Sierra Club Report

WATER WOES: UNCOVERING THE TRUE COST
OF SUMMIT’S CARBON CAPTURE PROJECT
Prepared by:
Wallace Taylor
Donald Johannsen
Jessica Wiskus
Jess Mazour
Pam Mackey Taylor
Steve Veysey
June 4, 2024
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About Sierra Club
Sierra Club is America’s and Iowa’s oldest and largest grass roots environmental organi-
zation. The Iowa Chapter has approximately 7,000 members throughout the state. Over
the years protection of Iowa’s waters has been a major issue for the Iowa Chapter. That
includes water withdrawal and allocation.
In 2020 Sierra Club challenged the proposal by Pattison Sand Company to withdraw wa-
ter from the Jordan aquifer in Clayton County. More recently we have challenged the
withdrawal of water to supply the carbon dioxide capture facilities for Summit Carbon
Solutions.
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CONTENTS
Page
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
WATER USE IN IOWA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
AQUIFERS IN IOWA IMPACTED BY WATER WITHDRAWAL . . . . . . . . . . . 10
DNR REGULATIONS AND POLICIES ON WATER WITHDRAWAL . . . . . . . 14
PROTECTION OF IOWA’S WATER RESOURCES ARE AT RISK DUE

TO THE GOVERNOR’S EXECUTIVE ORDER 10 . . . . . . . . . . . . . . . . . . . . . . 16
USE OF WATER BY ETHANOL PLANTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
WATER USE FOR CARBON CAPTURE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
IMPACT OF SUMMIT CARBON CAPTURE ON WATER USE . . . . . . . . . . . . 19
IMPACT OF SUSTAINABLE AVIATION FUEL FROM ETHANOL. . . . . . . . . 21
RECOMMENDATIONS FOR POLICIES AND ACTIONS. . . . . . . . . . . . . . . . . 22
CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
APPENDIX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
ATTACHMENT A: DNR initial decision summary for Lawler

Carbon Capture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 1
ATTACHMENT B: DNR initial decision summary for Goldfield

Carbon Capture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 5
ATTACHMENT C: Summit Ethanol Plant 2023 Water Usage

Spreadsheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 9
ATTACHMENT D: Application form for water withdrawal . . . . . . . . . . . APP. 11
ATTACHMENT E: Water usage charts for Lakeview Plymouth

Energy, Merill . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 17
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ATTACHMENT F: Water usage charts for Green Plains, Shenandoah. . . . APP. 22
ATTACHMENT G: Water usage charts for Quad County Corn

Processors, Galva . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 27
ATTACHMENT H: Water usage charts for Little Sioux Corn

Processors, Marcus . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 32
ATTACHMENT I: Water usage charts for Green Plains, Superior. . . . . . . APP. 37
ATTACHMENT J: Water usage charts for Louis Dreyfus,

Grand Junction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 42
ATTACHMENT K: Water usage charts for Corn LP, Goldfield . . . . . . . . APP. 47
ATTACHMENT L: Water usage charts for Golden Grain Energy,

Mason City . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 52
ATTACHMENT M: Water usage charts for Absolute Energy,

St Ansgar. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 57
ATTACHMENT N: Water usage charts for Homeland Energy,

New Hampton . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 62
ATTACHMENT O: Water usage charts for Pine Lake Corn Processors,

Steamboat Rock . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 67
ATTACHMENT P: Water usage charts for Siouxland Energy,

Sioux Center . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 72
ATTACHMENT Q: Water usage charts for Lincolnway Energy,

Nevada . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . APP. 77
ATTACHMENT R: Water usage charts for Valero, Albert City . . . . . . . . APP. 82
ATTACHMENT S: Water usage charts for POET, Arthur. . . . . . . . . . . . . APP. 87
ATTACHMENT T: Water usage charts for POET, Ashton . . . . . . . . . . . . APP. 92
ATTACHMENT U: Water usage charts for Valero, Charles City . . . . . . . APP. 97
ATTACHMENT V: Water usage charts for POET, Coon Rapids . . . . . . . APP. 102
ATTACHMENT W: Water usage charts for POET, Corning . . . . . . . . . . APP. 107
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ATTACHMENT X: Water usage charts for POET, Emmetsburg . . . . . . . APP. 112
ATTACHMENT Y: Water usage charts for POET, Fairbank . . . . . . . . . . APP. 117
ATTACHMENT Z: Water usage charts for Valero, Fort Dodge . . . . . . . . APP. 122
ATTACHMENT AA: Water usage charts for POET, Gowrie . . . . . . . . . . APP. 127
ATTACHMENT BB: Water usage charts for POET, Hanlontown . . . . . . APP. 132
ATTACHMENT CC: Water usage charts for Valero, Hartley . . . . . . . . . APP. 137
ATTACHMENT DD: Water usage charts for POET, Hudson . . . . . . . . . APP. 142
ATTACHMENT EE: Water usage charts for POET, Iowa Falls. . . . . . . . APP. 147
ATTACHMENT FF: Water usage charts for POET, Jewell . . . . . . . . . . . APP. 152
ATTACHMENT GG: Water usage charts for Valero, Lakota . . . . . . . . . APP. 157
ATTACHMENT HH: Water usage charts for POET, Menlo . . . . . . . . . . APP. 162
ATTACHMENT II: Water usage charts for POET, Shell Rock . . . . . . . . APP. 167
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INTRODUCTION
Many Iowans believe that Iowa’s aquifers hold enough water to meet the state’s needs for
personal use, drinking water, livestock, and industrial uses.
Recent water concerns have raised issues concerning depletion of Iowa’s water aquifers,
such as extended drought, plans to use groundwater for carbon dioxide capture, increased
use for irrigation, and expansion of ethanol production, including using ethanol for
sustainable aviation fuel.
The Iowa Department of Natural Resources (DNR) has been granting water withdrawal
permits to business and industries for large quantities of water each year with little regard
for the impact on aquifers. At the same time, the quantity of water in the aquifers is
largely unknown. And there have been no studies of the projected water withdrawal and
the ability of the aquifers to sustain the withdrawal.
BACKGROUND
Water is life! This truth has been a rallying cry for efforts to protect our water resources.
We know that our streams, lakes and rivers are polluted. In the most recent list of water
segments impaired by pollution, there are 576 polluted water segments with 743 different
pollutants causing the impairments.1 Hundreds more have been removed from the current
list but still impaired. But there is an aspect of Iowa’s water resources that has received
far less attention: water quantity.
The amount of water available for our use has never been a concern for Iowans. We have
always been blessed with adequate rainfall and snowfall in order to recharge the aquifers
under our rich soil.
Aquifers are underground bodies of water enclosed in areas between layers of rock or
soil. There are two types of aquifers – bedrock aquifers and alluvial aquifers. Aquifers
between layers of rock are called bedrock aquifers. Those between layers of soil near
rivers and streams are called alluvial aquifers.2 When we are digging a well, we are
tapping into those aquifers.
But what happens when there is not enough rainfall and snowfall to maintain the aquifers
and we are withdrawing too much water to keep the aquifers sustainable for future use?
As we will show in this report, that is what is happening now.
Iowa has four major aquifers: Cretaceous (Dakota), Mississippian, Silurian-Devonian,

and Cambrian-Ordovician (Jordan). These aquifers are at different depths, even in
different parts of the state, and somewhat overlap in the areas of the state in which they
1 https://programs.iowadnr.gov/adbnet/Assessments/Summary/2024
2 https://usgs.gov/publications/alluvial-and-bedrock-aquifers-denver-basin-eastern-colorados-dual-
ground-water
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occur.3 In addition there are alluvial aquifers throughout the state in shallow sandy soils
formed in river valleys. These aquifers are extremely vulnerable to pollution infiltration.
In order for aquifers to remain viable, the water in them must be replenished, or
recharged. Natural groundwater recharge occurs as precipitation falls on the land surface,
infiltrates into soils, and moves through pore spaces down to the water table. Natural
recharge also can occur as surface-water leakage from rivers, streams, lakes, and
wetlands. Artificial recharge can be done through injection of water through wells. This
method often is applied to recharge deep aquifers where natural recharge is not effective
at recharging these aquifers.
Iowa’s aquifers are in danger of not being adequately recharged. Confined aquifers can
take hundreds of years to recharge despite annual fluctuations in rainfall. For example, the
map below shows the water level decline in the Jordan Aquifer between 2015 and 2023.
From Iowa DNR stakeholder presentation, July 19, 2023.4

3 https://www.iowadnr.gov/environmental-protection/water-quality/water-monitoring/groundwater
4 Iowa Department of Natural Resources presentation from the Water Use Program Annual Stakeholder
Meeting (July 19, 2023), available at
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The Iowa Code and Iowa Department of Natural Resources (DNR) regulations establish
requirements for the withdrawal of water from the state’s aquifers. Iowa Code Section
455B.262(2) states:
The general welfare of the people of the state requires that the water resources of
the state be put to beneficial use which includes ensuring that the waste or
unreasonable use, or unreasonable methods of use of water be prevented, and that
the conservation and protection of water resources be required with the view to
their reasonable and beneficial use in the interest of the people, and that the public
and private funds for the promotion and expansion of the beneficial use of water
resources be invested to the end that the best interests and welfare of the people
are served.
Chapters 50 and 52 of the DNR regulations define the procedure and criteria for the DNR
to issue permits for the withdrawal of groundwater from the aquifers. How DNR has not
adequately regulated water withdrawal, resulting in too much water being withdrawn, will
be detailed below in the section on DNR regulations and policies.
One of the primary uses causing depletion of the aquifers is the use of water by ethanol
plants. Currently 31 of the 42 ethanol plants in Iowa will be using carbon capture
technology for the pipeline proposed by Summit Carbon Solutions. Water use for those 31
ethanol plants in Iowa can range from 195 million gallons per year to 646 million gallons
per year, depending on the size and amount of ethanol production per plant. Using data
from the Department of Natural Resources reports, it is estimated that the 42 ethanol
plants in Iowa withdraw over 12 billion gallons of water a year from the aquifers and 13.5
billion gallons per year from all sources. Can Iowa’s aquifers continue to withstand this
amount of water depletion? The evidence indicates the answer is no.
A significant concern now is that there are proposals to extract even more water at the
ethanol plants to be used to capture carbon dioxide from the plants. The water would be
used to compress the carbon dioxide so it can be transported in pipelines to be
sequestered underground in other states or used to extract oil and gas from almost
depleted oil and gas wells. A carbon dioxide capture facility would use an estimated 36
million gallons of water per year to 205 gallons of water per year. It is estimated that the
Summit carbon capture process will require 3.36 billion gallons of water annually.
This report will explain how we can protect our aquifers and ensure that we have water
for life.
https://www.iowadnr.gov/Portals/idnr/uploads/water/wse/2023stakeholderupdate.pdf&yed=2ahUKEwi
8845_3pKGAxW638DHV31AG8QFnoECBYQAQ&usg=AOvVaw3dQOuzoayq6xPQPXi
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WATER USE IN IOWA
Iowa’s groundwater is siphoned up for many uses. The table below identifies those many
uses and groundwater withdrawals in millions of gallons per year (MGY), during 2022,
the most recent data.
Water usage for 2022, based on Iowa Department of Natural Resources Reports.
Numbers are in millions of gallons per year.
Use Category Percent DNR Adjustment Water usage Aquifer Alluvial

Aquifer Water Use for adjusted for Water Water
water Total ethanol plants Ethanol plant Source Source
source5 Alluvial receiving wa- water sourced
and Aquifer ter from public from public
water systems6 water systems
Ethanol Production 90% 7,653 5,847 13,500 12,150 1,350
Heating/ Cooling 70% 7,669 7,669 5,368 2,301
Animal Feeding
40% 4,410 4,410 1,764 2,646
Operation
Industrial / Com-
40% 95,686 95,686 38,274 57,412
mercial
Public Water
35% 157,251 -5,847 151,404 52,991 98,413
System
Irrigation - Corn &
30% 31,846 31,846 9,554 22,292
Soybean
Irrigation - Golf
30% 2,750 2,750 825 1,925
Course
Irrigation –
30% 2,975 2,975 893 2,083
Specialty Crops
Other 25% 511 511 128 383
Recreational 5% 11,994 11,994 600 11,394
Power Generation 1% 491,720 491,720 4,917 486,803
Quarry 1% 29,376 29,376 294 29,082
Totals 843,841 843,841 127,758 716,083
5 The determination of the percent aquifer vs. alluvial water was done by sampling a statistically
significant number of permits from each DNR category.
6 Ethanol production for the 42 ethanol plants in Iowa per the Iowa Renewable Fuels association Director
Mr. Monte Shaw was reported as 4.5 billion gallons for 2022. Analysis of the 31 ethanol plants on the
Summit pipeline along with several other public sources indicate it requires at least 3 gallons of water
to produce 1 gallon of ethanol. A ratio of 3 was used for this analysis. A total of 3 gal. water/ gal.
ethanol x 4.5 billion gal. ethanol = 13.5 billion gallons of water that would be required to produce 4.5
billion gallons of ethanol. The DNR water permits for ethanol production in 2022 totals 7,653 MGY
which is 5,847 MGY less than the 13,500 MGY that would be required. Of the 31 ethanol plants on the
Summit pipeline 10 either do not have a DNR water permit or reported zero water usage. This would
indicate that some ethanol plants are sourcing water from other sources such as the Public Water
System. In order to provide a more accurate understanding of the total water use by ethanol plants
5,847 MGY will be moved from the Public water category to the Ethanol Production category.
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Based on information from Iowa DNR Water Use Annual Stakeholder Meeting, July 19,
2023
The total water withdrawn from the aquifers in 2022, from the table, is almost 128 billion
gallons per year. Adding carbon capture processes for the 31 Summit ethanol plants in
Iowa would require an additional 3.36 billion gallons of water per year from the aquifers.
AQUIFERS IN IOWA IMPACTED BY WATER WITHDRAWAL
As explained above, the two types of aquifers are alluvial aquifers and bedrock aquifers.
Alluvial aquifers are fairly quickly recharged by rain and snow melt, but bedrock aquifers
recharge very slowly.7
The focus of this report is on bedrock aquifers. Bedrock aquifers are underground rock
formations with open spaces called pores in which water accumulates. The four major
aquifers in Iowa, Cretaceous (Dakota), Mississippian, Silurian-Devonian, and Cambrian-
Ordovician (Jordan), are at different depths and become deeper as they move from
northeast to southwest, as shown by the diagram below.
7 https://usgs.gov/publications/alluvial-and-bedrock-aquifers-denver-basin-eastern-colorados-dual-
ground-water
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And the aquifers cover different, although somewhat overlapping, areas of the state, as
shown by the diagram below.
There are no reliable numbers for the amount of water in these aquifers, nor a
comprehensive understanding of how quickly and substantially the aquifers are being
depleted. However, the water levels in a majority of the Cretateous (Dakota) aquifer wells
in northwest Iowa show long-term declines between 1984 and 2021, as shown in the
graph below. Obviously, this pattern is not sustainable.
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From The IGS Geode, Activities of the Iowa Geological Survey, p. 10. 2020-2021
Likewise, water use from the Jordan Aquifer has become a concern. The Jordan Aquifer is
“the most productive and extensive bedrock aquifer in Iowa” and ”is the most utilized
bedrock aquifer in the state” and “is the principal source of water for numerous public
water supplies and industries.”8 But it is not an unlimited resource. The Jordan is a
confined aquifer, meaning that the waters that comprise the source are ancient, and local
rains do not penetrate into the aquifer to recharge it. A study published by the Iowa
Geological Survey in 2017 found that the age of the water in the Jordan was between
69,000 and 178,000 years old.9
Water levels in the Jordan have been in decline this past decade. Some areas of the state
have seen the aquifer go down by over 50 feet.10 The map below from Iowa DNR
illustrates the potentiometric surface – which is similar to a water table – of the Jordan
8 Update for Jordan Aquifer Stakeholders (2020), available at

https://www.iowadnr.gov/Portals/idnr/uploads/water/wse/JordanAquiferStakeholderReport2020.pdf&ve
d=2ahUKEwiCm97Pqt6FAxVuCnkGHb1zBGsQFnoECBUQAQ&usg=AOvVaw2SG4lVtHSp2xAWB
H9N_e6G
9 Schilling, et al., Estimating groundwater age in the Cambrian-Ordovician aquifer in Iowa:
implications for biofuel production and other water uses, Environmental Earth Sciences, v. 76, no. 2
(2017).
10 https://www.iowadnr.gov/Portals/idnr/uploads/water/wse/
2023stakeholderupdate.pdf&yed=2ahUKEwi8845_3pKGAxW638DHV31AG8QFnoECBYQAQ&usg
=AOvVaw3dQOuzoayq6xPQPXi
12 | P a g e
Aquifer. Potentiometric surface applies to confined aquifers and represents the level to
which the water would rise if the containing layers were not present. Static water level
applies to unconfined aquifers.
The depletion of this source is so concerning that the DNR recently developed special
rules about the use of this aquifer.11 DNR has a plan for lowering consumption of water
from the Jordan Aquifer in general, and two areas have been designated as special
11 567 Iowa Administrative Code § 52.4(3)

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concern, which have been termed Protected Source areas, outlined in red on the map
above. These Protected Source areas are currently located in Webster, Linn and Johnson
Counties. These are areas where, according to this DNR document, “cones of depression”
have been noted, where the constant pumping of groundwater lowers the potentiometric
surface, forming a sort of conical, downward shape. A cone of depression is the “canary
in the coal mine,” telling us that we are in particular danger.
Nevertheless, even with these new protections, the Jordan continues to be subject to
overuse. The authors of the 2017 study on the Jordan recommended that ethanol
production not be located in places where deep groundwater reserves, like the Jordan
Aquifer, would be consumed.12 They also detailed the way that ethanol production has
drawn increasingly on water from bedrock aquifers across the state. Over the course of a
decade, for example, use of the Jordan for ethanol increased by 36%. In conclusion, the
authors recommended that ethanol production not be located in places where deep
groundwater reserves, like the Jordan Aquifer, would be consumed. Despite this warning,
Iowa DNR water supply engineer Chad Fields said recently, “We’ve seen an increase in
use. There’s about, on average, 25 billion gallons that are taken out of the Jordan Aquifer
per year. And we see an increase of about 8%... every year from that aquifer in use.”13
This year the Iowa Legislature passed a law that appropriates $250,000 for “purposes of
supporting a groundwater planning and resource assessment project to be administered by
the Iowa geological survey.”14 This study will provide a much needed assessment of the
status of our aquifers and should guide the DNR in determining how to address permit
applications for water withdrawal.
DNR REGULATIONS AND POLICIES ON WATER WITHDRAWAL
The Iowa Legislature has tasked the Iowa DNR with the obligation to protect Iowa’s
groundwater resource and regulate water withdrawal from the groundwater in the
aquifers. Unfortunately, the DNR has not taken this task seriously.
Section 455B.262 of the Iowa Code states:
It is recognized that . . . the orderly development, wise use, protection, and

conservation of the water resources of the state by their considered and proper use
is of paramount importance to the welfare and prosperity of the people of the state,
and to realize these objectives it is the policy of the state to correlate and vest the
powers of the state in a single agency, the [DNR], with the duty and authority to
assess the water needs of all water users . . . .

(2017).
13 https://www.kcrg.com/2024/04/19/drought-high-usage-stressing-iowas-water-resources/.
14 https://www.legis.iowa.gov/legislation/BillBook?ba=SF2421&ga=90.
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************************************
The general welfare of the people of the state requires that the water resources of
the state be put to beneficial use which includes ensuring that the waste or
unreasonable use, or unreasonable methods of use of water be prevented, and that
the conservation and protection of water resources be required with the view to
their reasonable and beneficial use in the interest of the people, and that the public
and private funds for the promotion and expansion of the beneficial use of water
resources be invested to the end that the best interests and welfare of the people
are served.
The legislative intent could not be more clear. Iowa’s groundwater resource must be
protected. That is the DNR’s responsibility.
DNR regulation 50.1 states:
The department has jurisdiction over the surface and groundwater of the state to
establish and administer a comprehensive program to ensure that the water
resources of the state be put to beneficial use to the fullest extent possible, that the
waste or unreasonable use, or unreasonable methods of use of water be prevented,
and that the conservation and protection of water resources be required with the
view to their reasonable and beneficial use in the interest of the people.
The DNR purports to carry out this duty by requiring any entity that proposes to obtain
more than 25,000 gallons of water during a period of 24 hours or less from any source of
groundwater to apply for a permit. The DNR’s permit application requests very little
information that would properly inform the DNR’s decision on issuing a permit. The
application simply asks for identity of the persons involved in making the application, the
water use category, the total allocation of water requested, and minimal details of the
location of the proposed water withdrawal. The only water use categories listed are:
animal feeding or dairy operations, ethanol production, heating/cooling,
industrial/commercial, crop irrigation, golf course/country club, power generation, public
water supply, quarry operation, and recreational water.
These use categories are limited and arbitrary. There is nothing in the statutes or the
regulations that specify those uses nor justify limiting the DNR’s review to just those
uses. As noted above, the privilege of using the public water resource is available only for
a beneficial use. And there is nothing in the statutes or regulations that defines a
beneficial use in terms of categories. Each specific application for water withdrawal must
be evaluated on its own merits. For example, the data discussed previously shows that
water use for an ethanol plant might range from 195 million gallons per year to 646
million gallons per year. The larger ethanol plant’s water withdrawal should not be
approved just because it is an ethanol plant. But that is how the DNR views its obligation.
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DNR rule 50.6(1) requires that the application to withdraw water must identify the aquifer
from which the water will be withdrawn, predict the effects of pumping with a reasonable
degree of confidence, and information to determine any permit conditions for well
interference. The application form does not require any of that information and the DNR
routinely does not require the information to be provided.
DNR rule 50.7(2) says that before making an initial decision on a water withdrawal
application, the DNR must prepare a summary report stating “whether the withdrawal or
use of the water conforms to relevant criteria,” identifying “the information used to
determine the potential for a proposed use of water to adversely affect other water users,”
describing “the effects on water levels anticipated to occur from the proposed use,” and
describing “if well interference has been found; and provid[ing] options for resolving”
any well interference. But in general, DNR’s summary reports are cursory two-page
conclusions with no supporting evidence provided. They conclude with a boilerplate
statement that, “The ability and intent of the applicant to devote a reasonable amount of
water to a beneficial use seem evident.”15 That conclusion cannot be evident without
supporting evidence.
In other words, Iowa DNR has been granting water withdrawal permits without any
reasonable determination as to the impacts on the aquifers. That is a violation of the letter
and intent of the law.
PROTECTION OF IOWA’S WATER RESOURCES ARE AT RISK DUE TO THE

GOVERNOR’S EXECUTIVE ORDER 10
The DNR is currently revising its rules to comply with the Governor’s Executive Order
10. The executive order requires all state agencies to repeal and then revise all of their
rules so the rules use fewer words, fewer restrictive terms, and are less burdensome on the
entities that are supposed to be regulated to protect the public and the environment.
One of the proposed revisions is to delete the following paragraph from rule 50.1:
The department has jurisdiction over the surface and groundwater of the state to
establish and administer a comprehensive program to ensure that the water
resources of the state be put to beneficial use to the fullest extent possible, that
the waste or unreasonable use or unreasonable methods of use of water be
prevented and that the conservation and protection of water resources be required
with the view to their reasonable and beneficial use in the interest of the people.
That paragraph should not be deleted, because it puts the concept of beneficial use in the
proper context of public benefit.
15 See, for example, Attachment A.

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More significantly, however, the rules and DNR policy in water use permitting should not
be based on classifications of beneficial use. As explained previously, the current DNR
protocol is to treat every application in a general classification as automatically being
permitted if the applicant is in the established use category. More significantly, however,
the rules and DNR policy in water use permitting should not be based on classifications
of beneficial use. As explained previously, the current DNR protocol is to treat every
application in a general classification as automatically being permitted if the applicant is
in the established use category. But these use categories are limited and arbitrary. By
contrast, the Iowa Code is very clear in its mandate: the privilege of using the public
water resource is available only for a beneficial use. Accordingly, DNR regulations must
be clear that water use permits should not be based on categories of use. For example, an
animal feeding operation of 500 animals will have less impact on the groundwater than an
operation of 5,000 animals. The 5,000 head operation should not be approved just
because it is an animal feeding operation. But that is how the DNR views its obligation.
Iowa Code and DNR regulations must be clear that water use permits should not be based
on categories of uses.
Proposed rule 50.13(3) deletes the previous requirement for public notice of an
application for renewal of a permit. That requirement should be retained. A renewal can
involve a significant modification or there may be new facts that make the renewal
problematic. Renewal should not be automatic. The public should be informed of these
applications.
Proposed rule 50.14(3) requires an appeal of an initial decision to the director within 30
days of mailing the notice. Of course the notice will only be mailed to the applicant, any
person who commented, and any person who requested a copy of the decision. So many
people who will be aggrieved by the decision will not have received a copy of the
decision. There should be no requirement for an appeal to the director. The decision
should be subject to judicial review pursuant to § 17A.19 of the Iowa Code just like any
other decision of the department that is not a contested case.
It is noted that Iowa Code § 455B.365(1) says that, subject to appeal, the department or
director may determine the duration, frequency, and amount of water withdrawal. But, for
the reasons stated above, that requirement for appeal should be limited to the applicant.
The public should not be forced to appeal to the director, since the public is not a party.
Instead, the public should be allowed to appeal a decision to district court. We believe that
is the intent of the law.
In proposed rule 50.20(2), withdrawal for industrial use and power generation is too
broad and vague. There are different types and levels of industrial use and power
generation. Each application should be evaluated on its own merits.
17 | P a g e
In proposed rule 50.20(3), withdrawal for community water supply does not consider the
size and nature of the community. Again, each application should be evaluated on its own
merits.
In proposed rule 50.20(4), withdrawal for recreational and aesthetic uses is determined on
a case-by-case basis. This is the way it should be done for all uses.
Sierra Club has asked the DNR to modify its proposed rules so that they are consistent
with the comments in this section. That way, our aquifers can be better protected.
USE OF WATER BY ETHANOL PLANTS
An ethanol plant uses water for several aspects of the ethanol production process. Cooling
tower water needs make up well over half (60 percent) of an ethanol plant’s utility water
use. Next is reverse osmosis feed water for steam (19 percent), followed by scrubber
water (17 percent) and then backwash/miscellaneous (4 percent).16 As noted above in the
background section, water use for ethanol plants in Iowa can range from 195 million
gallons per year to 646 million gallons per year, depending on the size and amount of
ethanol production per plant.
According to the table above of Iowa water usage, the total amount of water used by
ethanol plants from aquifers in Iowa in 2022 was over 12 billion gallons for water from
aquifers and 13.5 billion gallons per year from all sources.
The amount of water ethanol plants have been withdrawing from aquifers has been
increasing, as shown in the pie chart below.17
16 https://ethanolproducer.com/articles/strategies-to-step-down-water-use-19717 .
(2017).
18 | P a g e
WATER USE FOR CARBON CAPTURE
Water is used in the operation to capture carbon dioxide at the ethanol plants for
dewatering, dust control, hydrostatic testing, and to cool the carbon dioxide because
compression of the carbon dioxide generates heat.18 At the individual ethanol plants, this
water usage for the carbon dioxide capture facility will be in addition to the water usage
for the ethanol process discussed above.
At the hearing before the Iowa Utilities Board on September 5, 2023, Summit’s Chief
Operating Officer, James Powell, described the process as follows:19
So, as you increase the pressure on the CO2 to reach the dense phase, that product
heats up.·And so we'll have a cooling system that circulates through that
compression cycle that keeps the product cooler.· And then we'll dehydrate that in
·· the later stages of compression.·We'll pull the water out of the stream in the later
stages of compression.
We know that in Iowa, Summit has obtained a water withdrawal permit from Iowa DNR
for the carbon dioxide capture facility at the Homeland Energy Solutions ethanol plant
near Lawler, Iowa, allowing the withdrawal of 55.9 million gallons of water per year.20
Summit also applied to withdraw 27.6 million gallons of water per year for the carbon
dioxide capture facility at the Corn L.P. ethanol plant near Goldfield, Iowa. A draft permit
was issued, but has not been finalized.21
After Sierra Club raised concerns about Iowa DNR’s indiscriminate permitting of water
withdrawal, Summit has withdrawn its applications for any additional permits at this time,
or has not made applications for additional withdrawals.
IMPACT OF SUMMIT CARBON CAPTURE ON WATER USE
Summit now proposes to capture carbon dioxide from 31 ethanol plants that would
impact Iowa’s aquifers. Summit initially designated 12 Iowa ethanol plants that would use
its pipeline.22 Then, on June 19, 2023, Summit added another ethanol plant, in Mitchell
County, Iowa, to its proposed pipeline project.23 On March 4, 2024, Summit added yet
another 18 ethanol plants to its project.24
18 Summit Carbon Solutions Otter Tail to Wilkin Project Route Permit Application, p. 134, available at
https://apps.commerce.state.mn.us/web/project/14959.
19 James Powell testimony, September 5, 2023, available at https://efs.iowa.gov/filing/4533255.
20 See Attachment A.
21 See Attachment B.
22 https://efs.iowa.gov/filing/4340573.
19 | P a g e
Using a ratio of 1.05 gallons of water for the carbon dioxide capture facility per gallon of
ethanol produced, based on an Illinois State Geological Survey circular25, the total water
usage for carbon dioxide capture at Summit’s 31 ethanol plant partners is 3.36 billion
gallons of water per year.26 When that amount of water is added to the water already used
for the ethanol production process, the total water usage for the 31 ethanol plants is 13.5
billion gallons of water per year, equivalent to the ethanol industry's current total water
usage. Summit's water needs for CCS are also equivalent to adding 10 or 11 more ethanol
plants in Iowa.27
As noted above, Iowa DNR has already given a permit to Summit for the carbon dioxide
facility at Homeland Energy Solutions. Summit submitted its application for the permit on
a form provided by Iowa DNR.28 However, the application did not include information
specifically required by 199 I.A.C. § 50.6(1) to identify the aquifer from which the water
would be withdrawn, predict the effects of pumping with a reasonable degree of
confidence, and information to determine any permit conditions for well interference.
Thus, Iowa DNR had insufficient information to make a decision to issue the permit. The
Water Use Summary Report prepared by Iowa DNR29 in support of the issuance of the
water withdrawal permit to Summit for the Homeland Energy capture facility states, “The
ability and intent of the applicant to devote a reasonable amount of water to a beneficial
use seem evident.” Unfortunately, the application for water use for the carbon dioxide
capture facility at the Homeland Energy plant was approved before the public knew about
it.
A second application by Summit for water withdrawal at the Corn LP ethanol plant in
Wright County has been put on hold due to public opposition.
In the meantime, Sierra Club, with the help of impacted landowner and retired engineer,
Don Johannsen, has produced an analysis of the impact of Summit’s water needs for
carbon dioxide capture. As shown by Attachments E through II, the carbon dioxide
capture facilities at Summit’s 31 designated ethanol plants will significantly impact the
aquifers and the communities surrounding the ethanol plants.
With the addition of the carbon dioxide capture equipment, the water use for the ethanol
production and the carbon dioxide capture process at many of the 31 ethanol plants will
surpass the usage of the cities and towns within 10 miles of the ethanol plant. See the
chart below.
25 Illinois State Geological Survey Circular 595 (2018), available at

https://www.ideals.illinois.edu/items/107988. The Illinois data are based on actual experience. There is
also a report based on modeling for the Red Trail project in North Dakota, using an estimate of .4
gallons of water per gallon of ethanol produced. We believe the Illinois data, based on actual
experience, is more accurate. But the Red Trail estimates are included in our analysis for comparison.
26 See Attachment C.
27 See Attachment C.
28 See Attachment D.
29 See Attachment A.
20 | P a g e
IMPACT OF SUSTAINABLE AVIATION FUEL FROM ETHANOL
With the advent of electric vehicles creating a trend away from using ethanol as an
additive to gasoline, the Iowa ethanol industry is now promoting the use of ethanol for
sustainable aviation fuel (SAF).30 And, of course, just as with carbon capture and storage,
the federal government has provided a tax credit as an incentive for the production of
SAF.31 Producers of SAF are eligible for a tax credit of $1.25 per gallon of SAF
produced. To qualify for the tax credit, the SAF must reduce greenhouse gas emissions by
50%. SAF that reduces greenhouse gas emissions by more than 50% is eligible for an
additional $0.01 per gallon for each percent the reduction exceeds 50%, up to $0.50 per
gallon.
At this point, it is unknown whether Iowa ethanol will actually be used for SAF and what
quantity of SAF might be produced and what amount of water will be used in the process.
30 https://www.desmoinesregister.com/story/opinion/columnists/iowa-view/2024/01/24/us-ethanol-role-
ustainable-aviation-fuel/72334412007/;
https://www.desmoinesregister.com/story/money/business/2023/12/16/sustainable-aviation-fuel-
standard-greet-model-corn-based-fuels-iowa-ethanol/71937161007/.
31 https://afdc.energy.gov/laws/13160.
21 | P a g e
But it behooves Iowa authorities to plan for this possibility. The increase in the use of
groundwater for SAF is significant.
As the chart below shows, with the addition of estimated production of SAF in 2030,
water use for ethanol production and carbon dioxide capture at the 31 ethanol plants tied
to Summit’s pipeline is estimated to be 74% of the total water used by the ethanol plants
and cities within the 31 surrounding 10 mile radius areas.
RECOMMENDATIONS FOR POLICIES AND ACTIONS
1. In order to protect Iowa’s water resources we must accurately determine the nature and
extent of those resources. We can’t know whether, or to what extent, applications for
water withdrawal from aquifers should be granted if we don’t know the impact on the
aquifers. So the first action that needs to be undertaken is a thorough study of Iowa’s
aquifers to determine how much water is available, how quickly the aquifer can be
recharged, and the impact of any further water withdrawal. This study should be done by
the Iowa DNR in cooperation with the Iowa Geological Survey.
22 | P a g e
2. The Iowa Legislature should fund an aquifer study annually in order to have current
and accurate information to determine how much water can be appropriately withdrawn
from the aquifers.
3. The Iowa Legislature should clarify, or perhaps remove, the concept of beneficial use
in the Iowa Code. Section 455B.261(4) of the Iowa Code defines beneficial use as “the
application of water to a useful purpose that inures to the benefit of the water user.” But in
Section 455B.262 of the Code, as set out above, beneficial use is discussed in the context
of public benefit, not as the benefit to the user. The legislature should at least change the
definition to clarify that beneficial use means benefit to the public, not simply benefit to
the water user. Alternatively, the privilege of using the public resource of Iowa’s water
could be based strictly on the public interest, not a beneficial use.
4. The DNR should revise its rules as explained above that ensure that the water is not
being overdrawn from the aquifers, that it is being withdrawn for a beneficial use, and
that the applications are evaluated on a case-by-case basis.
CONCLUSION
Iowa’s precious resource of groundwater is under assault. Cities, industries, and farming
are depleting the aquifers more quickly than they can be recharged. Iowa legislators and
state officials must take this problem seriously.
Unfortunately, the Iowa DNR has not considered the condition of the aquifers when
granting permission for withdrawing water from the aquifers. Permits are granted as a
matter of course, without addressing whether the proposed use is actually a beneficial use
and whether the amount of water withdrawal requested is justified. And now, with the
advent of carbon dioxide capture and other uses for ethanol, including sustainable
aviation fuel, the situation will only become worse. We need to determine whether carbon
dioxide capture is really a beneficial use and whether there are better sources than ethanol
for sustainable aviation fuel.
There are many important questions that we cannot answer here, such as how much water
remains in Iowa’s aquifers, how fast are our aquifers depleting, and how many years of
water do we have left if Iowa approves public water for carbon capture and storage, and
most importantly, what do we do when we run out of water? We have these questions
because no entity has gathered the information needed to answer all of these questions.
The legislature needs to allocate funding so that the data can be collected. All of these
questions must be answered before we wind up in a water crisis because plain and simple:
water is life.
23 | P a g e
APPENDIX
24 | P a g e
Appendix 1
ATTACHMENT A: DNR initial decision summary for Lawler Carbon Capture

Appendix 2
Appendix 3
Appendix 4
Appendix 5
ATTACHMENT B: DNR initial decision summary for Goldfield Carbon Capture

Appendix 6
Appendix 7
Appendix 8
Appendix 9
ATTACHMENT C: Summit Ethanol Plant 2023 Water Usage Spreadsheet

Summit Ethanol Plant 2023 Water, Electrical and Natural Gas Usage.
Plant Name Nearest City Ethanol CO2 Reported Reported Ratio Estimated Estimated Ratio Estimated Estimated Total 2023 Total Max DNR Ratio Percent Water Electrical Natural Gas Population
Production Production DNR 2023 Reported Required 2023 Estimated Water Usage Water Usage Ethanol Plant water permit 2023 plant vs. Equivalent Equivalent Equivalent all cities within a
Capacity* ***** Water Water 2023 gal. DNR Water 2023 gal. for CO2 for CO2 and CO2 and CO2 capture permit city number of number of number of 10 mile radius of
Summit No.
MGY millions of Permit** Usage ** water per Water Usage water per capture *** capture **** capture water water usage gal. water people equal to people equal to people equal to the ethanol
metric MGY MGY gal. Ethanol Permit MGY gal. 0.4 ratio 1.05 ratio usage MGY water/ usage ethanol plant ethanol plant ethanol plant plant.
tonnes per MGY Ethanol MGY MGY 1.05 ratio gal. % 2023 water electrical usage natural gas Without
year MGY ethanol usage with CO2 with CO2 usage with CO2 duplicate cities
capture capture capture in overlapping
areas
1 Lakeview Plymouth Energy LLC. Merrill 65 0.16 284.0 299.48 4.61 284.0 299.48 4.61 26.0 68.3 367.7 352.3 4.37 54% 14,400 14,500 42,300 12,402
2 Green Plains Inc. - Shenandoah Shenandoah 80 0.20 92.0 32.67 0.41 240.0 240.00 3.00 32.0 84.0 324.0 324.0 3.00 66% 12,700 17,900 52,000 6,421
3 Quad County Corn Processors Galva 34 0.09 315.0 209.16 6.15 315.0 209.16 6.15 13.6 35.7 244.9 350.7 9.26 67% 9,600 7,600 22,100 4,766
4 Little Sioux Corn Processors Marcus 161 0.40 1036.1 645.77 4.01 1036.1 645.77 4.01 64.4 169.1 814.8 1205.2 6.44 91% 31,900 36,000 104,700 3,208
5 Green Plains Inc. - Superior Superior 60 0.15 422.0 291.16 4.85 422.0 291.16 4.85 24.0 63.0 354.2 485.0 7.03 50% 13,900 13,400 39,000 13,874
6 Louis Dreyfus - Grand Junction Grand Junction 125 0.31 630.7 354.57 2.84 630.7 375.00 3.00 50.0 131.3 506.3 762.0 5.05 78% 19,800 28,000 81,300 5,505
7 Corn LP Goldfield 80 0.20 262.0 172.11 2.15 262.0 240.00 3.00 32.0 84.0 324.0 346.0 3.28 63% 12,700 17,900 52,000 7,567
8 Golden Grain Energy LLC. Mason City 135 0.34 683.0 359.86 2.67 683.0 405.00 3.00 54.0 141.8 546.8 824.8 5.06 41% 21,400 30,200 87,800 30,398
9 Absolute Energy LLC. St. Ansgar 130 0.33 842.7 341.04 2.62 842.7 390.00 3.00 52.0 136.5 526.5 979.2 6.48 79% 20,600 29,100 84,500 5,511
10 Homeland Energy Solution New Hampton 195 0.49 681.2 424.50 2.18 681.2 585.00 3.00 78.0 204.8 789.8 886.0 3.49 85% 30,900 43,600 126,800 5,323
11 Pine Lake Corn Processors LLC. Steamboat Rock 80 0.20 320.0 271.42 3.39 320.0 271.42 3.39 32.0 84.0 355.4 404.0 4.00 57% 13,900 17,900 52,000 10,436
12 Siouxland Energy Cooperatives Sioux Center 65 0.16 425.0 0.00 0.00 425.0 195.00 3.00 26.0 68.3 263.3 493.3 6.54 37% 10,300 14,500 42,300 17,295
13 Lincolnway Energy LLC. Nevada 90 0.23 27.0 0.00 0.00 270.0 270.00 3.00 36.0 94.5 364.5 364.5 3.00 15% 14,300 20,100 58,500 81,400
14 Valero Renewable Fuels - Albert City Albert City 135 0.34 610.0 324.62 2.40 610.0 405.00 3.00 54.0 141.8 546.8 751.8 4.52 91% 21,400 30,200 87,800 2,239
15 POET Biorefining - Arthur Arthur 132 0.33 761.0 375.59 2.85 761.0 396.00 3.00 52.8 138.6 534.6 899.6 5.77 63% 20,900 29,500 85,800 12,484
16 POET Biorefining - Ashton Ashton 68 0.17 250.0 171.46 2.52 250.0 204.00 3.00 27.2 71.4 275.4 321.4 3.68 49% 10,800 15,200 44,200 11,351
17 Valero Renewable Fuels - Charles City Charles City 140 0.35 No Permit 0.00 0.00 420.0 420.00 3.00 56.0 147.0 567.0 567.0 3.00 71% 22,200 31,300 91,000 8,998
18 POET Biorefining - Coon Rapids Coon Rapids 65 0.16 237.4 149.37 2.30 237.4 195.00 3.00 26.0 68.3 263.3 305.7 3.65 83% 10,300 14,500 42,300 2,162
19 POET Biorefining - Corning Corning 90 0.23 No Permit 0.00 0.00 270.0 270.00 3.00 36.0 94.5 364.5 364.5 3.00 88% 14,300 20,100 58,500 1,965
20 POET Biorefining - Emmetsburg Emmetsburg 68 0.17 350.0 211.07 3.10 350.0 211.07 3.10 27.2 71.4 282.5 421.4 5.15 70% 11,100 15,200 44,200 4,826
21 POET Biorefining Fairbank Fairbank 132 0.33 578.0 368.43 2.79 578.0 396.00 3.00 52.8 138.6 534.6 716.6 4.38 63% 20,900 29,500 85,800 12,039
22 Valero Renewable Fuels - Ft. Dodge Fort Dodge 110 0.28 No Permit 0.00 0.00 330.0 330.00 3.00 44.0 115.5 445.5 445.5 3.00 40% 17,400 24,600 71,500 26,300
23 POET Biorefining - Gowrie Gowrie 90 0.23 No Permit 0.00 0.00 270.0 270.00 3.00 36.0 94.5 364.5 364.5 3.00 83% 14,300 20,100 58,500 2,830
24 POET Biorefining - Hanlontown Hanlontown 80 0.20 245.0 166.36 2.08 245.0 240.00 3.00 32.0 84.0 324.0 329.0 3.06 51% 12,700 17,900 52,000 12,062
25 Valero Renewable Fuels - Hartley Hartley 140 0.35 570.0 389.23 2.78 570.0 420.00 3.00 56.0 147.0 567.0 717.0 4.07 82% 22,200 31,300 91,000 4,767
26 Poet Biorefining - Hudson S.D. Hudson 80 0.20 No Permit 0.00 0.00 240.0 240.00 3.00 32.0 84.0 324.0 324.0 3.00 61% 12,700 17,900 52,000 7,940
27 POET Biorefining Iowa Falls Iowa Falls 112 0.28 525.0 347.75 3.10 525.0 347.75 3.10 44.8 117.6 465.4 642.6 4.69 75% 18,200 25,100 72,800 6,030
28 POET Biorefining - Jewel Jewel 90 0.23 No Permit 0.00 0.00 270.0 270.00 3.00 36.0 94.5 364.5 364.5 3.00 69% 14,300 20,100 58,500 6,533
29 Valero Renewable Fuels - Lakota Lakota 110 0.28 0.0 239.58 2.18 330.0 330.00 3.00 44.0 115.5 445.5 445.5 3.00 88% 17,400 24,600 71,500 2,369
30 POET Biorefining - Menlo Menlo 132 0.33 No Permit 0.00 0.00 396.0 396.00 3.00 52.8 138.6 534.6 534.6 3.00 82% 20,900 29,500 85,800 4,747
31 POET Biorefining Shell Rock Shell Rock 131 0.33 578.0 368.43 2.81 578.0 393.00 3.00 52.4 137.6 530.6 715.6 4.41 57% 20,800 29,300 85,200 15,369
Totals 3205 8.06 10,725 6,514 13,642 10,151 1,282 3,365 13,516 17,007 61% 529,004 717,362 2,083,250 338,286
* Per Iowa Renewable Fuels Association or company web page Weighted average 2023 gal. water/ gal. ethanol w/o CO2 capture 3.17 w/ CO2 capture 4.22 Permit water/ gal. 5.31 %/ total 16.5% 22.4% 65.1% 10.6%
** per DNR WACOP Permit Search Assumed minimum ratio gal. water/ gal. ethanol 3.0 Average percent plant vs. city water usage 66% 2022 population of Iowa 3,201,000
*** Ratio calculated from Trimeric Red Trail Energy Report 29 Nov 2019 0.4 Assumed daily city water use/ person/ day - gallons 70
**** Ratio calculated from the Illinois ISGS CO2 capture report. 1.05 Minimum 33 3.00 237 195 3.00 36 245 Water****** Electrical Natural Gas
*****Ratio for tonnes CO2 produced per MG Ethanol 2514 Maximum 646 6.15 1036 646 6.15 205 815 Equivalent people/ million gallon ethanol 158.5 223.8 650.0
Average 436 ******At 3 gallon water/ gal. ethanol
Original Route on Docket HLP-2021-0001 Ethanol plants without a DNR water permit or no reported 2023 water usage
Added to Route on Docket HLP-2023-0004 on 19 June 2023 Ethanol plants operating at less than capacity or less than minimum water/ ethanol ratio
Added to IUB Docket HLP-2024-0001 - 0014 on 4 March 2024 Entered Values
Don Johannsen
May 2024 Page 1 of 1 Print Date: 6/3/2024
Appendix 11
ATTACHMENT D: Application form for water withdrawal

Appendix 12
Appendix 13
Appendix 14
Appendix 15
Appendix 16
Appendix 17
ATTACHMENT E: Water usage charts for Lakeview Plymouth Energy, Merill

Appendix 18
#1 Lakeview Plymouth Energy LLC. Merrill Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Ethanol Plant without CO2 Capture
No. Ethanol Plant/ Town Population **Water **2023 Comments
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Merrill Iowa - -
Lakeview Plymouth Energy LLC. 284.0 299.5 Without CO2 capture water requirement
Combined Towns All Water Usage 316.9 316.9 City residential use assumes 70 gal./person/day
1 Seney 50 1.3 1.3 Water usage too small to require a permit
2 Brunsville 129 3.3 3.3 Water usage too small to require a permit
3 Merrill 717 18.3 18.3
4 Hinton 935 23.9 23.9
5 Le Mars 10,571 270.1 270.1
Percentage of ethanol plant usage of total water usage 12,402 47.3% 48.6%
Conclusion: Without CO2 Capture

This ethanol plant consumes 49% of the water used by the cities and plant
within the surrounding 10 mile radius (314 square miles).
Don Johannsen
Appendix 19
Ethanol Plant with CO2 Capture
No. Ethanol Plant/ Town Population **Water **2023 2023 Comments
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Merrill Iowa - - - -
1 Seney 50 1.3 1.3 Water usage too small to require a permit
2 Brunsville 129 3.3 3.3 Water usage too small to require a permit
No Permits 179 4.6 4.6 0.7%
3 Merrill 717 18.3 18.3 2.7%
4 Hinton 935 23.9 23.9 3.5%
5 Le Mars 10571 270.1 270.1 39.5%
9 Ethanol plant water for Ethanol Production 284 299.5 43.7% Without CO2 Capture water requirement
10 Ethanol Plant water for CO2 Capture 68.3 68.3 10.0% Additional CO2 Capture water requirement
Total Plant and Towns 12,402 669.1 684.6 100.0%
Percentage of ethanol plant usage of total water usage 52.6% 53.7%
Conclusion: With CO2 Capture
within the surrounding 10 mile radius (314 square miles)
*Ethanol Production Capacity of Plant - MGY 65
Factor: Water required to cool and compress the CO2 for
1.05
capture - MGY Water/ MGY Ethanol
Calculate additional water required for CO2 Capture - MGY 68.25
Calculate ratio of gallons of water/ gallons of Ethanol 4.6
Total water requirement of towns and Ethanol plant - MGY 689.2
Total water requirement of towns - MGY 321.4
Total water requirement for ethanol plant - MGY 367.7
Ratio of ethanol plant water use vs. surrounding area 1.14
Percentage of ethanol plant usage of total water usage 53.4%
Total Population within the 10 mile radius 12,402
Don Johannsen
Appendix 20
Water Use
Typical water use per person per day - Gallons/ person/ day 70
Equivalent # of people ethanol plant water use w/o CO2 capture 11,721
Equivalent # of people ethanol plant water use w/ CO2 capture 14,393
Electricity Use
Electricity to produce Ethanol - kWh/ gallon EtOH for production 0.6
Total Electricity used to produce ethanol - kWh 39,000,000
Electrical use to capture CO2 - kWh/ gallon EtOH 0.377
Total Electricity used to capture CO2 - kWh 24,505,000
Total electricity to produce ethanol and capture CO2 - kWh 63,505,000
Typical electrical use/ residence - kWh/year 10,476.0
Equivalent number of residences 6,062.0
Number of people / residence 2.4
Equivalent number of people 14,549
Natural Gas Use

Natural gas use per gallon of ethanol for production - BTU's/ gal. 26,000
Natural gas use for ethanol plant - BTU's 1.690E+12
Natural gas use per gal. of ethanol for CO2 capture - BTU's/ gal. 0
Typical Natural Gas use/ residence - BTU's/ year 96,000,000
Equivalent number of residences 17,604
* Ethanol Capacity per Iowa Renewable Fuels Association ** Ethanol Plant Water usage per the greater of DNR WACOP Permit or 3 times ethanol capacity.
Don Johannsen
No. 1 Lakeview Plymouth Energy Ethanol Plant (65 MGY) near Merrill
Appendix 21
Ethanol plant 2023 water usage vs. surrounding residential water usage of towns within
a ten mile radius MGY (Millions of Gallons per Year).
No Permit cities: No Permits, 4.6, 0.7% Merrill, 18.3, 2.7% Hinton, 23.9, 3.5%
Seney
Brunsville Le Mars, 270.1, 39.5%
Ethanol Plant water for

CO2 Capture, 68.3, 10.0% With the proposed CO2 capture
system the Plymouth Energy
Merrill Plant will use 54%
of the total water used by the
plant and cities within the
surrounding 10 mile radius.
(314 square miles)
With combined production and

CO2 capture the ethanol
plant power and 2023 water
Ethanol plant water for usage would be equivalent to:
Ethanol Production, Water: 14,400 people.
299.5, 43.7% Electricity: 14,500 People.
Natural Gas: 42,300 People
This plant uses as much
water as all the cities
within a 10 mile radius.
4.6 gallons of water per gallon of ethanol used for production. LeMars reported a water usage The total population of the
An additional 1.05 gallon is required for CO2 capture. of 1278 MGY in 2023. This would cities within the 10 mile radius
be 331 gal/person/day vs. a is 12,400.
typical value of 70 - over 5 times
The plant draws it's water from an alluvial source.
average water usage.
Don Johannsen
May 2024 Print Date:5/20/2024
Appendix 22
ATTACHMENT F: Water usage charts for Green Plains, Shenandoah

Appendix 23
#2 Green Plains Inc. Shenandoah Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Shenandoah Iowa - -
Green Plains Inc. Shenandoah Plant 240.0 240.0 Without CO2 capture water requirement
1 Imogene 39 1.0 1.0 Water usage too small to require a permit
2 Riverton 245 6.3 6.3
3 Farragut 490 12.5 12.5
4 Essex 722 18.4 18.4
5 Shenandoah 4,925 125.8 125.8

Don Johannsen
Appendix 24
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Shenandoah Iowa - - - - City residential use assumes 70 gal./person/day
1 Imogene 39 1.0 1.0 0.2% Water usage too small to require a permit
2 Riverton 245 6.3 6.3 1.3%
3 Farragut 490 12.5 12.5 2.6%
4 Essex 722 18.4 18.4 3.8%
5 Shenandoah 4925 125.8 125.8 25.8%
6 Ethanol plant water for Ethanol Production 240 240 49.2% Without CO2 Capture water requirement
1.05
Calculate additional water required for CO2 Capture - MGY 84
Don Johannsen
Appendix 25
Water Use
Electricity Use
Natural Gas Use

* Ethanol Capacity per Iowa Renewable Fuels Association ** Water usage per the greater of DNR WACOP Permit or 3 times ethanol capacity.
Don Johannsen
Appendix 26
#2 Green Plains Inc. Ethanol Plant (80 MGY) near Shenandoah

No Permit cities: Riverton, 6.3, 1.3% Farragut , 12.5, 2.6% Essex, 18.4, 3.8%
Imogene, 1.0, 0.2%
Imogene
Shenandoah, 125.8, 25.8%
CO2 Capture, 84.0, 17.2%
With the proposed CO2 capture
system the Green Plains Inc.
Shenandoah Plant will use 66%
The ethanol plant will
(314 square miles)
use twice as much
water as the cities
within a 10 mile radius With combined production and
usage would be equivalent to:
Water: 12,700 people.
Electricity: 17,900 People.
Ethanol plant water for Ethanol
Production, 240, 49.2%
3.0 gallons of water per gallon of ethanol used for production. The total population of the
An additional 1.05 is required for CO2 capture. cities within the 10 mile radius
is 6,421
The plant draws it's water from an unconsolidated aquifer.
The water level in this area has been stable since 2015.
Don Johannsen
May 2024 Page 11 of 11 Print Date:5/20/2024
Appendix 27
ATTACHMENT G: Water usage charts for Quad County Corn Processors, Galva
Appendix 28
#3 Quad County Corn Processors - Galva Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Galva Iowa - -
Quad County Corn Processors Galva Plant 315 209.2 Without CO2 capture water requirement
1 Hanover 50 1.3 1.3 Water usage too small to require a permit
2 Galva 435 11.1 11.1
3 Schaller 729 18.6 18.6
4 Holstein 1,501 38.4 38.4
5 Ida Grove 2,051 52.4 52.4

Don Johannsen
Appendix 29
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Galva Iowa - - - - City residential use assumes 70 gal./person/day
1 Hanover 50 1.3 1.3 0.3% Water usage too small to require a permit
2 Galva 435 11.1 11.1 3.0%
3 Schaller 729 18.6 18.6 5.1%
4 Holstein 1501 38.4 38.4 10.5%
5 Ida Grove 2051 52.4 52.4 14.3%
6 Ethanol plant water for Ethanol Production 315.0 209.2 57.0% Without CO2 Capture water requirement
1.05
Don Johannsen
Appendix 30
Water Use
Electricity Use
Natural Gas Use

Natural gas use for ethanol plant - BTU's 884,000,000,000
Don Johannsen
Appendix 31
#3 Quad County Corn Processors Ethanol Plant (34 MGY) near Galva
Non Permit cities: Hanover, 1.3, 0.3% Galva, 11.1, 3.0% Schaller, 18.6, 5.1%
Hanover
Holstein, 38.4, 10.5%

CO2 Capture, 35.7, 9.7%
system the Quad County Corn
This plant will use twice Processors Galva Plant will use
as much water as the 67% of the total water used by
cities within a 10 mile the plant and cities within the
radius of the plant. surrounding 10 mile radius.
(314 square miles)
Ethanol plant water for

Ethanol Production, With combined production and
209.2, 57.0% CO2 capture the ethanol
6.2 gallons of water per gallon of ethanol is Natural Gas: 22,100 People
used for production. This plant has the highest
water to ethanol ratio of all the Summit plants. Ida Grove, 52.4, 14.3%
An additional 1.05 gallon is required for
CO2 capture. The total population of the
cities within the 10 mile radius
The plant draws it's water from the Cretaceous aquifer. is 4,766.
This aquifer has been stable since 2015
Don Johannsen
Appendix 32
ATTACHMENT H: Water usage charts for Little Sioux Corn Processors, Marcus
Appendix 33
#4 Little Sioux Corn Processors Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Marcus Iowa - -
Little Sioux Corn Processors Marcus Plant 1036.1 645.8 Without CO2 capture water requirement
1 Germantown 50 1.3 1.3 Water usage too small to require a permit
2 Meridan 161 4.1 4.1 Water usage too small to require a permit
3 Cleghorn 240 6.1 6.1
4 Marcus 1,079 27.6 27.6
5 Remsen 1,678 42.9 42.9

Don Johannsen
Appendix 34
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Marcus Iowa - - - - City residential use assumes 70 gal./person/day
1 Germantown 50 1.3 1.3 0.1% Water usage too small to require a permit
2 Meridan 161 4.1 4.1 0.5% Water usage too small to require a permit
3 Cleghorn 240 6.1 6.1 0.7%
4 Marcus 1079 27.6 27.6 3.1%
5 Remsen 1678 42.9 42.9 4.8%
1.05
Don Johannsen
Appendix 35
Water Use
Electricity Use
Total electricity to produce ethanol and capture CO2 - kWh 1.573E+08
Natural Gas Use

Don Johannsen
Appendix 36
#4 Little Sioux Corn Processors Ethanol Plant (161 MGY) near Marcus
No Permit cities: Germantown, 1.3, 0.1% Meridan, 4.1, 0.5% Cleghorn, 6.1, 0.7%
Germantown Marcus, 27.6, 3.1%
Meridan
Remsen, 42.9, 4.8%
Ethanol Plant water for With the proposed CO2 capture

CO2 Capture, 169.1, system the Little Sioux Corn
18.9% Processors Plant will use 91%
(314 square miles)

This plant will use Water: 31,900 people.
9 times as much water Electricity: 36,000 People.
as the cities within Natural Gas: 104,650 People
a 10 mile radius.
The total population of the

4.0 gallons of water per gallon of ethanol cities within the 10 mile radius
is used for production. An additional 1.05 is 3,208
gallon is required for CO2 capture. Ethanol plant water for
Ethanol Production,
645.8, 72.0%
The plant draws it's water from the Devonian aquifer
The water level in the area has been stable since 2015
Don Johannsen
Appendix 37
ATTACHMENT I: Water usage charts for Green Plains, Superior

Appendix 38
#5 Green Plains - Superior Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Superior Iowa - -
Green Plains Inc. - Superior Plant 422.0 291.2 Without CO2 capture water requirement
1 Superior 132 3.4 3.4 Water usage too small to require a permit
2 Orleans 521 13.3 13.3 Water usage too small to require a permit
3 Arnolds Park/ Okoboji 1,878 48.0 48.0
4 Spirt Lake 5,439 139.0 139.0
5 Estherville 5,904 150.8 150.8

Don Johannsen
Appendix 39
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Superior Iowa - - - - City residential use assumes 70 gal./person/day
1 Superior 132 3.4 3.4 0.5% Water usage too small to require a permit
2 Orleans 521 13.3 13.3 1.9% Water usage too small to require a permit
3 Arnolds Park/ Okoboji 1878 48.0 48.0 6.8%
4 Spirt Lake 5439 139.0 139.0 19.6%
5 Estherville 5904 150.8 150.8 21.3%
1.05
Don Johannsen
Appendix 40
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 41
#5 Green Plains Inc. Ethanol Plant (60 MGY) near Superior

No Permit cities: Superior, 3.4, 0.5% Orleans, 13.3, 1.9% Arnolds Park/ Okoboji, 48.0, 6.8%
Superior
Orleans Spirt Lake, 139.0, 19.6%

Ethanol Plant water for system the Green Plains Inc.
CO2 Capture, 63.0, 8.9% Superior Plant will use 50%
Ethanol plant water for (314 square miles)
Ethanol Production,
291.2, 41.1%
Estherville reported 2023 plant power and 2023 water
water usage of 396 MGY usage would be equivalent to:
and a population of 5,904. Water: 13,900 people.
This is 184 gal. per Electricity: 13,400 People.
person/day - about Natural Gas: 39,000 People
2.5 times the typical
residential water usage
of 70 gal./ day.
Estherville, 150.8, 21.3% cities within the 10 mile radius
4.9 gallons of water per gallon of ethanol is used for production. is 13,874.
An additional 1.05 is required for CO2 capture.
The plant draws it's water from the Cretaceous Aquifer This plant will use as much water as all the cities
Water levels in this area are down as much as 30 feet since 2015 within a 10 mile radius of the plant.
Don Johannsen
Appendix 42
ATTACHMENT J: Water usage charts for Louis Dreyfus, Grand Junction

Appendix 43
#6 Louis Dreyfuss - Grand Junction Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Grand Junction, Iowa - -
Louis Dreyfuss - Grand Junction Plant 630.7 375.0 Without CO2 capture water requirement
1 Berkley 23 0.6 0.6 Water usage too small to require a permit
2 Dana 38 1.0 1.0 Water usage too small to require a permit
3 Beaver 46 1.2 1.2 Water usage too small to require a permit
4 Cooper 50 1.3 1.3 Water usage too small to require a permit
5 Rippey 220 5.6 5.6 Water usage too small to require a permit
6 Paton 221 5.6 5.6
7 Grand Junction 725 18.5 18.5
8 Jefferson 4,182 106.9 106.9

Don Johannsen
Appendix 44
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Grand Junction, Iowa - - - - City residential use assumes 70 gal./person/day
1 Berkley 23 0.6 0.6 Water usage too small to require a permit
2 Dana 38 1.0 1.0 Water usage too small to require a permit
3 Beaver 46 1.2 1.2 Water usage too small to require a permit
4 Cooper 50 1.3 1.3 Water usage too small to require a permit
5 Rippey 220 5.6 5.6 Water usage too small to require a permit
No Permit 377 9.6 9.6 1.5%
6 Paton 221 5.6 5.6 0.9%
7 Grand Junction 725 18.5 18.5 2.9%
8 Jefferson 4182 106.9 106.9 16.5%
9 Ethanol plant water for Ethanol Production 630.7 375 58.0% Without CO2 Capture water requirement
1.05
Don Johannsen
Appendix 45
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 46
#6 Louis Dreyfuss Ethanol Plant (125 MGY) near Grand Junction

No Permit cities:
Berkley No Permit, 9.6, 1.5% Paton, 5.6, 0.9% Grand Junction, 18.5, 2.9%
Dana
Beaver Jefferson, 106.9, 16.5%
Cooper
Rippey With the proposed CO2 capture
system the Louis Dreyfuss
Grand Junction Plant will use
Ethanol Plant water for 78% of the total water used by
CO2 Capture, 131.3, the plant and cities within the
20.3% surrounding 10 mile radius.
(314 square miles)
This plant will use four
times as much water as
all the cities within a 10
mile radius of the plant.

Ethanol plant water for cities within the 10 mile radius
3.0 gallons of water per gallon of ethanol is used for production.
Ethanol Production, 375, is 5,505.
An additional 1.05 gallon is required for CO2 capture.
58.0%
The plant draws it's water from the Pennsylvanian aquifer.
The water level in this area is down as much as 30 feet since 2015
Don Johannsen
Appendix 47
ATTACHMENT K: Water usage charts for Corn LP, Goldfield

Appendix 48
#7 Corn LP - Goldfield Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Goldfield, Iowa - -
Corn LP Goldfield Plant 262 240 Without CO2 capture water requirement
1 Holmes 50 1.3 1.3 Water usage too small to require a permit
2 Hardy 57 1.5 1.5 Water usage too small to require a permit
3 Thor 181 4.6 4.6
4 Renwick 234 6.0 6.0
5 Goldfield 634 16.2 16.2
6 Clarion 2,810 71.8 71.8
7 Eagle Grove 3,601 92.0 92.0

Don Johannsen
Appendix 49
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Goldfield, Iowa - - - - City residential use assumes 70 gal./person/day
1 Holmes 50 1.3 1.3 Water usage too small to require a permit
2 Hardy 57 1.5 1.5 Water usage too small to require a permit
No Permit 107 2.7 2.7 0.5%
3 Thor 181 4.6 4.6 0.9%
4 Renwick 234 6.0 6.0 1.2%
5 Goldfield 634 16.2 16.2 3.1%
6 Clarion 2810 71.8 71.8 13.9%
7 Eagle Grove 3601 92.0 92.0 17.8%
1.05
Don Johannsen
Appendix 50
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 51
#7 Corn LP Ethanol Plant (80 MGY) near Goldfield

Thor, 4.6, 0.9% Renwick, 6.0, 1.2%
No Permit, 2.7, 0.5% Goldfield, 16.2, 3.1%
No Permit cities:
Holmes
Hardy Clarion, 71.8, 13.9%

CO2 Capture, 84.0, 16.2% system the Corn LP Goldfield
Plant will use 63% of the
total water used by the plant
and cities within the
(314 square miles)
This plant will use twice

as much water as all With combined production and
the cities within a 10 CO2 capture the ethanol
mile radius of the plant. plant power and 2023 water
Ethanol plant water for Natural Gas: 52,000 People
Ethanol Production,
240.0, 46.4%
3.0 gallons of water per gallon of ethanol is used for production. Eagle Grove, 92.0, 17.8% The total population of the
An additional 1.05 gallon is required for CO2 capture. cities within the 10 mile radius
is 7,567.
The plant draws it's water from the Mississippian aquifer.
Water levels in this area are down as much as 30 feet since 2015
Don Johannsen
Appendix 52
ATTACHMENT L: Water usage charts for Golden Grain Energy, Mason City
Appendix 53
#8 Golden Grain Energy - Mason City Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Mason City, Iowa - -
Golden Grain Energy - Mason City Plant 683.0 405.0 Without CO2 capture water requirement
1 Portland 50 1.28 1.28 Water usage too small to require a permit
2 Rock Falls 150 3.83 3.83 Water usage too small to require a permit
3 Rudd 358 9.15 9.15
4 Plymouth 375 9.58 9.58
5 Rockford 758 19.37 19.37
6 Nora Springs 1,369 34.98 34.98
7 Mason City 27,338 698.49 698.49

Don Johannsen
Appendix 54
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Mason City, Iowa - - - - City residential use assumes 70 gal./person/day
1 Portland 50 1.3 1.3 0.10% Water usage too small to require a permit
2 Rock Falls 150 3.8 3.8 0.29% Water usage too small to require a permit
No Permit 200 5.1 5.1 0.4%
3 Rudd 358 9.1 9.1 0.7%
4 Plymouth 375 9.6 9.6 0.7%
5 Rockford 758 19.4 19.4 1.5%
6 Nora Springs 1369 35.0 35.0 2.6%
7 Mason City 27338 698.5 698.5 52.8%

1.05
Don Johannsen
Appendix 55
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 56
#8 Golden Grain Energy Ethanol Plant (135 MGY) near Mason City
No Permit cities: No Permit, 5.1, 0.4% Rudd, 9.1, 0.7% Plymouth, 9.6, 0.7%
Portland
Rockford, 19.4, 1.5%
Rock Falls
Nora Springs, 35.0, 2.6%
CO2 Capture, 141.8, With the proposed CO2 capture
10.7% system the Golden Grain Energy
Mason City Plant will use 41%
Ethanol Production,
405.0, 30.6%
(314 square miles)

Mason City reported 2023
water usage of 2,093 MGY
and a population of 27,338..
This is 210 gal./day/ person - usage would be equivalent to:
3 times the typical Water: 21,400 people.
residential water usage of Electricity: 30,200 People.
70 gal./ day. Natural Gas: 87,800 People
3.0 gallons of water per gallon of ethanol is used for production. Mason City, 698.5, 52.8% The total population of the
is 30,398
The plant draws it's water from the Jordan aquifer.
Don Johannsen
Appendix 57
ATTACHMENT M: Water usage charts for Absolute Energy, St Ansgar

Appendix 58
#9 Absolute Energy LLC Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near St. Ansgar Iowa - -
Absolute Energy LLC Plant 842.7 390.0 Without CO2 capture water requirement
1 Toeterville 50 1.3 1.3 Water usage too small to require a permit
2 Otranto 50 1.3 1.3 Water usage too small to require a permit
3 Mona 50 1.3 1.3 Water usage too small to require a permit
4 Carpenter 87 2.2 2.2 Water usage too small to require a permit
5 Rose Creek Mn. 397 10.1 10.1 Minnesota Usage
6 Lyle Mn. 521 13.3 13.3 Minnesota Usage
7 London Mn. 1,310 33.5 33.5 Minnesota Usage
8 Johnsburg Mn. 1,428 36.5 36.5 Minnesota Usage
9 Stacyville 458 11.7 11.7
10 St. Ansgar 1,160 29.6 29.6

Don Johannsen
Appendix 59
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near St. Ansgar Iowa - - - - City residential use assumes 70 gal./person/day
1 Toeterville 50 1.3 1.3 Water usage too small to require a permit
2 Otranto 50 1.3 1.3 Water usage too small to require a permit
3 Mona 50 1.3 1.3 Water usage too small to require a permit
4 Carpenter 87 2.2 2.2 Water usage too small to require a permit
5 Rose Creek Mn. 397 10.1 10.1 Minnesota Usage
6 Lyle Mn. 521 13.3 13.3 Minnesota Usage
7 London Mn. 1310 33.5 33.5 Minnesota Usage
8 Johnsburg Mn. 1428 36.5 36.5 Minnesota Usage
No Permit Iowa 237 6.1 6.1 0.9%
Minnesota Usage 3656 93.4 93.4 14.0%
9 Stacyville 458 11.7 11.7 1.8%
10 St. Ansgar 1160 29.6 29.6 4.4%
Total Plant and Towns 5511 1219.5 667.3 100.0%
1.05
Don Johannsen
Appendix 60
Water Use
Equivalent number of people Ethanol plant w/ CO2 capture 20,607
Electricity Use
Natural Gas Use

Natural gas use for ethanol plant - BTU's 3,380,000,000,000
Number of people / residences 2.4
Don Johannsen
Appendix 61
#9 Absolute Energy LLC Ethanol Plant (130 MGY) near St. Ansgar
Ethanol plant 2023 water usage vs. surrounding residential water usage of towns within a ten
mile radius - MGY (Millions of Gallons per Year).
Ethanol Plant water for No Permit Iowa, 6.1, 0.9% Minnesota Usage, 93.4, 14.0%
CO2 Capture, 136.5,
Stacyville, 11.7, 1.8%
20.5%
St. Ansgar, 29.6, 4.4%
No Permit cities:
Toeterville
Otranto
system the Absolute Energy
Mona
St. Ansgar Plant will use 79%
Carpenter
Rose Creek Mn.
Lyle Mn.
London Mn.
(314 square miles)
Johnsburg Mn.
usage would equivalent to:
This plants uses four
times as much water
as all the other cities
Ethanol plant water for The total population of the

Ethanol Production, cities within the 10 mile radius
390.0, 58.4% is 5,511.
This water level is down as much as 30 feet since 2015
Don Johannsen
Appendix 62
ATTACHMENT N: Water usage charts for Homeland Energy, New Hampton

Appendix 63
#10 Homeland Energy Solution - Ethanol Plant Energy and Water Usage vs. Cities with in a 10 mi. radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near New Hampton/ Lawler Iowa - -
Homeland Energy Solution - New Hampton plant 681.2 585.0 Without CO2 capture water requirement
1 Jackson Jct. 37 0.9 0.9 Water usage too small to require a permit
2 Alpha 50 1.3 1.3 Water usage too small to require a permit
3 Jerico 50 1.3 1.3 Water usage too small to require a permit
4 Waucoma 299 7.6 7.6
5 Lawler 406 10.4 10.4
6 Fredericksburg 987 25.2 25.2
7 New Hampton 3,494 89.3 89.3

Don Johannsen
Appendix 64
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near New Hampton/ Lawler Iowa - - - - City residential use assumes 70 gal./person/day
1 Jackson Jct. 37 0.9 0.9 Water usage too small to require a permit
2 Alpha 50 1.3 1.3 Water usage too small to require a permit
3 Jerico 50 1.3 1.3 Water usage too small to require a permit
No Permit 137 3.5 3.5 0.4%
4 Waucoma 299 7.6 7.6 0.8%
5 Lawler 406 10.4 10.4 1.1%
6 Fredericksburg 987 25.2 25.2 2.7%
7 New Hampton 3494 89.3 89.3 9.6%
Total Plant and Towns 5,323 1,022.0 925.8 100.0%

1.05
Don Johannsen
Appendix 65
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 66
#10 Homeland Energy Solutions Ethanol Plant (195 MGY) near New Hampton/ Lawler
No Permit cities: No Permit, 3.5, 0.4% Waucoma, 7.6, 0.8% Lawler, 10.4, 1.1% Fredericksburg, 25.2, 2.7%
Jackson Jct.
Alpha
Jerico New Hampton, 89.3, 9.6%

CO2 Capture, 204.8, system the Homeland Energy
22.1% Solution Plant will use 85%
(314 square miles)

This plant uses 5.5 Water: 30,900 people.
times as much water Electricity: 43,600 People.
as the surrounding Natural Gas: 126,800 People
cities in a 10 mile radius.
3.0 gallons of water per gallon of ethanol is used for production. Ethanol plant water for The total population of the
An additional 1.05 gallon is required for CO2 capture. Ethanol Production, cities within the 10 mile radius
585.0, 63.2% is 5,323.
Don Johannsen
Appendix 67
ATTACHMENT O: Water usage charts for Pine Lake Corn Processors, Steamboat Rock
Appendix 68
#11 Pine Lake Corn Processors Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Steamboat Rock, Iowa - -
Pine Lake Corn Processors - Steamboat Rock Plant 320.0 271.4 Without CO2 capture water requirement
1 Owasa 34 0.9 0.9 Water usage too small to require a permit
2 Austinville 50 1.3 1.3 Water usage too small to require a permit
3 Wellsburg 720 18.4 18.4 Water usage too small to require a permit
4 Steamboat Rock 264 6.7 6.7
5 Ackley 1,599 40.9 40.9
6 Eldora 2,663 68.0 68.0
7 Iowa Falls 5,106 130.5 130.5

Don Johannsen
Appendix 69
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Steamboat Rock, Iowa - - - - City residential use assumes 70 gal./person/day
2 Austinville 50 1.3 1.3 Water usage too small to require a permit
3 Wellsburg 720 18.4 18.4 Water usage too small to require a permit
No Permit 804 20.5 20.5 3.3%
4 Steamboat Rock 264 6.7 6.7 1.1%
5 Ackley 1599 40.9 40.9 6.6%
6 Eldora 2663 68.0 68.0 10.9%
7 Iowa Falls 5106 130.5 130.5 21.0%

1.05
Don Johannsen
Appendix 70
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 71
#11 Pine Lake Corn Processors Ethanol Plant (80 MGY) near Steamboat Rock
Ethanol plant 2023 water usage vs. surrounding Residential water usage of towns within
No Permit cities: No Permit, 20.5, 3.3% Steamboat Rock, 6.7, 1.1%
Owasa
Austinville Ackley, 40.9, 6.6%
Wellsburg
Eldora, 68.0, 10.9%

CO2 Capture, 84.0, 13.5% system the Pine Lake Corn
Processors Plant will use 57%
This plant uses more (314 square miles)
water than all the other
cities within a 10 mile With combined production and
radius. CO2 capture the ethanol
Ethanol Production,
271.4, 43.6%

3.4 gallons of water per gallon of ethanol is used for production. Iowa Falls, 130.5, 21.0%
An additional 1.05 gallon is required for CO2 capture. is 10,436.
The plant draws it's water from the Mississippian/ Jordan aquifer.
This water level in this area is down as much as 30 feet since 2015
Don Johannsen
Appendix 72
ATTACHMENT P: Water usage charts for Siouxland Energy, Sioux Center

Appendix 73
#12 Siouxland Energy Cooperatives Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Sioux Center, Iowa - -
Siouxland Energy Cooperatives - Sioux Center Plant 425.0 195.0 Without CO2 capture water requirement
1 Perkins 50 1.3 1.3 Water usage too small to require a permit
2 Carmel 50 1.3 1.3 Water usage too small to require a permit
3 Newkirk 50 1.3 1.3 Water usage too small to require a permit
4 Maurice 265 6.8 6.8 Water usage too small to require a permit
5 Hull 2,384 60.9 60.9 Water usage too small to require a permit
6 Orange City 6,267 160.1 160.1
7 Sioux Center 8,229 210.3 210.3

Don Johannsen
Appendix 74
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Sioux Center, Iowa - - - - City residential use assumes 70 gal./person/day
1 Perkins 50 1.3 1.3 Water usage too small to require a permit
2 Carmel 50 1.3 1.3 Water usage too small to require a permit
3 Newkirk 50 1.3 1.3 Water usage too small to require a permit
4 Maurice 265 6.8 6.8 Water usage too small to require a permit
5 Hull 2384 60.9 60.9 Water usage too small to require a permit
No Permit 2799 71.5 71.5 10.1%
6 Orange City 6267 160.1 160.1 22.7%
7 Sioux Center 8229 210.3 210.3 29.8%

1.05
Don Johannsen
Appendix 75
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 76
#12 Siouxland Energy Cooperatives Ethanol Plant (65 MGY) near Sioux Center
No Permit cities: Ethanol Plant water for No Permit, 71.5, 10.1%
Perkins CO2 Capture, 68.3, 9.7%
Orange City, 160.1, 22.7%
Carmel
Newkirk
Maurice
Hull With the proposed CO2 capture
system the Siouxland Energy
Cooperatives Plant will use 37%
Ethanol plant water for plant and cities within the
Ethanol Production, 195, surrounding 10 mile radius.
27.7% (314 square miles)
Orange City reported 2023 With combined production and

water usage 375 MGY and CO2 capture the ethanol
a population of 6,267. plant power and 2023 water
This is 164 gal./day/ person usage would be equivalent to:
- 2.3 times the typical Water: 10,300 people.
residential water usage of Electricity: 14,500 People.
70 gal./ day. Natural Gas: 42,300 People
3.0 Gallons of water per gallon of ethanol The total population of the
is used for production. An additional 1.05 cities within the 10 mile radius
gallon is required for CO2 capture. is 17,295.
Sioux Center, 210.3,

The plant draws it's water from the Cretaceous aquifer.
29.8%
This water level in this area has been stable since 2015
Don Johannsen
Appendix 77
ATTACHMENT Q: Water usage charts for Lincolnway Energy, Nevada

Appendix 78
#13 Lincolnway Energy LLC. - Nevada Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Nevada, Iowa - -
Lincolnway Energy LLC. Nevada Plant 270 270 Without CO2 capture water requirement
1 Fernald 50 1.3 1.3 Water usage too small to require a permit
2 Iowa Center 50 1.3 1.3 Water usage too small to require a permit
3 Kelley 304 7.8 7.8 Water usage too small to require a permit
4 Cambridge 827 21.1 21.1
5 Gilbert 1,211 30.9 30.9
6 Roland 1,362 34.8 34.8
7 Huxley 4,244 108.4 108.4
8 Nevada 6,925 176.9 176.9
9 Ames 66,427 1697.2 1697.2

Don Johannsen
Appendix 79
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Nevada, Iowa - - - - City residential use assumes 70 gal./person/day
1 Fernald 50 1.3 1.3 Water usage too small to require a permit
2 Iowa Center 50 1.3 1.3 Water usage too small to require a permit
3 Kelley 304 7.8 7.8 Water usage too small to require a permit
No Permit 404 10.3 10.3 0.4%
4 Cambridge 827 21.1 21.1 0.9%
5 Gilbert 1211 30.9 30.9 1.3%
6 Roland 1362 34.8 34.8 1.4%
7 Huxley 4244 108.4 108.4 4.4%
8 Nevada 6925 176.9 176.9 7.2%
9 Ames 66427 1697.2 1697.2 69.4%

1.05
Don Johannsen
Appendix 80
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 81
#13 Lincolnway Energy LLC. Ethanol Plant (90 MGY) near Nevada
No Permit cities:
Fernald Gilbert, 30.9, 1.3%
No Permit, 10.3, 0.4% Cambridge, 21.1, 0.9%
Iowa Center
Kelly Ethanol Plant water Roland, 34.8, 1.4%
for CO2 Capture,
Huxley, 108.4, 4.4%
94.5, 3.9%
Nevada, 176.9, 7.2%
Ethanol Production, 270, With the proposed CO2 capture
11.0% system the Lincolnway Energy
Plant will use 15%
The city of Nevada reported of the total water used by the
2023 water usage of 643 plant and cities within the
MGY and a population of surrounding 10 mile radius.
6,925. This is 254 gal. per (314 square miles)
person/ day - about 4 times
typical residential water
Ames has a water permit plant power and 2023 water
of 3.8 billion gallons/ year. usage would be equivalent to:
And used 2.5 billion. Water: 14,300 people.
This large water usage Electricity: 20,100 People.
overshadows any other usage. Natural Gas: 58,500 People
3.0 gallons of water per gallon of ethanol used

for production. An additional 1.05 gallon is
Ames, 1697.2, 69.4% cities within the 10 mile radius
required for CO2 capture.
is 81,400.
The plant draws it's water from an alluvial water source.
Don Johannsen
Appendix 82
ATTACHMENT R: Water usage charts for Valero, Albert City

Appendix 83
#14 Valero Renewable Fuels - Albert City Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Albert City, Iowa - -
Valero Renewable Fuels - Albert City Plant 610 405 Without CO2 capture water requirement
1 Varina 68 1.7 1.7 Water usage too small to require a permit
2 Marathon 230 5.9 5.9
3 Albert City 677 17.3 17.3
4 Laurens 1,264 32.3 32.3

Don Johannsen
Appendix 84
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Albert City, Iowa - - - - City residential use assumes 70 gal./person/day
1 Varina 68 1.7 1.7 0.3% Water usage too small to require a permit
2 Marathon 230 5.9 5.9 1.0%
3 Albert City 677 17.3 17.3 2.9%
4 Laurens 1264 32.3 32.3 5.3%

1.05
Don Johannsen
Appendix 85
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 86
#14 Valero Renewable Fuels Ethanol Plant (135 MGY) near Albert City
No permit cities: Varina, 1.7, 0.3% Marathon, 5.9, 1.0% Albert City, 17.3, 2.9%
Varina
Laurens, 32.3, 5.3%

CO2 Capture, 141.8, system the Valero Renewable
23.5% Fuels Albert City Plant will use
91% of the total water used by
the plant and cities within the
(314 square miles)

This plant will use nine times as usage would be equivalent to:
much water as the surrounding Water: 21,400 people.
cities within a 10 mile radius. Electricity: 30,200 People.
3.0 gallons of water per gallon of

ethanol for production. An additional
1.05 gallons are required for CO2
capture. Ethanol plant water for The total population of the
Ethanol Production, cities within the 10 mile radius
The plant draws it's water from the Cretaceous aquifer 405.0, 67.1% is 2,239.
Don Johannsen
Appendix 87
ATTACHMENT S: Water usage charts for POET, Arthur

Appendix 88
#15 POET Biorefining - Arthur Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Arthur, Iowa - -
POET Biorefining - Arthur Plant 761 396 Without CO2 capture water requirement
1 Arthur 222 5.7 5.7 Water usage too small to require a permit
2 Kiron 267 6.8 6.8 Water usage too small to require a permit
3 Ida Grove 2,051 52.4 52.4
4 Odebolt 9,944 254.1 254.1

Don Johannsen
Appendix 89
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Arthur, Iowa - - - - City residential use assumes 70 gal./person/day
1 Arthur 222 5.7 5.7 0.7% Water usage too small to require a permit
2 Kiron 267 6.8 6.8 0.8% Water usage too small to require a permit
3 Ida Grove 2051 52.4 52.4 6.1%
4 Odebolt 9944 254.1 254.1 29.8%

1.05
Don Johannsen
Appendix 90
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 91
#15 POET Biorefining Ethanol Plant (132 MGY) near Arthur

No permit Cities: Ethanol Plant water for Arthur, 5.7, 0.7% Kiron, 6.8, 0.8%
Arthur CO2 Capture, 138.6, Ida Grove, 52.4, 6.1%
Kiron 16.2%
Odebolt, 254.1, 29.8%
The plant will use nearly With the proposed CO2 capture
twice as much water as system the POET Biorefining
all the cities in the Arthur Plant will use 63%
surrounding 10 mile of the total water used by the
radius. plant and cities within the
(314 square miles)

Ethanol Production,
396.0, 46.4%
3.0 gallons of water per gallon of ethanol used for production. is 12,484.
The plant draws it's water from the Devonian aquifer.

Don Johannsen
Appendix 92
ATTACHMENT T: Water usage charts for POET, Ashton

Appendix 93
#16 POET Biorefining - Ashton Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Ashton, Iowa - -
POET Biorefining - Ashton Plant 250 204 Without CO2 capture water requirement
1 Matlock 74 1.9 1.9 Water usage too small to require a permit
2 Ashton 436 11.1 11.1 Water usage too small to require a permit
3 George 1,077 27.5 27.5
4 Sanborn 1,392 35.6 35.6
5 Sibley 2,860 73.1 73.1
6 Sheldon 5,512 140.8 140.8

Don Johannsen
Appendix 94
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Ashton, Iowa - - - - City residential use assumes 70 gal./person/day
1 Matlock 74 1.9 1.9 0.3% Water usage too small to require a permit
2 Ashton 436 11.1 11.1 2.0% Water usage too small to require a permit
3 George 1077 27.5 27.5 4.9%
4 Sanborn 1392 35.6 35.6 6.3%
5 Sibley 2860 73.1 73.1 12.9%
6 Sheldon 5512 140.8 140.8 24.9%

1.05
Don Johannsen
Appendix 95
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 96
#16 POET Biorefining Ethanol Plant (68 MGY) near Ashton

Ethanol plant 2023 water usage vs. surrounding Residential water usage of towns within
Ashton, 11.1, 2.0% George, 27.5, 4.9% Sanborn, 35.6, 6.3%
No permit cities: Matlock, 1.9, 0.3% Sibley, 73.1, 12.9%

Matlock
Ashton
system the POET Biorefining
Ashton Plant will use 49%
CO2 Capture, 71.4, 12.6%
(314 square miles)
The plant uses as
much water as all With combined production and
the surrounding CO2 capture the ethanol
cities within a plant power and 2023 water
10 mile radius. usage would be equivalent to:
Ethanol plant water for Electricity: 15,200 People.
Ethanol Production, 204, Natural Gas: 44,200 People
36.1%

3.0 gallons of water per gallon of ethanol is used for production. Sheldon, 140.8, 24.9% is 11,351.
The plant draws it's water from an unconsolidated aquifer.

This water level in this area has been stable since 2015.
Don Johannsen
Appendix 97
ATTACHMENT U: Water usage charts for Valero, Charles City

Appendix 98
#17 Valero Renewable Fuels - Charles City Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Charles City, Iowa - -
Valero Renewable Fuels - Charles City 420 420 Without CO2 capture water requirement
1 Roseville 50 1.3 1.3 Water usage too small to require a permit
2 Orchard 68 1.7 1.7 Water usage too small to require a permit
3 Colwell 55 1.4 1.4
4 Floyd 313 8.0 8.0
5 Rudd 358 9.1 9.1
6 Rockford 758 19.4 19.4
7 Charles City 7,396 189.0 189.0

Don Johannsen
Appendix 99
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Charles City, Iowa - - - - City residential use assumes 70 gal./person/day
1 Roseville 50 1.3 1.3 0.2% Water usage too small to require a permit
2 Orchard 68 1.7 1.7 0.2% Water usage too small to require a permit
3 Colwell 55 1.4 1.4 0.2%
4 Floyd 313 8.0 8.0 1.0%
5 Rudd 358 9.1 9.1 1.1%
6 Rockford 758 19.4 19.4 2.4%
7 Charles City 7396 189.0 189.0 23.7%

1.05
Don Johannsen
Appendix 100
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 101
#17 Valero Renewable Fuels Ethanol Plant (140 MGY) near Charles City
No permit cities: Orchard, 1.7, 0.2% Colwell, 1.4, 0.2% Floyd, 8.0, 1.0%
Roseville
Orchard Roseville, 1.3, 0.2% Rudd, 9.1, 1.1%
Rockford, 19.4, 2.4%

CO2 Capture, 147.0, Charles City, 189.0, 23.7%
18.4%
Charles City reported 2023 system the Valero Renewable
water usage 867 MGY and Fuels Plant will use 71%
a population of 7,396.
This is 321 gal./day/ person -
almost 5 times the typical
residential water usage of surrounding 10 mile radius.
70 gal./ day. (314 square miles)
This plant uses almost

three times as much water
as all the surrounding cities
in a 10 mile radius.
Ethanol plant water for Electricity: 31,300 People.
Ethanol Production, 420, Natural Gas: 91,000 People
52.7%
3.0 gallons of water per gallon of ethanol used for production.

is 8,998.
This plant does not have a DNR water permit. It is not known where the plant draws it's
water from. This water level in this area is down as much as 30 feet since 2015
Don Johannsen
Appendix 102
ATTACHMENT V: Water usage charts for POET, Coon Rapids

Appendix 103
#18 POET Biorefining - Coon Rapids Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Coon Rapids, Iowa - -
Poet Biorefining - Coon Rapids Plant 237.4 195.0 Without CO2 capture water requirement
1 Dedham 224 5.7 5.7 Water usage too small to require a permit
2 Bagley 233 6.0 6.0 Water usage too small to require a permit
3 Bayard 405 10.3 10.3
4 Coon Rapids 1,300 33.2 33.2

Don Johannsen
Appendix 104
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Coon Rapids, Iowa - - - - City residential use assumes 70 gal./person/day
1 Dedham 224 5.7 5.7 1.8% Water usage too small to require a permit
2 Bagley 233 6.0 6.0 1.9% Water usage too small to require a permit
3 Bayard 405 10.3 10.3 3.2%
4 Coon Rapids 1300 33.2 33.2 10.4%
5 Ethanol plant water for Ethanol Production 237.4 195 61.2% Without CO2 Capture water requirement

1.05
Don Johannsen
Appendix 105
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 106
#18 POET Biorefining Ethanol Plant (65 MGY) near Coon Rapids
No permit cities: Dedham, 5.7, 1.8% Bagley, 6.0, 1.9% Bayard, 10.3, 3.2%
Dedham
Bagley Coon Rapids, 33.2, 10.4%

CO2 Capture, 68.3, 21.4%
Coon Rapids Plant will use 83%
(314 square miles)

This plant will use almost Electricity: 14,500 People.
5 times as much water Natural Gas: 42,300 People
as all the surrounding
cities within a 10 mile radius.

An additional 1.05 gallons will be required for CO2 capture. The total population of the
Ethanol Production, 195, is 2,162.
The plant draws it's water from an alluvial source. 61.2%
Don Johannsen
Appendix 107
ATTACHMENT W: Water usage charts for POET, Corning

Appendix 108
#19 POET Biorefining - Corning Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Corning, Iowa - -
POET Biorefining - Corning Plant 270 270 Without CO2 capture water requirement
1 Carbon 36 0.9 0.9 Water usage too small to require a permit
2 Mount Etna 50 1.3 1.3 Water usage too small to require a permit
3 Brooks 50 1.3 1.3 Water usage too small to require a permit
4 Nodaway 74 1.9 1.9 Water usage too small to require a permit
5 Prescott 191 4.9 4.9 Water usage too small to require a permit
6 Corning 1,564 40.0 40.0

Don Johannsen
Appendix 109
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Corning, Iowa - - - - City residential use assumes 70 gal./person/day
1 Carbon 36 0.9 0.9 0.2% Water usage too small to require a permit
2 Mount Etna 50 1.3 1.3 0.3% Water usage too small to require a permit
3 Brooks 50 1.3 1.3 0.3% Water usage too small to require a permit
4 Nodaway 74 1.9 1.9 0.5% Water usage too small to require a permit
5 Prescott 191 4.9 4.9 1.2% Water usage too small to require a permit
6 Corning 1564 40.0 40.0 9.6%

1.05
Don Johannsen
Appendix 110
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 111
#19 POET Biorefining Ethanol Plant (90 MGY) near Corning

Mount Etna, 1.3, 0.3% Brooks, 1.3, 0.3% Nodaway, 1.9, 0.5%
No permit cities: Carbon, 0.9, 0.2% Prescott, 4.9, 1.2%

Carbon
Mount Etna Ethanol Plant water Corning, 40.0, 9.6%
Brooks for CO2 Capture,
Nodaway 94.5, 22.8%
Prescott With the proposed CO2 capture
The plant will use nearly Corning Plant will use 88%
nine times as much water of the total water used by the
as all the cities in the plant and cities within the
surrounding 10 mile radius. surrounding 10 mile radius.
(314 square miles)
The city of Corning has a DNR

water permit for 500 MGY and With combined production and
a population of 1,564. CO2 capture the ethanol
This is 652 gal./day/ person - plant power and 2023 water
over 9 times the typical residential usage would be equivalent to:
water usage of 70 gal./ day.
It is assumed the city is using
water for other purposes.
3.0 gallons of water per gallon of ethanol for production.

An additional 1.05 gallons will be required for CO2 capture.
Ethanol plant water for The total population of the
This plant does not have a DNR water permit. Ethanol Production, 270, cities within the 10 mile radius
It is not known where this plant draws it's water from. 65.1% is 1,965.
Don Johannsen
Appendix 112
ATTACHMENT X: Water usage charts for POET, Emmetsburg

Appendix 113
#20 POET Biorefining - Emmetsburg Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Emmetsburg, Iowa - -
POET Biorefining - Emmetsburg Plant 350 211.1 Without CO2 capture water requirement
1 Rodman 31 0.8 0.8 Water usage too small to require a permit
2 Curlew 37 0.9 0.9 Water usage too small to require a permit
3 Cylinder 87 2.2 2.2 Water usage too small to require a permit
4 Ayrshire 133 3.4 3.4 Water usage too small to require a permit
5 Graettinger 832 21.3 21.3
6 Emmetsburg 3,706 94.7 94.7

Don Johannsen
Appendix 114
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Emmetsburg, Iowa - - - - City residential use assumes 70 gal./person/day
1 Rodman 31 0.8 0.8 Water usage too small to require a permit
2 Curlew 37 0.9 0.9 Water usage too small to require a permit
3 Cylinder 87 2.2 2.2 Water usage too small to require a permit
4 Ayrshire 133 3.4 3.4 Water usage too small to require a permit
No Permit 288 7.3584 7.3584 1.8%
5 Graettinger 832 21.3 21.3 5.2%
6 Emmetsburg 3706 94.7 94.7 23.3%

1.05
Don Johannsen
Appendix 115
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 116
#20 POET Biorefining Ethanol Plant (68 MGY) near Emmetsburg

No Permit cities: Ethanol Plant water No Permit, 7.3584, 1.8% Graettinger, 21.3, 5.2%
Rodman for CO2 Capture, Emmetsburg, 94.7, 23.3%
Curlew
Cylinder
Ayrshire
Emmetsburg Plant will use 70%
This plant will use over plant and cities within the
twice the water used surrounding 10 mile radius.
by all the cities in the (314 square miles)
surrounding 10 mile
radius. With combined production and
Emmetsburg reported 2023 plant power and 2023 water
water usage of 214 MGY and usage would be equivalent to:
a population of 3,706. Water: 11,100 people.
This is 158 gal./person/ day -
2.3 times the typical
residential water usage of
70 gal./ day.

Ethanol Production, is 4.826.
211.1, 52.0%
3.1 gallons of water per gallon of ethanol used for production. The plant draws it's water from the Cretaceous aquifer
An additional 1.05 gallons will be required for CO2 capture. This water level in this area has been stable since 2015
Don Johannsen
Appendix 117
ATTACHMENT Y: Water usage charts for POET, Fairbank

Appendix 118
#21 POET Biorefining - Fairbank Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Fairbank, Iowa - -
POET Biorefining - Fairbank Plant 578 396 Without CO2 capture water requirement
1 Littleton 50 1.3 1.3 Water usage too small to require a permit
2 Oran 50 1.3 1.3 Water usage too small to require a permit
3 Hazelton 713 18.2 18.2 Water usage too small to require a permit
4 Dunkerton 842 21.5 21.5
5 Readlyn 845 21.6 21.6
6 Fairbank 1,111 28.4 28.4 No DNR Water Permit
7 Jesup 2,508 64.1 64.1
8 Oelwein 5,920 151.3 151.3
Percentage of ethanol plant usage of total water usage 12039 65.3% 56.3%

Don Johannsen
Appendix 119
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Fairbank, Iowa - - - - City residential use assumes 70 gal./person/day
1 Littleton 50 1.3 1.3 Water usage too small to require a permit
2 Oran 50 1.3 1.3 Water usage too small to require a permit
3 Hazelton 713 18.2 18.2 Water usage too small to require a permit
No Permit 813 20.8 20.8 2.5%
4 Dunkerton 842 21.5 21.5 2.6%
5 Readlyn 845 21.6 21.6 2.6%
6 Fairbank 1111 28.4 28.4 3.4% No DNR Water Permit
7 Jesup 2508 64.1 64.1 7.6%
8 Oelwein 5920 151.3 151.3 18.0%

1.05
Don Johannsen
Appendix 120
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 121
#21 POET Biorefining - Fairbank Ethanol Plant (132 MGY) near Fairbank
No Permit, 20.8, 2.5% Dunkerton, 21.5, 2.6% Readlyn, 21.6, 2.6%
No Permit cities: Ethanol Plant water for

Fairbank, 28.4, 3.4%
Littleton CO2 Capture, 138.6,
Oran 16.5%
Jesup, 64.1, 7.6%
Hazelton

This plant will use almost
twice as much water as
Emmetsburg Plant will use 63%
all the surrounding cities
(314 square miles)
Ethanol plant water for With combined production and

Ethanol Production, 396, CO2 capture the ethanol
47.0% plant power and 2023 water
3.0 gallons of water per gallon of ethanol used for production. Oelwein, 151.3, 18.0% The total population of the
is 12,039.
Don Johannsen
Appendix 122
ATTACHMENT Z: Water usage charts for Valero, Fort Dodge

Appendix 123
#22 Valero Renewable Fuels Ethanol Fort Dodge Plant Energy and Water Usage
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Fort Dodge Iowa - -
Valero Renewable Fuels Fort Dodge 330 330 Without CO2 capture water requirement
1 Coalville 50 1.3 1.3 Water usage too small to require a permit
2 Kalo 50 1.3 1.3 Water usage too small to require a permit
3 Knierim 53 1.4 1.4
4 Clare 136 3.5 3.5
5 Moorland 168 4.3 4.3
6 Barnum 175 4.5 4.5
7 Callender 368 9.4 9.4
8 Otho 429 11.0 11.0
9 Fort Dodge 24,871 635.5 635.5

Don Johannsen
Appendix 124
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Fort Dodge Iowa - - - - City residential use assumes 70 gal./person/day
1 Coalville 50 1.3 1.3 Water usage too small to require a permit
2 Kalo 50 1.3 1.3 Water usage too small to require a permit
3 Knierim 53 1.4 1.4 Permit less than 5
4 Clare 136 3.5 3.5 Permit less than 5
5 Moorland 168 4.3 4.3 Permit less than 5
6 Barnum 175 4.5 4.5 Permit less than 5
No Permit 100 2.6 2.6 0%
Permits less than 5 MGY 532 13.6 13.6 1%
7 Callender 368 9.4 9.4 1%
8 Otho 429 11.0 11.0 1%
9 Fort Dodge 24871 635.5 635.5 57%
10 Ethanol plant water for Ethanol Production 330 330 30% Without CO2 Capture water requirement
11 Ethanol Plant water for CO2 Capture 115.5 115.5 10% Additional CO2 Capture water requirement
Total Plant and Towns 26300 1117.5 1117.5 100.00%
1.05
Total population within the 10 mile radius 26,300
Don Johannsen
Appendix 125
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 126
#22 Valero Renewable Fuels Ethanol Plant (110 MGY) near Fort Dodge
No Permit cities: Ethanol Plant No Permit, 2.6, 0.2% Permits less than 5 MGY, 13.6, 1.2%
Coalville water for CO2 Callender, 9.4, 0.8%
Kalo Capture, 115.5,
Less than 5 MGY 10.3% Otho, 11.0, 1.0%
Knerium
Clare With the proposed CO2 capture
Moorland system the Valero Renewable
Fuels Fort Dodge Plant will use
40% of the total water used by
the plant and cities within the
(314 square miles)
Ethanol Production, 330, With combined production and
29.5% CO2 capture the ethanol
The large use of water by Electricity: 24,600 People.
Fort Dodge overshadows Natural Gas: 71,500 People
any other use of water
in the area.
Fort Dodge, 635.5, 56.9% The total population of the
3.0 gallons of water per gallon of ethanol used for production. is 26,300
An additional 1.05 gallons is required for CO2 capture.
The plant draws it's water from the Fort Dodge city water system. Fort Dodge has a water permit value of 4,000 MGY and used
Fort Dodge gets it's water from the Mississippian Aquifer. 4,119 MGY in 2023. It uses 454 gal/person/day vs. typical 70.
Water level in this area is down more than 50 feet since 2015 It appears the city provides water to other industries.
Don Johannsen
Appendix 127
ATTACHMENT AA: Water usage charts for POET, Gowrie

Appendix 128
#23 POET Biorefining - Gowrie Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Gowrie, Iowa - -
POET Biorefining - Gowrie Plant 270 270 Without CO2 capture water requirement
1 Rinard 38 1.0 1.0 Water usage too small to require a permit
2 Burnside 50 1.3 1.3 Water usage too small to require a permit
3 Lanyon 50 1.3 1.3 Water usage too small to require a permit
4 Somers 128 3.3 3.3 Water usage too small to require a permit
5 Moorland 168 4.3 4.3
6 Harcourt 264 6.7 6.7
7 Callender 368 9.4 9.4
8 Farnhamville 383 9.8 9.8
9 Otho 429 11.0 11.0
10 Gowrie 952 24.3 24.3

Don Johannsen
Appendix 129
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Gowrie, Iowa - - - - City residential use assumes 70 gal./person/day
1 Rinard 38 1.0 1.0 Water usage too small to require a permit
2 Burnside 50 1.3 1.3 Water usage too small to require a permit
3 Lanyon 50 1.3 1.3 Water usage too small to require a permit
4 Somers 128 3.3 3.3 Water usage too small to require a permit
No Permit 266 6.8 6.8 1.6%
5 Moorland 168 4.3 4.3 1.0%
6 Harcourt 264 6.7 6.7 1.5%
7 Callender 368 9.4 9.4 2.2%
8 Farnhamville 383 9.8 9.8 2.2%
9 Otho 429 11.0 11.0 2.5%
10 Gowrie 952 24.3 24.3 5.6%
1.05
Don Johannsen
Appendix 130
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 131
#23 POET Biorefining - Gowrie Ethanol Plant (90 MGY) near Gowrie
Moorland, 4.3, 1.0% Harcourt, 6.7, 1.5% Callender, 9.4, 2.2%
No Permit cities:
Rinard Farnhamville, 9.8, 2.2%
Burnside No Permit, 6.8, 1.6% Otho, 11.0, 2.5%
Lanyon
Summers Gowrie, 24.3, 5.6%

CO2 Capture, 94.5, 21.6% With the proposed CO2 capture
Gowrie Plant will use 83%
(314 square miles)
This plant uses almost With combined production and

five times more water CO2 capture the ethanol
than all the surrounding plant power and 2023 water
cities within a 10 mile usage would be equivalent to:
radius. Water: 14,300 people.
3.0 gallons of water per gallon of ethanol used for production. Ethanol plant water for
An additional 1.05 gallons is required for CO2 capture. Ethanol Production, 270,
61.8% The total population of the
The plant does not have a DNR water permit.
It is not known where the plant draws it's water from.
is 2,830.
Don Johannsen
Appendix 132
ATTACHMENT BB: Water usage charts for POET, Hanlontown

Appendix 133
#24 POET Biorefining - Hanlontown Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Hanlontown, Iowa - -
POET Biorefining - Hanlontown Plant 245.0 240 Without CO2 capture water requirement
1 Hanlontown 206 5.3 5.3
2 Joice 208 5.3 5.3
3 Kensett 257 6.6 6.6
4 Fertile 305 7.8 7.8
5 Manly 1,256 32.1 32.1
6 Lake Mills 2,143 54.8 54.8
7 Clear lake 7,687 196.4 196.4

Don Johannsen
Appendix 134
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Hanlontown, Iowa - - - - City residential use assumes 70 gal./person/day
1 Hanlontown 206 5.3 5.3 0.8%
2 Joice 208 5.3 5.3 0.8%
3 Kensett 257 6.6 6.6 1.0%
4 Fertile 305 7.8 7.8 1.2%
5 Manly 1256 32.1 32.1 5.1%
6 Lake Mills 2143 54.8 54.8 8.7%
7 Clear lake 7687 196.4 196.4 31.1%

1.05
Don Johannsen
Appendix 135
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 136
#24 POET Biorefining Ethanol Plant (80 MGY) near Hanlontown

Joice, 5.3, 0.8% Kensett, 6.6, 1.0%
Hanlontown, 5.3, 0.8% Fertile, 7.8, 1.2%
Manly, 32.1, 5.1%

CO2 Capture, 84.0, 13.3% Lake Mills, 54.8, 8.7%

This plant uses as much Hanlontown Plant will use 51%
water as all the surrounding of the total water used by the
cities within a 10 mile radius plant and cities within the
(314 square miles)
Ethanol plant water for With combined production and

Ethanol Production, 240, CO2 capture the ethanol
38.0% plant power and 2023 water
3.0 gallons of water per gallon of ethanol used for production. Clear lake, 196.4, 31.1% The total population of the
An additional 1.05 gallons is required for CO2 capture. cities within the 10 mile radius
is 12,062.
This water level in this area are down as much as 30 feet since 2015
Don Johannsen
Appendix 137
ATTACHMENT CC: Water usage charts for Valero, Hartley

Appendix 138
#25 Valero Renewable Fuels - Hartley Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Hartley, Iowa - -
Valero Renewable Fuels - Hartley Plant 570 420 Without CO2 capture water requirement
1 May City 50 1.28 1.28 Water usage too small to require a permit
2 Moneta 50 1.28 1.28 Water usage too small to require a permit
3 Melvin 199 5.08 5.08 Water usage too small to require a permit
4 Everly 575 14.69 14.69
5 Primghar 896 22.89 22.89
6 Sanborn 1,392 35.57 35.57
7 Hartley 1,605 41.01 41.01

Don Johannsen
Appendix 139
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Hartley, Iowa - - - - City residential use assumes 70 gal./person/day
1 May City 50 1.3 1.3 Water usage too small to require a permit
2 Moneta 50 1.3 1.3 Water usage too small to require a permit
3 Melvin 199 5.1 5.1 Water usage too small to require a permit
No Permit 299 7.6 7.6 1.1%
4 Everly 575 14.7 14.7 2.1%
5 Primghar 896 22.9 22.9 3.3%
6 Sanborn 1392 35.6 35.6 5.2%
7 Hartley 1605 41.0 41.0 6.0%

1.05
Don Johannsen
Appendix 140
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 141
#25 Valero Renewable Fuels Ethanol Plant (140 MGY) near Hartley
No Permit cities: No Permit, 7.6, 1.1% Everly, 14.7, 2.1% Primghar, 22.9, 3.3%
May City Sanborn, 35.6, 5.2%
Moneta
Melvin Hartley, 41.0, 6.0%

21.3% Fuels Hartley Plant will use 82%
This plant uses four plant and cities within the
times as much water surrounding 10 mile radius.
as all the surrounding (314 square miles)
cities within a 10 mile
radius.

An additional 1.05 gallon is required for CO2 capture. Ethanol plant water for The total population of the
Ethanol Production, 420, cities within the 10 mile radius
The plant draws it's water from the Cretaceous aquifer. 61.0% is 4,767.
Don Johannsen
Appendix 142
ATTACHMENT DD: Water usage charts for POET, Hudson

Appendix 143
#26 POET Biorefining - Hudson S.D. Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Hudson, South Dakota - -
POET Biorefining, Hudson S.D. Plant 240 240 Without CO2 capture water requirement
1 Fairview SD 65 1.7 1.7 South Dakota
2 Hudson SD 329 8.4 8.4 South Dakota
3 Alcester SD 787 20.1 20.1 South Dakota
4 Hawarden 2,700 69.0 69.0
5 Rock Valley 4,059 103.7 103.7

Don Johannsen
Appendix 144
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Hudson, South Dakota - - - - City residential use assumes 70 gal./person/day
1 Fairview SD 65 1.7 1.7 0.3% South Dakota
2 Hudson SD 329 8.4 8.4 1.6% South Dakota
3 Alcester SD 787 20.1 20.1 3.8% South Dakota
4 Hawarden 2700 69.0 69.0 13.1%
5 Rock Valley 4059 103.7 103.7 19.7%

1.05
Don Johannsen
Appendix 145
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 146
#26 POET Biorefining Ethanol Plant (80 MGY) near Hudson South Dakota
Hudson SD, 8.4, 1.6% Alcester SD, 20.1, 3.8%
Fairview SD, 1.7, 0.3% Hawarden, 69.0, 13.1%

CO2 Capture, 84.0, 15.9%
Hudson Plant will use 61%
This plant uses 1.5 of the total water used by the
times as much water plant and cities within the
as all the surrounding surrounding 10 mile radius.
cities within a 10 (314 square miles)

Ethanol plant water for Water: 12,700 people.
Ethanol Production, 240, Electricity: 17,900 People.
45.6% Natural Gas: 52,000 People
Rock Valley, 103.7, 19.7%

3.0 gallons of water per gallon of ethanol is used for production. The total population of the
is 7,940.
It is not known where this plant draws it's water from.
Don Johannsen
Appendix 147
ATTACHMENT EE: Water usage charts for POET, Iowa Falls

Appendix 148
#27 POET Biorefining Iowa Falls Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Iowa Falls, Iowa - -
POET Biorefining Iowa Falls Plant 525.0 347.8 Without CO2 capture water requirement
2 Bradford 50 1.3 1.3 Water usage too small to require a permit
3 Popejoy 77 2.0 2.0 Water usage too small to require a permit
4 Alden 763 19.5 19.5
5 Iowa Falls 5,106 130.5 130.5

Don Johannsen
Appendix 149
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Iowa Falls, Iowa - - - - City residential use assumes 70 gal./person/day
1 Owasa 34 0.9 0.9 0.1% Water usage too small to require a permit
2 Bradford 50 1.3 1.3 0.2% Water usage too small to require a permit
3 Popejoy 77 2.0 2.0 0.3% Water usage too small to require a permit
4 Alden 763 19.5 19.5 3.1%
5 Iowa Falls 5106 130.5 130.5 21.1%

1.05
Don Johannsen
Appendix 150
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 151
#27 POET Biorefining Ethanol Plant (112 MGY) near Iowa Falls
Bradford, 1.3, 0.2% Popejoy, 2.0, 0.3%
No permit cities:
Owasa, 0.9, 0.1% Alden, 19.5, 3.1%
Owasa
Bradford Iowa Falls, 130.5, 21.1%
Popejoy

CO2 Capture, 117.6, system the POET Biorefining
19.0% Iowa Falls Plant will use 75%
Iowa Falls reported 2023 (314 square miles)
water usage of 332 MGY
and a population of 5,106.
This is 178 gal./day/ person With combined production and
- about 2.5 times the typical
residential water usage of
70 gal./ day.
Ethanol Production,
347.8, 56.1%
3.1 gallons of water per gallon of ethanol is used for production. This plant uses 3 times The total population of the
An additional 1.05 gallon is required for CO2 capture. as much water as all the cities within the 10 mile radius
surrounding cities within is 6,030.
The plant draws it's water from the Jordan aquifer. a 10 mile radius.
Don Johannsen
Appendix 152
ATTACHMENT FF: Water usage charts for POET, Jewell

Appendix 153
#28 POET Biorefining - Jewel Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Jewel. Iowa - -
POET Biorefining - Jewel Plant 270 270 Without CO2 capture water requirement
1 Randall 154 3.9 3.9
2 Kamrar 179 4.6 4.6 Water usage too small to require a permit
3 Stanhope 364 9.3 9.3
4 Radcliffe 555 14.2 14.2
5 Blairsburg 713 18.2 18.2
6 Jewell 1,216 31.1 31.1
7 Story City 3,352 85.6 85.6

Don Johannsen
Appendix 154
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Jewel. Iowa - - - - City residential use assumes 70 gal./person/day
1 Randall 154 3.9 3.9 0.7%
2 Kamrar 179 4.6 4.6 0.9% Water usage too small to require a permit
3 Stanhope 364 9.3 9.3 1.8%
4 Radcliffe 555 14.2 14.2 2.7%
5 Blairsburg 713 18.2 18.2 3.4%
6 Jewell 1216 31.1 31.1 5.8%
7 Story City 3352 85.6 85.6 16.1%

1.05
Don Johannsen
Appendix 155
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 156
#28 POET Biorefining Ethanol Plant (90 MGY) near Jewel

No permit cities:
Kamrar Kamrar, 4.6, 0.9% Stanhope, 9.3, 1.8% Radcliffe, 14.2, 2.7%
Blairsburg, 18.2, 3.4%
Randall, 3.9, 0.7%
Jewell, 31.1, 5.8%
CO2 Capture, 94.5, 17.8%

This plant will use 2.2 system the POET Biorefining
times as much water Jewel plant will use 69%
as all the cities within of the total water used by the
a 10 mile radius. plant and cities within the
(314 square miles)

Ethanol Production, 270,
50.8%
Story City, 85.6, 16.1% Natural Gas: 58,500 People
This plant does not have a DNR water permit. cities within the 10 mile radius
It is not known where this plant draws it's water from. is 6,533.
This water level in this area is down 30-40 feet since 2015
Don Johannsen
Appendix 157
ATTACHMENT GG: Water usage charts for Valero, Lakota

Appendix 158
#29 Valero Renewable Fuels - Lakota Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Lakota, Iowa - -
Valero Renewable Fuels Lakota Plant 330 330 Without CO2 capture water requirement
1 Pilot Grove Mn. 167 4.3 4.3 Minnesota Town
2 Elmore Mn. 549 14.0 14.0 Minnesota Town
3 Ledyard 121 3.1 3.1
4 Lakota 267 6.8 6.8
5 Swea City 566 14.5 14.5
6 Bancroft 699 17.9 17.9

Don Johannsen
Appendix 159
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Lakota, Iowa - - - - City residential use assumes 70 gal./person/day
1 Pilot Grove Mn. 167 4.3 4.3 0.8% Minnesota Town
2 Elmore Mn. 549 14.0 14.0 2.8% Minnesota Town
3 Ledyard 121 3.1 3.1 0.6%
4 Lakota 267 6.8 6.8 1.3%
5 Swea City 566 14.5 14.5 2.9%
6 Bancroft 699 17.9 17.9 3.5%

1.05
Don Johannsen
Appendix 160
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 161
#29 Valero Renewable Fuels Ethanol Plant (110 MGY) near Lakota
Elmore Mn., 14.0, 2.8% Ledyard, 3.1, 0.6% Lakota, 6.8, 1.3%
Pilot Grove Mn., 4.3, 0.8% Swea City, 14.5, 2.9%
Bancroft, 17.9, 3.5%

22.8% Fuels Lakota plant will use 88%
(314 square miles)
This plant uses over
7 times as much water
as all the surrounding With combined production and
cities within a 10 CO2 capture the ethanol
mile radius. plant power and 2023 water
3.0 gallons of water per gallon of ethanol is used for production. Ethanol plant water for The total population of the
An additional 1.05 gallon is required for CO2 capture. Ethanol Production, 330, cities within the 10 mile radius
65.2% is 2,369.
Don Johannsen
Appendix 162
ATTACHMENT HH: Water usage charts for POET, Menlo

Appendix 163
#30 POET Biorefining - Menlo Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Menlo, Iowa - -
POET Biorefining Menlo Plant 396.0 396.0 Without CO2 capture water requirement
1 Menlo 345 8.8 8.8 Water usage too small to require a permit
2 Casey 387 9.9 9.9
3 Dexter 640 16.4 16.4
4 Guthrie Center 1,593 40.7 40.7
5 Stuart 1,782 45.5 45.5

Don Johannsen
Appendix 164
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Menlo, Iowa - - - - City residential use assumes 70 gal./person/day
1 Menlo 345 8.8 8.8 1.3% Water usage too small to require a permit
2 Casey 387 9.9 9.9 1.5%
3 Dexter 640 16.4 16.4 2.5%
4 Guthrie Center 1593 40.7 40.7 6.2%
5 Stuart 1782 45.5 45.5 6.9%

1.05
Don Johannsen
Appendix 165
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 166
#30 POET Biorefining Ethanol Plant (132 MGY) near Menlo

No permit cities: Menlo, 8.8, 1.3% Casey, 9.9, 1.5% Dexter, 16.4, 2.5%
Menlo Guthrie Center, 40.7, 6.2%
Stuart, 45.5, 6.9%

CO2 Capture, 138.6,
21.1% With the proposed CO2 capture
Menlo plant will use 82%
This plant uses 4.5 plant and cities within the
times as much water surrounding 10 mile radius.
as all the surrounding (314 square miles)
cities within as 10
mile radius.
Ethanol plant water for Water: 20,900 people.
Ethanol Production, 396, Electricity: 29,500 People.
60.4% Natural Gas: 85,800 People

is 4,747.
This plant does not have a DNR water Permit. It is not know where
this plant draws it's water from. This water level in this area is
down as much as 30 feet since 2015
Don Johannsen
Appendix 167
ATTACHMENT II: Water usage charts for POET, Shell Rock

Appendix 168
#31 POET Biorefining - Shell Rock Ethanol Plant Energy and Water Usage vs. Cities within a 10 mile radius
Permit Water
Value Usage
MGY MGY
Ethanol Plant - Near Shell Rock, Iowa - -
POET Biorefining - Shell Rock Plant 578 393 Without CO2 capture water requirement
1 Finchford 50 1.3 1.3 Water usage too small to require a permit
2 Plainsfield 393 10.0 10.0 Water usage too small to require a permit
3 Allison 966 24.7 24.7
4 Janesville 1,034 26.4 26.4
5 Clarksville 1,264 32.3 32.3
6 Shell Rock 1,268 32.4 32.4
7 Waverly 10,394 265.6 265.6

Don Johannsen
Appendix 169
Permit Water Water
Value Usage Usage
MGY MGY % of Total
Ethanol Plant - Near Shell Rock, Iowa - - - - City residential use assumes 70 gal./person/day
1 Finchford 50 1.3 1.3 Water usage too small to require a permit
2 Plainsfield 393 10.0 10.0 Water usage too small to require a permit
No Permit 443 11.3 11.3 1.2%
3 Allison 966 24.7 24.7 2.7%
4 Janesville 1034 26.4 26.4 2.9%
5 Clarksville 1264 32.3 32.3 3.5%
6 Shell Rock 1268 32.4 32.4 3.5%
7 Waverly 10394 265.6 265.6 28.8%

1.05
Don Johannsen
Appendix 170
Water Use
Electricity Use
Natural Gas Use

Don Johannsen
Appendix 171
#31 POET Biorefining Ethanol Plant (131 MGY) near Shell Rock
No Permit cities: No Permit, 11.3, 1.2% Allison, 24.7, 2.7% Janesville, 26.4, 2.9%
Finchford
Clarksville, 32.3, 3.5%
Plainsfield
Shell Rock, 32.4, 3.5%

CO2 Capture, 137.6, system the POET Biorefining
14.9% Shell Rock plant will use 57%
The plant uses 1.3
times as much water
(314 square miles)
as all the surrounding
cities within a 10
mile radius.
Ethanol plant water for usage would be equivalent to:
Ethanol Production, Water: 20,800 people.
393.0, 42.6% Electricity: 29,300 People.
3.0 gallons of water per gallon of ethanol is used for production. The total population of the
Waverly, 265.6, 28.8%
is 15,369.
Don Johannsen

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WATER WOES: UNCOVERING THE TRUE COST

OF SUMMIT’S CARBON CAPTURE PROJECT

WATER USE IN IOWA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

AQUIFERS IN IOWA IMPACTED BY WATER WITHDRAWAL . . . . . . . . . . . 10

DNR REGULATIONS AND POLICIES ON WATER WITHDRAWAL . . . . . . . 14

PROTECTION OF IOWA’S WATER RESOURCES ARE AT RISK DUE

USE OF WATER BY ETHANOL PLANTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

WATER USE FOR CARBON CAPTURE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

IMPACT OF SUMMIT CARBON CAPTURE ON WATER USE . . . . . . . . . . . . 19

IMPACT OF SUSTAINABLE AVIATION FUEL FROM ETHANOL. . . . . . . . . 21

RECOMMENDATIONS FOR POLICIES AND ACTIONS. . . . . . . . . . . . . . . . . 22

ATTACHMENT A: DNR initial decision summary for Lawler

ATTACHMENT B: DNR initial decision summary for Goldfield

ATTACHMENT C: Summit Ethanol Plant 2023 Water Usage

ATTACHMENT D: Application form for water withdrawal . . . . . . . . . . . APP. 11

ATTACHMENT E: Water usage charts for Lakeview Plymouth

ATTACHMENT G: Water usage charts for Quad County Corn

ATTACHMENT H: Water usage charts for Little Sioux Corn

ATTACHMENT I: Water usage charts for Green Plains, Superior. . . . . . . APP. 37

ATTACHMENT J: Water usage charts for Louis Dreyfus,

ATTACHMENT K: Water usage charts for Corn LP, Goldfield . . . . . . . . APP. 47

ATTACHMENT L: Water usage charts for Golden Grain Energy,

ATTACHMENT M: Water usage charts for Absolute Energy,

ATTACHMENT N: Water usage charts for Homeland Energy,

ATTACHMENT O: Water usage charts for Pine Lake Corn Processors,

ATTACHMENT P: Water usage charts for Siouxland Energy,

ATTACHMENT Q: Water usage charts for Lincolnway Energy,

ATTACHMENT R: Water usage charts for Valero, Albert City . . . . . . . . APP. 82

ATTACHMENT S: Water usage charts for POET, Arthur. . . . . . . . . . . . . APP. 87

ATTACHMENT T: Water usage charts for POET, Ashton . . . . . . . . . . . . APP. 92

ATTACHMENT U: Water usage charts for Valero, Charles City . . . . . . . APP. 97

ATTACHMENT W: Water usage charts for POET, Corning . . . . . . . . . . APP. 107

ATTACHMENT Y: Water usage charts for POET, Fairbank . . . . . . . . . . APP. 117

Iowa has four major aquifers: Cretaceous (Dakota), Mississippian, Silurian-Devonian,

From Iowa DNR stakeholder presentation, July 19, 2023.4

Use Category Percent DNR Adjustment Water usage Aquifer Alluvial

AQUIFERS IN IOWA IMPACTED BY WATER WITHDRAWAL

8 Update for Jordan Aquifer Stakeholders (2020), available at

11 567 Iowa Administrative Code § 52.4(3)

DNR REGULATIONS AND POLICIES ON WATER WITHDRAWAL

Section 455B.262 of the Iowa Code states:

It is recognized that . . . the orderly development, wise use, protection, and

12 Schilling, et al., Estimating groundwater age in the Cambrian-Ordovician aquifer in Iowa:

DNR regulation 50.1 states:

PROTECTION OF IOWA’S WATER RESOURCES ARE AT RISK DUE TO THE

15 See, for example, Attachment A.

USE OF WATER BY ETHANOL PLANTS

IMPACT OF SUMMIT CARBON CAPTURE ON WATER USE

25 Illinois State Geological Survey Circular 595 (2018), available at

RECOMMENDATIONS FOR POLICIES AND ACTIONS

ATTACHMENT A: DNR initial decision summary for Lawler Carbon Capture

ATTACHMENT B: DNR initial decision summary for Goldfield Carbon Capture

ATTACHMENT C: Summit Ethanol Plant 2023 Water Usage Spreadsheet

ATTACHMENT D: Application form for water withdrawal

ATTACHMENT E: Water usage charts for Lakeview Plymouth Energy, Merill

Conclusion: Without CO2 Capture

Natural Gas Use

Ethanol Plant water for

With combined production and