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An Open Letter to the Iowa DNR on Particulate Matter 2.5 Compliance

by Paul Deaton

To: Wendy Rains, Iowa Department of Natural Resources

Subject: Air Quality PM2.5 State Implementation Plan Public Comment

Dear Wendy:

As a citizen of Iowa and a member of the Johnson County
Board of Health, I have some concerns regarding the proposed State Implementation Plan (SIP) for managing
particulate matter 2.5 (PM2.5).

I would note that the state appears to be in compliance
with the current standard and that is laudable. Enforcement of compliance with
the law is an important part of what citizens expect from the Iowa Department
of Natural Resources.

Here are my concerns:

As an agricultural state, during planting and harvest
times, there is an increase in the release of particulate matter due to
agricultural activity. Some of this fugitive dust escapes the property of the
agricultural activity and presents a health hazard. Any State Implementation Program should consider
how, if at all, agricultural activity should be considered as a separate issue.
There is no mention of farming or agriculture in the State Implementation Program draft, and this is a
serious omission given the scope and special circumstances that seasonal
agricultural activities in Iowa represent. I do not believe that compliance with the federal law adequately addresses this issue.

The Ambient Air Monitoring plan is approved by the
Environmental Protection Agency and we are in compliance according to that
standard, as outlined in the draft State Implementation Plan. However, the state of Iowa produces
substantially more electricity from energy sources with PM2.5 emissions than
the nationwide average. These electricity generating operations produce
substantial amounts of PM2.5 emissions, and the monitoring network does not
appear adequate to capture or evaluate the PM2.5 emissions from coal burning
facilities. For example, Iowa State University has a coal fired power plant and
there is not a monitoring station nearby. At a minimum, the Iowa DNR should
study the locations of the coal burning industrial activity in Iowa vis-à-vis
the monitoring network and ensure that Iowans are protected from these
emissions which have a recognized deleterious effect on the health of nearby
residents. Monitoring can help do this, but there appear to be obvious gaps in
the network coverage that need to be addressed in the SIP.

I appreciate your consideration of my comments and look
forward to a timely response.

Regards, Paul

Find out more at the Iowa Department of Natural Resources Air Quality Public Input Hub.

Download the Draft Iowa State Implementation Plan for the National Ambient Air Quality Standards.

Send a comment to the Iowa Department of Natural Resources on this issue no later than October 5, 2009 by sending an e-mail to wendy.rains@dnr.iowa.gov.

Attend the public hearing Monday, October 5, 2009 at 10:00 AM at the Iowa Department of Natural Resources Air Quality Bureau office located at 7900 Hickman Road, Suite 1, Windsor Heights, Iowa.

~Paul Deaton is a native Iowan living in rural Johnson County.  Check out his blog, Big Grove Garden.    E-mail Paul Deaton