park in Des Moines.
2. Raccoon River IA 04-KAC-1116 - a 15.b9 -mile segment of the river, including the entire
section that runs through Des Moines Water Works Park and includes the intake at the
Fleur Drive Treatment Plant in Des Moines.
Board of Water Works Trustees
74
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DMWW has raised concerns about nitrate in raw source waters for years. We built our nitrate
removal facility in 1992 to combat the issue, and since that time nitrate concentrations in the
river flowing past the intake at our Fleur Drive Treatment Plant have not improved. (See chart).
MONTHLY AVERAGE NITRATE CONCENTRATION - RACCOON RIVER
JANUARY 1974 - AUGUST 2024
70
18
1G
Monthly average nitrate concentrations show significant volatility, but the trend line in both
rivers continues to increase. This year, nitrate concentrations in the Raccoon River were among
the highest we have seen, reaching a peak of 18.23 mg/L on June 24, nearly doubling the
drinking water standard of 10 mg/L. In the Des Moines River, nitrate concentrations reached
15.56 mg/L on May 16, also higher than the drinking water standard.
Des Moines Water Works supports EPA's proposed additions to the 2024 impaired waters list, as
it is our hope that the creation of Total Maximum Daily Loads (TMDLs) will allow for more
sustainable drinking water sources well into the future. Thank you for the opportunity to
comment.
Please feel free to contact me if you have any questions or need additional information.
Sincerely,
Ted Corrigan,
CEO and General Manager
Des Moines Water Works <
Des Moines, Iowa
75
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From:
To:
Cc:
Subject:
Date:
Ed Brocksmith
R7-WaterDivision
Ed Brocksmith
Iowa water polution
Friday, December 13, 2024 9:01:32 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing
unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
I remember when Arkansas refused the EPA's request to add impaired waters. EPA
added them anyway.
Sincerely,
Ed Brocksmith
Tahlequah, Oklahoma
76
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From:
To:
Subject:
Date:
Robert Swanson
R7-WaterDivision
Iowa DNR and water
Friday, December 13, 2024 9:07:32 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
1 Renner Boulevard
Lenexa, KS 66219
Dear Mr. KoMcliaucl,
I urge you to require the Iowa Department of Natural Resources to atiltil the seven
impairments the US Environmental Protection Agency identified as containing
unhealthy and dangerous nitrate levels to 2024 Iowa 301 impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mig/L or higher.
So far the Iowa DNR is resisting their inclusion. To protect the public health of all
lowams, each segment should be assign ;ory 5 impairment and require a TMDL
for the following reasons:
¦ mi ii 'I 111 DNR is improperly applying 111 > IH "o rule to determine nitrate impairments.
This rule us athematical calculation developed by the EPA to designate a water as
impaired if water samples reveal pollutants 10% of the time. While the I pports
this rule for a variety of pollutants, it does not do so for nitrate due to its established
toxicity.
Consuming water laden with nitrate levels of 10 nig/L or more endangers public health.
It can cause methemoglobinemia, blue baby syndroi: condition in infants.
Studies link consuming high nitrate levels to colorectal, kidney, ovarian, stomach and
thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mig/L one hundred percent of the
time. The I"'1 II"1 • methodology for measuring the nitrate levels I ¦ ih "4 rule is
faulty and irresponsible.
; DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies i iiitfall and drought oven j \ nod of several years. This is another
flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
'¥ jcoach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairme n't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
enable watershed groups to accurately develop plans that can have a meaningful impact
on mitigating polluted waterways.
The Iowa Environmental Council recommends II"1,1 II"1 u i ill § year window to
evaluate impairments in waterways, a common-sense approach that would give a more
accurate assessment of the presence of pollutants.
'¥ usal to add these seven segments to the 2024 303(d) list does a disservice to
lowams. Half of Io1 -ways that undergo tests are impaired, and only half are
77
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tested every two years. This is an appalling state of affairs. At the very least, the Iowa
I" 1 I"1 I »uM add these waterbodies to the 2024 list and ji letter job protecting public
health.
Sincerely yours,
Robert and Cynthia Swanson
78
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From:
To:
Subject:
Date:
Attachments:
JAN CORDERMAN
R7-WaterDivision
2024 Iowa 303(d) list of impaired waters
Friday, December 13, 2024 9:48:17 AM
December 13. 2024. to EPA re IA DNR .docx
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Please consider the attached letter in your deliberations regarding this matter.
Jan Corderman, Steering Committee
Iowa Alliance for Responsible Ag
79
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December 13, 2024
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list of
impaired waters.
Numerous water samples revealed these water segments affecting the Cedar,
Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10
mg/L or higher. So far the Iowa DNR is resisting their inclusion. To protect
the public health of all Iowans, each segment should be assigned a Category
5 impairment and require a TMDL for the following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants 10%
of the time. While the EPA supports this rule for a variety of pollutants, it
does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a fatal
condition in infants. Studies link consuming high nitrate levels to colorectal,
kidney, ovarian, stomach and thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate levels
using the 10% rule is faulty and irresponsible.
80
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( 2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annua! cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments.
In wet years, as we saw this spring, rivers and streams that previously
appeared unimpaired contain high levels of nitrate and phosphorus pollutants
released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet
year then removing it during a dry year if impairments don't appear present is
inconsistent and problematic. It doesn't provide an accurate picture of Iowa's
water quality nor does it enable watershed groups to accurately develop plans
that can have a meaningful impact on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a
disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling state
of affairs. At the very least, the Iowa DNR should add these waterbodies to
the 2024 list and do a better job protecting public health.
Sincerely yours.
Jan Corderman
81
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From:
To:
Subject:
Date:
Paula A. Mohr
R7-WaterDivision
Iowa"s rivers
Friday, December 13, 2024 9:56:51 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I live near the Des Moines River and I am writing to urge you to require the Iowa
Department of Natural Resources to add the seven impairments the US
Environmental Protection Agency identified as containing unhealthy and dangerous
nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk rivers had nitrate levels of 10 mg/L or
higher. So far the Iowa DNR is resisting their inclusion. To protect the public health of
all lowans, each segment should be assigned a Category 5 impairment and require a
TMDL for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments.
This rule uses a mathematical calculation developed by the EPA to designate a water
as impaired if water samples reveal pollutants 10% of the time. While the EPA
supports this rule for a variety of pollutants, it does not do so for nitrate due to its
established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public
health. It can cause methemoglobinemia, blue baby syndrome, a fatal condition in
infants. Studies link consuming high nitrate levels to colorectal, kidney, ovarian,
stomach and thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent
of the time. The DNR's methodology for measuring the nitrate levels using the 10%
rule is faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies of rainfall and drought over a period of several years. This is another
flawed approach.
82
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During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year
then removing it during a dry year if impairments don't appear present is inconsistent
and problematic. It doesn't provide an accurate picture of Iowa's water quality nor
does it enable watershed groups to accurately develop plans that can have a
meaningful impact on mitigating polluted waterways
The Iowa Environmental Council recommends the DNR use a 5-10 year window to
evaluate impairments in waterways, a common-sense approach that would give a
more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a
disservice to lowans. Half of Iowa's waterways that undergo tests are impaired, and
only half are tested every two years. This is an appalling state of affairs. At the very
least, the Iowa DNR should add these waterbodies to the 2024 list and do a better job
protecting public health.
Sincerely,
Paula Mohr
Keosauqua, Iowa
83
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From: Lori Lohman
To: R7-WaterDivision
Subject: Iowa Water Quality
Date: Friday, December 13, 2024 10:07:58 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Rentier Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments the US
Environmental Protection Agency identified as containing unhealthy and dangerous nitrate levels to 2024
Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines, Iowa, Raccoon,
and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all lowans, each segment should be assigned a Category 5
impairment and require a TMDL for the following reasons:
( 1) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule uses a
mathematical calculation developed by the EPA to designate a water as impaired if water samples reveal
pollutants 10% of the time. While the EPA supports this rule for a variety of pollutants, it does not do so for
nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health. It can cause
methemoglobinemia, blue baby syndrome, a fatal condition in infants. Studies link consuming high nitrate
levels to colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the time. The DNR's
methodology for measuring the nitrate levels using the 10% rule is faulty and irresponsible.
( 2 ) The DNR bases the remov al or inclusion of impaired waters on the 303(d) list on annual cycles of
water data monitoring. But that doesn't take into account the inconsistencies of rain tall and drought over a
period of several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years, as we saw this
spring, rivers and streams that previously appeared unimpaired contain high levels of nitrate and phosphorus
pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then remov ing it during a
dry year if impairments don't appear present is inconsistent and problematic. It doesn't prov ide an accurate
picture of Iowa's water quality nor does it enable watershed groups to accurately dev elop plans that can
have a meaningful impact on mitigating polluted waterways.
The Iowa Env ironmental Council recommends the DNR use a 5-10 year w indow to ev aluate impairments in
waterways, a common-sense approach that would give a more accurate assessment of the presence of
pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to lowans. Half of
Iowa's waterways that undergo tests are impaired, and only half are tested every two years. This is an
appalling state of affairs. At the very least, the Iowa DNR should add these waterbodies to the 2024 list and
do a better job protecting public health.
Sincerely yours,
Lori Lohman
84
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From:
To:
Subject:
Date:
Fonziba Koster
R7-WaterDivision
Please add these waters to the list of impaired waters in Iowa
Friday, December 13, 2024 11:02:04 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the
following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
(2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
85
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The DNR*s approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these
waterbodies to the 2024 list and do a better job protecting public health.
Sincerely,
Fonziba Koster
Fonziba Koster
86
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From: Roger Leahv
To: R7-WaterDivision
Cc: Diane Rosenberg - JFAN
Subject: Require the Iowa DNR to Add Waterways with Dangerous Nitrate Levels to the Impaired Water List
Date: Friday, December 13, 2024 12:26:13 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing
unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or
higher. So far the Iowa DNR is resisting their inclusion. To protect the public health of
all lowans, each segment should be assigned a Category 5 impairment and require a
TMDL for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments.
This rule uses a mathematical calculation developed by the EPA to designate a water
as impaired if water samples reveal pollutants 10% of the time. While the EPA
supports this rule for a variety of pollutants, it does not do so for nitrate due to its
established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public
health. It can cause methemoglobinemia, blue baby syndrome, a fatal condition in
infants. Studies link consuming high nitrate levels to colorectal, kidney, ovarian,
stomach and thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent
of the time. The DNR's methodology for measuring the nitrate levels using the 10%
rule is faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies of rainfall and drought over a period of several years. This is another
flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year
then removing it during a dry year if impairments don't appear present is inconsistent
and problematic. It doesn't provide an accurate picture of Iowa's water quality nor
does it enable watershed groups to accurately develop plans that can have a
meaningful impact on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to
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evaluate impairments in waterways, a common-sense approach that would give a
more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a
disservice to lowans. Half of Iowa's waterways that undergo tests are impaired, and
only half are tested every two years. This is an appalling state of affairs. At the very
least, the Iowa DNR should add these waterbodies to the 2024 list and do a better job
protecting public health.
Sincerely,
Roqer Leah\
88
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From:
To:
Subject:
Date:
Patricia Timmens
R7-WaterDivision
Iowa nitrate levels
Friday, December 13, 2024 1:03:40 PM
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
Dear Mr. Robichaud,
I am hopeful you will require the Iowa Department of Natural Resources to add the seven impairments the US
Environmental Protection Agency identified as containing unhealthy and dangerous nitrate levels to 2024 Iowa
303(d) list of impaired waters.
Water samples revealed these water segments affecting the Cedar, Des Moines, Iowa, Raccoon, and South Skunk
Rivers had nitrate levels of 10 mg/L or higher. Iowa DNR is resisting their inclusion. To protect the public health of
all of us in Iowa, each segment should be assigned a Category 5 impairment and require a TMDL for the following
reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule uses a mathematical
calculation developed by the EPA to designate a water as impaired if water samples reveal pollutants 10% of the
time. While the EPA supports this rule for a variety of pollutants, it does not do so for nitrate due to its established
toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more is dangerous. It can cause methemoglobinemia, blue
baby syndrome, a fatal condition in infants. Studies link consuming high nitrate levels to colorectal, kidney, ovarian,
stomach and thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the time. The DNR's
methodology for measuring the nitrate levels using the 10% rule is faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual cycles of water data
monitoring. That does not take into account the inconsistencies of rainfall and drought over a period of several
years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years, as we saw this spring,
rivers and streams that previously appeared unimpaired contain high levels of nitrate and phosphorus pollutants
released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then removing it during a dry
year if impairments don't appear present is inconsistent and problematic. It doesn't provide an accurate picture of
Iowa's water quality nor does it enable watershed groups to accurately develop plans that can have a meaningful
impact on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to evaluate impairments in
waterways, a common-sense approach that would give a much more accurate assessment of the presence of
pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to all of us in Iowa. Half of
Iowa's waterways that undergo tests are impaired, and only half are tested every two years. This is appalling. At the
very least, the Iowa DNR should add these waterbodies to the 2024 list and do a better job protecting our public
health.
Thank you for your time and attention.
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Patricia Timmens in Cincinnati Iowa.
-------
From: Michael Schmidt
To: R7-WaterDivision
Cc: Josh Mandelbaum
Subject: Comments on Iowa impaired waters list
Date: Friday, December 13, 2024 2:06:01 PM
Attachments: imaaeOOl.pna
IEC comments - 2024 EPA 303d additions.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Mr. Robichaud:
I have attached comments on behalf of the Iowa Environmental Council and Environmental Law &
Policy Center regarding EPA's proposed disapproval of Iowa's 2024 impaired waters list. Please
contact us if you have any questions regarding these comments.
Thank you for the opportunity to comment.
Sincerely,
I ¦
Michael R. Schmidt (he/him) | General Counsel
Iowa Environmental Council
505 Fifth Avenue Suite 850
Des Moines IA 50309
iaenvironment. org
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Vs J Iowa
'SCSC Environmental
x/x/
= Council
December 13, 2024
Jeffery Robichaud
Water Division
U.S. EPA Region 7
11201 Renner Blvd
Lenexa, KS 66219
Email: R7-WaterDivision@epa.gov
RE: 2024 List of Iowa Impaired Waters
Dear Mr. Robichaud:
505 Fifth Avenue, Suite 850
Des Moines, Iowa 50309-2317
515.244.1194 phone
iecmail@iaenvironment.org
www. i aenvironm ent. or g
The Iowa Environmental Council (IEC) and Environmental Law & Policy Center (ELPC) offer
the following comments on the action proposed by the U.S. Environmental Protection Agency
(EPA) on Iowa's 2024 list of Section 303(d) impaired waters. IEC is a nonprofit alliance of 100
organizations, at-large board members from business, farming, the sciences and education, and
over 500 individual members. ELPC is a non-profit corporation with an office in Des Moines
that works to promote clean energy, clean air, and clean water.
IEC and ELPC have raised concerns about nitrate in drinking water for years, including a
petition for emergency action to address groundwater contamination in Northeast Iowa and a
recently-updated report by IEC on health impacts of nitrate. We appreciate that EPA's action
recognizes the persistent problem Iowa faces in addressing continued nitrate pollution.
I. GENERAL COMMENTS
EPA has requested comment on its proposed addition of seven impairments to Iowa's impaired
waters list.
The additions by EPA reflect a numeric standard for nitrate applicable for drinking water uses.
Iowa's impaired waters list is incomplete for other uses because Iowa still lacks numeric
nutrient criteria or a microcystin standard. EPA issued recommendations for microcystin and
numeric nutrient water quality standards that would protect recreational users from harmful algae
blooms. In fact, the EPA's numeric nutrient criteria recommendations relied heavily on Iowa
water quality data. When the Iowa Department of Natural Resources (DNR) released the 2020
and 2022 impaired waters lists, IEC called on the state to adopt microcystin and numeric nutrient
criteria. DNR has not indicated that it will adopt those standards, and no timeline or formal
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process has been set to begin the process of adopting criteria. DNR left those priorities out of the
2021-2023 Triennial Review.
DNR has an opportunity to include development of numeric nutrient criteria in the 2024-2026
Triennial Review, which the agency should conduct this year to satisfy the three-year
requirement in federal regulations.1 DNR has the information it needs to begin the work of
adopting criteria, which are necessary to understand the condition of Iowa's waters and make
progress on protecting Iowans from negative health impacts.
II. ADEQUACY OF MONITORING
The state's monitoring program is not sufficiently rigorous and does not allow for comparison
over time. When the impaired waters list is released, DNR staff takes the position that the results
cannot be interpreted to give Iowans an understanding of Iowa's water quality. This is due at
least partially to using data that is collected from all available sources instead of being collected
through a standardized, rigorous monitoring scheme that allows comparison over time.2 EPA's
action in this case reflects, in part, the different sources of water quality monitoring data in Iowa.
If the state provided greater funding to support a common monitoring plan that used a watershed
approach to collect data and assess water quality, the impaired waters list would be a much more
useful tool for actually understanding the state's water quality and progress toward meeting
water quality standards. IEC and ELPC urge the development of a standardized monitoring plan
using the watershed approach that is scientifically rigorous, allows interpretation of results, and
is useful to the public. Such a plan might resemble Minnesota's watershed lake and stream
monitoring program, which fully assesses watersheds on a 10-year cycle.
III. MONITORING METHODOLOGY
IEC and ELPC support EPA's proposed action for two reasons: the inapplicability of the "10%
rule" to nitrate and the monitoring window considered by DNR.
a. Nitrate Methodology
Iowa DNR has relied on a "10% rule" to determine whether waters with limited data qualify as
supporting their designated uses or impaired. The rule uses a mathematical evaluation developed
by EPA to assess the likelihood of an exceedance based on small numbers of samples. DNR has
used the method in past years to assess water quality for nitrate that applies to drinking water
1 33 U.S.C. § 1313(c)(1); 40 C.F.R. § 131.20(a). Iowa DNR's last review of water quality standards was conducted
in 2021. See Iowa DNR, "Triennial Review Work Plan and Responsiveness Summary 2021-2023" (Sept. 2021),
available at
https://www.iowadnr.gov/Portals/idnr/uploads/watermonitoring/standards/Iowas%20Triennial%20Review%20Work
%20Plan%202021 -2023 .pdf.
2 Iowa DNR. "Methodology for Iowa's 2024 Water Quality Assessment, Listing, and Reporting Pursuant to Sections 305(b),
303(d), and 314 of the Federal Clean Water Act" ("Methodology"). 29 Sept. 2023. Pg. 13-16.
2
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sources.3 In its 2024 assessment methodology, DNR expanded its use of the 10% rule to use a
modified approach for waters with seven to nine samples.4
EPA supported the use of this rule for conventional pollutants such as biochemical oxygen
demand. However, in its review of DNR's 2024 methods, EPA called for DNR not to apply the
approach to nitrate in its public comments to the state.5 EPA reasoned that nitrate is not a
conventional pollutant and has known toxicity; allowing exceedances does not align with the
designated use.6
IEC and ELPC agree with EPA that allowing nitrate to exceed the drinking water standard as
proposed by DNR is inconsistent with the water body fully supporting the designated use. Water
treatment providers need to ensure that nitrate is below the standard at all times, not just 90
percent of the time. As EPA noted in its proposed decision document, the drinking water
standard was calculated "to protect infants, and all other groups, against the nononcogenic
effects presented by nitrate and nitrite in drinking water."7
IEC summarized the risks of high nitrate concentrations for human health in Nitrate in Drinking
Water: A Public Health Concern for All Iowans, updated in 2024.8 The report notes that the
drinking water standard protects against acute health risks - those that occur with short-term
exposure. Allowing any fraction of exceedance above the standard would increase the risk of
methemoglobinemia.
b. Monitoring Window
DNR's approach to use one cycle to impair and a three-year window of monitoring data to delist
for all impairments is not rational or practical. DNR's reliance on a three-year period to list and
delist waters for impairment is not reasonable or practical for the purposes of addressing
impairments.9 When a waterway does not show signs of an impairment during one cycle, it does
not mean that the waterway has actually improved or the impairment has been addressed. As we
have seen in recent years, drought has seriously impacted the flows of Iowa's streams and rivers.
Reduced flows can mask an impairment due to temporary reductions of pollutants entering
waterways. However, the impairment may quickly reappear when flows return to normal. Using
one cycle to remove waters from the list could create a situation where a waterway is removed
and added to the list, back and forth, in subsequent cycles, leaving it in limbo for development of
3 See Iowa DNR, "Methodology for Iowa's 2022 Water Quality Assessment, Listing, and Reporting Pursuant to
Sections 305(b) and 303(d) of the Federal Clean Water Act," Feb. 9, 2022, at 49.
4 Iowa DNR, "Methodology for Iowa's 2024 Water Quality Assessment, Listing, and Reporting Pursuant to Sections
305(b), 303(d), and 314 of the Federal Clean Water Act," Sept. 29, 2023, at 11.
5 U.S. EPA Region 7, "Partial Approval/Partial Disapproval of Iowa's 2024 Section 303(d) List," Nov. 12, 2024, at
9.
6 Id. at 13.
7 Id. (citing National Primary Drinking Water Regulations Final Rule, 1991).
8 IEC (May 2024), available at
https://www.iaenvironment.org/webres/File/IEC Nitrate in Drinking Water 2024FINAL.pdf.
9 Id at 14 (describing use of three year periods for binomial parameters).
3
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a TMDL and causing confusion for watershed groups that are trying to make improvements and
install pollution reduction practices.
Analysis of longer-term nitrate data show that there has not been a significant improvement in
nitrate loading in the Cedar River.10 Estimated annual concentrations of nitrate-N increased from
5.1 mg/L in 1990 to 6.6 mg/L in 2020.11 DNR cannot reasonably conclude that the Cedar River
no longer has a nitrate problem. As shown in Figure 1, the Des Moines River has similarly had
temporary declines during the 2020-2022 period that DNR considered, despite significantly
exceeding the standard in 2024 and showing a small upward trend during this period.
Figure 1. Nitrate Concentrations in the Des Moines River at 2nd Ave,
2020-2024 (with linear trendline).12
18
DNR should consider moving to a 5- or 10-year window for assessing waters for impairments.
The longer window would conform to the window used to assess progress on the Nutrient
Reduction Strategy.
IV. CONCLUSION
IEC and ELPC support EPA's proposed additions to the 2024 impaired waters list. While Iowa's
drinking water utilities have a strong track record of meeting drinking water standards, the state
faces serious problems with nitrate contamination in drinking water sources and needs stronger
action to ensure that all Iowans will have safe drinking water in the future.
"Water Quality Gauge, Cedar River, Palo, IA," Iowa Water Quality Information System, IIHR. University of
Iowa (last accessed Nov. 7, 2022), available at: https://iwqis.iowawis.org/app/.
11 Stephen J. Kalkhoff, "Hydrologic and Water-Quality Conditions in the Cedar River Alluvial Aquifer, Linn
County, Iowa, 1990-2019," U.S. Geological Survey (2021) at 48.
12 U.S. Geological Survey, available at https://waterdata.usgs.gov/monitoring-location/05482000/.
4
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Thank you for the opportunity to comment on the draft 2024 impaired waters list. Please let us
know if you have questions about these comments.
Sincerely,
/s/ Michael R. Schmidt
Michael R. Schmidt
General Counsel
Iowa Environmental Council
505 5th Ave. Suite 850
Des Moines, IA 50309
/s/ Joshua T. Mandelbaum
Joshua T. Mandelbaum
Senior Attorney
Environmental Law & Policy Center
505 5th Ave. Suite 333
Des Moines, IA 50309
5
96
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From:
To:
Subject:
Date:
marv Johannsen
R7-WaterDivision
Iowa DNR Water Regulations
Friday, December 13, 2024 10:52:02 AM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
am urging the EPA to require the Iowa DNR to do it's job to protect Iowans from polluted
waterways. Iowa is now #2 in the Nation for rising cancer levels. The Confined Animal
Feeding Operations (CAFO) industry in Iowa is in all reality unregulated. Until Iowa citizens
are protected by our own State Legislators, we need the federal government office like the
EPA to atleast inform us of the continued high levels of contaminated waterways.
Mary Johannsen
Concerned Iowa Citizen
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Caution; This email originated from outside EPA, please exercise additional caution when deciding
whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing unhealthy
and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher.
So far the Iowa DNR is resisting their inclusion. To protect the public health of all
lowans, each segment should be assigned a Category 5 impairment and require a TMDL
for the following reasons:
(1) The DNR is improperly applying the 10% rule to determine nitrate impairments. This
rule uses a mathematical calculation developed by the EPA to designate a water as
impaired if water samples reveal pollutants 10% of the time. While the EPA supports
this rule for a variety of pollutants, it does not do so for nitrate due to its established
toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health.
It can cause methemoglobinemia, blue baby syndrome, a fatal condition in infants.
Studies link consuming high nitrate levels to colorectal, kidney, ovarian, stomach and
thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of
the time. The DNR's methodology for measuring the nitrate levels using the 10% rule is
faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies of rainfall and drought over a period of several years. This is another
flawed approach.
98
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During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
enable watershed groups to accurately develop plans that can have a meaningful impact
on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to
evaluate impairments in waterways, a common-sense approach that would give a more
accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice
to lowans. Half of Iowa's waterways that undergo tests are impaired, and only half are
tested every two years. This is an appalling state of affairs. At the very least, the Iowa
DNR should add these waterbodies to the 2024 list and do a better job protecting
public.
Sincerely,
Pamela Karll Slowick
Fairfield, IA.
99
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From:
To:
Subject:
Date:
Dan Haua
R7-WaterDivision
Public comment on Iowa's 2024 Section 303(d) list and 7 water segments being added
Friday, December 13, 2024 5:17:04 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear Water Division Staff,
I agree with the EPA's decision to add seven river segments to Iowa's impaired waters list. I hope
that this change will lead to greater transparency about how nitrate pollution of surface waters
affects the cost and safety of drinking water, but am concerned there will be unintended
consequences.
Iowa's Credible Data Law has sometimes been a convenient excuse to assess fewer waters, and
thereby discover fewer problems. However, that doesn't seem to be the issue here. Each of the
water bodies on this list had at least one "credible" nitrate sample violating the 10 mg/L drinking
water standard during the three year assessment period.
• Raccoon River: 38/755
• Cedar River: 1/36 or 7/151
• Lower Pes Moines River: 2/33
• Upper Pes Moines River: 11/758
• Iowa River: 5/146 or 18/2698
• South Skunk River: 2/36
As I understand it, the issue is the threshold for impairment. Since fewer than 10% of the samples
(accounting for some statistical correction factor) exceeded 10 mg/L, IDNR says these sites meet the
standard. EPA says they do not.
The Iowa DNR's position is not defensible. In the draft 2024 assessment, Raccoon River near Des
Moines was shown as fully supporting its designated use for drinking water because
A) Nitrate in the Raccoon River exceeded 10 mg/L nitrate less than 10% of the time during the 2020-
2022 assessment period
B) Nitrate in finished drinking water at the Des Moines Waterworks never exceeded 10 mg/L.
This makes no sense. Even one sample exceeding the Maximum Contaminant Level for nitrate would
constitute a violation of the Safe Drinking Water Act, requiring public notice. To avoid this, the Des
Moines Waterworks had to run its nitrate removal facility for weeks in 2022 at a cost of $10,000 a
day, as well as blending water from other sources and asking residents to reduce water use. Clearly,
poor water quality is limiting that beneficial use of the river water!
However, the South Skunk River no longer supplies drinking water to the City of Oskaloosa. The City
now gets its water from an alluvial aquifer, and is able to achieve low levels of nitrate in finished
water (1.17 mg/L, in the latest Consumer Confidence report) without expensive treatment. I
understand that the Clean Water Act does not allow designated uses to be removed if restoring
them is still achievable. However, I hope that in prioritizing and writing TMDLs we can be cognizant
of facts on the ground. In the unlikely event that a TMDL for the Skunk Skunk River is written and it
leads to stricter effluent limits for upstream point sources, we might be imposing real costs on Ames,
Story City, and Nevada without achieving real benefits for Oskaloosa.
I am also concerned that disallowing the 10% binomial rule might lead to further politicization of
funding for water monitoring. Water quality in rivers is highly variable, and daily or weekly
monitoring might pick up on a short-term spike in nitrate that is missed by monthly monitoring. If a
single sample can trigger impairment but there are no rules on how often a site has to be monitored,
cutting budgets for monitoring programs becomes a tempting way to evade regulation and
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controversy.
Dan Haug ~ Water Quality Specialist
Prairie Rivei's of Iowa ~ 501(c)(3) Non-Profit
3116 S, Duff Avenue, Suite 201 ~ Ames, IA 50010
tel. 515.232.0048 ~ fax 515.233.1131
dhaug@Drrcd.org ~ www.orrcd.org
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From:
To:
Subject:
Date:
Steven Paulsrud
R7-WaterDivision
Water
Friday, December 13, 2024 6:37:10 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing unhealthy
and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher.
So far the Iowa DNR is resisting their inclusion. To protect the public health of all
Iowans, each segment should be assigned a Category 5 impairment and require a TMDL
for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments.
This rule uses a mathematical calculation developed by the EPA to designate a water as
impaired if water samples reveal pollutants 10% of the time. While the EPA supports
this rule for a variety of pollutants, it does not do so for nitrate due to its established
toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health.
It can cause methemoglobinemia, blue baby syndrome, a fatal condition in infants.
Studies link consuming high nitrate levels to colorectal, kidney, ovarian, stomach and
thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of
the time. The DNR's methodology for measuring the nitrate levels using the 10% rule is
faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies of rainfall and drought over a period of several years. This is another
flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
102
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enable watershed groups to accurately develop plans that can have a meaningful impact
on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to
evaluate impairments in waterways, a common-sense approach that would give a more
accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice
to Iowans. Half of Iowa's waterways that undergo tests are impaired, and only half are
tested every two years. This is an appalling state of affairs. At the very least, the Iowa
DNR should add these waterbodies to the 2024 list and do a better job protecting public
health.
Sincerely yours,
Your Signature
Steven Paulsrud, D.O.
103
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From:
To:
Subject:
Date:
Murray Foster
R7-WaterDivision
Require the Iowa DNR to Add Waterways with Dangerous Nitrate Levels to the Impaired Water List
Friday, December 13, 2024 10:57:00 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments
the US Environmental Protection Agency identified as containing unhealthy and dangerous
nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines,
Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the
Iowa DNR is resisting their inclusion. To protect the public health of all Iowans, each segment
should be assigned a Category 5 impairment and require a TMDL for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule
uses a mathematical calculation developed by the EPA to designate a water as impaired if
water samples reveal pollutants 10% of the time. While the EPA supports this rule for a
variety of pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health. It can
cause methemoglobinemia, blue baby syndrome, a fatal condition in infants. Studies link
consuming high nitrate levels to colorectal, kidney, ovarian, stomach and thyroid cancers as
well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the time.
The DNR's methodology for measuring the nitrate levels using the 10% rule is faulty and
irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual
cycles of water data monitoring. But that doesn't take into account the inconsistencies of
rainfall and drought over a period of several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years, as
we saw this spring, rivers and streams that previously appeared unimpaired contain high levels
of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it enable
watershed groups to accurately develop plans that can have a meaningful impact on mitigating
104
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polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to evaluate
impairments in waterways, a common-sense approach that would give a more accurate
assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to
Iowans. Half of Iowa's waterways that undergo tests are impaired, and only half are tested
every two years. This is an appalling state of affairs. At the very least, the Iowa DNR should
add these waterbodies to the 2024 list and do a better job protecting public health.
105
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From:
To:
Subject:
Date:
Diane James
R7-WaterDivision
Iowa Water
Saturday, December 14, 2024 5:11:31 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear Mr. Robichaud,
Please require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the
following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
(2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
106
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The DNR's approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these
waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
Diane James
107
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From:
To:
Subject:
Date:
Nancv Leahv
R7-WaterDivision
Please uphold our water safety!
Saturday, December 14, 2024 11:18:10 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their inclusion.
To protect the public health of all lowans, each segment should be
assigned a Category 5 impairment and require a TMDL for the following
reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
108
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(2) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
severalyears. This is anotherflawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a
wetyearthen removing it duringa dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10year
window to evaluate impairments in waterways, a common-sense
approach that would give a more accurate assessment of the presence of
pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list
does a disservice to lowans. Half of Iowa's waterways that undergo tests
are impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these
waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
Nancy Leahy
-------
From:
To:
Subject:
Date:
Susan Johnson
R7-WaterDivision
Clean water for all Iowans
Saturday, December 14, 2024 6:18:35 PM
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
VIr. Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments
the US Environmental Protection Agency identified as containing unhealthy and dangerous
nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines,
Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the
Iowa DNR is resisting their inclusion. To protect the public health of all Iowans, each segment
should be assigned a Category 5 impairment and require a TMDL for the following reasons:
(1) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule
uses a mathematical calculation developed by the EPA to designate a water as impaired if
water samples reveal pollutants 10% of the time. While the EPA supports this rule for a
variety of pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health. It can
cause methemoglobinemia, blue baby syndrome, a fatal condition in infants. Studies link
consuming high nitrate levels to colorectal, kidney, ovarian, stomach and thyroid cancers as
well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the time.
The DNR's methodology for measuring the nitrate levels using the 10% rule is faulty and
irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual
cycles of water data monitoring. But that doesn't take into account the inconsistencies of
rainfall and drought over a period of several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years, as
we saw this spring, rivers and streams that previously appeared unimpaired contain high levels
of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it enable
watershed groups to accurately develop plans that can have a meaningful impact on mitigating
110
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polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to evaluate
impairments in waterways, a common-sense approach that would give a more accurate
assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to
Iowans. Half of Iowa \ waterways that undergo fesls are impaired, and only half are tested
every two years. This is an appalling state of affairs. At the very least, the Iowa DNR should
add these waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
Frances Bumieister
111
-------
From:
To:
Subject:
Date:
iennifer fishback
R7-WaterDivision
Iowa Dept. of Natural Resources
Saturday, December 14, 2024 9:47:59 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
USEPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
Please convince the Iowa DNR to add the seven impairments that have unhealthy nitrate levels
to the 2024 Iowa list of impaired waters. The Cedar, Des Moines, Iowa, Raccoon, and South
Skunk Rivers had nitrate levels of lOmg or higher. They need a category 5 impairment.
The Iowa DNR is using the 10% rule to measure these waterways but you're not supposed to
use that for nitrates. Those waters should never be at 10%. High nitrates are linked to
colorectal, kidney, ovarian, stomach, and thyroid cancer, plus birth defects. Drinking water
should never exceed 10%. Cancer rates in Iowa are very high and growing higher.
The Iowa DNR measurements don't take drought into consideration. Wet years show more
accurately how much impairment there really is. During drought, levels don't measure as high
so these rivers are taken off the lists not because they are not impaired but because it is too dry
to tell. That inconsistency makes it difficult to make a clear correction plan. Iowa
Environmental Council suggests the Iowa DNR use a 5-10 year window to evaluate, which
would be more accurate, but the DNR refuses.
We hope you can help all of us in Iowa with our continuing water problems.
Sincerely,
Jennifer Fishback
112
-------
From:
To:
Subject:
Date:
Jim Karpen
R7-WaterDivision
Please crack down on Iowa"s DNR
Sunday, December 15, 2024 10:59:04 AM
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
Thank you for your efforts to protect Iowans. We have the second highest cancer rate in the country, and I hope that
your vigilance will improve that.
Please ensure that segments of the Des Moines, Raccoon, Cedar, Iowa and South Skunk Rivers are added to the list
of segments requiring a TDML. These segments have high levels of nitrates. Iowa's DNR is using a faulty and
inconsistent method to measure nitrates.
The DNR should also create a plan to mitigate high nitrate levels.
We appreciate your efforts.
Jim
113
-------
From: Bob Koczela
To: R7-WaterDivision
Subject: Please protect Iowans from toxic water
Date: Sunday, December 15, 2024 6:49:28 PM
Attachments: Letter to EPA.12-15-24.pdf
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear Mr. Robichaud,
Please find my signed letter below.
Thank you.
Sincerely,
Bob Koczela
Bob Koczela
Expert Tree Consulting. Inc.
A.S., Arboriculture
Certified Arborist, ISA #MW-5052A
Member, Past Board Member, Iowa Arborist Association
114
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Dear Mr, Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing unhealthy
and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines,
Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the
Iowa DNR is resisting their inclusion. To protect the public health of all lowans, each
segment should be assigned a Category 5 impairment and require a TMDL for the following
reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments. This
rule uses a mathematical calculation developed by the EPA to designate a water as
impaired if water samples reveal pollutants 10% of the time. While the EPA supports this
rule for a variety of pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health. It
can cause methemoglobinemia, blue baby syndrome, a fatal condition in infants. Studies
link consuming high nitrate levels to colorectal, kidney, ovarian, stomach and thyroid
cancers as well as birth defects.
Drinking water should never exceed nit-ate levels of 10 mg/L one hunt/red percent of the
time. The DNR's methodology for measuring the nitrate levels using the 10% rule is faulty
and irresponsible.
(2) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual
cycles of water data monitoring. But that doesn't take into account the inconsistencies of
rainfall and drought over a period of several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years,
as we saw this spring, rivers and streams that previously appeared unimpaired contain high
levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
enable watershed groups to accurately develop plans that can have a meaningful impact
on mitigating polluted waterways.
The lows Environmental Council recommends the DNR use a 5-10 year window to evaluate
impairments in waterways, a common-sense approach that would give a more accurate
assessment of the presence of pollutants
115
-------
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to
lowarts. Half of Iowa's waterways that undergo tests are impaired, and only half are tested
every two years. This is an appalling state of affairs. At the very least, the Iowa DNR should
add these waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours, ,
Bob Koc^ela
Expert Tree Consulting. Inc.
A.S., Arboriculture
Certified Arborist, ISA #MW-505?A
Member, Past Board Member, Iowa Arborist Association
116
-------
From:
To:
Subject:
Date:
Sheila Grecian
R7-WaterDivision
Iowas'water quality
Monday, December 16, 2024 10:41:49 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I am a native Iowan and am outraged at how Big Ag has been allowed to destroy our
water!! I live in Des Moines where we pay more for nitrate removal systems, and I do
not drink the water when I travel through rural Iowa. It is shameful!
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing unhealthy
and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher.
So far the Iowa DNR is resisting their inclusion. To protect the public health of all
Iowans, each segment should be assigned a Category 5 impairment and require a TMDL
for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments.
This rule uses a mathematical calculation developed by the EPA to designate a water as
impaired if water samples reveal pollutants 10% of the time. While the EPA supports
this rule for a variety of pollutants, it does not do so for nitrate due to its established
toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health.
It can cause methemoglobinemia, blue baby syndrome, a fatal condition in infants.
Studies link consuming high nitrate levels to colorectal, kidney, ovarian, stomach and
thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of
the time. The DNR's methodology for measuring the nitrate levels using the 10% rule is
faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies of rainfall and drought over a period of several years. This is another
flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
117
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contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
enable watershed groups to accurately develop plans that can have a meaningful impact
on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to
evaluate impairments in waterways, a common-sense approach that would give a more
accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice
to Iowans. Half of Iowa's waterways that undergo tests are impaired, and only half are
tested every two years. This is an appalling state of affairs. At the very least, the Iowa
DNR should add these waterbodies to the 2024 list and do a better job protecting public
health.
Sincerely yours,
Sheila Gregan
Des Moines, IA
"The only thing necessary for the triumph of evil is for good people to do nothing"
118
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To:
Subject:
Date:
Linda Eosres
R7-WaterDivision
The DNA in Iowa mist be accountable fcr dirt/ water—a letter from an Iowan
Monday, December 16, 2024 10:48:52 /SM
| Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Jeffrey Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments the US
Environmental Protection Agency identified as containing unhealthy and dangerous nitrate levels to 2024
Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines, Iowa, Raccoon,
and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all lowans, each segment should be assigned a Category 5
impairment and require a TMDL for the following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule uses a
mathematical calculation developed by the EPA to designate a water as impaired if water samples reveal
pollutants 10% of the time. While the EPA supports this rule for a variety of pollutants, it does not do so for
nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health. It can cause
methemoglobinemia, blue baby syndrome, a fatal condition in infants. Studies link consuming high nitrate
levels to colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the time. The DNR's
methodology for measuring the nitrate levels using the 10% rule is faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual cycles of water
data monitoring. But that doesn't take into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years, as we saw this
spring, rivers and streams that previously appeared unimpaired contain high levels of nitrate and phosphorus
pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then removing it during a
dry year if impairments don't appear present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to accurately develop plans that can have
a meaningful impact on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to evaluate impairments in
waterways, a common-sense approach that would give a more accurate assessment of the presence of
pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to lowans. Half of
Iowa's waterways that undergo tests are impaired, and only half are tested every two years. This is an
appalling state of affairs. At the very least, the Iowa DNR should add these waterbodies to the 2024 list and
do a better job protecting public health.
Sincerely yours,
Linda Egenes
119
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From:
To:
Subject:
Date:
Attachments:
Diane Rosenberg
R7-WaterDivision
Public Comments Regarding Iowa 303(d) List
Monday, December 16, 2024 2:26:06 PM
imaaeOOl.ipg
JFAN Public Comments on 2024 Iowa 303fd1 List.docx
Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
Jefferson County Farmers & Neighbors, Inc. is a 501c3 community organization that
educates the public about the environmental, public health, and quality of life impacts
of concentrated animal feeding operations. In this, we advocate for clean water.
These public comments are regarding the seven impairments of the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers that the EPA is directing the Iowa
Department of Natural Resources to add to the 2024 Iowa 303(d) list. Given that the
nitrate levels of those segments were above the 10 mg/L EPA limit, it is
unconscionable that the DNR is resisting their inclusion.
We urge you to require the DNR to include those impairments for the following
reasons:
1.) Nitrate is a toxic pollutant, dangerous to health at levels higher than 10 mg/L and
fatal to infants. Numerous studies link consuming water containing high nitrate levels
to a variety of cancers including colorectal, kidney, ovarian, stomach and thyroid
cancers as well as birth defects. Studies also link nitrate consumption to these cancers
at levels between 5-10 mg/L.
The DNR is using the 10% rule to determine nitrate impairments. The EPA supports
this rule for a variety of pollutants, but not for nitrate due to its known toxicity.
Drinking water should be free of nitrates over lOmg/L 100% of the time otherwise it's
a public health threat. Iowa's cancer rates are the second highest in the nation and
continuing to grow. The state should be safeguarding its citizens by creating a TMDL
for each of these impairments.
2.) The DNR is using an annual cycle to determine whether water quality is impaired or
not, but that doesn't account for inconsistent levels of rainfall and drought. As we
continue to experience the effects of climate change and irregular weather patterns,
an annual cycle is not an effective nor accurate way to determine water impairments.
The DNR's approach of adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments aren't present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
enable watershed groups to accurately develop plans that can have a meaningful
impact on mitigating polluted waterways.
JFAN supports the Iowa Environmental Council's recommendation that the DNR use a
5-10 year window to evaluate water impairments to provide a more realistic
120
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assessment of nitrates in waterways.
3.) Not only should the seven impairments be added to the 303(d) list, there should be
a more robust effort to actually create TMDLs to improve water quality. But the DNR's
efforts are woefully inadequate and barely existent.
There are 577 Category 5 segments in the current 303(d) list that each need a TMDL.
As of today, there have been no approved TMDL's in 2024, only two in 2023, one in
2022, and three in 2021 and seven in 2020. That's a 0.02% completion rate over the
last five years. This is simply unacceptable. Iowa's dirty water will never get clean with
this paltry level of action. I urge you to require the DNR to not only add these seven
impairments, but to take serious steps to rectify all the Category 5 impairments in an
expedient manner.
Iowans deserve clean water and they deserve to have an agency that cares enough
about the public health of its citizenry. Half of our tested waterways wind up as either
Category 4 or 5 and only half are tested every two years. Why does the EPA allow this
state of affairs in Iowa?
At the very least, the EPA should require the DNR to add these seven impairments to
its 2024 Iowa 303(d) list.
We additionally support the public comments of the Iowa Environmental Council.
Sincerely yours,
Diane Rosenberg
Diane Rosenberg
President and Executive Director
Jefferson County Farmers & Neighbors, Inc.
P.O. Box 811
Fairfield, IA 52556
Toice Mail
www.jfaniowa.org
jfan@lisco.com
www.Facebook.com/JFANIowa
https: //Twitter, com/J FAN Iowa
Iowa Alliance for Responsible Agriculture (IARA)
www.iowaresponsibleagriculture.org
"It always seems impossible until it's done." - Nelson Mandela
121
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FARMS, NOT FACTORIES!
December 16, 2024
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
Jefferson County Farmers & Neighbors, Inc. is a 501c3 community organization that educates the
public about the environmental, public health, and quality of life impacts of concentrated animal
feeding operations. In this, we advocate for clean water.
These public comments are regarding the seven impairments of the Cedar, Des Moines, Iowa,
Raccoon, and South Skunk Rivers that the EPA is directing the Iowa Department of Natural
Resources to add to the 2024 Iowa 303(d) list. Given that the nitrate levels of those segments were
above the 10 mg/L EPA limit, it is unconscionable that the DNR is resisting their inclusion.
We urge you to require the DNR to include those impairments for the following reasons:
1.) Nitrate is a toxic pollutant, dangerous to health at levels higher than 10 mg/L and fatal to
infants. Numerous studies link consuming water containing high nitrate levels to a variety of
cancers including colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth defects.
Studies also link nitrate consumption to these cancers at levels between 5-10 mg/L.
The DNR is using the 10% rule to determine nitrate impairments. The EPA supports this rule for a
variety of pollutants, but not for nitrate due to its known toxicity.
Drinking water should be free of nitrates over lOmg/L 100% of the time otherwise it's a public
health threat. Iowa's cancer rates are the second highest in the nation and continuing to grow. The
state should be safeguarding its citizens by creating a TMDL for each of these impairments.
2.) The DNR is using an annual cycle to determine whether water quality is impaired or not, but
that doesn't account for inconsistent levels of rainfall and drought. As we continue to experience
the effects of climate change and irregular weather patterns, an annual cycle is not an effective nor
accurate way to determine water impairments.
The DNR's approach of adding an impaired waterway identified during a wet year then removing it
during a dry year if impairments aren't present is inconsistent and problematic. It doesn't provide
122
-------
an accurate picture of Iowa's water quality nor does it enable watershed groups to accurately
develop plans that can have a meaningful impact on mitigating polluted waterways.
JFAN supports the Iowa Environmental Council's recommendation that the DNR use a 5-10 year
window to evaluate water impairments to provide a more realistic assessment of nitrates in
waterways.
3.) Not only should the seven impairments be added to the 303(d) list, there should be a more
robust effort to actually create TMDLs to improve water quality. But the DNR's efforts are woefully
inadequate and barely existent.
There are 577 Category 5 segments in the current 303(d) list that each need a I'M PL. As of today
there have been no approved TMDL's in 2024, only two in 2023, one in 2022, and three in 2021
and seven in 2020. That's a 0.02% completion rate over the last five years. This is simply
unacceptable. Iowa's dirty water will never get clean with this paltry level of action. I urge you to
require the DNR to not only add these seven impairments, but to take serious steps to rectify all
the Category 5 impairments in an expedient manner.
Iowans deserve clean water and they deserve to have an agency that cares enough about the public
health of its citizenry. Half of our tested waterways wind up as either Category 4 or 5 and only half
are tested every two years. Why does the EPA allow this state of affairs in Iowa?
At the very least, the EPA should require the DNR to add these seven impairments to its 2024 Iowa
303(d) list.
We additionally support the public comments of the Iowa Environmental Council.
Sincerely yours,
Diane Rosenberg
Executive Director
123
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From:
To:
Subject:
Date:
Richard Sims
R7-WaterDivision
Require the DNR to Add Waterways with Dangerous Nitrate Levels to the Impaired Water List
Monday, December 16, 2024 7:53:08 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the
following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
(2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
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into account the inconsistencies of rainfall and drought over a period of
several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these
waterbodies to the 2024 list and do a better job protecting public health.
Please take this action NOW,
Rich Sims
Fairfield, Iowa
125
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DEC 1 7 202^
December 10,2024
Environmental Protection Agency, Region 7
Water Division
Via email tu R7-WauJl'DlviMUn(M>cuaTgev- liS
Re: Iowa's 2024 Section 303(d) list and 7 water segments being added
Dear Water Division Staff,
Thanks you for your attention to this matter. 1 appreciate the opportunity to comment on the
proposed revisions to the 2024 Section 303(d) list. I support adding the 7 water quality limited
segments to the 303(d) list identified in your November 12, 2024, letter to Ed Tormey at the Iowa
Department of Natural Resources (DNR). The 7 segments include portions of the following rivers
and involve nitrate and nitrite pollution: • Cedar River . Des Moines River . Iowa River • Raccoon
River • South Skunk River.
I support the EPA's analysis of the Iowa Department of Natural Resources processes and methods of
determining whether a water should be listed on the Section 303(d) list, including.
. The DNR did not use the Iowa Water Quality Information System data, including information from
the U S Geological Survey and the University of Iowa's Iowa Institute for Hydrologic Research
monitors. This data is credible and collected by professionals dealing with water quality issues.
Iowa DNR should be required to use the information in formulating the 303(d) list.
. The DNR did not use information in the Clean Water Hub. This information is collected by trained^
volunteers. Iowa DNR should be required to use the information in formulating the 303(d) list.-We
sunnort the EPA's analysis that says that "data excluded from the state s analysis must be based
technical, science-based rationale and not rely solely upon Iowa's 'Credible Data Law - DNR has
been able to use the credible data law to hide the fact that some waters is Iowa are polluted and
need to be put on the 303(d) list. The Credible Data Law has allowed DNR to keep the 303(d) list
shorter than it should be. It therefore allows polluters to keep polluting.
. I support EPA's analysis that the DNR should not be using the 10% rule to determine if a water
bidv is polluted with nitrate and N, nitrite as N, and nitrate plus nitrite as N. Given that excess
amounts of nitrate and nitrite can be injurious to human health, the toxic levels of those substan
should force a water body of the 303(d) list. , hmr that
. in the letter to Ed Tormey and the decision document, EPA noted that hey alerted the DNR that
the DNR is "not assessing all pollutants with toxic effects with reasonable consideration of
the DNR is not assessing a«p ^ being considered- ta tUeir comment letter about
'the draft 303(d) list It makes me angry that DNR chose to ignore those comments and did not tot
! ^ ' limited segments on the 303(d) list submitted to DNR.
Che 7 wa er fl jnt0 hQW the DNR is prioritizing those waters on the 303(d) tot1for
the"current 303(d) list are numerous water segmentsb^e been
are entitled to extra protection.
u, manl_ ,,par<; fhese Outstanding Iowa Waters have been on the list is the fact
£ Dmts designated them as low priori* for preparing TMDLs. They have been designated as
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Tier 111 and Tier IV, putting them at the bottom of the priority list, essentially condemning them to
perhaps never having a TMDL prepared. This is a clear violation of the intent, if not the specific
language, of the Clean Water Act. Section 303(d) says the priority ranking must be made "taking
into account the severity of the pollution and the uses to be made of such waters." 33 U.S.C. §
1313(d)(1)(A).
• 1 am concerned that the DNR is not fully implementing the plans to improve water quality that
have been identified as part of the TMDL process. Given efforts by the state to reduce income taxes
and the programs supported by those taxes, it appears that the TMDLs will not be implemented any
time in the near future. The process of listing a water on the 303(d) list should result in water
quality improvement in the near future. The 303(d) list and the TMDLs mean nothing if the TMDLs
are not implemented.
TVie state of Iowa needs to come to grips with the excessive amounts of nitrate and nitrite that are
entering the water bodies in the state. Along with that, efforts need to begin for setting water
quality standards for nutrients. Plus, the state needs to undertake serious efforts to reduce the
nutrients entering water bodies, through the TMDL process. Iowa's voluntary Nutrient Reduction
Strategy is not working in reducing nutrients in the state's waters.
adding the 7 water quality limited segments to the 2024 303(d).
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From:
To:
Subject:
Date:
Moni Havne
R7-WaterDivision
Clean Water Standards
Tuesday, December 17, 2024 2:55:34 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments
the US Environmental Protection Agency identified as containing unhealthy and dangerous
nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines,
Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the
Iowa DNR is resisting their inclusion. To protect the public health of all Iowans, each segment
should be assigned a Category 5 impairment and require a TMDL for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule
uses a mathematical calculation developed by the EPA to designate a water as impaired if
water samples reveal pollutants 10% of the time. While the EPA supports this rule for a
variety of pollutants, it does not do so for nitrate due to its established toxicity.
Not only my grandchildren, but all Iowans deserve to have clean drinking water. I may be able
to afford an RO system, but with nearly 50% of the children in my county(Jefferson) on
supported school lunches, most of their families need your help!!
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the
time. The DNR's methodology for measuring the nitrate levels using the 10% rule is faulty
and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual
cycles of water data monitoring. But that doesn't take into account the inconsistencies of
rainfall and drought over a period of several years. Iowa has had multiple years of severe
drought putting more concentrations of chemicals in our water/waterways.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it enable
watershed groups to accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
Close to where I live, Lake Darling, has not been clean enough for swimming or recreation for
decades! About 10 years ago, the watershed leading to Lake Darling was completely
renovated...we could use the lake for about 3 years before it was again too polluted with
nitrogen, causing high bacterial counts!! Excuse me?! Why bother to use taxpayer dollars to
repair something that is only going to be damaged again.
We need the standards in place to keep our water clean.
This is just one tiny example of all the damaged, dirty, toxic lakes and streams in Iowa.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to evaluate
impairments in waterways, a common-sense approach that would give a more accurate
assessment of the presence of pollutants.
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The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to
Iowans. Half of Iowa's waterways that undergo tests are impaired, and only half are tested
every two years. This is an appalling state of affairs. At the very least, the Iowa DNR should
add these water bodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
Moni Hayne
129
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From:
To:
Subject:
Date:
Lisa Ashelman
R7-WaterDivision
my comment - DNR Must Be Accountable for our Dirty Water in Iowa!
Tuesday, December 17, 2024 9:50:04 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the
following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
(2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
130
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several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these
waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours, in Iowa
Dr. Lisa A she/man, PhD, Hon; MS Psych
Technologies of World Peace
131
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From:
To:
Cc:
Subject:
Date:
Attachments:
Shawn Richmond
Pratt. David: Paxson. Chelsea fshe/her/hersl: Robichaud. Jefferv: R7-WaterDivision
Christina Gruenhaaen: Matt Steinfeldt: Daniel Headv
Comments on EPA Region 7 Partial Disapproval of 2024 Iowa 303(d) List
Wednesday, December 18, 2024 9:47:23 AM
imaaeOOl.ipg
IFBF Comments (12 18 241.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Thankyou for the opportunity to comment on the EPA Region 7 partial disapproval of Iowa's
2024 303(d) list.
Please find comments from Iowa Farm Bureau Federation attached.
Shawn Richmond
Conservation & Natural Resources Policy Advisor
Iowa Farm Bureau Federation
5400 University Avenue | West Des Moines, IA 50266
¦
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December 18, 2024
Submitted via email to R7-WaterDivision@epa.gov
Jeffery Robichaud
EPA Region 7
Water Division
Lenexa, KS 66219
RE: Comments on EPA Region 7 Partial Disapproval of 2024 Iowa 303(d) List
The Iowa Farm Bureau Federation (IFBF) appreciates the opportunity to submit these
comments to U.S. Environmental Protection Agency Region 7 ("EPA-7") in response to the
November 13, 2024, partial disapproval by EPA-7 of Iowa's 2024 303(d) list. IFBF is the state's
largest general farm organization with more than 159,000 members. We support voluntary
approaches to water quality protection and improvement including development of projects that
encourage education, demonstration, and implementation of science-based, proven, voluntary
practices that protect water quality.
Regarding the comments submitted by EPA-7 on the 2024 draft 303(d) list, it is
extremely troubling that EPA-7 is requiring that the Iowa Department of Natural Resources
(DNR) change their assessment methodology. This type of requirement clearly oversteps EPA-
7's role and authority. See 33 U.S.C. § 1313(d)(2); 40 C.F.R. § 130.7(d)(2). EPA-7 attempting to
subrogate this role from DNR goes entirely against the concept of cooperative federalism,
especially given that this comes after over 20 years of successful approaches and cooperation on
Iowa's 303(d) list. EPA-7's role is to either approve or disapprove listings and is not to dictate
the assessment methodology utilized by the State.
In reviewing the comments submitted by EPA-7 to the DNR on the draft 2024 303(d) list
and the subsequent response to those comments provided by DNR, we agree with the strong
rationale and justification provided by DNR in declining to make the changes requested by EPA-
7 in its submission. We also agree with DNR's assessment that EPA-7 failed to provide any
scientific or regulatory basis to support its methodology changes or to support the addition of the
seven water segments they are proposing.
EPA-7 claiming the 10% binomial rule is "non-defensible" does not make it so,
especially given the long-standing acceptance by EPA-7 of how this data analysis rule has been
applied in the past by Iowa and other Region 7 states. EPA-7 has provided no supporting
rationale or justification in their comments or decision document to support this claim. Contrary
to EPA-7's assertion that the binomial rule utilized by DNR is "non-defensible", 10% binomial
exceedance approaches are well-recognized and accepted statistical approaches that are
commonly applied to environmental monitoring datasets and analyses.
Additionally, EPA-7 appears to be intentionally concealing information from the public
about both the data source and the percentage of samples exceeding 10 mg/L in Table 1 of the
decision document by not including a column showing the total number of samples taken during
the data ranges listed. For example, reviewing the existing and readily available data provided by
5400 University Avenue, West Des Moines, IA 50266-5997 / (515) 225-5400
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DNR, all the additional segments are below 10 mg/L 94% of the time or better. One segment
proposed to be listed is below 10 mg/L 99.3% of the time and another 98.5% of the time
reviewing current data. Despite EPA-7 claiming that the 10% rule is non-defensible, this
information should be included to ensure full transparency for review, especially since EPA-7
has provided no scientific basis for nullifying use of the 10% rule.
The data presented by EPA for the seven segments does not match the existing and
readily available water quality data, and EPA's refusal to identify the data set or the source of the
data makes it suspect. For transparency and confidence in the process, the public has the right to
know where the additional data came from, to see the full data set, to know whether the samples
were taken properly or processed according to proper QA/QC procedures including within the
prescribed time frame, and have the opportunity to comment. The public should be allowed the
information to decide for themselves whether the cited numbers accurately represent the water
quality for those segments. Listing these segments as impaired misrepresents the available data
and misleads the public with an assertion that these water segments are toxic and polluted.
Further, EPA inconsistently sets water quality standards for drinking water designated
uses. Nitrate seems to be the only evaluated constituent where raw surface water is required to
meet finished drinking water standards. Raw surface water is exposed to the elements, and it is
reasonable to expect that it be treated prior to distribution to a water system. Further, nitrite and
nitrate are not considered "toxic" under the Clean Water Act as opined in the EPA-7 partial
denial letter. Nitrogen is required to sustain life, and it appears naturally in the environment. It is
not listed as a toxic pollutant in the Clean Water Act or its implementing regulations found in 40
C.F.R. § 401.15. EPA-7 should refrain from such inaccurate descriptions of nitrogen, nitrate, or
nitrite in future decision documents. The standard applied in the future to surface water used for
drinking water should consider that the Safe Drinking Water Act requires raw surface water to be
treated or blended to meet drinking water standards.
Given the major departure from the well-established and accepted historical policy on
reviewing impaired waters lists that this decision document is proposing, we also have serious
concerns that EPA-7 actions are inconsistent with the requirements of the Administrative
Procedures Act (APA) by not conducting a formal rulemaking process regarding its proposed
changes, which could put EPA-7 at risk of litigation. Under current rules, the list approved by
EPA-7 must meet the requirements of 40 C.F.R. 130.7(b). See 40 C.F.R. 130.7(d)(2).
In this decision letter, EPA gives itself new authorities to approve or disapprove the
state's long-standing, previously accepted data analysis methodology in conflict with current
rules and statutes. Decision letter p. 13-14; See also 33 U.S.C. § 1313(d)(2); 40 C.F.R. §
130.7(d)(2). EPA-7 also changed the status of nitrate and nitrite from a conventional pollutant to
a toxic pollutant without providing appropriate notice and comment under the APA for the rule
change. See 40 C.F.R. § 401.15. Based on this new methodology and status, it found seven
stream segments as impaired which also do not meet the requirements of 130.7(b) with the use of
phantom data that has not been described or identified as required under 130.7(b)(6)(ii). These
actions and findings change the regulatory requirements for submission and review of the
integrated lists. Such legislative rulemaking requires formal rulemaking, including a notice and
comment period, which is lacking in this instance. See 5 U.S.C. § 553; Iowa League of Cities v.
E.P.A., 711 F.3d 844 (8th Cir. 2013), enforced sub nom. Iowa League of Cities v. Env't Prot.
Agency, No. 11-3412, 2021 WL 6102534 (8th Cir. Dec. 22, 2021). As a result, EPA-7 should
2
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reconsider these actions and findings and not add the additional seven stream segments to Iowa's
integrated list.
In conclusion, IFBF finds that the 2024 303(d) list as prepared and submitted by DNR in
June 2024 should be approved by EPA-7 as submitted after assessing the rationale and
justification submitted to EPA-7 by DNR, EPA's submitted comments and its decision letter.
IFBF objects to the EPA-7 finding of seven additional segments as impaired, adding stream
segments for which supporting data has not been identified and to all changes imposed by EPA-7
regarding Iowa's assessment methodology and evaluation process.
3
135
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From:
To:
Subject:
Date:
Md
R7-WaterDivision
Water quality in Iowa
Wednesday, December 18, 2024 1:32:17 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven
impairments the US Environmental Protection Agency identified as containing unhealthy
and dangerous nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des
Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher.
So far the Iowa DNR is resisting their inclusion. To protect the public health of all
Iowans, each segment should be assigned a Category 5 impairment and require a TMDL
for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments.
This rule uses a mathematical calculation developed by the EPA to designate a water as
impaired if water samples reveal pollutants 10% of the time. While the EPA supports
this rule for a variety of pollutants, it does not do so for nitrate due to its established
toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health.
It can cause methemoglobinemia, blue baby syndrome, a fatal condition in infants.
Studies link consuming high nitrate levels to colorectal, kidney, ovarian, stomach and
thyroid cancers as well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of
the time. The DNR's methodology for measuring the nitrate levels using the 10% rule is
faulty and irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on
annual cycles of water data monitoring. But that doesn't take into account the
inconsistencies of rainfall and drought over a period of several years. This is another
flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet
years, as we saw this spring, rivers and streams that previously appeared unimpaired
contain high levels of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it
136
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enable watershed groups to accurately develop plans that can have a meaningful impact
on mitigating polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to
evaluate impairments in waterways, a common-sense approach that would give a more
accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice
to Iowans. Half of Iowa's waterways that undergo tests are impaired, and only half are
tested every two years. This is an appalling state of affairs. At the very least, the Iowa
DNR should add these waterbodies to the 2024 list and do a better job protecting public
health.
Sincerely yours,
Maralyn Schulze
Marshalltown, Iowa
Sent from my iPhone
137
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| Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments
the US Environmental Protection Agency identified as containing unhealthy and dangerous
nitrate levels to 2024 Iowa 303(d) list of impaired waters.
Numerous water samples revealed these water segments affecting the Cedar, Des Moines,
Iowa, Raccoon, and South Skunk Rivers had nitrate levels of 10 mg/L or higher. So far the Iowa
DNR is resisting their inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the following reasons:
( 1 ) The DNR is improperly applying the 10% rule to determine nitrate impairments. This rule
uses a mathematical calculation developed by the EPA to designate a water as impaired if water
samples reveal pollutants 10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers public health. It can
cause methemoglobinemia, blue baby syndrome, a fatal condition in infants. Studies link
consuming high nitrate levels to colorectal, kidney, ovarian, stomach and thyroid cancers as
well as birth defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred percent of the
time. The DNR's methodology for measuring the nitrate levels using the 10% rule is faulty and
irresponsible.
( 2 ) The DNR bases the removal or inclusion of impaired waters on the 303(d) list on annual
cycles of water data monitoring. But that doesn't take into account the inconsistencies of
rainfall and drought over a period of several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal impairments. In wet years, as
we saw this spring, rivers and streams that previously appeared unimpaired contain high levels
of nitrate and phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a wet year then
removing it during a dry year if impairments don't appear present is inconsistent and
problematic. It doesn't provide an accurate picture of Iowa's water quality nor does it enable
watershed groups to accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year window to evaluate
impairments in waterways, a common-sense approach that would give a more accurate
assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to
Iowans. Half of Iowa's waterways that undergo tests are impaired, and only half are tested
every two years. This is an appalling state of affairs. At the very least, the Iowa DNR should
add these waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
Jo Ann Sadler
Correctionville, Iowa
-------
From:
To:
Subject:
Date:
Linda Ouinn
R7-WaterDivision
Oversight needed for Iowa DNR
Wednesday, December 18, 2024 4:37:32 PM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the seven impairments
the US Environmental Protection Agency identified as containing unhealthy and dangerous
nitrate levels to 2024 Iowa 303(d) list of impaired waters.
You've no doubt heard rationale and supporting evidence from the experts. I'm no expert but I
do paddle some of Iowa's impaired waterways. And find it very, very sad to see our waterways
in such a state of damage, and devoid of the bird and aquatic life. A healthy stream with
vegetated banks is hard to come by where I live in eastern Iowa.
The DNR's refusal to add these seven segments to the 2024 303(d) list does a disservice to
lowans. Half of Iowa's waterways that undergo tests are impaired, and only half are tested
every two years. This is an appalling state of affairs. At the very least, the Iowa DNR should add
these waterbodies to the 2024 list and do a better job protecting public health.
A federal agency as yours, EPA, is so needed to help our state do the right thing; to place the
environment and people above corporations and politics that are running amuck in Iowa.
Please require the DNR to do its job to protect me and all lowans from toxic water!
Sincerely,
Linda Quinn of Iowa City
139
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From: Mcintosh. Tamara
To: R7-WaterDivision
Subject: Iowa DNR"s comment, re: 303(d) list
Date: Thursday, December 19, 2024 9:38:41 AM
Attachments: DNR comment to EPA - 303fd1 list fDec 20241.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
See attached.
Thank you.
TMM
Tamara Mcintosh
General Counsel
Legal Services Bureau
Iowa Department of Natural Resources
6200 Park Avenue, Suite 200
Des Moines, IA 50321
www.iowadnr.gov
140
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governor., KIM REYNOLDS
n otPfJ3R, CHRIS COURNOYER
101... — MENTOF NATURAL RESOURCES
DIRECTOR, KAYLA LYON
December 19, 2024
VIA E-MAIL
EPA - Region 7
ATTN: Jeffery Robichaud
11201 Renner Blvd.
Lenexa, KS 66219
RE: comment in response to EPA's partial disapproval of Iowa's 303(d) list
Mr. Robichaud:
The Iowa Department of Natural Resources (DNR) objects to the EPA's November 12, 2024, decision to partially
disapprove Iowa's 303(d) list because the EPA's letter contains several legal errors. DNR also objects to the
letter's implication that some of Iowa's water is not safe, and that DNR is not meeting either the letter or the
spirit of the law.
DNR agrees that nitrate is a harmful pollutant, and has created a water quality standard specific for surface
drinking water sources consistent with this reality. This standard and its associated monitoring and testing
methodologies are based on rigorous science and are protective. And it works: Iowa's out-of-faucet finished
drinking water has a near-perfect compliance rate of 99.6% with the federal Safe Drinking Water Act's (SDWA)
nitrate maximum contaminant level (MCL).1 The tiny fraction of public water supplies that failed to hit the mark
have subsequently installed more protective treatments or have acquired an alternative source.
The EPA approved Iowa's nitrate water quality standard for surface drinking water sources over 20 years ago.
The EPA has likewise approved Iowa's 303(d) list based on that standard for just as long. The standard has not
changed in the interim, and the EPA hasn't had concerns with the standard until now. Ultimately, the goal of
both the EPA and DNR is the same: to ensure that Iowa's surface drinking water sources meet water quality
standards so that, in turn, Iowa's tap water is safe to drink. It is safe.
While nitrate is a consequential and harmful pollutant, the EPA has never legally classified nitrate as a "Toxic
Pollutant" under the CWA. Congress specifically mandated that the EPA "shall . . . list" all CWA-designated toxic
pollutants in a table.2 That table contains 65 pollutants but, notably, nitrate is not among them.3 Nor is nitrate
on EPA's alternative toxic "Priority Pollutants" list, which has 129 pollutants.4 Yet, the EPA is suddenly
demanding that Iowa act as if nitrate is one of these collective 194 pollutants. It is not. There is legal and
scientific significance to listing nitrate as a "Toxic Pollutant" under the CWA, including more costs, regulatory
oversight, and burdens. In the end, listed or not, Iowa's drinking water must meet SDWA's nitrate MCL, which it
does.5
1 The DNR's Public Drinking Water Program 2023 Annual Compliance Report available at:
https://www.iowadnr.gov/Portals/idnr/uploads/water/wse/2023%20lowa%20Drinking%20Water%20Annual%20Compliance%20Report.
pdf (asof Dec 17, 2024)
2 33 USC § 1317(a)(1)
3 40 CFR§ 401.15
4 40 CFR Part 423, Appendix A
5 Supra, FN 1
Phone: 515-725-8200
6200 PARK AVE STE 200, DES MOINES IA 50321
wwwJoMtDNR.gov
Fax: 515-725-8201
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As this shows, the EPA is violating federal law in several ways. For one, the EPA's treatment of nitrate as a de
facto listed Toxic Pollutant is illegal rulemaking under the Administrative Procedure Act.6 So too is the EPA's
treatment of its multitude of guidance documents and website statements as binding when, by law, they are
not.7 Second, the EPA's patchwork approach to nitrate across the country violates the Administrative Procedure
Act for being arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.8 Some states
mirror Iowa's approach to assessing nitrate in surface drinking water sources whereas others don't test at all. In
other words, the EPA is holding Iowa to a very high standard that it does not enforce elsewhere. Third, the EPA
is required by the CWA to evaluate Iowa's 303(d) list only against DNR's applicable, duly enacted, and EPA-
approved water quality standard, not against what the EPA wishes the standard was.9
Furthermore, the EPA refused to explain or provide its reasoning, data, and methodology behind its partial
disapproval. Both the DNR and the public are expected to provide comments on the EPA's decision, yet not all of
the information is available. DNR takes great effort to explain its decisions and to provide data to the public,
such as through the AQulA and ABDNet databases, which have comprehensive historic monitoring and
assessment data;10 the EPA should hold itself to the same standard.
Therefore, the DNR requests that the EPA withdraw its partial disapproval. Absent a withdrawal, DNR demands
that the EPA establish loads for the identified impaired waters consistent with 40 CFR § 130.7(d)(2) and provide
the public an opportunity to review and comment by publishing in the Federal Register.11
Sincerely,
Kayla Lyon, Director
6 See, e.g., Iowa League of Cities v. E.P.A., 711 F.3d 844 (8th Cir 2013) and 5 USC § 553; see also Loper Bright Enterprises v. Raimando, 144
S.Ct. 2244, 2261 (June 2024).
7 Notwithstanding Congress' "shall list" mandate, the EPA has the following statement on its website: ""The list was intended ... as a
starting point... .Portions of both lists are outdated. As such, the pollutants on these lists are not the only ones regulated...available
at: https://www.epa.aov/ea/toxic~and-prioritv-pollutants~under-clean-water-act (as of Dec. 16, 2024); see also supra FN 6.
8 5 USC § 706(2)(A)
9 33 USC § 1313(d)(2) and 40 C.F.R. § 130.7(d)(2); see also 40 CFR § 131.20(b) and 40 CFR part 25 (detailing public participation processes
around establishing or modifying water quality standards)
10 ADBnet database available at::
https://proerams.iowadnr.eov/adbnet/#:~:text=ADBNet%20is%20an%20online%20database.state%20water%20quality%20standards%2
C%20and (as of Dec 17, 2024)
11 See, e.g., 119 Fed. Reg. 51884 (June 20, 2024) (containing the EPA's 303(d) list decision for Arkansas and formally soliciting public
comment)
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Date:
Attachments:
From:
To:
Subject:
Caitlin Golle
R7-WaterDivision
Public comment submission - concerning the decision to add seven water quality-limited segments to Iowa's
2024 303(d) list
Thursday, December 19, 2024 10:10:51 AM
IowaCCI 12.19.24 public comment EPAr7.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Dear EPA region 7,
Please see our letter and comments in the document attached. This letter presents ~100
public comments and ~500 names signed onto our cover letter requesting transparency and
accountability from the Iowa DNR, by requiring the 7 impaired water segments to be added to
the 2024 Iowa's Impaired Waters List.
We look forward to your response.
Thankyou,
Caitlin Golle (She/Her)
Community Organizer:Farming & the Environment
Iowa Citizens for Community Improvement
Cell:
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t • • lowa
Citizens for
Community
Improvement
Des Moines, IA 50311
Ph 515-282-0484
www.iowacci.org
Facebook/iowacci
2001 Forest Avenue
We talk. We act. We get it done.
To: R7-WaterDivision@epa.gov
12/19/14
Jeffery Robichaud
Water Division
U.S. EPA Region 7
11201 Renner Blvd
Lenexa, KS 66219
From: Members and supporters of lowa Citizens for Community Improvement
Re: Concerning the decision to add seven water quality-limited segments to Iowa's 2024 303(d) list.
Dear Mr. Robichaud and to those it may concern at the Environmental Protection Agency,
As the people of lowa, many of us have grown up playing in our waterways and continue to enjoy
them to this day. The Cedar, Des Moines, lowa, Racoon, and South Skunk Rivers are places of
importance to us.
Any water in lowa that is impaired should be recognized as such, especially for nitrate pollution and
contamination. Nitrates in our water pose a very serious problem in lowa, with consequences to our
health. We should have the right to clear and transparent water quality reporting data if there is any
hope to improve. That means that the DNR must hold themselves to the highest standard and adapt
their methodology on ethics and worst-case impact to human health and drinking water supplies.
We want our water quality in lowa to improve. It will not if we continue to allow for lax regulations
and loopholes.
Please enforce the addition of these seven water quality-limited segments to Iowa's 2024 303(d) list
so that it may reflect 712 WALSs for 581 water bodies listed.
Based on ethics and the security of our health and environment, we support the EPA's request for the
lowa DNR to revise assessment of class "C" waters, remove the non-defensible use of the 10% rule in
relation to nitrate and any other pollutants with toxic effects treated as conventional pollutants, and
to assess pollutants with toxic effects with reasonable consideration of the individual pollutant and
potential adverse effects.
Without strong enforcement, our waters and communities bear the burden of unacknowledged risk
and a false sense of improvement.
We want the best for lowa, our environment, water and people - and upholding the lowa DNR to high
standards is an important step to moving towards a healthier lowa.
Thank you for standing up for our water,
501 Members and supporters of lowa Citizens for Community Improvement.
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Margot Bilanin from Iowa City, IA - "A balance of ag practices w/ clean waterways is our right as a tax
paying citizen of this state."
Jenn Boccella from Ankeny, IA - "Accurate date is paramount."
Mark Edwards from Boone, IA - "After working for the Iowa DNR for 30 years, starting the Water Trails
Program, and reducing erosion from human use I am appalled at the lack of concern for our water by
the DNR and the public. Thank you for stepping in and enforcing the law."
Carolyn Uhlenhake -Walker from Des Moines, IA - "All people have a right to clean water!!!!! Water
quality is at crisis-level here in Iowa! We must act now!"
Sharon Moss from Iowa city, IA - "All seven impaired segments should be added to the 2024 Impaired
Waters list - especially since companies were given the green light to pollute"
Linda Fitzgerald from Cedar Falls, IA - "As a citizen of the Cedar River watershed, who has been doing
nitrate sampling through 2024, from drought to flood to drought, and as an avid kayaker, I am
dismayed at the refusal of Iowa DNR to add to the Impaired Waters list. Please enforce the additions
to the 2024 list."
Tim Glaza from Des Moines, IA - "Clean up our water!"
Clare Smith-Larson from Altoona, IA - "Come on and SHAPE up."
Christine Schlotfelt from Iowa City, IA - "Current and future lowans deserve clean water. Prove that
Big Ag doesn't own our state and add these impaired waters to the list."
Jacquelyn Smith from West Des Moines, IA - "DNR help us clean up rivers. Streams, lakes n all water in
Iowa it is your responsibility to see we have clean water to drink and for recreation"
Mary Woolever from Ankeny, IA - "DNR Protect our drinking water! Please do your Job DNR. Keep all
of us safe! Thanks."
Patricia Bowen from Iowa City, IA - "Do your job DNR. or does DNR really stand for Do Nothing
Really? That's what I've been saying for years. Prove me wrong."
Ann Zerkel from Iowa City, IA - "Do your job! All our lives depend on you!"
David Andrews from Ames, IA - "Go get'em!"
Karen Manning from Maquoketa, IA - "Good information and high standards are what lowans expect
and deserve from our DNR."
Virginia Meyer from Lone Tree, IA - "Help us with our fight for clean water because our DNR will not."
Rachel Mills from Cedar Rapids, IA - "HIGH Standards are what the DNR is responsible for!"
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Margo Vanderhill from Alton, IA - "I am concerned that the high nitrate levels will affect the health of
my granddaughters. If left off the list, I cannot even find out which water is impaired!!!"
Carol Tack from Decorah, IA - "I am very concerned about the water quality in Iowa. I have read that
about half of our waterways are impaired and it could even be more. We have the 2nd highest cancer
rates in the country and nitrates cause cancer."
Susie Petra from Ames, IA - "I do deserve clean water. Actually, so do you and the ones you love. So:
enforce high standards! Add the newest seven impaired water segments! Enforce cleaning up our
waters! Please, please help us. Help us get the action we deserve, to clean up our waters! I learned
to swim in these waters, and my brother & I fished with our dad, in these waters. Today, I would not
risk doing either. And this degradation has happened in my lifetime! Please"
Sally Hartman from Iowa City, IA - "I don't know anyone that actually wants polluted water in Iowa.
Please get on the stick, add seven impaired water segments to the list of Impaired Waters, and add
buffer zones to streams, lakes and rivers. Our lives depend on it!"
Zack Jones from Malvern, IA - "I live in Southwest Iowa where there was a recent spill In Red Oak. It is
very clear water quality is not a priority. The 2 most important things are water and air. I wish todays
is leadership thought more about what we are leaving for future generations. Besides ongoing
destruction of habitat and ecosystems. We need more focus on the balance of life in all respects"
Nancy Bakken from Cresco, IA - "I live surrounded by hog operations, with a river, the Upper Iowa
River, only 300 yards down the hill from three facilities, and then running through our farm. It is
imperative that Iowa DNR provides lowans with the truth about our water quality all across the state.'
Kristin Erickson from Decorah, IA 'I support enforcing high standards on the Iowa DNR by adding all
seven impaired segments to 2024 impaired waters list. The threat to our health in Iowa is our number
1 issue."
Janet Miller from Ackley, IA - "I urge you to ensure transparency and accountability in water quality
reporting. Ignoring these impaired segments undermines public trust and jeopardizes efforts to
safeguard community health and the environment. Let's prioritize accurate data and proactive
measures to protect our vital water resources. Iowa has the second highest cancer rate in the nation!"
Carol Boyce from Dysart, IA - "I was just diagnosed with cancer, and several others I know have also
been recently diagnosed. I am a kayaker also, and I find it difficult to find places to kayak that aren't
contaminated with pollutants in Iowa. Please ensure the DNR complies with regulations. I'm saddened
by the state of Iowa's waterways"
Deb Van Horn from Decorah, IA - "If there's something to hide then there is definitely a concern.
Something of this nature requires total transparency. Ignorance is not bliss and not informing the
public of a potential hazard to their health is deceitful and reprehensible."
Joy Scanlan from Massena, IA - "If we don't have clean water, we don't have healthy animals to eat,
our babies die, and the vegetables we eat bring more poison into our bodies. What's left? God will
find other things to do with this world that will not include humans."
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Danielle Wirth from Woodward, IA - "In Iowa, the Iowa DNR is fully owned by the Iowa Farm Bureau.
Family farms are disappearing, and with them, the small towns in Iowa where engaged citizens acted
to protect their local communities. We can no longer allow our children to swim in surface waters.
Wildlife, including game fish and mammals we hunt for food, are disappearing or are sick with
disease. The DNR must comply with water quality standards that protect citizen's rights to Life, Liberty
and the Pursuit of Happiness."
Dan Freeman from St. Ansgar, IA - "Iowa DNR also needs to determine how much water are in the
Aquifers, before any private corporation well permitting Protect Iowa's water!"
Dan Hill from Iowa City, IA - "Iowa DNR exists to enhance the quality of life for lowans, improve Iowa's
natural resources and ensure a legacy for future generations. Why is the DNR refusing to comply?!"
Barbara and Jim Dale from Decorah, IA - "Iowa has lost its status as a desirable state to live and work
in, largely due to the contamination of our waters. We must remediate this situation. Our health and
our economy rely on accurate and conscientious testing. We must know the status of our water
continuously. Nothing can be more important to our state than clean water."
David Stickrod from Glenwood, IA - "Iowa has the highest cancer rate and the worst water quality in
the country, combined with rising numbers of corporate animal farms. Get a clue EPA. Help us!"
Virginia Paulson from Iowa City, IA - "Iowa is 2nd highest in the country for cancer and 44th in the
nation for health care provider access. We must stop turning our environment into a chemical
wasteland. Iowa is going in the wrong direction. Let us clean up our soil and water and keep Iowa
habitable for ourselves, our children, our grandchildren, and all future generations."
Jack Mithelman from Urbandale, IA - "Iowa is extremely high cancer rates are directly related to our
poor water quality. We BEG the EPA to take forceful action against Iowa DNR to correct this."
Zita Cashin from Conrad, IA - "Iowa residents health is being impacted due to the current water
quality, resulting in one of the highest levels of cancer in the US. We NEED CLEAN WATER!"
Barbara Beaumont from North Liberty, IA - "Iowa won't do anything to clean up the water unless it is
forced to do so."
Rodger Routh from Ankeny, IA - "lowans deserve and demand clean water and the DNR must Do Its
Job!!!"
Alene Rickels from Iowa Falls, IA - "lowans deserve clean water in their environment. Please protect
our waters. Please take all steps to ensure our water in Iowa is safe, lowans deserve clean water."
Barbara Kalbach from Dexter, IA - "lowans have been living with impaired waterways for many years
now. There has been no effort by our state government to slow the livestock, chemical, & fertilizer
run-off that enters our lakes, streams & rivers every year. As a #2 cancer state, it is time for our GOP
Legislature & Governor to address this!! The Iowa DNR &the State of Iowa have ignored our
increasing water impairment for many years. Please do not allow them to ignore the EPA, too."
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Laurie Klosterboer from McGregor, IA - "Iowa's DNR needs to monitor not only water quality (against
the governor's wishes) but also monitor the quantity. Our 10,000 large animal operations, tech
centers, and possibly hundreds of miles of C02 pipeline will dry up our aquifers quickly. What comes
first, drinking water for everyone or someone's profits? Thank you for overseeing our waters! It's
time to address lowans' water quality - we can only get drinking water locally, and Iowa's local
sources are full of nitrates and ag chemicals. Cancer rates in our state are growing annually. Don't put
this off any longer, please!"
Robin Arnold from West Des Moines, IA - "Iowa's drinking water problem needs addressed! It has only
gotten worse each year. Please enforce accuracy of correct data collection to aid in real solutions.
Thank you!"
Mike Delaney from Windsor Heights, IA - "Iowa's water is not as bad as some people think. We need
transparency so that lowans know the truth. Sweeping bad news, like the Nishnabotna spill, under the
rug is not acceptable. Iowa politicians and the DNR can no longer be trusted to protect our health."
Mary Taft from Iowa City, IA - "Iowa's water quality must be monitored by the DNR. It is its function.
Do your job!"
Jeff Milks from Oelwein, IA - "Is it any wonder that Iowa has the second highest cancer rates in the
nation?? This is on YOUR WATCH!!"
Deverie Kiedaisch from Keokuk, IA - "It is essential for lowans to have clean water for our very
survival."
Renee Grummer Miller from Cedar Rapids, IA - "It's time to improve the health of lowans by cleaning
up our water. Please enforce high standards on the Iowa DNR by adding all seven impaired segments
to the 2024 Impaired Waters list."
Melissa Silver from Iowa City, IA - "It's important to have accurate data so we make the best, most
informed decisions. Thank you, Melissa Silver"
Ron Melsha from Solon, IA - "It's time to give the DNR full power and stop the Farm Bureau from
poisoning the state. Clean water and air for everyone."
Leslie Davis from Marshalltown, IA - "List all impaired waterways."
Martin White from Clive, IA - "Make the DNR do the right thing for the people of this state."
Susan Moore from Fort Dodge, IA - "Nitrates are high in the water in this state! Iowa is one of (if not
the most) states with highest cancer rates."
Daniel Bennett from LeClaire, IA - "No action is NOT an option. STOP letting our so called "farmers"
pollute our state without consequences. Make our legislators understand that the almighty dollar is
NOT the goal! Clean and safe drinking water is!!!"
Jim Walters from Iowa City, IA - "Our government in Iowa has been captured by people who do not
care about clean water and the safety of our citizens. It is up to the EPA to do something about this."
5
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Jeff Adams from Eldora, IA - "Please Don't make me lose trust in the DNR."
Beverly Butler from Mason City, IA - "Please enforce high standards on the Iowa DNR by adding all
seven impaired segments to the 2024 Impaired Waters list. Everyone deserves clean water."
Rachel Mithelman from Urbandale, IA - "Please enforce the addition of these 7 impaired waterways
to the list. We must protect Iowa's rivers and streams, and since the DNR is unwilling, we truly need
your assistance on this."
Melissa Erickson from Boone, IA - "Please help lowans have safer drinking water."
Louise Kaufman from Mason City, IA - "Please HELP us."
Martha McCormick from Ames, IA - "Please please look out for us lowans. We cannot make sure the
right laws are in place for lowans but u can. Please do your job to protect our water."
Becky Evans from Des Moines, IA - "Please protect our drinking water, a most basic right for all
lowans."
Janet Wilson from Iowa City, IA - "Please protect the people and our life blood, that is the water and
soil on which we stand and depend on for life itself. Please, this is why you have the job and
responsibilities you have. You were not elected to pad your own pockets or to bring big businesses
that will over use and pollute our livelihood and poison our the environment which supports all of our
lives. This is your job. Please do it. Thank you. Janet Wilson."
Nick Schutt from Alden, IA - "Please protect the people you work for! Please do your job protecting
the people and not the special interest groups. Thank you"
Maureen McCue from Oxford, IA - "Please, for our health and all those who share our environment,
let's get the information we need to protect all of us!"
Hugh Espey from Des Moines, IA - "Put these 7 water segments on our impaired waters list, now!!
Iowa DNR is trying to hide the truth - EPA needs to put people before polluters! We need to crack
down on water pollution. Nitrate in our drinking water can make us sick. Iowa has had over 700
impaired waters for the past 10 yrs - it's not getting any better. Iowa DNR needs to work with
grassroots lowans to fix the problem, not ignore it!"
Kimberly Smith from Altoona, IA - "Thank you for your diligent work. Our government turns a blind
eye to the concerns and problems of this state. When will they care enough to take action?"
Russ Ver Ploeg from Des Moines, IA - "The DNR needs to address residents' concerns about water
quality rather than ignore what ag and other businesses do to our water ways."
Martin Monroe from Des Moines, IA - "The Federal government should hold States accountable, for
misrepresenting the citizens, in favor of Pipeline Profiteers! The Governor and Legislative leaders are
directing the DNR and Utilities Board to censor any opposition to the Pipeline Racketeers. Any
member of Iowa's Legislature who has stock or stand benefit financially, from the Pipelines or other
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Private Investments are ethically required to Not Vote, on legislation regarding personal profiteering,
or using their public position to profit personally or supporting family members as well."
Joshua McDonald from Iowa City, IA - "The only way we will keep our country strong and safe is to
have honest, and transparent government agencies, at all levels, working with industry and the
people. Water quality data belongs to the people."
Victoria Springer from Grinnell, IA - "The residents of Iowa suffer from questionable outdated water
systems and unsafe swimming and recreation options due to the disgusting state of rivers, lakes and
streams. Whole countries have banned the poisons used on Iowa crops which causes cancer and
Parkinsons disease. Science matters. Help!"
Nancy Huisinga from Des Moines, IA - "The time is NOW to take recommendations and advisement
regarding water quality from DNR. I have no grandchildren, but many of you may. They deserve to
grow up with clean, clear waterways in our state."
Gerry Hanson from Parnell, IA - "The water usage from ethanol and carbon capture will drain our
aquifers! Good luck trying to farm after that happens! Nobody will want to live in an area with ethanol
production, pipelines and water. This must stop!!!!!!!!!!!!"
Shari Hawk from Ankeny, IA - "This is the absolute minimum that must be expected to assure lowans
are protected from the effects of our polluted waterways."
Lynn Underberg from Dayton, IA - "This is unacceptable. Not informing the public of known risks to
water supplies is negligent. What is standing in your way from just doing the right thing?"
Roxanne Jackson from Hanlontown, IA - "water is a precious resource-don't take it for granted.
Protect lowans right to clean water, stop giving our water to any large for-profit corporation that puts
our access to water in jeopardy."
Silvia R Cianzio from Des Moines, IA - "Water is an essential component of our bodies and life, its
quality impacts all sources of life and health, for us humans and for every being organisms that
cohabit our planet. It is imperative that all of us have access to clean and pure sources of water, to
assure our planet and the future generations. Please, acct accordingly, and maintain transparency in
all areas related to survival of our resources, and those in the planet. Be honest, responsible, and well
intentioned on the actions you All take. Please, protect lowans health wellbeing!!!!!!!!"
Paige Liebrecht from Coralville, IA - "Water pollution kills people"
Bonnie Murphy from Coralville, IA - "Water quality in Iowa is very important and has been declining in
ways that are under our control if we have the will to do the right thing."
Beverly Ross from Kellogg, IA - "WATER SAFETY IN IOWA IS URGENT"
David and Mary Timmer from Pella, IA - "We could safely play in waterways with our children; but our
grandchildren cannot. Time for a change."
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Susan Beary from Lovilia, IA - "We deserve to know about high nitrate levels that can harm our health,
the DNR needs to add the 7 segments to the impaired waters list, citizens deserve transparency on
this."
Darlene Clark from Dubuque, IA - "We do not want or need high nitrate levels. Protect all lowans!
Please."
Cindy Pospisil from Mt Vernon, IA - "We have 2 farm rental properties that we have installed reverse
osmosis equipment due to high nitrate levels."
Todd Southworth from Waterloo, IA - "We haven't been able to drink our own well water for years -
nitrates, and we aren't even farmers!"
Rosalind Andersen from Davenport, IA - "We need clean water without nitrates and an EPA that
supports the people."
Dennis Den Hartog from Fort Dodge, IA - "We need cleaner water for all of us."
Erin Garity from West Des Moines, IA - "We need water quality transparency. How are we to know
what is in our water, and how it could affect us if we don't have access to the data. This is a right all
lowans and Americans should have."
Daniel DeShane from Coal Valley, IL - "WHAT IS WRONG WITH IOWA?"
Lawrence Ginter from Rhodes, IA - "With climate change and drought it is important that we protect
Iowa's water supply and our rivers and lakes."
Patricia Fuller from Council Bluffs, IA - "Yes, thank you for standing up for water. We cannot continue
to play politics when it comes to our impaired waters affecting our health, we have the second
highest rate of cancer in the nation. This might very well be due to the excessive amount of nitrates in
our water due to the huge amount of Confined feeding operations and massive agriculture overuse of
fertilizer"
Lori Hauenstein from Nevada, IA - "You are there to serve all lowans and not just agricultural
interests. We are the only state with rising cancer rates. No wonder our state has a brain drain. Pigs
over people and large corporate farms seem to be the only groups served by DNR."
Edward T. Hotchkin from Des Moines, IA - "You may try to pull one over on us, but you can't fool our
health. The truth will come out!!!"
Arie Sirotiakfrom Ames, IA
Dennis Goodrich from Ames, IA
Diane Pierce from Ames, IA
Donna Prizgintas from Ames, IA
Jo Ann Kovar from Ames, IA
Josephine O'Donnell from Ames, IA
Mary Sand from Ames, IA
MJ Banwart from Ames, IA
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Rae Hattan from Ames, IA
Robert Ryerson from Ames, IA
Ruth Barnett from Ames, IA
Steven Pecenka from Ames, IA
Tessa Brow from Ames, IA
Walter Neal from Ames, IA
Ellen Hansen from Ankeny, IA
Eva Moritz from Ankeny, IA
Jane Alderman from Ankeny, IA
Kathy Graeve from Ankeny, IA
Kathy Avey from Ankeny, IA
Melissa Owen from Ankeny, IA
Patricia Carlson from Ankeny, IA
Paul Carlson from Ankeny, IA
Terri Burton-Wire from Ankeny, IA
Terri Hannan from Ankeny, IA
Vicki Bowman from Ankeny, IA
Bernard Webb from Ankeny, IA
Dixie Webb from Ankeny, IA
Kerensa Good-Bloyd from Bettendorf, IA
Marilyn Hawthorn from Bettendorf, IA
Theresa Johnson from Bettendorf, IA
Janet Vielhaber from Bondurant, IA
Jo Kassel from Boone, IA
Lydia Hayes from Calmar, IA
Jerry Uhlman from Carlisle, IA
Mary Allen from Carter Lake, IA
Jon Linn from Casey, IA
Bob Condra from Cedar Falls, IA
Melissa Heston from Cedar Falls, IA
Marian Kuper from Cedar Falls, IA
Ashley Pastor from Cedar Rapids, IA
Julie Hanson from Cedar Rapids, IA
L. Darrel Wriderfrom Cedar Rapids, IA
Mindy Kruckenberg from Cedar Rapids, IA
Nicole Weber from Cedar Rapids, IA
Rev Curt Miner from Cedar Rapids, IA
Tom Mohan from Cedar Rapids, IA
Beth Herrickfrom Cedar Rapids, IA
April Beth Wiles from Charles City, IA
Sharon Lawson from Clinton, IA
Linda Lonn from Clarinda, IA
Kathleen Serinofrom Clive, IA
Tamara Holmes from Coon Rapids, IA
Matt McAndrewfrom Coralville, IA
Barbara Akre from Coralville, IA
Jane Knoedel from Coralville, IA
Phil Klein from Coralville, IA
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William Pusateri from Coralville, IA
Matthew Olive from Corning, IA
Jo Ann Sadler from Correctionville, IA
Jeremy Menard from Council Bluffs, IA
Thomas Reardon from Council Bluffs, IA
Steve Hultman from Crescent, IA
Peggy Noel from Creston, IA
Barb Buckton from Cumming, IA
Harold Moody Jr. from Davenport, IA
Kathleen Murteyfrom Davenport, IA
Leslie DuPreefrom Davenport, IA
Mary Rehmann from Davenport, IA
Michael Husteddefrom Davenport, IA
Roy Birchard from Davenport, IA
Sharon Kendall Dunn from Davenport, IA
David Dunn from Davenport, IA
Carolyn Corbin from Decorah, IA
Christine Kilarski from Decorah, IA
Erik Sessions from Decorah, IA
M J Borelli from Decorah, IA
Marc Oyloefrom Decorah, IA
Mic Martin from Decorah, IA
Patsy Martinson from Decorah, IA
Steve Gude from Des Moines, IA
Adam Mason from Des Moines, IA
Barbara Klubalfrom Des Moines, IA
Beth Wilson from Des Moines, IA
Bill Nassif from Des Moines, IA
Brian Kennedy from Des Moines, IA
Dan Ketchumfrom Des Moines, IA
Donald Shepherd from Des Moines, IA
Eric Saylorfrom Des Moines, IA
Evan Schultz from Des Moines, IA
Gina Schlesselman-Tarango from Des Moines, IA
Hal Rusk from Des Moines, IA
Holly Hallman from Des Moines, IA
Jake Grobefrom Des Moines, IA
Janet Rominefrom Des Moines, IA
JEAN O'Donnell from Des Moines, IA
Jeanie Hagedorn, chm from Des Moines, IA
Jen Sinklerfrom Des Moines, IA
Jody Gibson from Des Moines, IA
John C. Holveckfrom Des Moines, IA
Julia Rendon from Des Moines, IA
Juliann Woodhouse from Des Moines, IA
Kerry Moore Kroneman from Des Moines, IA
Marsha Szymczukfrom Des Moines, IA
Maryanne Sobiech from Des Moines, IA
10
153
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Megan McDowell from Des Moines, IA
Michael Farley from Des Moines, IA
Nicole Wherry from Des Moines, IA
Nina Lfrom Des Moines, IA
Patsy Shors from Des Moines, IA
Peggy Fitch from Des Moines, IA
Rachel Rovinefrom Des Moines, IA
Robin Madison from Des Moines, IA
Ryan Lombard from Des Moines, IA
Susan Stroopefrom Des Moines, IA
Virginia Wadsley from Des Moines, IA
Wanda Wendtfrom Des Moines, IA
Anna Gebhardtfrom Des Moines, IA
Christina Brandon from Des Moines, IA
J L Trent from Des Moines, IA
Jane Freeman from Des Moines, IA
Jill Tenney from Des Moines, IA
Jon Betz from DeWitt, IA
Robin Ketchum from Dexter, IA
Antonino Erba from Dubuque, IA
Briana Moss from Dubuque, IA
Dorothy Schwendinger from Dubuque, IA
Frank Belcastro from Dubuque, IA
Julie Johnson from Dubuque, IA
Kristin Glomstad-Yoon from Dubuque, IA
Paul Francis Schultz from Dubuque, IA
Sarah Wirth from Dubuque, IA
Steven Neal from Earlham, IA
Julie Duhn from Eldora, IA
Colene Colby from Elgin, IA
Dale Steichen from Elgin, IL
Don Langstaff from Fairfield, IA
Hurd Hess from Fairfield, IA
Jerry Avise-Roue from Fairfield, IA
Melinda Arndtfrom Fairfield, IA
Sandra Randofrom Fairfield, IA
David Matt from Fairfield, IA
David Ballou from Fairfield, IA
Karen Beinefrom Floyd, IA
Judith Neal from Fort Dodge, IA
Laura Elsingerfrom Garnavillo, IA
Dean DePreefrom George, IA
Amy Stickrod from Glenwood, IA
Holly Kooistra from Grimes, IA
Judy Cohen from Grimes, IA
Nancy Cadmus from Grinnell, IA
Gordie Felgerfrom Hiawatha, IA
Joseph Driscoll from Honey Creek, IA
11
154
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Jacquelene Rasmussen from Huxley, IA
Virgil Hovdenfrom Independence, IA
Gaye Wiekierak from Indianola, IA
Margaret Vernon from Indianola, IA
Elaine Donovan from Iowa, IA
Allie Koolbeckfrom Iowa City, IA
Anne Fitzgerald from Iowa City, IA
Barbara Helmickfrom Iowa City, IA
Cari Linkenmeyer from Iowa City, IA
Carol McGhan from Iowa City, IA
Carol DeProsse from Iowa City, IA
Dan Daly from Iowa City, IA
David Leshtz from Iowa City, IA
Deb Quade from Iowa City, IA
Del Holland from Iowa City, IA
Gaylen Wobeterfrom Iowa City, IA
J.L. McClure from Iowa City, IA
Jane Sexton from Iowa City, IA
Jennifer Breon from Iowa City, IA
Jerry Cilekfrom Iowa City, IA
John Elson from Iowa City, IA
Joy Smith from Iowa City, IA
Julie Mock from Iowa City, IA
Karmen Bergerfrom Iowa City, IA
Laura Kerr from Iowa City, IA
Loulwa Soweid from Iowa City, IA
Lynn Sidwell from Iowa City, IA
Mandi Remington from Iowa City, IA
Mary Kirkpatrick from Iowa City, IA
Mary Light from Iowa City, IA
Matthew Gordon from Iowa City, IA
Melody Smith from Iowa City, IA
Paul Muhlefrom Iowa City, IA
Rhonda Rowden from Iowa City, IA
Sandy Beck from Iowa City, IA
Sheri Deal-Tyne from Iowa City, IA
Sydney Landstrom from Iowa City, IA
Tony Wobeter from Iowa City, IA
Victoria Fernandez from Iowa City, IA
Wendy Keen from Iowa City, IA
Nancy Nicholson from Iowa Falls, IA
Jane Alexander from Jefferson, IA
Barbara Minear from Johnston, IA
Doug Minear from Johnston, IA
Mary Scarcello from Johnston, IA
Megan Down from Johnston, IA
Rich Gradoville from Johnston, IA
Taylor Nelson from Johnston, IA
12
155
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Kathy Vitasek from Johnston, IA
James Berge from Kensett, IA
Sue Huff from Keosauqua, IA
Jo Fokken from Kingsley, IA
Lou Willis from Knoxville, IA
Gary Osland from Laurel, IA
Ken French from LeMars, IA
Mike DeCookfrom Lovilia, IA
Ian Souterfrom Manilla, IA
Gene Jackson from Marshalltown, IA
Wiltse McWilliam from Marshalltown, IA
Bettie Bolarfrom Marshalltown, IA
Connie Johnson from Mason City, IA
Curt Nelson from Mason City, IA
Deb Lassisefrom Mason City, IA
Denise Miller from Mason City, IA
Marci Turner from Mason City, IA
Mary Sue Kislingbury from Mason City, IA
Sheila Goeken from Mason City, IA
Thomas Willett from Mason City, IA
Marie DeVriesfrom Mount Vernon, IA
Marsha Acord from Mount Vernon, IA
Allison Castle from Muscatine, IA
Belen Rodriguez from Muscatine, IA
Dave Duitfrom Nevada, IA
Michael Madden from New City, NY
Linda Schraderfrom Newton, IA
Caitlin Gollefrom Nora Springs, IA
Amy McBeth from North Liberty, IA
Matthew Tonelli from North Liberty, IA
Weldon Woodward from North Liberty, IA
Melinda Rankinsfrom Norwalk, IA
Jeff Milks from Oelwein, IA
Ashlie Sveum from Osage, IA
Patricia Wickham from Osage, IA
Penney Morse from Osage, IA
Alan Farley from Perry, IA
Madison Lamb from Perry, IA
Nancy Pinkerton from Pleasant Hill, IA
Steve Monk from Polk City, IA
Jim Vorland from Preston, IA
Michael Lundyfrom Riverton, IA
Brian Walshire from Rowley, IA
Christopher Lish from San Rafael, CA
Frank Kloucek from Scotland, SD
Debra Hattan from Sioux City, IA
Mary Starry from Solon, IA
David Damstrom from Spencer, IA
13
156
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Connie Rosenberg from St. Ansgar, IA
Berleen Wobeterfrom Toledo, IA
David Eash from Urbandale, IA
Ginny Swift from Urbandale, IA
Rosemary Partridge from Wall Lake, IA
Becky Edmondon from Walnut, IA
Patrick Morrissey from Waterloo, IA
Mackenzie Jones from Waukee, IA
Kathleen Snellingfrom Waverly, IA
Kim Folkersfrom Waverly, IA
Marlene Bringolf from Webster City, IA
Elizabeth Ahrens from West Branch, IA
Brett Hollenbeck from West Des Moines, IA
Dianne Kobberdahl from West Des Moines, IA
Eric Morse from West Des Moines, IA
Karsen Duve from West Des Moines, IA
Laurie Jones from West Des Moines, IA
Robert Hughes from West Des Moines, IA
Stacie Schmidt from Windsor Heights, IA
Cheri Grauerfrom Winterset, IA
MJ Banwartfrom Ames, IA
Bernard Webb from Ankeny, IA
Nyakota Ding from Urbandale, IA
Anna McGeefrom Denver, CO
Sarah Jedd from Des Moines, IA
Jane Freeman from Des Moines, IA
Michael Ziegenhorn from Iowa City, IA
Bear Hickman from Milwaukee, IA
Larry Fitzpatrick from Iowa City, IA
Mindy Kruckenberg from Cedar Rapids, IA
Connie Johnson from Mason City, IA
Drew Greene from Ames, IA
Allison Simpson from Bellevue, IA
Wendy Hopp from Asbury, IA
Jake Riosfrom Dubuque, IA
Nicholas Agan from Dubuque, IA
Kyle Belcher from Coralville, IA
Lindsay Schmitt from Dubuque, IA
Johnathan Temenakfrom North Liberty, IA
Caitlin Gollefrom Nora Springs, IA
Diane Rosenberg from Fairfield, IA
Alicia Ehlersfrom Dubuque, IA
Carlene Schaefer from Dubuque, IA
Sandra Helmkefrom North Liberty, IA
Lisa McPherson from Mount Pleasant, IA
Andrew Leonard from Cedar Rapids, IA
John M Dooleyfrom Davenport, IA
Eric Stewart from Davenport, IA
14
157
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Catherine Petersen from Davenport, IA
Andrew Petersen from Davenport, IA
Robert Hopp from Asbury, IA
Debbie Sommers-Krause from Bettendorf, IA
Linda Holvikfrom Marshalltown, IA
Bonnie Grimmius from Marshalltown, IA
Terri Burton-Wire from Ankeny, IA
Hurd Hess from Fairfield, IA
Marie Zibert from Des Moines, IA
Michael Powers from Coralville, IA
Nicholas Knight from Earlham, IA
Regina MacRaefrom Des Moines, IA
Denise Fletcher from Toledo, IA
Robert Traer from Iowa City, IA
Todd Southworth from Waterloo, IA
Mary Light from Iowa City, IA
Mike Evans from Chariton, IA
Kathleen Brown from Fairfield, IA
Jackie Smith from West Des Moines, IA
Antonino Erba from Dubuque, IA
Edward Kropa from Mount Pleasant, IA
Toby Rainefrom Minneapolis, MN
Amanda Gran from Des Moines, IA
Jaime Izaguirre from Dubuque, IA
Katie Bryan from Des Moines, IA
Kim Callahan from Des Moines, IA
Ava Auen-Ryan from Omaha, NE
Matthew Covington from Des Moines, IA
Edward Wollnerfrom West Des Moines, IA
158
15
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From:
To:
Subject:
Date:
June Oliver
R7-WaterDivision
Iowa Water Polution Disgrace
Thursday, December 19, 2024 11:43:48 AM
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Jeffrey Robichaud
Water Division
US EPA Region 7
11201 Renner Boulevard
Lenexa, KS 66219
Dear Mr. Robichaud,
I urge you to require the Iowa Department of Natural Resources to add the
seven impairments the US Environmental Protection Agency identified as
containing unhealthy and dangerous nitrate levels to 2024 Iowa 303(d) list
of impaired waters.
Numerous water samples revealed these water segments affecting the
Cedar, Des Moines, Iowa, Raccoon, and South Skunk Rivers had nitrate
levels of 10 mg/L or higher. So far the Iowa DNR is resisting their
inclusion. To protect the public health of all Iowans, each segment should
be assigned a Category 5 impairment and require a TMDL for the
following reasons:
(1 ) The DNR is improperly applying the 10% rule to determine nitrate
impairments. This rule uses a mathematical calculation developed by the
EPA to designate a water as impaired if water samples reveal pollutants
10% of the time. While the EPA supports this rule for a variety of
pollutants, it does not do so for nitrate due to its established toxicity.
Consuming water laden with nitrate levels of 10 mg/L or more endangers
public health. It can cause methemoglobinemia, blue baby syndrome, a
fatal condition in infants. Studies link consuming high nitrate levels to
colorectal, kidney, ovarian, stomach and thyroid cancers as well as birth
defects.
Drinking water should never exceed nitrate levels of 10 mg/L one hundred
percent of the time. The DNR's methodology for measuring the nitrate
levels using the 10% rule is faulty and irresponsible.
(2 ) The DNR bases the removal or inclusion of impaired waters on the
303(d) list on annual cycles of water data monitoring. But that doesn't take
into account the inconsistencies of rainfall and drought over a period of
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several years. This is another flawed approach.
During drought years, rivers and streams flow less and conceal
impairments. In wet years, as we saw this spring, rivers and streams that
previously appeared unimpaired contain high levels of nitrate and
phosphorus pollutants released by the heavy rainfall.
The DNR's approach to adding an impaired waterway identified during a
wet year then removing it during a dry year if impairments don't appear
present is inconsistent and problematic. It doesn't provide an accurate
picture of Iowa's water quality nor does it enable watershed groups to
accurately develop plans that can have a meaningful impact on mitigating
polluted waterways.
The Iowa Environmental Council recommends the DNR use a 5-10 year
window to evaluate impairments in waterways, a common-sense approach
that would give a more accurate assessment of the presence of pollutants.
The DNR's refusal to add these seven segments to the 2024 303(d) list does
a disservice to Iowans. Half of Iowa's waterways that undergo tests are
impaired, and only half are tested every two years. This is an appalling
state of affairs. At the very least, the Iowa DNR should add these
waterbodies to the 2024 list and do a better job protecting public health.
Sincerely yours,
June Oliver
160
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From: Reaaan Giesenschlaa
To: R7-WaterDivision
Cc: Ed Thomas: Tom Lvnch
Subject: TFI Comments on the EPA Region 7 Partial Disapproval of 2024 Iowa 303(d) List
Date: Thursday, December 19, 2024 11:49:19 AM
Attachments: TFI Comments EPA Region 7 Partial Disapproval of 2024 Iowa 303fd1 List.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Hello -
Please see the attachment for comments on behalf of The Fertilizer Institute. Please reach out
if there are any questions.
Thankyou,
Reagan Giesenschlag
Director, Government Affairs
The Fertilizer Institute
4201 Wilson Blvd, Suite 700
Arlington, VA 22203
161
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December 19, 2024
Submitted via email to R7-WaterDivision(a)eva.gov
Jeffery Robichand
EPA Region 7
Water Division
Lenexa, KS 66219
RE: Comments on the EPA Region 7 Partial Disapproval of2024 Iowa 303(d) List
Dear Mr. Robichand:
The Fertilizer Institute (TFI), on behalf of its member companies, submits these comments
addressing the U.S. Environmental Protection Agency Region 7 (EPA-7) in response to the partial
disapproval-7 of Iowa's 2024 303(d) list made on November 13, 2024.
Statement of Interest
TFI represents the nation's fertilizer industry, including producers, importers, retailers,
wholesalers, and companies that are engaged in all aspects of the fertilizer supply chain. Fertilizer
is a key ingredient in feeding a growing global population, which is expected to surpass 9.5 billion
people by 2050. Half of all food grown around the world today is made possible through the use
of fertilizer.
TFI member companies have a long history of supporting initiatives for the protection and
improvement of water quality. TFI member companies have committed significant time and
resources to reduce N and P loadings through our 4R Nutrient Stewardship Program, the 4R
Research Fund, and state 4R Certification Programs. By fostering innovative solutions, advocating
for best practices, and collaborating with stakeholders, TFI is committed to safeguarding aquatic
ecosystems, ensuring sustainable water management, and enhancing the overall health of water
resources for future generations.
Opening Statement
TFI recognizes the importance of protecting U.S. waters and supports voluntary approaches to
water quality protection and improvement. TFI is deeply concerned with EPA-7's request for the
Iowa Department of Natural Resources (DNR) to modify its assessment methodology and believes
this decision goes beyond EPA-7's authority. Listing of impaired waters should be based on
logical, effective scientific methods that allow states to prioritize and direct resources to
watersheds with systemic issues. TFI agrees with the rationale provided by Iowa DNR in response
to comments submitted by EPA-7 and supports the decisions to decline requested changes.
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For the reasons outlined below, TFI opposes EPA-7's partial denial and believes major deviations
to historically accepted methodology should be subject to a formal rulemaking process.
TFI Comments
TFI has reviewed comments submitted by EPA-7 to DNR and DNR's subsequent response. TFI
fully supports DNR's rationale and justification for declining changes requested by EPA-7 and
provides the following comments:
• EPA-7's responsibility is limited to approving or disapproving listings, not dictating
assessment methodology used by the state. This partial disapproval contradicts the
principles of cooperative federalism, particularly considering that this occurs after more
than 20 years of successful collaboration and approaches regarding Iowa's 303(d) list.
• EPA-7 has not provided sufficient scientific or regulatory rationale to support methodology
changes, claims that the 10% binomial rule is "non-defensible" for nitrates, and the addition
of the proposed seven water segments.
• EPA-7 should provide greater transparency (i.e. data sources and full data sets) on
additional data considered for the proposed seven segments since the data presented does
not match existing and readily available data. Notably, EPA-7 fails to disclose the total
number of samples taken in Table 1, which limits the ability to make substantive comments
on the assessment of water segments being proposed for addition.
• EPA-7's requests are a major departure from well-established and historical policies for
reviewing impaired waters list and such significant changes require a formal rulemaking
process.
Conclusion
TFI appreciates EPA's consideration of these comments in response to the partial disapproval of
Iowa DNRs 2024 303(d) list. We will gladly provide any additional information necessary to help
;hanged. Please contact me by telephone at
if you would like to discuss our comments
or if we can provide any additional information.
Sincerely,
Reagan Giesenschlag
Director, Government Affairs
163
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From: Madsen. Tami
To: R7-WaterDivision
Subject: Public Comment on Iowa Impaired Waters
Date: Thursday, December 19, 2024 8:47:48 PM
Attachments: Outlook-fiQ54eOs.Dna
CIWW public comment letter Impaired Waters.pdf
I Caution: This email originated from outside EPA, please exercise additional caution when
deciding whether to open attachments or click on provided links.
Good Evening Mr. Robichaud,
Thankyou for the opportunity to provide comment on the 2024 Impaired Water List.
Please see my attached letter concerning the same.
With Respect,
Tami Madsen
Executive Director
Central Iowa Water Works
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Temporary address:
2201 George Flagg Parkway
lies, IA 50321
email: info@ciww.Qov
CENTRAL IOWA WATER WORKS
December 19,2024
Jeffrey Robiehaud
VV.iter Division
U.S. lii'A Region 7
11201 Rentier Blvd.
Lenexa, K S 6621c)
E i na: 1: R7- WaterDivision@epa.gov
RE: Iowa Impaired Waters List - 2024
Dear Mr. Robiehaud,
Central Iowa Water Works (CIWW) is a regional water production authority founded b> twelve
entities representing utilities, communities, and rural providers. CI WW is responsible for drinking
water treatment. ivnier system planning, and the wholesale delivery of water across central Iowa.
On behalf of CIWW. I would like to thank the U.S. Environmental Protection Agency for your
attention to Iowa's impaired waters list and for the proposed additions of two segments that serve
an important role in providing clean, reliable water for the benefit of twenty percent of the state's
population.
The two proposed additions to the impaired waters list thai itre of direct concern to the CIWW
service population are:
1. Pes VInines River 1A 04-1. DM-1211 - a 6.53-mtle segment of the river, which includes
Des Moines Water Work's intake at Prospect Park in I>es Moines.
2. Raccoon River 1A 04-RAC-l16 - a 15.59-mile segment of the river, including the entire
section that runs through Des Moines Water Works Park aid includes the intake at the Fleur
Drive Treatment Plant in Des Moines.
Data measured hy Des Moines Water Works (DVIWW). our contract operator, shows concerning
trends with nitrate concentrations in the segment of the Raccoon River Slowing past the intake at
lite Fleur Drive treatment plant. This year, nitrate concentrations in the Raccoon River were among
the highest they have seen, reaching a peak of I X.?3 nig I on June 24. nearly doubling the drinking
water standard of 10 mg'L. In the Des Moines River, nitrate concentrations reached 15.56 mg/L.
on May 16, also higher than the drinking wafer standard.
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This letter serves as Central Iowa Water Works* comment in support of the addition of Des Moines
'River IA 04-UDM-1211 and Raccoon River IA 04-RAC-1116 to the 2024 impaired waters list.
Thank you for the opportunity to provide remarks on this important matter.
Sincerely,
Tami Madsen
Executive Director
Email: |
Phone:
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3. Appendix B: The EPA-approved Iowa 2024 CWA Section 303(d) List
Definitions: N - Nitrogen; Bold - WQLSs added to list; PCBs - Polychlorinated biphenyls; and aka - Also Known As.
Number Water Body ID
Water Body Name
Impairment Cause
Impaired Use
New
Listing
1
IA 01-MAQ-20
Backbone Lake
Escherichia coli (E. coli)
Primary Contact Recreation
2
IA 04-UDM-1291
Badger Lake
Secchi Disk Transparency
Primary Contact Recreation
3
IA 02-WFC-820
Bailey Creek
Biological Integrity
Aquatic Life
4
IA 03-SSK-3053
Ballard Creek
Fish Kill(s)
Aquatic Life
5
IA 06-LSR-1631
Barringer Slough
Dissolved Oxygen
Aquatic Life
6
IA 01-TRK-215
Bass Creek
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
7
IA 01-TRK-215
Bass Creek
Thermal Modifications
Aquatic Life
8
IA 01-TRK-216
Bass Creek
Escherichia coli (E. coli)
Primary Contact Recreation
9
IA 01-UIA-251
Bear Creek
Escherichia coli (E. coli)
Primary Contact Recreation
10
IA Ol-VOL-297
Bear Creek
Escherichia coli (E. coli)
Primary Contact Recreation
11
IA 02-CED-517
Bear Creek
Benthic Macroinvertebrates
Aquatic Life
12
IA 02-CED-517
Bear Creek
Escherichia coli (E. coli)
Primary Contact Recreation
13
IA 02-CED-523
Bear Creek
Escherichia coli (E. coli)
Primary Contact Recreation
14
IA 01-UIA-286
Beaver Creek
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
15
IA 01-UIA-286
Beaver Creek
Thermal Modifications
Aquatic Life
16 IA 02-CED-555 Beaver Creek
Escherichia coli (E. coli)
Primary Contact Recreation
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Number Water Body ID Water Body Name
17 IA 02-CED-557 Beaver Creek
18 IA 02-CED-582 Beaver Creek
19 IA 04-UDM-1233 Beaver Creek
20 IA 02-WFC-818 Beeds Lake
21 IA 04-UDM-1243 Big Creek
22 IA 04-UDM-6540 Big Creek
23 IA 04-UDM-1242 Big Creek Lake
24 IA 02-ICD-602 Big Hollow Creek
25 IA 02-ICD-6496 Big Hollow Lake
26 IA 02-ICD-6496 Big Hollow Lake
27 IA 02-ICD-6496 Big Hollow Lake
28 IA 06-BSR-1522 Big Sioux River
29 IA 06-BSR-1522 Big Sioux River
30 IA 06-BSR-1524 Big Sioux River
31
32
IA06-BSR-1525
IA 02-IOW-656
Big Sioux River
Big Wall Lake
Impairment Cause
Benthic Macroinvertebrates
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Secchi Disk Transparency
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Chlorophyll-a
Fish Kill(s)
Chlorophyll-a
PH
Secchi Disk Transparency
Fish Kill(s)
Selenium
PH
PH
Dissolved Oxygen
New
Impaired Use
Listing
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation X
Aquatic Life, Primary Contact
Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life X
Aquatic Life, Primary Contact
Recreation
Aquatic Life, Primary Contact
X
Recreation
Aquatic Life
168
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Number
Water Body ID
Water Body Name
33 IA01-UIA-284
34 IA01-UIA-284
35 IA 02-CED-546
36 IA 02-CED-546
37 IA 02-CED-550
38 IA 04-RAC-1134
39 IA 01-YEL-433
40 IA 01-YEL-433
41 IA 02-CED-518
42 IA 04-RAC-3105
43 IA 01-TRK-221
44 IA 04-UDM-1252
45 IA 04-UDM-1256
46 IA 06-BOY-1502
47 IA 06-BOY-1502
48 IA 04-UDM-1255
49 IA 01-TRK-217
50 IA 06-BSR-1529
Bigalks Creek
Bigalks Creek
Black Hawk Creek
Black Hawk Creek
Black Hawk Creek
Black Hawk Lake
Bloody Run
Bloody Run
Blue Creek
Blue Heron Lake
Bohemian Creek
Boone River
Boone River
Boyer River
Boyer River
Briggs Woods Lake
Brockamp Creek
Broken Kettle Creek
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
Thermal Modifications
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Secchi Disk Transparency
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Fish Kill(s)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Selenium
Aquatic Life
Secchi Disk Transparency
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Biological Integrity
Aquatic Life
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Number Water Body ID Water Body Name
51 IA 01-WPS-358 Brophy Creek
52 IA 06-WEM-1735 Browns Lake
53 IA Ol-VOL-317 Brush Creek
54 IA Ol-VOL-318 Brush Creek
55 IA 04-RAC-1209 Brushy Creek
56 IA 04-RAC-1818 Brushy Creek
57 IA 01-MAQ-45 Buck Creek
58 IA 01-YEL-428 Buck Creek
59 IA 04-EDM-985 Buffalo Creek
60 IA 04-EDM-986 Buffalo Creek
61 IA 02-CED-580 Burr Oak Creek
62 IA 02-CED-581 Burr Oak Creek
63 IA 04-UDM-1826 Buttermilk Creek
64 IA 02-WIN-845 Calmus Creek
65 IA 01-NEM-6372 Candlelight Creek
66 IA 01-UIA-260 Canoe Creek
67 IA 06-WEM-1714 Carter Lake
68 IA01-UIA-275 Casey Springs
69 IA 01-TRK-124 Catfish Creek
Impairment Cause
Benthic Macroinvertebrates
Turbidity
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Fish Kill(s)
Fish Kill(s)
Benthic Macroinvertebrates
Benthic Macroinvertebrates
Fish Bioassessments
Fish Bioassessments
Benthic Macroinvertebrates
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Biological Integrity
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Dissolved Oxygen
Escherichia coli (E. coli)
Escherichia coli (E. coli)
New
Impaired Use
Listing
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life X
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation X
Primary Contact Recreation
Primary Contact Recreation
170
-------
Number Water Body ID Water Body Name
70 IA 01-TRK-125 Catfish Creek
71 IA 01-TRK-125 Catfish Creek
72 IA 03-SKU-6549 Cedar Creek
73 IA 03-SKU-905 Cedar Creek
74 IA 04-LDM-1053 Cedar Creek
75 IA 04-LDM-1054 Cedar Creek
76 IA 02-CED-449 Cedar River
77 IA 02-CED-451 Cedar River
78 IA 02-CED-456 Cedar River
79 IA 02-CED-462 Cedar River
80 IA 02-CED-469 Cedar River
81 IA 02-CED-470 Cedar River
82 IA 02-CED-472 Cedar River
83 IA 02-CED-477 Cedar River
84 IA 02-CED-477 Cedar River
85 IA 02-CED-478 Cedar River
86 IA 02-CED-479 Cedar River
87 IA 02-CED-456 Cedar River
88 IA 06-LSR-1663 Center Lake
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Kill(s)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Bioassessments
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Copper
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Nitrate plus nitrite as N
Drinking Water
Secchi Disk Transparency
Primary Contact
Recreation
171
-------
Number Water Body ID Water Body Name
89 IA 05-CHA-1318 Centerville Reservoir Upper
90 IA 05-CHA-1313 Chariton Creek
91 IA 05-CHA-1307 Chariton River
92 IA 05-CHA-1308 Chariton River
93 IA 05-CHA-1310 Chariton River
94 IA 05-CHA-1310 Chariton River
95 IA 05-CHA-1311 Chariton River
96 IA 05-CHA-1311 Chariton River
97 IA 05-CHA-1312 Chariton River
98 IA 03-SKM-886 Chatfield Lake
99 IA 01-UIA-6437 Clark Creek
100 IA 01-UIA-235 Clear Creek
101 IA 01-UIA-249 Clear Creek
102 IA 01-TRK-134 Cloie Branch
103 IA 01-TRK-134 Cloie Branch
104 IA01-MAQ-51 Coffins Creek
105 IA 01-UIA-280 Coldwater Creek
Impairment Cause
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Bioassessments
Biological Integrity
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Fish Kill(s)
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Temperature
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Impa
ired Use
Human Health
Primary Contact
Recreation
Primary Contact
Recreation
Primary Contact
Recreation
Primary Contact
Recreation
Aquatic Life
Aquatic Life
Primary Contact
Recreation
Primary Contact
Recreation
Human Health
Aquatic Life
Aquatic Life
Primary Contact
Recreation
New
Listing
Secondary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation,
Secondary Contact Recreation
172
-------
Number
Water Body ID
Water Body Name
106 IA01-UIA-265
107 IA 05-CHA-1323
108 IA 02-IOW-630
109 IA 02-IOW-630
110 IA 02-IOW-630
111 IA 02-ICD-605
112 IA 01-VOL-303
113 IA 01-VOL-304
114 IA 01-TRK-210
115 IA 01-TRK-211
116 IA 01-TRK-212
117 IA 01-TRK-213
118 IA 06-LSR-1583
119 IA 01-NEM-86
120 IA 06-LSR-1634
121 IA 06-LSR-1634
122 IA 06-FLO-1562
123 IA 02-CED-591
Coon Creek
Cooper Creek
Coralville Reservoir
Coralville Reservoir
Coralville Reservoir
Cottonwood Drain
Cox Creek
Cox Creek
Crane Creek
Crane Creek
Crane Creek
Crane Creek
Crawford Creek Impoundment
Crow Creek
Dan Greene Slough
Dan Greene Slough
Deep Creek
Deer Creek
Impairment Cause
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Chlorophyll-a
Escherichia coli (E. coli)
Turbidity
Biological Integrity
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Benthic Macroinvertebrates
PH
Escherichia coli (E. coli)
Dissolved Oxygen
PH
Biological Integrity
Escherichia coli (E. coli)
New
Impaired Use
Listing
Primary Contact Recreation,
Secondary Contact Recreation
Aquatic Life
Primary Contact Recreation X
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life, Primary Contact
Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
173
-------
Number Water Body ID
Water Body Name
124 IA 04-LDM-1002
125 IA 04-LDM-1003
126 IA 04-LDM-1004
127 IA 04-LDM-1004
128 IA 04-LDM-1005
129 IA 04-LDM-1010
130 IA 04-LDM-1010
131 IA 04-UDM-1215
132 IA 04-UDM-1216
133 IA 04-UDM-1217
134 IA 04-UDM-1219
135 IA 04-UDM-1220
136 IA 04-UDM-1220
137 IA 04-UDM-1221
138 IA 04-UDM-1222
139 IA 04-UDM-1223
140 IA 04-LDM-1011
141 IA 04-UDM-1211
142 IA 06-WEM-1716
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Des Moines River
Desoto Bend
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Kill(s)
Aquatic Life
Fish Kill(s)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Kill(s)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Nitrate plus nitrite as N
Drinking Water
Nitrate plus nitrite as N
Drinking Water
Chlorophyll-a
Primary Contact
Recreation
174
-------
Number Water Body ID Water Body Name
143 IA 06-WEM-1716 Desoto Bend
144 IA 03-NSK-861 Diamond Lake
145 IA 06-LSR-1672 Diamond Lake
146 IA 01-TRK-202 Dibble Creek
147 IA 05-CHA-1336 Dick Creek
148 IA 01-YEL-438 Dousman Creek
149 IA 04-UDM-6494 Drainage Ditch 97
150 IA 01-TRK-2002 Dry Branch
151 IA 02-CED-507 Dry Creek
152 IA 06-BSR-1878 Dry Creek
153 IA 01-TRK-189 Dry Mill Creek
154 IA 01-UIA-272 Dry Run
155 IA 01-UIA-272 Dry Run
156 IA 02-CED-554 Dry Run
157 IA 02-CED-554 Dry Run
158 IA 02-CED-6293 Dry Run
159 IA 02-CED-2063 Dry Run (North Branch)
160 IA 02-CED-2062 Dry Run (South Branch)
New
Impairment Cause Impaired Use
Listing
Turbidity
Primary Contact Recreation
Chlorophyll-a
Aquatic Life
PH
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Biological Integrity
Aquatic Life
Dissolved Oxygen
Aquatic Life
Fish Kill(s)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
Thermal Modifications
Aquatic Life
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
175
-------
Number Water Body ID
161 IA 01-UIA-6552
162 IA 01-UIA-254
163 IA 02-IOW-779
164 IA 02-CED-1880
165 IA 02-IOW-769
166 IA 05-NSH-1823
167 IA 05-GRA-1350
168 IA 04-LDM-1065
169 IA 05-NSH-1414
170 IA 05-NSH-1415
171 IA 05-NOD-1391
172 IA 05-NOD-1391
173 IA 05-NOD-1392
174 IA 06-LSR-1652
175 IA 01-UIA-279
176 IA 02-IOW-777
177 IA 02-IOW-777
178 IA 02-IOW-773
179 IA 01-TRK-175
Water Body Name
Dry Run Creek
Duck Creek
Eagle Lake
East Branch Blue Creek
East Branch Iowa River
East Branch West Nishnabotna River
East Fork Medicine Creek
East Lake (Osceola)
East Nishnabotna River
East Nishnabotna River
East Nodaway River
East Nodaway River
East Nodaway River
East Okoboji Lake
East Pine Creek
East Twin Lake
East Twin Lake
Eldred Sherwood Lake
Elk Creek
Impairment Cause
Escherichia coli (E. coli)
Escherichia coli (E. coli)
PH
Fish Kill(s)
Benthic Macroinvertebrates
Biological Integrity
Biological Integrity
Dissolved Oxygen
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Biological Integrity
Escherichia coli (E. coli)
Fish Bioassessments
Mercury
Benthic Macroinvertebrates
Chlorophyll-a
Total Suspended Solids (TSS)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
New
Impaired Use
Listing
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life X
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life X
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Human Health X
Aquatic Life
Aquatic Life X
Aquatic Life X
Primary Contact Recreation
Primary Contact Recreation
176
-------
Number Water Body ID Water Body Name
180 IA 06-LSR-1629 Elk Lake
181 IA 06-LSR-1629 Elk Lake
182 IA 06-LSR-1629 Elk Lake
183 IA 02-IOW-657 Elm Lake
184 IA 02-IOW-657 Elm Lake
185 IA 04-LDM-1057 English Creek
186 IA 02-WIN-840 Fin And Feather Lake
187 IA 05-CHA-1341 Fivemile Creek
188 IA 02-SHL-788 Flood Creek
189 IA 06-FLO-1552 Floyd River
190 IA 06-FLO-1552 Floyd River
191 IA 06-FLO-1553 Floyd River
192 IA 06-FLO-1554 Floyd River
193 IA 06-FLO-6266 Floyd River
194 IA 04-UDM-1752 Fourmile Lake
195 IA 04-FOX-994 Fox River
196 IA 04-FOX-995 Fox River
197 IA 04-FOX-995 Fox River
New
Impairment Cause Impaired Use
Listing
Chlorophyll-a
Aquatic Life
PH
Aquatic Life
Total Suspended Solids (TSS)
Aquatic Life
Chlorophyll-a
Aquatic Life
Total Suspended Solids (TSS)
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
PH
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Selenium
Aquatic Life
Fish Bioassessments
Aquatic Life
Biological Integrity
Aquatic Life
Fish Kill(s)
Aquatic Life
Dissolved Oxygen
Aquatic Life
Fish Bioassessments
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Fish Bioassessments
Aquatic Life
177
-------
Number
Water Body ID
Water Body Name
198 IA01-UIA-248
199 IA 03-SKU-896
200 IA 02-CED-465
201 IA 04-LDM-6311
202 IA 01-TRK-127
203 IA Ol-VOL-322
204 IA 04-RAC-1118
205 IA 04-RAC-1118
206 IA 05-PLA-1472
207 IA 06-LSR-1625
208 IA 06-LSR-1625
209 IA 04-RAC-6537
210 IA 03-NSK-862
211 IA 01-YEL-447
212 IA 01-YEL-447
213 IA 01-VOL-307
214 IA 01-VOL-307
French Creek
Geode Lake
George Wyth Lake
Grade Lake
Granger Creek
Grannis Creek
Grays Lake
Grays Lake
Green Valley Lake
Gustafson Lake
Gustafson Lake
Halburn Creek
Hawthorn Lake
Hecker Creek
Hecker Creek
Hewett Creek
Hewett Creek
Impairment Cause
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Secchi Disk Transparency
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Chlorophyll-a
Secchi Disk Transparency
PH
Escherichia coli (E. coli)
Secchi Disk Transparency
Fish Kill(s)
Chlorophyll-a
Chloride
Fish Bioassessments
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Impaired Use
Primary Contact Recreation,
Secondary Contact Recreation
Human Health
Primary Contact Recreation
Human Health
Secondary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life, Primary Contact
Recreation, Drinking Water
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
New
Listing
178
-------
Number Water Body ID Water Body Name
215 IA 01-VOL-307 Hewett Creek
216 IA01-NMQ-110 Hickory Creek
217 IA 03-SSK-950 Hickory Grove Lake
218 IA 04-UDM-1304 High Lake
219 IA 04-UDM-1304 High Lake
220 IA 02-CED-552 Holland Creek
221 IA 02-CED-6491 Holland Creek
222 IA 01-MAQ-53 Honey Creek
223 IA 01-MAQ-6560 Honey Creek
224 IA 05-CHA-1337 Honey Creek
225 IA 05-CHA-2019 Honey Creek
226 IA 01-TRK-191 Howard Creek
227 IA 02-CED-504 Indian Creek
228 IA 02-CED-504 Indian Creek
229 IA 02-CED-505 Indian Creek
230 IA 03-SSK-943 Indian Creek
231 IA 03-SSK-943 Indian Creek
232 IA 05-NSH-1425 Indian Creek
233 IA 06-BSR-1531 Indian Creek
New
Impairment Cause Impaired Use
Listing
Thermal Modifications
Aquatic Life
Biological Integrity
Aquatic Life
Secchi Disk Transparency
Primary Contact
Recreation
Chlorophyll-a
Aquatic Life
Total Suspended Solids (TSS)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Secondary Contact Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
179
-------
Number Water Body ID Water Body Name
234 IA 02-IOW-677 Iowa Lake
235 IA 02-IOW-677 Iowa Lake
236 IA 04-BLU-969 Iowa Lake
237 IA 04-BLU-969 Iowa Lake
238 IA 04-BLU-969 Iowa Lake
239 IA 04-BLU-969 Iowa Lake
240 IA 02-IOW-624 Iowa River
241 IA 02-IOW-633 Iowa River
242 IA 02-IOW-634 Iowa River
243 IA 02-IOW-635 Iowa River
244 IA 02-IOW-638 Iowa River
245 IA 02-IOW-639 Iowa River
246 IA 02-IOW-639 Iowa River
247 IA 02-IOW-640 Iowa River
248 IA 02-IOW-640 Iowa River
249 IA 02-IOW-641 Iowa River
250 IA 02-IOW-642 Iowa River
251 IA 02-IOW-644 Iowa River
252 IA 02-IOW-645 Iowa River
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Ammonia
Aquatic Life
X
Chlorophyll-a
Aquatic Life
X
PH
Aquatic Life, Drinking Water
X
Total Suspended Solids (TSS)
Aquatic Life
X
Benthic Macroinvertebrates
Aquatic Life
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact Recreation
X
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
180
-------
Number Water Body ID
253 IA 02-IOW-646
254 IA 02-IOW-647
255 IA 02-IOW-648
256 IA 02-IOW-628
257 IA 02-IOW-628
258 IA 01-UIA-247
259 IA 05-CHA-1332
260 IA 05-CHA-1332
261 IA01-NMQ-105
262 IA 06-LSR-1605
263 IA 05-CHA-1330
264 IA 05-CHA-1330
265 IA 06-WED-1686
266 IA 06-WED-1687
267 IA 04-LDM-1080
268 IA 05-NSH-1435
269 IA 03-SKU-924
270 IA 01-WPS-356
271 IA 03-SSK-930
Water Body Name
Iowa River
Iowa River
Iowa River
Iowa River
Iowa River
Irish Hollow Creek
Jackson Creek
Jackson Creek
Johns Creek
Johns Creek
Jordan Creek
Jordan Creek
Keg Creek
Keg Creek
Lake Ahquabi
Lake Anita
Lake Darling
Lake Hendricks
Lake Keomah
New
Impairment Cause Impaired Use
Listing
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Nitrate as N
Drinking Water
Nitrate plus nitrite as N
Drinking Water
Benthic Macroinvertebrates
Aquatic Life
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Fish Bioassessments
Aquatic Life
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Bioassessments
Aquatic Life
Biological Integrity
Aquatic Life
Secchi Disk Transparency
Primary Contact
Recreation
Secchi Disk Transparency
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Chlorophyll-a
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
181
-------
Number Water Body ID Water Body Name
111 IA 06-WEM-1711 LakeManawa
273 IA 06-WEM-1711 LakeManawa
274 IA 04-LDM-1016 Lake Miami
275 IA 06-BSR-1532 Lake Pahoja
276 IA 04-LDM-1035 Lake Wapello
277 IA 02-CED-524 Lime Creek
278 IA 02-CED-525 Lime Creek
279 IA 01-MAQ-54 Lindsey Creek
280 IA 02-IOW-705 Little Bear Creek
281 IA 02-CED-574 Little Cedar River
282 IA 04-RAC-1176 Little Clear Lake
283 IA 04-RAC-1176 Little Clear Lake
284 IA 04-UDM-6542 Little Creek
285 IA01-TRK-131 Little Maquoketa River
286 IA 05-GRA-1357 Little River
287 IA 05-GRA-1358 Little River Watershed Lake
288 IA 05-GRA-1358 Little River Watershed Lake
289 IA 06-BSR-1798 Little Rock River
290 IA 06-BSR-1799 Little Rock River
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact
Recreation
Turbidity
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Dissolved Oxygen
Aquatic Life
PH
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Fish Bioassessments
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
182
-------
Number Water Body ID Water Body Name
291 IA 06-BSR-1800 Little Rock River
292 IA 06-LSR-1564 Little Sioux River
293 IA 06-LSR-1565 Little Sioux River
294 IA 06-LSR-1570 Little Sioux River
295 IA 06-LSR-1573 Little Sioux River
296 IA 06-LSR-1577 Little Sioux River
297 IA 06-LSR-1578 Little Sioux River
298 IA 06-LSR-1578 Little Sioux River
299 IA 06-LSR-1579 Little Sioux River
300 IA 06-LSR-1659 Little Spirit Lake
301 IA 01-TRK-160 Little Turkey River
302 IA 01-TRK-162 Little Turkey River
303 IA 01-TRK-162 Little Turkey River
304 IA 01-TRK-163 Little Turkey River
305 IA 01-TRK-207 Little Turkey River
306 IA 01-TRK-208 Little Turkey River
307 IA 01-TRK-209 Little Turkey River
308 IA Ol-VOL-328 Little Volga River
Impairment Cause
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Bioassessments
Benthic Macroinvertebrates
Ammonia
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
New
Impaired Use
Listing
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life X
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
183
-------
Number Water Body ID Water Body Name
309 IA Ol-VOL-328 Little Volga River
310 IA 04-UDM-1278 Lizard Creek
311 IA 04-UDM-1281 Lizard Lake
312 IA 05-GRA-1381 Loch Ayr
313 IA 03-SSK-2007 Long Dick Creek
314 IA 03-SSK-960 Long Dick Creek
315 IA 05-GRA-1376 Lotts Creek
316 IA 02-IOW-758 Lower Pine Lake
317 IA 01-YEL-446 Ludlow Creek
318 IA 01-TRK-123 Lux Creek
319 IA 04-UDM-1260 Lyons Creek
320 IA 01-NEM-81 Mad Creek
321 IA 06-BOY-1505 Manteno Park Pond
322 IA 06-LSR-1581 Maple River
323 IA 06-LSR-1581 Maple River
324 IA 01-MAQ-13 Maquoketa River
325 IA 01-MAQ-14 Maquoketa River
326 IA 01-MAQ-15 Maquoketa River
327 IA01-MAQ-15 Maquoketa River
New
Impairment Cause Impaired Use
Listing
Mercury - Fish Consumption Advisory Human Health
Escherichia coli (E. coli)
Primary Contact
Recreation
PH
Aquatic Life
Secchi Disk Transparency
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Fish Bioassessments
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Dissolved Oxygen
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Selenium
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
184
-------
Number Water Body ID
328 IA01-MAQ-16
329 IA01-MAQ-16
330 IA01-MAQ-19
331 IA 04-RAC-1160
332 IA 04-RAC-1160
333 IA 05-PLA-1470
334 IA 05-PLA-1470
335 IA 05-PLA-1470
336 IA 02-CED-508
337 IA 02-CED-508
338 IA 04-LDM-1089
339 IA 02-CED-463
340 IA 01-TRK-128
341 IA 01-TRK-6487
342 IA 05-GRA-1378
343 IA 05-GRA-1378
344 IA 01-TRK-138
345 IA 05-NOD-1400
346 IA 04-LDM-1083
Water Body Name
Maquoketa River
Maquoketa River
Maquoketa River
Marrowbone Creek
Marrowbone Creek
McKinley Lake
McKinley Lake
McKinley Lake
McLoud Run
McLoud Run
Meadow Lake
Meyers Lake
Middle Fork Catfish Creek
Middle Fork Catfish Creek
Middle Fork Grand River
Middle Fork Grand River
Middle Fork Little Maquoketa River
Middle Nodaway River
Middle River
New
Impairment Cause Impaired Use
Listing
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Dissolved Oxygen
Aquatic Life
Chlorophyll-a
Primary Contact
Recreation
PCBS - Fish Consumption Advisory
Human Health
Secchi Disk Transparency
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Kill(s)
Aquatic Life
Secchi Disk Transparency
Primary Contact
Recreation
Chlorophyll-a
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Benthic Macroinvertebrates
Aquatic Life
Biological Integrity
Aquatic Life
Biological Integrity
Aquatic Life
185
-------
Number Water Body ID Water Body Name
347 IA 04-LDM-1083 Middle River
348 IA 06-LSR-1667 Milford Creek
349 IA 06-LSR-1615 Mill Creek
350 IA 04-LDM-1045 Miller Creek
351 IA 01-YEL-427 Miners Creek
352 IA Ol-VOL-314 Mink Creek
353 IA 02-CED-6490 Minnehaha Creek
354 IA 01-UIA-283 Minor Creek
355 IA01-NEM-61 Mississippi River
356 IA01-NEM-62 Mississippi River
357 IA01-NEM-62 Mississippi River
358 IA01-NEM-63 Mississippi River
359 IA 06-WEM-1707 Missouri River
360 IA 06-WEM-1708 Missouri River
361 IA 06-WEM-1709 Missouri River
362 IA 06-WEM-1715 Missouri River
363 IA 06-WEM-1720 Missouri River
364 IA 06-WEM-1721 Missouri River
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact Recreation
Benthic Macroinvertebrates
Aquatic Life
Biological Integrity
Aquatic Life
Fish Kill(s)
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Fecal Coliform
Primary Contact Recreation
Fecal Coliform
Primary Contact Recreation
PCBS - Fish Consumption Advisory
Human Health
Fecal Coliform
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
186
-------
Number Water Body ID
365 IA 06-WEM-1722
366 IA 03-SSK-6508
367 IA 02-CED-513
368 IA 05-NOD-1404
369 IA 04-LDM-1071
370 IA 02-IOW-658
371 IA 02-IOW-658
372 IA 02-IOW-658
373 IA 02-CED-6489
374 IA 06-WED-1699
375 IA 06-WED-1701
376 IA 04-LDM-1048
377 IA 04-LDM-1049
378 IA 02-CED-519
379 IA 05-NSH-1457
380 IA 06-BSR-1546
381 IA 06-BSR-1546
382 IA 06-BSR-1546
Water Body Name
Missouri River
Montgomery Creek
Morgan Creek
Mormon Trail Lake
Morris Lake
Morse Lake
Morse Lake
Morse Lake
Mosquito Creek
Mosquito Creek
Mosquito Creek
Muchakinock Creek
Muchakinock Creek
Mud Creek
Mud Creek
Mud Creek
Mud Creek
Mud Creek
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Dissolved Oxygen
Aquatic Life
Chlorophyll-a
Aquatic Life
PH
Aquatic Life
Total Suspended Solids (TSS)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Biological Integrity
Aquatic Life
Biological Integrity
Aquatic Life
Biological Integrity
Aquatic Life
Fish Bioassessments
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Fish Bioassessments
Aquatic Life
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
PH
Aquatic Life, Primary Contact
Recreation
187
-------
Number Water Body ID
383 IA 05-GRA-1361
384 IA 05-CHA-1335
385 IA 05-CHA-1335
386 IA 05-NSH-1412
387 IA 05-NOD-1401
388 IA 05-NOD-1389
389 IA 04-LDM-1988
390 IA 01-UIA-255
391 IA 01-TRK-223
392 IA 01-VOL-330
393 IA 01-VOL-330
394 IA 04-FAB-992
395 IA 02-CED-551
396 IA 01-TRK-129
397 IA 01-TRK-6486
398 IA01-NMQ-88
399 IA 01-NMQ-88
400 IA01-NMQ-90
Water Body Name
Nine Eagles Lake
Ninemile Creek
Ninemile Creek
Nishnabotna River
Nodaway Lake
Nodaway River (aka West Nodaway
R.)
North
Banner Lake
North
Bear Creek
North
Branch Turkey River
North
Branch Volga River
North
Branch Volga River
North
Fabius River
North
Fork Black Hawk Creek
North
Fork Catfish Creek
North
Fork Catfish Creek
North
Fork Maquoketa River
North
Fork Maquoketa River
North
Fork Maquoketa River
Impairment Cause
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Fish Bioassessments
Escherichia coli (E. coli)
Secchi Disk Transparency
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Fish Bioassessments
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Kill(s)
Benthic Macroinvertebrates
Impaired Use
Human Health
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Human Health
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Human Health
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
188
-------
Number Water Body ID Water Body Name
401 IA01-NMQ-90 North Fork Maquoketa River
402 IA01-NMQ-90 North Fork Maquoketa River
403 IA 01-YEL-2005 North Fork Yellow River
404 IA 01-YEL-448 North Fork Yellow River
405 IA 04-RAC-1139 North Raccoon River
406 IA 04-RAC-1139 North Raccoon River
407 IA 04-LDM-1097 North River
408 IA 04-LDM-1097 North River
409 IA 03-NSK-853 North Skunk River
410 IA 03-NSK-853 North Skunk River
411 IA 03-NSK-854 North Skunk River
412 IA 03-NSK-859 North Skunk River
413 IA 01-TRK-205 Nutting Creek
414 IA 06-LSR-1638 Ocheyedan River
415 IA 02-IOW-685 Old Mans Creek
416 IA 01-TRK-198 Otter Creek
417 IA 01-TRK-198 Otter Creek
418 IA 02-CED-514 Otter Creek
New
Impairment Cause Impaired Use
Listing
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Dissolved Oxygen
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Fish Bioassessments
Aquatic Life
Chromium
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation,
Secondary Contact Recreation
Thermal Modifications
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
189
-------
Number Water Body ID Water Body Name
419 IA 02-CED-594 Otter Creek
420 IA 06-BOY-1518 Otter Creek
421 IA02-IOW-720 Otter Creek Lake
422 IA01-UIA-257 Paint Creek (aka Pine Creek)
423 IA 02-SHL-790 Palmer Creek
424 IA 01-UIA-259 Patterson Creek
425 IA 01-TRK-168 Pecks Creek
426 IA 01-TRK-168 Pecks Creek
427 IA 06-BSR-1527 Perry Creek
428 IA 02-CED-485 Pike Run
429 IA 02-CED-486 Pike Run
430 IA 01-TRK-179 Pine Creek
431 IA 01-TRK-6638 Pine Creek
432 IA 01-UIA-278 Pine Creek
433 IA 06-LSR-1649 Pleasant Lake
434 IA 06-LSR-1649 Pleasant Lake
435 IA 06-LSR-1649 Pleasant Lake
Impairment Cause
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Secchi Disk Transparency
Escherichia coli (E. coli)
Fish Kill(s)
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Biological Integrity
Benthic Macroinvertebrates
Biological Integrity
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Chlorophyll-a
PH
Total Suspended Solids (TSS)
New
Impaired Use
Listing
Primary Contact Recreation
Aquatic Life X
Primary Contact Recreation X
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Secondary Contact Recreation
Primary Contact Recreation,
Secondary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
190
-------
Number Water Body ID
436 IA 01-MAQ-46
437 IA 01-MAQ-46
438 IA 01-MAQ-47
439 IA 06-WED-1683
440 IA 01-TRK-165
441 IA 01-TRK-165
442 IA 03-SKM-888
443 IA 02-IOW-6396
444 IA 03-SSK-6598
445 IA 04-UDM-1796
446 IA 04-UDM-6545
447 IA 06-LSR-1647
448 IA 04-RAC-1116
449 IA 02-IOW-1899
450 IA 04-LDM-1073
451 IA 04-LDM-1017
452 IA 04-LDM-1017
453 IA 02-IOW-6412
Water Body Name
Plum Creek
Plum Creek
Plum Creek
Plum Creek
Point Hollow Creek (aka White Pine
Creek)
Point Hollow Creek (aka White Pine
Creek)
Pollmiller Park Lake
Prairie Creek
Prairie Creek
Prairie Creek
Prairie Creek
Prairie Lake
Raccoon River
Ralston Creek
Red Haw Lake
Red Rock Reservoir
Red Rock Reservoir
Rhine Creek
Impairment Cause
Benthic Macroinvertebrates
Fish Kill(s)
Fish Kill(s)
Biological Integrity
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Wastewater
Escherichia coli (E. coli)
Biological Integrity
Escherichia coli (E. coli)
PH
Nitrate plus nitrite as N
Hydrocarbons - Priority Organics
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Turbidity
Fish Kill(s)
New
Impaired Use
Listing
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Human Health
General Use
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Drinking Water X
General Use
Human Health
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
191
-------
Number Water Body ID Water Body Name
454 IA 02-WIN-832 Rice Lake
455 IA 02-WIN-832 Rice Lake
456 IA 01-TRK-186 Roberts Creek
457 IA 01-TRK-188 Roberts Creek
458 IA 04-LDM-1019 Roberts Creek Lake
459 IA 01-NEM-6373 Robin Creek
460 IA 01-MAQ-2 Rock Creek
461 IA 02-CED-3026 Rock Creek
462 IA 02-CED-585 Rock Creek
463 IA 02-CED-586 Rock Creek
464 IA 02-CED-586 Rock Creek
465 IA 02-CED-587 Rock Creek
466 IA 02-CED-588 Rock Creek
467 IA 06-BSR-1534 Rock River
468 IA 06-BSR-1537 Rock River
469 IA 06-BSR-1538 Rock River
470 IA 06-BSR-1538 Rock River
471 IA 02-CED-526 Rodgers Park Lake
New
Impairment Cause Impaired Use
Listing
Chlorophyll-a Aquatic Life X
Aquatic Life, Primary Contact
pH
Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Turbidity
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Dissolved Oxygen
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
PH
Aquatic Life, Primary Contact
Recreation
Chlorophyll-a
Primary Contact Recreation
192
-------
Number Water Body ID
Water Body Name
472 IA 02-IOW-6403
473 IA 01-TRK-218
474 IA 01-MAQ-6561
475 IA 05-PLA-2064
476 IA 03-SKU-902
477 IA 03-SKU-902
478 IA 03-SKU-902
479 IA 04-UDM-1213
480 IA 04-UDM-1213
481 IA 02-SHL-782
482 IA 02-SHL-783
483 IA 02-SHL-783
484 IA 02-SHL-784
485 IA 02-SHL-787
486 IA 01-MAQ-l
487 IA 01-MAQ-l
488 IA 01-UIA-6596
489 IA 01-MAQ-44
Roff Creek
Rogers Creek
Routherford Branch
Sands Timber Lake (aka Blockton
Reservoir)
Saunders Branch
Saunders Branch
Saunders Branch
Saylorville Reservoir
Saylorville Reservoir
Shell Rock River
Shell Rock River
Shell Rock River
Shell Rock River
Shell Rock River
Shrickers Slough
Shrickers Slough
Siewers Spring
Silver Creek
Impairment Cause
Wastewater
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Turbidity
Ammonia
Coal Tar
Dissolved Oxygen
Chlorophyll-a
Secchi Disk Transparency
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Mercury - Fish Consumption Advisory
Escherichia coli (E. coli)
Chlorophyll-a
Secchi Disk Transparency
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Impaired Use
General Use
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Human Health
Primary Contact Recreation
Human Health
Human Health
Primary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation
Aquatic Life
New
Listing
193
-------
Number Water Body ID Water Body Name
490 IA 01-TRK-192 Silver Creek
491 IA 01-TRK-2057 Silver Creek
492 IA 01-UIA-250 Silver Creek
493 IA 01-UIA-282 Silver Creek
494 IA 05-NSH-1454 Silver Creek
495 IA 02-SHL-796 Silver Lake
496 IA 06-BSR-1533 Sixmile Creek
497 IA 06-BSR-1533 Sixmile Creek
498 IA 04-UDM-1250 Skillet Creek
499 IA 03-SKU-889 Skunk River
500 IA 02-CED-6565 Slough Creek
501 IA 06-WEM-1734 Snyder Bend Lake
502 IA 06-WEM-1734 Snyder Bend Lake
503 IA 04-LDM-1033 Soap Creek
504 IA 06-SOL-1673 Soldier River
505 IA 06-SOL-1673 Soldier River
506 IA 06-SOL-1673 Soldier River
507 IA 04-LDM-1085 South Banner Lake
Impairment Cause
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Bioassessments
PH
Biological Integrity
Escherichia coli (E. coli)
Biological Integrity
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Chlorophyll-a
Turbidity
Fish Bioassessments
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Selenium
Mercury - Fish Consumption Advisory
Impaired Use
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life, Primary Contact
Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation
Aquatic Life
Human Health
New
Listing
194
-------
Number Water Body ID
508 IA01-UIA-252
509 IA 03-SKU-6271
510 IA 01-TRK-171
511 IA 01-TRK-130
512 IA 05-CHA-1327
513 IA 05-CHA-1327
514 IA 05-CHA-1328
515 IA 05-CHA-1328
516 IA 02-IOW-748
517 IA 02-IOW-748
518 IA 02-IOW-751
519 IA 02-IOW-752
520 IA 02-IOW-752
521 IA 04-RAC-1181
522 IA 04-LDM-1074
523 IA 04-LDM-1074
524 IA 03-SSK-926
525 IA 03-SSK-927
526 IA 03-SSK-931
Water Body Name
South Bear Creek
South Big Creek
South Cedar Creek (aka Cedar Creek)
South Fork Catfish Creek
South Fork Chariton River
South Fork Chariton River
South Fork Chariton River
South Fork Chariton River
South Fork Iowa River
South Fork Iowa River
South Fork Iowa River
South Fork Iowa River
South Fork Iowa River
South Raccoon River
South River
South River
South Skunk River
South Skunk River
South Skunk River
Impairment Cause
Escherichia coli (E. coli)
Fish Kill(s)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Bioassessments
Biological Integrity
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Dissolved Oxygen
Benthic Macroinvertebrates
Benthic Macroinvertebrates
Dissolved Oxygen
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
New
Impaired Use
Listing
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life X
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
195
-------
Number Water Body ID Water Body Name
527 IA 03-SSK-934 South Skunk River
528 IA 03-SSK-934 South Skunk River
529 IA 03-SSK-935 South Skunk River
530 IA 03-SSK-927 South Skunk River
531 IA 04-RAC-1168 South Twin Lake
532 IA 04-RAC-1168 South Twin Lake
533 IA01-NEM-87 Spencer Creek
534 IA 02-CED-589 Spring Creek
535 IA 02-CED-6566 Spring Creek
536 IA 06-LSR-1569 Spring Lake
537 IA 01-UIA-288 Staff Creek
538 IA 01-NEM-6370 Stafford Creek
539 IA 01-TRK-178 Steeles Branch
540 IA 01-TRK-6568 Steeles Branch
541 IA 06-LSR-1644 Stony Creek
542 IA 04-RAC-1143 Storm Lake
543 IA 02-CED-489 Sugar Creek
Impairment Cause
Biological Integrity
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Nitrate plus nitrite as N
Chlorophyll-a
Turbidity
Fish Kill(s)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Secchi Disk Transparency
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Biological Integrity
Escherichia coli (E. coli)
Benthic Macroinvertebrates
New
Impaired Use
Listing
Aquatic Life
Primary Contact Recreation
Aquatic Life
Drinking Water X
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation X
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
196
-------
Number Water Body ID Water Body Name
544 IA 04-RAC-1174 Sunken Grove Lake
545 IA 01-YEL-439 Suttle Creek
546 IA 01-YEL-439 Suttle Creek
547 IA 04-UDM-1232 Swan Lake
548 IA 04-UDM-1232 Swan Lake
549 IA 04-UDM-1232 Swan Lake
550 IA 01-UIA-274 Ten Mile Creek
551 IA 01-UIA-274 Ten Mile Creek
552 IA 01-TRK-121 Tetes Des Morts Creek
553 IA 01-TRK-122 Tetes Des Morts Creek
554 IA 05-GRA-1351 Thompson River
555 IA 05-NSH-1436 Troublesome Creek
556 IA01-UIA-269 Trout Creek (aka Trout Run)
557 IA01-UIA-269 Trout Creek (aka Trout Run)
558 IA 01-UIA-266 Trout River
559 IA 04-UDM-6543 Turkey Creek
560 IA 01-TRK-148 Turkey River
561 IA 01-TRK-148 Turkey River
Impairment Cause
PH
Benthic Macroinvertebrates
Dissolved Oxygen
Chlorophyll-a
PH
Sedimentation/Siltation
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Bioassessments
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Mercury - Fish Consumption Advisory
Impaired Use
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation,
Secondary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Human Health
New
Listing
197
-------
Number Water Body ID
562 IA 01-TRK-149
563 IA 01-TRK-152
564 IA 01-TRK-153
565 IA 01-TRK-154
566 IA 01-TRK-156
567 IA 02-CED-590
568 IA 05-GRA-1367
569 IA 05-GRA-1367
570 IA 04-UDM-1231
571 IA 04-UDM-1231
572 IA 01-UIA-273
573 IA Ol-VOL-325
574 IA 04-LDM-1046
575 IA 01-WPS-394
576 IA 01-TRK-1885
577 IA 04-UDM-6541
578 IA 04-UDM-6544
579 IA 03-SKU-6410
Water Body Name
Turkey River
Turkey River
Turkey River
Turkey River
Turkey River
Turtle Creek
Twelve Mile Creek Lake
Twelve Mile Creek Lake
Twelve-mile Lake
Twelve-mile Lake
Twin Springs Creek
Unnamed Creek (aka Volga Lake
Outlet)
Unnamed Creek (near Eddyville)
Unnamed Creek (near Hazleton)
Unnamed Tributary to Bass Creek
Unnamed Tributary to Big Creek
Unnamed Tributary to Big Creek
Unnamed tributary to Brush Creek
Impairment Cause
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Chlorophyll-a
Secchi Disk Transparency
Chlorophyll-a
Total Suspended Solids (TSS)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Kill(s)
Fish Kill(s)
Fish Kill(s)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Wastewater
New
Impaired Use
Listing
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation X
Primary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
General Use
198
-------
Number Water Body ID
580 IA 01-TRK-6408
581 IA 03-SKU-6573
582 IA 03-SKU-6581
583 IA 03-SKU-6585
584 IA 02-CED-6594
585 IA 02-CED-6294
586 IA 01-UIA-6557
587 IA 01-UIA-6558
588 IA 01-UIA-6600
589 IA 03-SSK-6599
590 IA 03-SKU-6591
591 IA 01-WPS-6457
592 IA 02-CED-6432
593 IA 01-TRK-6612
594 IA 06-BSR-1934
595 IA 06-LSR-6342
Water Body Name
Unnamed tributary to Catfish Creek
Unnamed Tributary to Cedar Creek
Unnamed Tributary to Cedar Creek
Unnamed Tributary to Cedar Creek
Unnamed Tributary to Cedar River
Unnamed Tributary to Dry Run
Unnamed Tributary to Dry Run Creek
Unnamed Tributary to Dry Run Creek
Unnamed Tributary to Dry Run Creek
Unnamed Tributary to loway Creek
Unnamed Tributary to Lake Geode
Unnamed Tributary to Lake Hendricks
Unnamed Tributary to Lime Creek
Unnamed Tributary to Little
Maquoketa River
Unnamed Tributary to Little Rock
River
Unnamed Tributary to Little Sioux
River
Impairment Cause
Wastewater
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Escherichia
coli (E.
coli)
Fish Kill(s)
Fish Kill(s)
Fish Kill(s)
New
Impaired Use
Listing
General Use
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
199
-------
Number Water Body ID
596 IA 01-MAQ-1963
597 IA 04-RAC-2036
598 IA 02-IOW-6588
599 IA 01-YEL-3066
600 IA 01-TRK-6620
601 IA 02-IOW-3063
602 IA 02-IOW-3064
603 IA 02-IOW-6300
604 IA 05-CHA-1915
605 IA 02-CED-3027
606 IA 01-UIA-6569
607 IA 02-IOW-6401
608 IA 02-CED-6567
609 IA 01-TRK-6580
610 IA 01-TRK-6589
Water Body Name
Unnamed Tributary to Maquoketa
River
Unnamed Tributary to Marrowbone
Creek
Unnamed Tributary to Muddy Creek
Unnamed Tributary to North Fork
Yellow River
Unnamed Tributary to Otter Creek
Unnamed Tributary to Price Creek
Unnamed Tributary to Price Creek
Unnamed Tributary to Ralston Creek
Unnamed Tributary to Rathbun
Reservoir
Unnamed Tributary to Rock Creek
Unnamed Tributary to Silver Creek
Unnamed tributary to Snyder Creek
Unnamed Tributary to Spring Creek
Unnamed Tributary to Tetes Des
Morts Creek
Unnamed Tributary to Tetes Des
Morts Creek
Impairment Cause
Impaired Use
New
Listing
Fish Kill(s)
Escherichia coli (E. coli)
Dissolved Oxygen
Escherichia coli (E. coli)
Fish Kill(s)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Kill(s)
Fish Kill(s)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Wastewater
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Aquatic Life
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
General Use
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
200
-------
Number Water Body ID
611 IA 01-TRK-6460
612 IA 01-UIA-6554
613 IA 01-UIA-6555
614 IA 01-UIA-6556
615 IA 01-YEL-6575
616 IA 01-UIA-6597
617 IA 01-TRK-2058
618 IA 01-UIA-6570
619 IA 02-CED-6262
620 IA 02-WFC-2075
621 IA 01-YEL-2059
622 IA 01-YEL-6574
623 IA 01-YEL-6582
Water Body Name
Unnamed Tributary to Turkey River
Unnamed Tributary to Unnamed
Tributary to Dry Run Creek
Unnamed Tributary to Unnamed
Tributary to Dry Run Creek
Unnamed Tributary to Unnamed
Tributary to Dry Run Creek
Unnamed Tributary to Unnamed
Tributary to Yellow River
Unnamed Tributary to Upper Iowa
River
Unnamed Tributary to UT to Silver
Creek
Unnamed Tributary to Waterloo
Creek
Unnamed Tributary to West Branch
Wapsinonoc Creek (aka Hoover
Creek)
Unnamed Tributary to West Fork
Cedar River
Unnamed Tributary to Yellow River
Unnamed Tributary to Yellow River
Unnamed Tributary to Yellow River
Impairment Cause
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Fish Kill(s)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Impaired Use
Secondary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
New
Listing
201
-------
Number Water Body ID Water Body Name
624 IA01-UIA-236 Upper Iowa River
625 IA01-UIA-236 Upper Iowa River
626 IA 01-UIA-237 Upper Iowa River
627 IA 01-UIA-237 Upper Iowa River
628 IA 01-UIA-238 Upper Iowa River
629 IA01-UIA-239 Upper Iowa River
630 IA01-UIA-239 Upper Iowa River
631 IA 01-UIA-239 Upper Iowa River
632 IA01-UIA-240 Upper Iowa River
633 IA 01-UIA-241 Upper Iowa River
634 IA01-UIA-241 Upper Iowa River
635 IA 01-UIA-241 Upper Iowa River
636 IA01-UIA-242 Upper Iowa River
637 IA 01-UIA-243 Upper Iowa River
638 IA01-UIA-244 Upper Iowa River
639 IA01-UIA-245 Upper Iowa River
640 IA Ol-VOL-291 Volga River
641 IA Ol-VOL-294 Volga River
642 IA Ol-VOL-295 Volga River
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
Mercury - Fish Consumption Advisory
Human Health
202
-------
Number Water Body ID Water Body Name
643 IA Ol-VOL-296 Volga River
644 IA 05-CHA-1329 Walker Branch
645 IA 01-WPS-372 Walnut Creek
646 IA 02-IOW-708 Walnut Creek
647 IA 02-IOW-709 Walnut Creek
648 IA 03-SSK-953 Walnut Creek
649 IA 04-RAC-1120 Walnut Creek
650 IA01-WPS-332 Wapsipinicon River
651 IA01-WPS-333 Wapsipinicon River
652 IA01-WPS-335 Wapsipinicon River
653 IA01-WPS-336 Wapsipinicon River
654 IA01-WPS-340 Wapsipinicon River
655 IA01-WPS-342 Wapsipinicon River
656 IA01-WPS-343 Wapsipinicon River
657 IA01-WPS-343 Wapsipinicon River
658 IA01-WPS-354 Wapsipinicon River
659 IA01-WPS-354 Wapsipinicon River
660 IA01-WPS-354 Wapsipinicon River
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Kill(s)
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
Fish Bioassessments
Aquatic Life
Fish Bioassessments
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Escherichia coli (E. coli)
Primary Contact
Recreation
Mercury - Fish Consumption Advisory
Human Health
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Secondary Contact Recreati
Fish Kill(s)
Aquatic Life
203
-------
Number Water Body ID
661 IA 01-WPS-6416
662 IA 01-UIA-253
663 IA 01-UIA-253
664 IA 06-LSR-1620
665 IA 06-LSR-1620
666 IA 05-GRA-1356
667 IA 04-RAC-1151
668 IA 06-FLO-1558
669 IA 05-PLA-1480
670 IA 02-CED-6264
671 IA 02-WFC-801
672 IA 06-LSR-1598
673 IA 06-LSR-1598
674 IA 06-LSR-1599
675 IA 05-CHA-1333
676 IA 04-LDM-1082
677 IA 05-NSH-1441
678 IA 05-NSH-1446
Water Body Name
Wapsipinicon River
Waterloo Creek
Waterloo Creek
Waterman Creek
Waterman Creek
Weldon River
West Branch Buttrick Creek
West Branch Floyd River
West Branch One Hundred And Two
River
West Branch Wapsinonoc
West Fork Cedar River
West Fork Little Sioux River
West Fork Little Sioux River
West Fork Little Sioux River
West Jackson Creek
West Lake (Osceola)
West Nishnabotna River
West Nishnabotna River
Impairment Cause
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Escherichia coli (E. coli)
Benthic Macroinvertebrates
Dissolved Oxygen
Biological Integrity
Benthic Macroinvertebrates
Fish Bioassessments
Biological Integrity
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Escherichia coli (E. coli)
Selenium
Biological Integrity
Benthic Macroinvertebrates
Dissolved Oxygen
Escherichia coli (E. coli)
Biological Integrity
Impaired Use
Primary Contact Recreation
Aquatic Life
Primary Contact Recreation,
Secondary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
Primary Contact Recreation
Primary Contact Recreation
Aquatic Life
Aquatic Life
Aquatic Life
Aquatic Life
Primary Contact Recreation
Aquatic Life
New
Listing
X
X
204
-------
Number Water Body ID
679 IA 05-NSH-1447
680 IA 06-LSR-2066
681 IA 04-UDM-1270
682 IA 04-UDM-1754
683 IA 04-UDM-1754
684 IA 05-TAR-1497
685 IA 02-IOW-778
686 IA 02-IOW-778
687 IA 02-IOW-778
688 IA 04-LDM-1059
689 IA 04-LDM-1825
690 IA 03-SSK-929
691 IA 03-SSK-929
692 IA01-NMQ-103
693 IA01-NMQ-103
694 IA 02-CED-6593
695 IA 06-FLO-1829
696 IA 06-LSR-1611
697 IA 06-LSR-1626
Water Body Name
West Nishnabotna River
West Okoboji Lake - Emersons Bay
West Otter Creek
West Swan Lake
West Swan Lake
West Tarkio Creek
West Twin Lake
West Twin Lake
West Twin Lake
White Breast Creek
White Breast Creek
White Oak Conservation Area Lake
White Oak Conservation Area Lake
Whitewater Creek
Whitewater Creek
Willow Creek
Willow Creek
Willow Creek
Willow Creek
New
Impairment Cause Impaired Use
Listing
Fish Kill(s)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Fish Kill(s)
Aquatic Life
Chlorophyll-a
Aquatic Life
Total Suspended Solids (TSS)
Aquatic Life
Biological Integrity
Aquatic Life
Chlorophyll-a
Aquatic Life
PH
Aquatic Life
Total Suspended Solids (TSS)
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Biological Integrity
Aquatic Life
Chlorophyll-a
Primary Contact Recreation
Secchi Disk Transparency
Primary Contact Recreation
Benthic Macroinvertebrates
Aquatic Life
Escherichia coli (E. coli)
Primary Contact Recreation
Escherichia coli (E. coli)
Primary Contact Recreation
Fish Kill(s)
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
Benthic Macroinvertebrates
Aquatic Life
205
-------
Number Water Body ID Water Body Name
698 IA 06-LSR-1626 Willow Creek
699 IA 06-LSR-6299 Willow Creek
700 IA 05-PLA-1477 Wilson Park Lake
701 IA 02-WIN-826 Winnebago River
702 IA 02-WIN-827 Winnebago River
703 IA 02-WIN-831 Winnebago River
704 IA 02-CED-530 Wolf Creek
705 IA 05-CHA-1339 Wolf Creek
706 IA 05-CHA-1339 Wolf Creek
707 IA 01-TRK-219 Wonder Creek
708 IA 01-YEL-2060 Yellow River
709 IA 01-YEL-435 Yellow River
710 IA 01-YEL-436 Yellow River
711 IA 01-YEL-437 Yellow River
712 IA 06-BOY-1514 Yellow Smoke Park Lake
New
Impairment Cause Impaired Use
Listing
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Secchi Disk Transparency
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Biological Integrity
Aquatic Life
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Escherichia coli (E. coli)
Primary Contact
Recreation
Fish Bioassessments
Aquatic Life
Fish Kill(s)
Aquatic Life
Fish Bioassessments
Aquatic Life
Mercury - Fish Consumption Advisory
Human Health
206
-------
4. Appendix C: Data Exceedances
Iowa DNR
Site
Number
Data Source
Location Name
Sample
Date
Parameter
Result
(mg/L)
05464420
U.S. Geological Survey
Cedar River at Blairs
Ferry Road at Palo, IA
06/15/2022
Nitrate + Nitrite (as
N)
10.3
05464420
U.S. Geological Survey
Cedar River at Blairs
Ferry Road at Palo, IA
07/12/2022
Nitrate + Nitrite (as
N)
10.1
99990021
Cedar Rapids Water Works
Cedar River
06/21/2022
Nitrate as N
13.66
99990021
Cedar Rapids Water Works
Cedar River
06/21/2022
Nitrite as N
0.045
99990021
Cedar Rapids Water Works
Cedar River
06/28/2022
Nitrate as N
11
99990021
Cedar Rapids Water Works
Cedar River
06/28/2022
Nitrite as N
0.043
2222222
U.S. Army Corp of
Engineers
Iowa River
(Downstream
05/16/2022
Nitrate + Nitrite (as
N)
10.5
Coralville Reservoir)
2222222
U.S. Army Corp of
Engineers
Iowa River
(Downstream
06/06/2022
Nitrate + Nitrite (as
N)
11.9
Coralville Reservoir)
2222222
U.S. Army Corp of
Engineers
Iowa River
(Downstream
06/21/2022
Nitrate + Nitrite (as
N)
10.8
Coralville Reservoir)
99990175
Publ
c Water Supply
Iowa River
05/11/2022
Nitrate as N
11.2
99990175
Publ
c Water Supply
Iowa River
05/12/2022
Nitrate as N
11
99990175
Publ
c Water Supply
Iowa River
06/05/2022
Nitrate as N
10.4
99990175
Publ
c Water Supply
Iowa River
06/07/2022
Nitrate as N
11.6
99990175
Publ
c Water Supply
Iowa River
06/08/2022
Nitrate as N
11
99990175
Publ
c Water Supply
Iowa River
06/22/2022
Nitrate as N
10.6
99990175
Publ
c Water Supply
Iowa River
06/23/2022
Nitrate as N
13
99990175
Publ
c Water Supply
Iowa River
06/24/2022
Nitrate as N
13.8
99990175
Publ
c Water Supply
Iowa River
06/25/2022
Nitrate as N
13
99990175
Publ
c Water Supply
Iowa River
06/27/2022
Nitrate as N
12
99990175
Publ
c Water Supply
Iowa River
06/28/2022
Nitrate as N
11
99990176
Publ
c Water Supply
Iowa River
05/12/2022
Nitrate as N
11.4
99990176
Publ
c Water Supply
Iowa River
06/08/2022
Nitrate as N
11.2
99990176
Publ
c Water Supply
Iowa River
06/15/2022
Nitrate as N
11
99990176
Publ
c Water Supply
Iowa River
06/22/2022
Nitrate as N
12
99990176
Publ
c Water Supply
Iowa River
07/06/2022
Nitrate as N
10.2
10620001
Iowa Department of
Natural Resources
South Skunk River
near Oskaloosa
11/02/2021
Nitrate + Nitrite (as
N)
11
10620001
Iowa Department of
Natural Resources
South Skunk River
near Oskaloosa
06/01/2022
Nitrate + Nitrite (as
N)
13
10900003
Iowa Department of
Natural Resources
Des Moines River
Upstream of Ottumwa
(US1)
06/04/2013
Nitrate + Nitrite (as
N)
13
207
-------
Iowa DNR
Site
Number
Data Source
Location Name
Sample
Date
Parameter
Result
(mg/L)
10900003
Iowa Department of
Natural Resources
Des Moines River
Upstream of Ottumwa
(US1)
07/01/2013
Nitrate + Nitrite (as N)
14
99990003
Des
Moines Water Works
Raccoon River
04/26/2022
N
trate as N
10.13
99990003
Des
Moines Water Works
Raccoon River
04/26/2022
N
trite as N
0.05
99990003
Des
Moines Water Works
Raccoon River
05/10/2022
N
trate as N
11.16
99990003
Des
Moines Water Works
Raccoon River
05/10/2022
N
trite as N
0.05
99990003
Des
Moines Water Works
Raccoon River
05/27/2022
N
trate as N
10.68
99990003
Des
Moines Water Works
Raccoon River
05/27/2022
N
trite as N
0.05
99990003
Des
Moines Water Works
Raccoon River
06/08/2022
N
trate as N
11.95
99990003
Des
Moines Water Works
Raccoon River
06/08/2022
N
trite as N
0.06
99990003
Des
Moines Water Works
Raccoon River
06/09/2022
N
trate as N
13.78
99990003
Des
Moines Water Works
Raccoon River
06/09/2022
N
trite as N
0.05
99990003
Des
Moines Water Works
Raccoon River
06/10/2022
N
trate as N
14.06
99990003
Des
Moines Water Works
Raccoon River
06/10/2022
N
trite as N
0.05
99990003
Des
Moines Water Works
Raccoon River
06/16/2022
N
trate as N
11.77
99990003
Des
Moines Water Works
Raccoon River
06/16/2022
N
trite as N
0.05
99990003
Des
Moines Water Works
Raccoon River
06/17/2022
N
trate as N
12.33
99990003
Des
Moines Water Works
Raccoon River
06/17/2022
N
trite as N
0.05
99990015
Des
Moines Water Works
Des Moines River
05/09/2022
N
trate as N
10.95
99990015
Des
Moines Water Works
Des Moines River
05/09/2022
N
trite as N
0.05
99990015
Des
Moines Water Works
Des Moines River
05/10/2022
N
trate as N
10.84
99990015
Des
Moines Water Works
Des Moines River
05/10/2022
N
trite as N
0.05
99990015
Des
Moines Water Works
Des Moines River
05/13/2022
N
trate as N
10.59
99990015
Des
Moines Water Works
Des Moines River
05/13/2022
N
trite as N
0.06
99990015
Des
Moines Water Works
Des Moines River
06/20/2022
N
trate as N
10.78
99990015
Des
Moines Water Works
Des Moines River
06/20/2022
N
trite as N
0.07
99990015
Des
Moines Water Works
Des Moines River
06/21/2022
N
trate as N
11.31
99990015
Des
Moines Water Works
Des Moines River
06/21/2022
N
trite as N
0.05
99990015
Des
Moines Water Works
Des Moines River
06/22/2022
N
trate as N
10.86
99990015
Des
Moines Water Works
Des Moines River
06/22/2022
N
trite as N
0.06
99990015
Des
Moines Water Works
Des Moines River
06/24/2022
N
trate as N
10.25
99990015
Des
Moines Water Works
Des Moines River
06/24/2022
N
trite as N
0.06
99990015
Des
Moines Water Works
Des Moines River
06/27/2022
N
trate as N
10.11
99990015
Des
Moines Water Works
Des Moines River
06/27/2022
N
trite as N
0.1
208
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