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Eric Schaeffer


Medium CAFO = 300-999 Cattle, 200-699 Dairy Cattle, 750-2499 Swine (over 55 lbs) ... CAFO = less than 300 Cattle, less than 200 Dairy Cattle, less than 750 Swine ... – PowerPoint PPT presentation

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Title: Eric Schaeffer

Clean Water Network (CWN) CAFO Briefing
  • Eric Schaeffer
  • Environmental Integrity Project
  • June 2, 2009

Animal Feeding Operations (AFOs)
  • Animal Feeding operation
  • Agricultural operation where animals are
    kept/raised in confinement animals are confined
    for at least 45 days in a 12-month period and
    there is no grass/vegetation in the confinement
    area during the normal growing season.
  • (http//

Concentrated Animal Feeding Operations (CAFOs)
  • A CAFO is an AFO that meets certain size
    requirements (here are a few examples)
  • Large CAFO 1,000 or more Cattle 700 or more
    Dairy Cattle 2,500 or more Swine (over 55 lbs),
    10,000 or more Swine (under 55 lbs).
  • Medium CAFO 300-999 Cattle, 200-699 Dairy
    Cattle, 750-2499 Swine (over 55 lbs), 3,000-9,999
    Swine (under 55 lbs).
  • Small CAFO less than 300 Cattle, less than 200
    Dairy Cattle, less than 750 Swine (over 55 lbs),
    less than 3,000 Swine (under 55 lbs).
  • (http//

CAFOs are Widespread in the United States
  • According to the epa
  • There are 19,000 medium and large CAFOs in the
    U.S and 75 of these may need NPDES permits.
  • However, only 9,000 or 47 of these have NPDES
    permits (as of March, 2009).
  • (http//
    rs/civil/enfalert/cafo-alert09.pdf at p.2).

CAFOs Impact Water Quality
  • CAFOs discharge nutrient rich manure into surface
    waters, resulting in surface water impairment.
  • States are required to keep a list of all
    impaired waters in the state (http//
    wow/tmdl/intro.html) and to submit a report to
    EPA on state water quality. (See CWA sections
    303(d) and 305(b)(1) respectively).
  • States frequently attribute impaired water
    quality to agriculture and to animal feeding
    operations in particular.

CAFOs Impact Water Quality
  • In Illinois, Animal Feeding Operations are listed
    as a potential source of stream impairment in 634
    stream miles throughout the state and agriculture
    is listed as a potential source of impairment of
    2,092 acres of inland lakes.
  • Michigan attributes 1,407 miles of impairment in
    rivers/streams to animal feeding/handling under
    the category of agriculture.
  • From state CWA 305(b) reports including impaired
    waters listed under 303(d).

Legal Authority for Regulating CAFO Discharges
into Waters of the United States
  • statute
  • The Clean Water Act (CWA) is the primary statute
    that covers discharges from CAFOs and CAFO
  • Regulation
  • CAFOs are regulated under EPA CAFO rules. After
    a long history of legal action, the final 2008
    Final CAFO rule is now in effect.

2008 Final CAFO Rule
  • Who must obtain a permit
  • 1) If CAFO discharges or proposes to discharge,
    then CAFO is required to apply for an NPDES
    permit. 2008 Final CAFO Rule at 70423.
  • 2) A CAFO can certify that it does not propose to
    discharge. Id. at 70426.
  • Revised National Pollutant Discharge Elimination
    System Permit Regulation and Effluent Limitations
    Guidelines for Concentrated Animal Feeding
    Operations in Response to the Waterkeeper
    Decision, 40 CFR Parts 9, 122 and 412, Vol. 73,
    No. 225 available at http//
    o/cafofinalrule.cfm hereinafter 2008 Final CAFO

2008 Final CAFO Rule
  • Proposal to discharge
  • CAFO proposes to discharge if based on an
    objective assessment it is designed, constructed,
    operated, or maintained such that a discharge
    will occur, not simply such that it might occur.
    Id. at 70423.

2008 Final CAFO RuleVoluntary Certification
  • no discharge Certification
  • A CAFO has the option to certify that it does
    not discharge or propose to discharge. This is
    completely voluntary. Id. at 70426.
  • Difference between uncertified and certified CAFO
  • A CAFO that does not certify and has a discharge
    is liable for the discharge (violation of Clean
    Water Act) failure to apply for a permit
    (permit application requirements). Id.
  • A CAFO that certifies and discharges is only
    liable for the discharge under the Clean Water
    Act. Id.

Air Emissions From CAFOs Are Significant
  • Based on EPA Estimates
  • The Poultry industry alone released an estimated
    700 million tons of ammonia to air in 2007-more
    than all other non-agricultural industries
  • Broiler producers in the top ten states released
    nearly 500 million pounds of ammonia- more than 8
    times the combined total reported to the toxics
    release inventory (TRI) by all industrial
  • This data is based on scientific studies cited to
    in EIPs report online (http//www.environmentalin

CAFO Ammonia Emissions Can Exceed OSHA Limits
  • OSHA limits ammonia emissions to 25 parts per
    million (ppm) over an 8 hour average/35ppm over a
    15 minute period.
  • Studies at tysons Broiler operations and at an
    Indiana egg laying operation measured ammonia
    above both short and long term osha levels.
  • (http//

Ammonia Emissions Affect Public Health
  • Ammonia is toxic and exposure to ammonia
    irritates the eyes, skin, throat, and lungs.
  • For more detail on the public health effects of
    ammonia, see the ATSDR toxicological profile for
    ammonia at http//

Ammonia Emitted by Broiler Operations (2007)
Ammonia Emitted by Egg Laying Operations (2007)
From the Illinois Citizens for Clean Air Water
(ICCAW), DeClerk CAFO, Mercer County,
IllinoisDischarge-in-ProgressLagoon discharging
into stream via berm wall
  • ..

From ICCAW, Northwest Illini Beef CAFO, Carroll
County, IllinoisDischarge about to happen Land
application area, lagoon, and feedlot adjacent to
Straddle Creek
From ICCAW, Northwest Illini Beef CAFO, Carroll
County, IllinoisDifferent View- note the large
surface waterway parallel to the lagoon and
intersecting with Straddle Creek.
From the Assateague Coastal Trust and the
Assateague COASTKEEPERPrincess Anne, MD,
February 5, 2009Poultry CAFOs Surround
Residential Street