Iowa CCI’s Master Matrix Toolkit

At Iowa CCI, we are organizing for a better food & farm system — one that works for family farmers, workers, eaters and the environment. The factory farm industry exploits communities, pollutes our natural resources, and negatively impacts our health and well-being, all for the sake of increasing profits. 

While the Master Matrix — the permitting application for large factory farms — is broken and is no substitute for local control, this is one of the tools in our organizing toolkit that allows counties and citizens to weigh in with the Iowa Department of Natural Resources (IDNR) on factory farm constructions in their communities to stop and slow the expansion of factory farms. When a community comes together and utilizes the Master Matrix, in combination with a grassroots base building and community organizing strategy, we can fight back and stop more factory farms from building in our communities. 

Without passing this resolution, there is virtually no way for the county to provide input or fight to protect their community, and the DNR approves nearly every factory farm application that comes across their desk. That’s why it’s important that all Iowa county boards of supervisors pass the master matrix every year. 

Counties that adopt the master matrix resolution can provide input to the DNR and the factory farm applicant on site selection, the proposed structures, and the facility management. These counties review the factory farm application and the master matrix, consider public input, and make a recommendation to the DNR whether the application should be approved or denied.

To adopt the master matrix resolution — officially referred to at the DNR as the Construction Evaluation Resolution — county supervisors must meet in January every year to vote to pass the resolution and then they must submit that resolution, via mail or email, to Kelli Book at the Iowa Department of Natural Resources (DNR) by January 31. 

To view a sample master matrix resolution, click here.

What is the Master Matrix?

The Master Matrix was passed by legislators, with the industry’s influence, in 2002. It’s a scoring system for factory farm applicants to evaluate whether or not they should be allowed to build, and looks at separation distances, along with air, water, and community impacts. 

The Master Matrix measures factors such as:

  • How close the factory farm is to the nearest resident, hospital, nursing home, childcare facility, public water source or private well
  • If the facility plans to use composting, landscaping, filters to reduce odors, etc.
  • If the applicant or any interested parties have a history of violations
  • If the facility has demonstrated community support or will provide any economic value to the community
  • If there is an emergency action plan, worker safety and protection plan, or closure plan 

Factory farm applicants fill out the Master Matrix themselves, picking which questions they answer because  they aren’t required to fill out all of the questions, and they only need a 50% score to pass (440 out of 880 points) — an “F” by most standards.

Communities can look at these Master Matrix applications to evaluate the grade applicants give themselves and find where applicants have omitted pertinent information, fudged the numbers or flat out lied — all problems that Iowa CCI members have found in previous factory farm applications. When we find these mistakes, communities can use this information to demand the county board of supervisors recommend the application for denial.

Click here to see what the master matrix scoring looks like. 

Without the county board of supervisors passing the Master Matrix resolution each January, counties would not be able to utilize the Master Matrix and provide input in the factory farm application process. Last year, 89 Iowa counties (shown in red in the map below) passed the master matrix resolution.

How does the Master Matrix fit into the factory farm permitting process?

In order to build, factory farms must apply for a construction permit from the Iowa DNR. The factory farm owner will submit paperwork – including the Master Matrix, Manure Management Plan, and construction permit application – to both the county auditor and DNR.

Once the the application is received, the county must follow these steps:

  1. Review the application. Once the factory farm application is submitted to the Iowa DNR, the DNR will send the county a formal instruction notice about next steps. The county should immediately start reviewing the application because from this point on, the county has 30 days to submit a recommendation to approve or deny the application.
  2. Notify the public. The county must publish a public notice in the paper notifying the public that a factory farm application has come in within 14 days. The notice will include the applicant’s name, township where the factory farm is being proposed, the type of factory farm it is, the animal unity capacity, and information on how the public can assess and review the application. The county must keep a copy of the construction permit application on file for the public, including the manure management plan and the master matrix.
  3. Review the master matrix. The county will need to review the applicant’s responses and supporting documents for the Master Matrix to determine if the points the applicant claimed are accurate and acceptable.
  4. Hold a public hearing. Although not required, the county can, and should, hold a public hearing to collect written and verbal comments from community residents. This is the only opportunity that residents will get to voice any concerns they have.
  5. Make a recommendation. After the county reviews the application and holds a public hearing (if they chose to do so), the county will make a recommendation to the DNR on if the factory farm application should be approved or denied. If the county finds any discrepancies in the application or master matrix, that should be included in their recommendation as the DNR can, and will, take off points based on the counties response. It is a common misconception that the county can be sued if they recommend the factory farm be denied, but this is not true. The county has every right to make a recommendation for or against the factory farm based on their review of the application and community input.
  6. Submit documents to the DNR. The county must submit the following documents to the DNR field officer via mail within 30 days of receiving the DNR’s instruction notice:
    1. The written county recommendation approving or denying the factory farm application
    2. The boards scoring of the master matrix, along with documentation and justification if points are denied
    3. Proof that the county notified the public
    4. Any other relevant documents that the county thinks is necessary, like public comments
  7. Wait for DNR’s response. Once all materials are received, the DNR will review the factory farm application and will make a final decision within 30 days. If the DNR approves the application against the county’s wishes, the county has 14 days to appeal the DNR’s decision to the Environmental Protection Commission (EPC). The EPC has 35 days to decide whether they will approve, deny, or modify the factory farm permit based on the information from the county, the DNR, and the developer.

For more information on the passing the Master Matrix or how to fight a factory farm in your community, contact us at