A Threat Unmet
Why Iowa’s Nutrient Strategy Falls Short Against Water Pollution
POLICY BRIEF
By David Osterberg and Aaron Kline

July 17, 2014
This IPP Policy Brief27-page PDF (including executive summary)
Executive Summary or 2-page PDF
News Release or 2-page PDF

Introduction

In 2010, the Gulf of Mexico “Dead Zone” was 7,700 square miles, one of the five highest recordings ever; in 2011, Lake Erie experienced its largest algal bloom ever at over 1,920 square miles; in 2012, over 50 percent of Iowa’s water bodies were classified as impaired. What’s wrong with this picture? One might conclude — as did the U.S. Environmental Protection Agency (EPA) — that conservation practices aimed at reducing nutrient loading into the nation’s waterways have not been effective and a new approach was needed. Thus, EPA required that states develop a nutrient reduction strategy to eliminate 45 percent of the nitrogen and phosphorus loads emitted within states draining into the Gulf of Mexico. In this paper we first examine the effects of excess nutrients in waterways and their effects on the Gulf of Mexico and Iowa waters. Next, we explain Iowa’s Nutrient Reduction Strategy (NRS), outlining the different roles for pollution reduction from point sources as opposed to nonpoint sources. Finally, we examine the effectiveness of voluntary conservation approaches in agriculture and recommend addressing missing components of Iowa’s NRS that can improve its effectiveness. The importance of changing certain conservation practices, from voluntary to requiring farmers to choose at least some practices, cannot be overstated. Our recommendations are consistent with the State-EPA Nutrient Innovations Task Group that noted:

“We believe that absent a profound change in current approaches and support for the development of a multi-sector framework of accountability for both point and nonpoint sources, we collectively are unlikely to be successful in responding to an increasingly pervasive source of pollution that comes from multiple sources in every state and affects not only near-field waters and habitats, but also those of neighboring and downstream states.”

Nutrients and Water Quality

Point sources of water pollution have a specific emission location such as the outfall pipe of a wastewater treatment plant. Nonpoint sources are all other sources such as runoff from agricultural fields or urban streets. Figure 1 illustrates this difference between point and nonpoint sources of water pollution. Nutrient loads (i.e., enhanced nitrogen and phosphorus) to waterways are contributing to increased water quality concerns across the U.S. from farm country like Iowa where sources of nutrients are primarily from nonpoint source. The consequence of adding high levels of nutrients to water bodies is eutrophication, whereby the nutrients themselves lead to increased plant growth (e.g., algal blooms). Hypoxia (i.e., deprivation of available oxygen) occurs when microbes decompose the increased dead plant matter using up the available oxygen and limiting other organisms from surviving in waterways. The National Science and Technology Council reported that “agriculture is the largest source of nitrogen pollution to coastal waters.” Moreover, in public drinking water systems from 1998 to 2008, “nitrate exceedances showed a significant increasing trend, nearly doubling the number of violations.”

Figure 1. Examples of Point and Nonpoint Sources of Water Pollution
Fig 1 Point/NonpointSource: Mississippi River/Gulf of Mexico Watershed Nutrient Task Force

Downstream — The Gulf of Mexico “Dead Zone”

In 2008, the EPA’s Hypoxia Task Force released the Gulf Hypoxia Action Plan 2008 as an update to its 2001 Action Plan. The Action Plan had input from all the states that contribute to nutrient loading in the Mississippi River Basin. The Action Plan established goals for reducing nutrient loads from point and nonpoint sources that would reduce the five-year average area of the Gulf hypoxic zone to under 1,900 square miles. The goal compares to the 2009-2013 running average of approximately 5,400 square miles. To achieve this reduction in the hypoxic zone, participating states are to develop nutrient reduction strategies. The goal for Iowa river basins was a 45 percent reduction in both nitrogen and phosphorus loads to waterways. The following figure shows the states where much of the nitrogen and phosphorus originates.


Figure 2. Eight States Send Heavy Nitrogen and Phosphorus Pollution to Gulf of Mexico

Fig 2 Gulf Impacts
*Source: United States Geological Survey

Closer to Home — Impaired Waters in Iowa

Under the Clean Water Act (CWA), each state must prepare and submit a listing of impaired waters every two years. The EPA designates five categories of water quality for a water body with Category 4 and Category 5 classifications recognized as impaired waters. Iowa conducted its latest review in 2012 identifying more than 600 water bodies across the state as impaired. DNR also illustrates impaired waters in 2012 in the map in Figure 3. The number of impaired waters increases nearly each time they are assessed, but whether it is harder to find places to swim and wade and eat the fish over time can’t be established because of changes in water quality standards over time. For example, after Iowa revised its stream designation system in 2006 to increase the stream miles designated for recreation, the bacteria limits for contact recreation suddenly applied to many more streams and a large number of new waters were listed as impaired for the first time due to existing E. coli bacteria data that was evaluated relative to the new recreation use designation. However, Table 1 shows that of Iowa’s waterways that were assessed, over 50 percent were classified as impaired in 2012. That nitrates at least are getting worse over time is demonstrated by data compiled by the Des Moines Water Works and presented below in two graphs as Figure 4. Data going back nearly 40 years shows worsening conditions in two rivers used as the water supply for a half million Iowans.

Table 1 Source: Iowa Department of Natural Resources

Figure 3. Impaired Waterways are a Problem Across the State
Fig 3 Map of Impaired Waterways
Source: Iowa Department of Natural Resources

For streams and rivers, three commonly identified contaminants contributed over 80 percent of the impairments:
• indicator bacteria (i.e. E. coli)
• biological impairments
• and fish kills

For lakes, 78 percent of impairments were caused by four common sources:
• algal turbidity
• ph (related to algae)
• non-algal turbidity (suspended sediment)
• and indicator bacteria (E. coli)

Fig 4a
Fig 4b
Des Moines Waterworks comments to Iowa DNR on proposed Amendments to Iowa Administrative Code. May 9, 2014.

These sources of impairments have direct links to agricultural operations as well as point sources and urban storm water runoff. In streams for example, indicator bacteria originate with failed septic systems but mainly animal waste (livestock and wildlife), while “most fish kill impairments are related to spills of animal waste that reach streams.” Further, for lakes, algal turbidity is the number one cause of impairments; excessive algal growth is linked to excess levels of phosphorus in the water that stimulates algal growth. It is important to note that nitrogen and phosphorus do not appear high on the list of impairments. This is because Iowa has not established numeric criteria for determining nitrogen and phosphorus impairment for water bodies other than nitrate (a form of nitrogen) for drinking water sources (six stream segments and one lake that are drinking water sources are listed as impaired for nitrate). A stream or lake could have excessively high amounts of nitrogen and phosphorus, but not be deemed impaired due to the lack of criteria for determining nutrient impairment.

Past regulations to protect Iowa water from nutrient pollution, and therefore protect Mississippi River and Gulf of Mexico water quality, have failed. Policy makers face an enormous challenge, and to date have not been effective in addressing the scale of nutrient pollution entering water bodies. This lack of success, and prompting from the EPA, was the impetus for the 2013 Iowa Nutrient Reduction Strategy (NRS).

The Iowa Nutrient Reduction Strategy

In 2013, after two years of work, Iowa released its 204-page NRS with a goal of reducing nitrogen and phosphorus discharges by 45 percent in an effective and cost-efficient manner; yet it includes no target date by which to achieve these goals. Progress in accomplishing the goals of the NRS resides with the state’s Water Resources Coordinating Council (WRCC). The WRCC consists of members from 19 state and federal institutions responsible for coordinating water resource activities or for providing expertise. An eight-point framework provided by EPA in a 2011 memo guides the NRS in its objective of identifying and implementing a comprehensive nutrient reduction strategy.

To achieve the NRS goals of a 45 percent reduction in nitrogen and phosphorus loads leaving the state, different strategies are employed for point and nonpoint sources of pollution: a science assessment for nonpoint sources and technology assessment for point sources. The percent of total emissions and the required reductions for point and nonpoint sources are listed in Table 2. Clearly, the bulk of the reduction requirements are from nonpoint sources.

Table 2. Agriculture’s Impact: Nonpoint Sources Dominant Share of Pollution Load
Table 2
*Source: Iowa Department of Agriculture and Land Stewardship, Iowa Department of Natural Resources, Iowa State University College of Agriculture and Life Sciences

Point Source Reduction

Point source water emissions are regulated under the CWA and require a National Pollutant Discharge Elimination System (NPDES) permit that sets limits on the amount and type of discharges allowed. In the 14-page point source section of the NRS, the focus is on two main areas for point source nitrogen and phosphorus reduction: a technology assessment and associated cost estimates for implementation.

Technology Assessment

The basis for point source reductions in Iowa’s NRS is an evaluation of three levels of nutrient removal technology available to point sources: biological nutrient removal, enhanced nutrient removal, and limit of technology removal. Each level provides different capacities of nutrient reduction starting with biological nutrient removal and progressing to the limit of technology in removing nutrients.

Cost estimates

Cost estimates are developed for the type of technology required to remove the necessary amount of nutrients from the wastewater. A technology is generally deemed affordable for a treatment plant if, “the ratio of projected total wastewater costs to a community’s Median Household Income is less than one percent.”

DNR believes that nutrient treatment will be affordable for 102 municipal and 28 industrial dischargers, and the point source reductions (4 of the 45 percent for nitrogen and 21 of the 45 percent for phosphorous) can be met by these facilities. These sources will be mandated to improve treatment to accomplish the point source part of the NRS goal.

Nonpoint Source Reduction

Almost 160 pages of the 204-page NRS are devoted to nonpoint source reduction, indicating the contribution of nonpoint pollution overall while describing the current science of nonpoint removal. Agriculture pollution is the largest source of water quality concerns of the state and its effects on the Gulf of Mexico’s “Dead Zone” as was shown in Table 2. In contrast to point source emissions, nonpoint source reductions are not mandated under the CWA but rather depend on voluntary implementation by agricultural producers. The science assessment for the nonpoint sources was conducted under a four-point process outlined below:

Establish Baseline Conditions

An effort was made to identify existing conditions causing nutrients to escape to water bodies. The variables that determine this include nutrient application rate and timing, crop rotations, and tile drainage. It was found that, “there is a lack of information on existing conditions, and a need for greater on-going documentation and reporting of this information.”

Review Scientific Literature to Assess Potential Performance of Practices

A listing of potential practices that could reduce nitrogen and phosphorus discharge with data to support their impacts on water quality was completed by a team from Iowa State University. An extensive literature review was conducted to assess actual reduction impacts of practices that make up the bulk of the NRS.

Estimate Potential Load Reductions of Implementing Nutrient Reduction Practices (Scenarios)

Scenarios were developed utilizing a suite of practices that could achieve the nonpoint source nitrogen and phosphorus reduction goals (41 of the 45 percent for nitrogen and 29 of the 45 percent for phosphorous). The NRS noted that the sample combinations of practices to achieve the targets listed by the authors were not recommendations but only presented as examples.

Estimate Cost of Implementation and Cost per Pound of Nitrogen and Phosphorus Reduction

Utilizing the scenarios developed to achieve the water quality goals, economic costs were applied to the scenarios. These costs included implementation and any loss in yield converted to an annual equalized cost for each scenario. The three identified scenarios’ annual costs ranged from $77 million to $1.2 billion. In addition, capital costs were from $1.2 billion to $4 billion.

What is Required to Achieve Nonpoint Goals

The NRS introduced a new attempt to address the continual water quality problems inside Iowa and in the Gulf of Mexico. The actions are sometimes called the Water Quality Initiative, but we will use the term NRS to refer to the report and suggestions emanating from it. Since the point source reductions are to be mandated, it can be assumed this NRS goal will be met. However, the nonpoint goal has to be accomplished by producers voluntarily changing practices. Mandating point source reductions but only asking for voluntary compliance for agriculture, which produces the lion’s share of the pollution, seems a heroic strategy.

It is easy to assume that mandating changes to point sources of pollution but not requiring any changes to agriculture is simply a reflection of the power of Iowa’s agricultural interests. The Des Moines Register referred to this political power in a hard-hitting water quality editorial on August 11, 2013, that states in part:

“The fact is, the political leadership of Iowa — including the governor, the secretary of agriculture and too many members of the Iowa Legislature — is far more attentive to the interests of big ag groups than the interests of ordinary Iowans who enjoy boating, swimming and clean drinking water. That’s because big ag spends a lot of money on elections and lobbying.

“As a result, Iowa counties that have zoning laws regulating the placement of factories and homes are forbidden by state law from regulating the sites of animal confinements. Farmers are asked only to voluntarily comply with conservation programs designed to reduce nitrates in rivers, lakes and ultimately the Gulf of Mexico.” (emphasis added)

There is a Cost of Pollution but Who Pays?

Generally, two principles describe funding methods to reduce pollution: either the Polluter Pays principle (PP), which applies to most industries, or the Pay the Polluter Principle (PTP), which “implies that the property rights to pollute rest with the polluter rather than society at large.” Voluntary approaches in agriculture rely on the PTP approach where farmers can receive payments to enact conservation measures. This contrasts with how most other industries are treated. They are required to make reductions with their own funding under the PP approach. An essential component of the PTP approach is a requirement that there be adequate funding to achieve the necessary pollution reduction. When there is a lack of available funding, the PTP approach may not be effective, shifting the burden of pollution back to society as a whole. For example, high levels of nitrates in Iowa’s waters, forces the Des Moines Water Works to incur significant expense to remove the nitrates, which is passed on to consumers. A 2013 interview between Perry Beeman of The Des Moines Register and Bill Stowe, Des Moines Water Works general manager, illustrates this point:

“The issue is the quality of the water in the Raccoon and Des Moines. This trend is absolutely off the scale. It’s like having serial tornadoes. You can deal with one, you can deal with two, but you can’t deal with them every day.

“The state’s Nutrient Reduction Strategy, with its emphasis on the voluntary measure, clearly isn’t working. And our ratepayers are paying significantly to remove nitrates.”

The Environmental Working Group’s Murky Waters reports Iowa is facing chronic poor water quality because the CWA does not require agriculture to mitigate pollution and instead relies on voluntary approaches that, according to the authors, are not effective. A related water quality concern is soil erosion into waterways. The Environmental Working Group’s Losing Ground reports voluntary compliance measures to reduce the rate of soil erosion have been ineffective as well. Murky Waters and Losing Ground both show that voluntary compliance measures have, to date, not been able to address the enormity of the environmental degradation associated with modern agricultural production.

Many environmental groups agree that voluntary measures are likely to be ineffective. However, it is reasonable to search the economics and sociological literature to see if and how voluntary practices can lead to reductions in soil loss and improvements in water quality. One of the first articles we found comes from a 1998 issue of the Journal of Soil & Water Conservation. Napier and Johnson’s study gives little to hope that voluntary measures will work.

“Study findings bring into serious question the utility of continuing to implement soil and water conservation practices using traditional voluntary approaches such as those used in the Darby Creek watershed."

This quote is not a promising start for proponents of voluntary-only measures. However, the literature studying voluntary measures to improve water quality shows how various techniques of “information, education and cost sharing” have been used to motivate some farmers and landowners to adopt soil and water protection practices in their fields. Cash incentives and appealing to neighborliness rather than regulation is most often used to reduce pollution from agriculture.

Accounting for the Culture of Farming

Agriculture is often exempt from complying with regulations. Occupational safety and health of farm workers is an example of this special treatment, referred to as “agricultural exceptionalism.” As Segerson explains,

“For example, in contrast to other sectors where regulatory approaches have been the norm for addressing environmental externalities, in the U.S. agriculture sector voluntary approaches (VAs) have been much more widely used.”

This “agricultural exceptionalism” has a long history dating back to the founding of the country with Thomas Jefferson stating that, “Cultivators of the earth are the most valuable citizens.” This idea that farmers are unique and require special protections and that the welfare of farmers coincides with the interests of the greater community is one reason this exceptionalism has been promulgated in American culture and law ever since.

Social Capital

If agricultural exceptionalism and freedom from regulations are to be congruent with the public good of the community, a social dynamic must be channeled to promote conservation practices amongst the farming population. This may occur through utilizing social capital, which suggests that social relationships among farmers have value and may be used as a motivating factor for adoption of conservation practices. An article by three Iowa State University (ISU) sociology professors explains social capital as “the resource potential of social relationships” that allows efficient mobilization of resources to achieve a goal. Social capital is an important concept when considering farmer adoption of conservation measures, because farmers’ motivations are linked to personal preferences and social pressures. Ryan and others suggest that conservation adoption by farmers is linked not only to economics, but also to social and aesthetic aspects. There is theoretical evidence that non-monetary motivation for conservation behavior can be important. In addition, much of the literature contains empirical evidence, often gleaned from surveys of farm operators.

Motivations

The social capital discussion highlights the importance of delving into the motivations of farmers when making conservation choices. A report exploring the adoption of conservation buffers near riparian zones showed that economic incentives were the lowest reason for adoption reported by farmers as seen in Table 3, while intrinsic motivation such as stewardship ethic, aesthetics and societal concern ranked higher. For example, statements such as “I want to conserve this land for future generations” ranked higher as a reason for acting than “Receive payment for conservation.”

Table 3. Varied Motivations for Conservation Choices

Table 3
Source: Ryan, Erickson and De Young

Social relationships and peer standing were shown to be an important component for the adoption, or lack thereof all over the world. A study of German and Scottish farmers showed social/cultural capital was built amongst farmers through being able to identify “good farming vs. bad farming.” In this context, good farming can be identified through farm management activities such as keeping a “tidy” farm, having straight lines in fields, or having the highest yields. In contrast, bad farming can be characterized as an “untidy” farm or unproductive fields. The ability of farmers to measure their performance against other farmers is important in a social/cultural context. Further, a survey of Australian livestock producers found that important motivators for conservation adoption were “respect by peers and appreciation by society as a whole.” For the NRS to depend on voluntary actions by farmers, this tidiness must apply not just to yields and pretty fields but to environmental stewardship as well.

Have Voluntary Approaches Worked in Iowa?

Voluntary approaches to minimizing nutrient pollution from agricultural producers have been the mainstay approach in the U.S. and Iowa. In defining a voluntary approach, Segerson states, “the key distinction between voluntary and mandatory approaches to environmental protection is the ability to impose unwanted costs on polluters.” According to Iowa Farm Bureau Federation President Craig Hill, Iowa’s voluntary approach will work only if every farmer actively participates to improve the environment, or in his words, the “water-quality program (is) not optional.”

For voluntary approaches to be effective, they must induce an attitude or behavior change in the farmer in terms of the importance of environmental conservation activities and their long-term sustainability. The adoption of conservation measures cannot be based solely on the farm’s economic bottom line if they are to be sustainable. Burton and others explore European conservation programs and argue that voluntary conservation “may not be effective” in changing behaviors because those that adopt practices do so for the “commercial” interests and the adopted measures involve little change in farming practices.

Closer to home, farmer adoption of conservation practices has been surveyed by the Iowa Farm and Rural Life Poll. This survey of approximately 1,200 Iowa farmers is conducted annually to gauge opinions on different topics. The 2011 Farm Poll queried farmers’ knowledge and expenditures on conservation programs and practices. When asked about their familiarity with conservation programs over a third of respondents were not familiar with a majority of the federal and state conservation programs, as shown in Table 4. On average, just over half of farmers were aware of conservation programs, but had never participated.

Table 4. 1 in 5 Farmers Not Familiar with Most Conservation Programs

Table 4
*Source: (Iowa State University Extension and Outreach 2011)

Table 5.Most Spend Little on Conservation

Table 5

Furthermore, as shown in Table 5, 51 percent of respondents reported they had made no conservation expenditures in the past 10 years and 72 percent had spent less than $5,000 in conservation investments over the 10-year period. As the authors of the poll state, “These findings are cause for concern given that soil erosion and water quality impairment continue to be major problems across Iowa.”

Further evidence alluding to the fact that voluntary measures have not been effective to date in changing farmers’ behaviors is the loss of Conservation Reserve Program (CRP) acres coinciding with higher corn prices. Iowa CRP acres are decreasing, falling by almost one-fourth, from 1,970,486 acres in 2007 to 1,525,012 in 2013. The drop in CRP enrollment has coincided with the ethanol boom and the rise in the price of corn, suggesting that the economic bottom line does affect a farmer’s willingness to adopt conservation measures. When subsidies pay less than cash rent, the conservation practices disappear.

Even though it appears that Iowa farmers are not readily implementing voluntary conservation practices as shown in the Iowa Farm and Rural Life Poll results and the loss of enrolled CRP land, Arbuckle illustrates that Iowa farmers are willing to accept additional conservation compliance requirements to be eligible for federal farm programs. Table 6 shows that in addition to soil erosion controls, 69 percent of farmers agree or strongly agree that controlling nutrient runoff from fields should be required to be eligible to receive federal farm program benefits, while 62 percent believe controlling nutrient runoff should be required regardless of federal farm programs. These results from recent surveys of Iowa farmers, provides ammunition for a policy that mandates at least some practices to improve water quality.

Table 6. Farmers Willing to Accept More Conservation Compliance Rules to Receive Federal Farm Benefits

Table 6 Source: Arbuckle, 2013

Voluntary Nutrient Management Effectiveness in Surveys and Actual Attainment

The Iowa Learning Farms, a program of ISU extension, has documented several watershed-based citizen awareness campaigns. Black Hawk Lake watershed is the latest report (2013). The methodology used to gather information about attitudes of stakeholders in the lake watershed included surveys, listening sessions and one-on-one interviews. The study had certain goals for phosphorous reduction in the watershed. The results are troubling first because the goals for phosphorus reduction came in at about one-fourth of the goal but also because of evidence from a survey done of farmers in the watershed. The report states:

“Just as telling is the large percentage of farmer respondents who replied they did not know if agricultural byproducts were impairing the water quality in their area. Thirty-one percent of farmer respondents claimed not to know if high bacteria counts were an issue, 25 percent said they did not know if fertilizers or nitrates affected the water quality, and 29 percent said the same for pesticide use. Even more discouraging is the percentage of farmer respondents who claimed agricultural practices had no effect on water quality in their area: 10 percent for high bacteria practices considered Most Responsible for Existing Watershed Pollution counts, 9 percent for fertilizer/nitrate use, and 22 percent for pesticide use. Taken together, the combined ‘don’t know’ and ‘not a problem’ responses indicate a large knowledge gap for landowners and farmer operators in the watershed.”

This report was released in 2013. The number of farmers responding to the survey who did not know if farming was causing a pollution problem or stated that it was not, is far from a majority. Still, one must remember that voluntary programs mean that a small number of farm operators who ignore their part in pollution can have an effect on an entire watershed. The report authors further noted discouragement in this survey result:

“Although farmers often claim a deep-seated knowledge of their land because they work it, the degree to which some farmers choose to not make the connection between how they farm and its impact on water quality is dispiriting.”

Achieving Nonpoint Goals: Six Policy Requirements

If voluntary reductions mean business as usual, then they will fail. This has been the approach for years and farm pollution and damage to the Gulf of Mexico continues. The NRS must mean more than continuing a failed policy. How do farm operators become congruent with the statement by Farm Bureau President Craig Hill that water quality programs are not optional? What might make voluntary programs work?

First, Give Attention to the Problems

Iowa Secretary of Agriculture Bill Northey has stated Iowans “are seeing a culture change of looking at these conservation practices both for soil erosion control and increasing water quality. They are becoming a normal part of farming and really second nature for a lot of farmers. … Iowa farmers and landlords are increasingly seeing added conservation measures not as a cost, but as a solid investment in the future of their operations. ... [I]t’s being seen as one of the drivers that makes land more productive and valuable.”

A voluntary-only framework such as the NRS depends on social capital values becoming more important. Landowners and farmers must be motivated to take social responsibility and accountability to one's neighbor downstream. For example, Watershed Management Authorities, established under 28E agreements in the Code of Iowa, leverage both private and public sector support in their attempts to bring rural and urban interests to the table. Farmer outreach and education in these projects help strengthen the community concept; farmers learn how conservation practices affect other citizens in the watershed community.

The Iowa Soybean Association (ISA) has been instrumental in supporting watershed projects across the state. ISA’s website states “clean water is good water.” ISA recommends testing and monitoring water quality in key soybean regions of the state. ISA lists many techniques including bioreactors and buffers of various types.

“That information, combined with in-field trials, offer farmers keen insight into taking better care of the land and water. Because soybean farmers know that being an environmentalist goes hand-in-hand with productivity.”

Private- and public-sector partnership and producers recognizing that conservation can make land more productive will be necessary to implement the sweeping landscape-scale change which is called for in the NRS. Jennifer Terry of the Iowa Environmental Council urges more of this motivation.

“Not only is the collection of water quality data important; that data must be made readily available to the public at the HUC 12 level and above. Iowans have a right to know how public sector funds are being spent and whether those dollars are actually making a difference in Iowa’s water quality.”

The initial rollout of the NRS used $2.8 million in cost-share conservation funding to help establish more than 100,000 acres of cover crops all over the state. This demonstrates farmer interest in the NRS. However, total corn and soybean acres in Iowa regularly exceed 23 million acres. Changes toward conservation investments must go beyond just the willing and motivate those who claim not to understand the connection between farm practices and water quality.

Second, Assure Sufficient Funding for Conservation Measures

An important consideration for adoption of voluntary conservation measures is the level of funding available to pay farmers to help implement the measures. As noted earlier, the three proposed scenarios in the NRS required annual funding of $77 million to $1.2 billion.

The largest source of funding for conservation practices comes from the federal government’s Conservation Reserve Program (CRP) with payments of $115 million in FY 2010. However, the technical services available in each county from the federal Natural Resources Conservation Service, is also large and many more NRCS programs provide cost share. These credible levels of funding and expertise are important but they have not been able, to date, to reduce the high level of nutrients leaving the state of Iowa.

Table 7. Many Conservation Sources Stagnant for Iowa

Table 7Table 7, taken from the NRS, shows some of the funding available for water quality improvement. The NRS found only about $15 million annually devoted by the state to water quality and conservation measures as recently as state fiscal year 2013.

Moreover, the NRS notes, “Iowa’s farmers’ requests for combined federal and state cost-share dollars to match with their own money to protect Iowa’s soil and water exceeds funds available annually in the range of $25-$100 million.” Even before the lofty goals were released, data in the NRS report showed there was not enough funding available for farmers’ own initiatives to implement conservation practices.

An Iowa Policy Project report from March 2012, prior to the release of the NRS, demonstrated an overall decrease in water quality funding of $5 million over the previous decade. Drops in the Bucket: The Erosion of Iowa Water Quality Funding found that this water-quality funding decline came despite greater needs for water protection and public willingness to fund it.

State government seemed initially to rise to the occasion and increase funding for water quality programs in 2013, after the release of the NRS, but fell back the following year.

Secretary Northey realizes the importance of funding. At the end of the 2014 legislative session, he praised the apparent continuing funding contained in appropriations bills sent to the Governor for his signature. “Vetoing this funding would give ammunition to the critics that Iowa isn’t serious about improving water quality and undermine” progress the state has made, said Northey.

Despite Secretary Northey’s plea, the Governor vetoed a substantial amount of the funding increase. According to the Iowa Environmental Council (IEC), “IDALS was ‘quick to tout’ an added $22.3 million and called the new funds evidence of continuing support for the state’s all-voluntary nutrient reduction strategy.” IEC found very disturbing the “30 percent decrease for the same programs” in the present [2015] fiscal year.

Iowa’s water quality improvement requires sustained and consistent funding, rather than one-time funding subject to the governor’s veto power. Iowa’s Legislature has an opportunity to provide this level of support by fully funding the Natural Resources and Outdoor Recreation Fund. In the 2010 general election, 63 percent of the voters in Iowa voted to amend the State Constitution to require a portion of any new sales tax be dedicated to “protecting and enhancing water quality and natural areas in the state.” The addition of more than $100 million annually in consistent, long-term funding could be used to hire permanent, full-time watershed project coordinators, as well as provide long term water quality monitoring. Proponents argued this would show an improvement in water quality in the state and a commitment to funding the NRS.

Third, Adopt Nutrient Criteria Standards

Another element missing from the NRS is the development of nutrient criteria standards for all of Iowa’s waters, in addition to sources of drinking water. The development of nutrient criteria standards is part of the EPA’s eight-point framework for reducing nutrient loads to waterways. However, Iowa has not developed nutrient criteria standards due to concerns with EPA’s statistical framework used for developing its recommendations. Iowa is concerned about the ability to achieve the strict criteria set out by EPA, because compliance would rest mainly with point source emitters and it would likely be financially infeasible for them to attain the necessary levels. Achievement of the necessary reduction would fall on point sources due to the ability to mandate implementation of reduction technology on point sources compared to the voluntary nature of nonpoint source reduction.

However, without numeric nutrient criteria and mandated reductions of nonpoint pollution, the status quo of continual water quality impairment will continue. The authors agree with the EPA that to make effective improvements in water quality, numeric nutrient criteria are required:

“It has long been EPA’s position that numeric nutrient criteria targeted at different categories of water bodies and informed by scientific understanding of the relationship between nutrient loadings and water quality impairment are ultimately necessary for effective state programs.”

One solution is for the nutrient standards to apply to agricultural or nonpoint sources that are demonstrated to cause the lion’s share of pollution. It is both inefficient and unreasonably expensive to put the total cost of remediation on city residents and point sources. This is another reason for mandating some agricultural practices.

Fourth, Initiate Water Quality Monitoring

In fall 2013, and again in spring 2014, IDALS awarded funds to several watershed demonstration projects, called WQI projects since they are part of the Water Quality Improvement or NRS strategy. “More than 30 partners from agriculture organizations, institutions of higher education, private industry, the local, state and federal government, and others, are working together on these projects with the Soil and Water Conservation Districts (SWCD) serving as the project leaders.” More than a dozen of these watershed groups have formed and received funding. However, little guidance has been provided to the watershed coordinators in each WQI project as to specific goals. Since these are local initiatives, latitude should, of course, be given. However, one requirement is obvious and essential and that is monitoring the water to demonstrate success. Millions of dollars of public funds have been given with no required monitoring. While the coordinators in the WQI watershed areas may be talented, their evaluation of success will be based on quantifying practices on the ground such as cover crops, buffer strips, etc, and indirectly estimating nutrient loading. In addition, watershed coordinators will track the number of farmer contacts and number of field days. That is not enough. The NRS must be able to demonstrate success cleaning the water and that requires direct monitoring to show if the goal of a 45 percent reduction in nutrients is being accomplished.

Fifth, Ask Each Farm To Choose Two Conservation Practices Statewide

Table 8. Several States Have Regulations to Address
Nutrient Problems from Row Crop Production
Table 8
Several states have realized the necessity of requiring certain conservation methods to reduce nutrient loads in their states as outlined in Table 8. For example, Florida has required certification of Best Management Practices in the Everglades while Minnesota has required buffer strips of 50 feet from shoreland districts. (Shoreland areas include land within 1,000 feet of lakes or 300 feet of perennial rivers and streams.) Iowa could set an example and be a leader in both agricultural production and environmental stewardship by requiring that at least two conservation practices be implemented on all farms.

The Iowa Soybean Association (ISA) lists many practices that can improve water quality. One recommendation is vegetative buffers strips along waterways. Such a requirement would provide a noticeable reduction in the amount of nitrogen and phosphorus, in addition to controlling sedimentation, trapping bacteria, and providing wildlife habitat. Helmers and others note that buffer performance will be affected by a number of factors including climate and site location, but overall, “buffers can have a positive impact on water quality.” Supporting this conclusion, the NRS finds that buffer strips intercepting water in the buffer’s root zone will provide a 91 percent reduction in nitrogen; however, a good deal of Iowa’s farmland is tiled meaning that much of the runoff would bypass the buffers, and in that case, there would only be a 7 percent reduction in nitrogen loading. In terms of phosphorus reductions, however, required buffer strips on all waterways would lead to reduced phosphorus loading of 58 percent, far beyond the required 45 percent. While the cost of implementation will vary based on location and conditions, the average cost (accounting for the cash rent of land that would have been used for corn or soybeans) of implementing buffer strips in Iowa would be approximately $228/acre of buffers installed. No benefits of the buffers are included in this calculation but water quality improvement and wildlife habitat are two obvious ones.

Other practices listed in the “clean water is good water” section of the ISA website are cover crops, bioreactors, grassed waterways, conservation uses for oxbows, contour farming and terraces. Establishing wetlands could be added but is not one of those practices listed by the ISA. We believe that allowing each producer to choose any two practices will help adherence to voluntary measures become congruent with the social good. It can be thought of as a form of cross compliance with a general freedom from specific mandatory conservation actions. It might be said that two practices are an arbitrary number, but, on the other hand, so is zero conservation actions — and in 2011, half of Iowa farmers surveyed reported that to be their commitment.

Sixth, Make Sure the Possibility of Government Intervention is Understood and Credible

The possibility of government intervention can play an important role in convincing farmers to adopt conservation practices and is an important aspect missing from Iowa’s NRS. This can be a large motivator for farmers as indicated by Iowa Farm Bureau Federation President Craig Hill, who has stated all farmers should be working to improve the environment on their farms, “To do otherwise would be irresponsible. It also would invite action by the federal government to use more regulations in its effort to improve water quality.”

Segerson and Wu developed an economic model examining a combination of a nonpoint voluntary approach raising the prospect of a tax if pre-determined goals were not achieved. They found that “combining a voluntary approach with the threat of a retroactive tax is more efficient than either a pure voluntary approach or a pure ambient tax.” Segerson continues this line of analysis in another article:

For example, a voluntary approach that is coupled with or supported by an underlying existing or threatened regulatory structure has the potential to be effective.

It is possible the very fact that Iowa has adopted the NRS may stall federal action. This is explicitly true if there is no timeline to show results of the new strategy. At a minimum, the WRCC should establish a time to meet the goals of the NRS. It should also set a number of intermediate benchmarks starting no more than three years in the future to ensure the new strategy is working. Iowa citizens should not have to wait a century for clean water.

Conclusion

The NRS is reported in the farm press to be a new approach to the serious problem of water quality degradation in Iowa and the U.S. Our report finds little reason for such optimism. There are a number of important pieces missing from Iowa’s NRS to expect it to lead to the contemplated reduction goals. The main fault is its reliance on a voluntary conservation approach for nonpoint source nutrient load reductions. Could dependence on mainly voluntary measures work? Perhaps it could, but not alone and only with the additions to the NRS we propose.

It is up to Iowa to sow the seeds that will harvest clean water for generations to come. Iowa’s taxpayers and farmers together must identify situations to achieve the most benefit for the lowest expense. This will require more than just a rollout of a new strategy hoping it will work. Success will require additional financial support. It will require adoption of new practices on every farm, buffers along our streams or other practices. It will require other policy changes mentioned above. The NRS alone is not enough for agriculture to achieve its share of the nutrient reductions necessary for Iowa to reduce nitrogen and phosphorus loads by 45 percent.


[Editor's Note: Bilbliography and citations are available in the PDF file of this report, found here.)

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David OsterbergDavid Osterberg is co-founder of the Iowa Policy Project who specializes in research on environment and energy issues. A former Iowa state representative, Osterberg holds an M.S. in water resources management and another in agricultural economics from the University of Wisconsin-Madison. He is a professor in the Department of Occupational and Environmental Health at the University of Iowa.


Peter FisherAaron Kline was a graduate student intern at the Iowa Policy Project in the 2013-14 school year. He recently received his master's degree from the School of Urban and Regional Planning at the University of Iowa.


We gratefully acknowledge generous funding support provided by the McKnight Foundation and the Fred and Charlotte Hubbell Foundation. Policy recommendations are solely the perspective of the authors and the Iowa Policy Project.