United States Government Accountability Office

GAO Testimony 

Before the Subcommittee on Environment 

and Hazardous Materials, Committee on 

Energy and Commerce, House of 

Representatives

CONCENTRATED ANIMAL 

FEEDING OPERATIONS 

EPA Needs More 

Information and a Clearly 

Defined Strategy to Protect 

Air and Water Quality 

Statement of Anu K. Mittal, Director 

Natural Resources and Environment 

For Release on Delivery

Expected at 10:00 a.m. EDT 

Wednesday, September 24, 2008

 

GAO-08-1177T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 24, 2008

CONCENTRATED ANIMAL FEEDING 

OPERATIONS 

EPA Needs More Information and a Clearly Defined 

Strategy to More Effectively Protect Air and Water 

Quality 

Highlights of GAO-08-1177T, a testimony 

before the Subcommittee on Environment 

and Hazardous Materials, Committee on 

Energy and Commerce, House of 

Representatives 

Concentrated animal feeding 

operations (CAFO) are large 

livestock and poultry operations 

that raise animals in a confined 

situation. CAFOs may improve the

efficiency of animal production, 

but the large amounts of manure 

they produce can, if improperly 

managed, degrade air and water

quality. The Environmental 

Protection Agency (EPA) regulates

CAFOs and requires CAFOs that

discharge certain pollutants to

obtain a permit. 

This testimony summarizes the 

findings of a September 4, 2008

GAO report (GAO-08-944) on (1) 

trends in CAFOs, (2) amounts of 

waste they generate, (3) findings of 

key research on CAFOs’ health and 

environmental impacts, (4) 

progress made in developing CAFO 

air emissions protocols, and (5) the 

effect of recent court decisions on

EPA’s regulation of CAFO water 

pollutants. GAO analyzed U.S.

Department of Agriculture’s 

(USDA) data from 1982 through 

2002 for large farms as a proxy for 

CAFOs; reviewed studies, EPA 

documents, laws, and regulations, 

and obtained the views of federal

and state officials. 

What GAO Recommends

In the September 2008 report, GAO 

recommended that EPA complete

its inventory of permitted CAFOs, 

reassess the air emissions 

monitoring study, and establish a 

strategy and timetable for 

developing a process-based model 

for measuring CAFO air emissions. 

EPA partially agreed with GAO’s 

recommendations. 

Because no federal agency collects accurate and consistent data on the 

number, size, and location of CAFOs, GAO could not determine the exact 

trends for these operations. However, using USDA data for large farms that 

raise animals as a proxy for CAFOs, it appears that the number of these 

operations increased by about 230 percent, from about 3,600 in 1982 to almost 

12,000 in 2002. The number of animals raised on large farms also increased 

during this 20-year period, but the rate of increase varied by animal type. 

Moreover, EPA does not have comprehensive, accurate data on the number of 

permitted CAFOs nationwide. As a result, the agency does not have the

information that it needs to effectively regulate these CAFOs. EPA is

currently working with the states to establish a new national data base. 

The amount of manure generated by large farms that raise animals depends on

the type and number of animals raised, but these operations can produce from

2,800 tons to 1.6 million tons of manure a year. Some large farms that raise 

animals can generate more manure annually than the sanitary waste produced 

by some U.S. cities. Manure can be used beneficially to fertilize crops; but 

according to some agricultural experts, when animal feeding operations are

clustered in certain geographic areas, the manure they produce may not be 

effectively used as fertilizer on adjacent cropland and could increase the 

potential of pollutants reaching nearby waters and degrading water quality. 

Since 2002, at least 68 government-sponsored or peer-reviewed studies have 

been completed that examined air and water quality issues associated with 

animal feeding operations and 15 have directly linked air and water pollutants 

from animal waste to specific health or environmental impacts. EPA has not 

yet assessed the extent to which pollutants from animal feeding operations 

may be impairing human health and the environment because it lacks key data 

on the amount of pollutants being discharged by these operations. 

Considered a first step in developing air emission protocols for animal feeding 

operations, a 2-year nationwide air emission monitoring study, largely funded 

by the industry, was initiated in 2007. However, the study, as currently 

structured, may not provide the scientific and statistically valid data it was 

intended to provide and that EPA needs to develop these protocols. In 

addition, EPA has not yet established a strategy or timetable for developing a 

more sophisticated process-based model that considers the interaction and 

implications of all emission sources at an animal feeding operation. 

Two recent federal court decisions have affected EPA’s ability to regulate

water pollutants discharged by CAFOs. The 2005 Waterkeeper decision 

required EPA to abandon the approach that it had proposed for regulating 

CAFOs in 2003. Similarly, the Rapanos decision has complicated EPA’s 

enforcement of CAFO discharges because EPA believes that it must now 

gather more evidence to establish which waters are subject to the Clean Water 

Act’s permitting requirements. 

To view the full product, including the scope 

and methodology, click on GAO-08-1177T. 

For more information, contact Anu K. Mittal, 

(202) 512-3841, mittala@gao.gov. 
Concentrated Animal Feeding Operations

Mr. Chairman and Members of the Subcommittee: 

We are pleased to be here today to discuss our recently issued report on 

concentrated animal feeding operations (CAFO).1

 As you know, CAFOs 

are large animal livestock and poultry operations that raise animals in 

confined situations. While CAFOs have improved the efficiency of the

animal production industry, they have also raised environmental and 

health concerns because the large amounts of manure they can produce, if 

not properly managed, may degrade air and water quality. Animal manure 

can be, and frequently is, used beneficially on farms to fertilize crops and 

restore nutrients to soil. However, if manure and wastewater from animal 

feeding operations are improperly managed, pollutants such as nitrogen, 

phosphorus, bacteria, and organic matter could enter nearby water bodies 

and could potentially impair human health and damage the environment. 

Improperly managed manure can also result in emissions to the air of 

particles and gases, such as ammonia and hydrogen sulfide, which could

also result in potentially harmful environmental and human health effects. 

The Environmental Protection Agency (EPA) has the authority under 

several federal laws to regulate water and air pollutants from CAFOs. EPA 

has specific authority under the Clean Water Act to regulate CAFOs like 

any other industry if they discharge into federally regulated waters.2

 Such 

CAFOs must obtain permits, from EPA or the states that EPA has 

authorized to administer this act, that stipulate how they will manage their 

discharges. In contrast, three other laws—the Clean Air Act, the 

Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERLCA), and the Emergency Planning and Community Right-toKnow Act of 1986 (EPCRA)—while not specifically citing CAFOs as 

regulated entities, provide EPA with certain authorities related to air 

emissions from these operations. 

Our testimony today summarizes the following five issues that we 

examined in our recent report: (1) trends in CAFOs; (2) the amount of 

waste they generate; (3) the findings of recent key academic, industry, and 

government research on the impacts of air and water pollutants from 

 1

GAO, Concentrated Animal Feeding Operations: EPA Needs More Information and a

Clearly Defined Strategy to Protect Air and Water Quality from Pollutants of Concern,

GAO-08-944 (Washington, D.C.: Sept. 4, 2008).

2

Section 502(14) of the Clean Water Act specifically defines point sources of pollution to 

include CAFOs. 

Page 1 GAO-08-1177T 
Concentrated Animal Feeding Operations

CAFOs on human health and the environment, and the extent to which 

EPA has assessed the nature and severity of such impacts; (4) the progress

that EPA and the states have made in regulating and controlling the 

emissions of, and in developing protocols to measure, air pollutants from 

CAFOs that could affect air quality; and (5) the extent to which recent 

court decisions have affected EPA and the states’ ability to regulate CAFO 

discharges that impair water quality. In conducting this work, we reviewed 

laws and regulations, federal and state agencies’ documents, and met with 

officials from EPA and the U.S. Department of Agriculture (USDA), 

industry, citizen and environmental groups, and academia. We also spoke 

with state officials and visited CAFOs in eight states.3

 In addition, we 

analyzed USDA data for large farms as a proxy for CAFOs, conducted 

library and Internet searches to identify key studies completed since 2002

on air and water pollutants from animal waste, and contacted state 

officials in all 50 states to determine which states had developed air 

emission regulations applicable to CAFOs and how recent court decisions 

had affected their ability to regulate CAFO discharges that impair water 

quality. We conducted our work between July 2007 and August 2008 in

accordance with generally government auditing standards. These 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe the evidence 

obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

In summary we found the following:

• Determining the trends in the number of CAFOs over time is difficult 

because no federal agency collects consistent, reliable data on CAFOs. 

However, USDA data for large farms that raise animals can serve as a 

proxy for estimating trends in the number and size of CAFOs. Using these 

data, we found that the number of these operations appears to have 

increased by about 230 percent from 1982 through 2002, from about 3,600 

to almost 12,000. Moreover, the number of animals per farm increased, but

the increase varied by animal type, with hog farms showing the largest 

increase at 37 percent. Although EPA has been compiling data from its 

regional offices in an effort to develop information on the number of 

permitted CAFOs nationwide, we found that the data are inconsistent and 

inaccurate and do not provide necessary information on the number and 

 3

These states were Arkansas, California, Colorado, Iowa, Maryland, Minnesota, North

Carolina, and Texas. 

Page 2 GAO-08-1177T 
Concentrated Animal Feeding Operations

characteristics of permitted CAFOs. We recommended that the agency

develop a complete and accurate inventory of permitted CAFOs and 

incorporate appropriate internal controls to ensure the quality of the data. 

EPA concurred with this recommendation and stated that it is currently 

working with its regional offices and the states to develop and implement 

a national data system to collect and record facility-specific information 

on permitted CAFOs. 

• While the amount of manure generated by large farms that raise animals 

depends on the type and number of animals raised, such farms can 

produce from over 2,800 tons to more than 1.6 million tons of manure a 

year. In order to provide a perspective on how much manure these 

operations produce, we compared the manure from some large farms that 

raise animals with sanitary waste produced by the populations of some 

U.S. cities. For example, a very large hog farm raising as many as 800,000 

hogs—of which there are at least two in the United States—could generate

more than 1.6 million tons of manure annually, or more than one-and-ahalf times the sanitary wastes produced by the about 1.5 million residents 

of Philadelphia, Pennsylvania. While we recognize that manure can be a

valuable resource used as fertilizer, some agricultural experts and 

government officials have raised concerns about the amount of manure 

produced by large feeding operations located within a specific geographic 

area. When such clustering of large operations occurs, the manure they

produce may not be effectively used as fertilizer on adjacent cropland and 

could increase the potential for pollutants to reach nearby waters and 

degrade water quality. 

• At least 68 government-sponsored or peer-reviewed studies have been 

completed on air and water pollutants from animal feeding operations 

since 2002. Of these 68 studies, 15 directly linked air and water pollutants 

from animal waste to specific health or environmental impacts, 7 found no

impacts on human health and the environment, and 12 identified indirect 

linkages. Thirty-four other studies focused on measuring the amount of 

water or air pollutants from animal feeding operations that are known to 

cause harm to humans or the environment. However, EPA has not yet 

assessed the extent to which air and water pollutants from CAFOs may be 

impairing human health and the environment because it lacks key 

information on the amount of pollutants discharged by these operations. 

• The ongoing national air emissions monitoring study is considered a first 

step in developing protocols for measuring and quantifying air pollutants 

emitted by animal feeding operations. While EPA believes that this 2-year 

study, initiated in 2007, will provide a scientific basis for estimating air 

emissions from animal feeding operations, concerns have been raised that 

Page 3 GAO-08-1177T 
Concentrated Animal Feeding Operations

the study, as currently structured, may not provide EPA with the scientific

and statistically valid data that it needs to develop these protocols. For 

example, the study does not include all of the combinations of animal 

types and geographic regional pairings recommended by EPA’s expert 

panel that would be representative of the animal feeding operations in the

United States. Furthermore, EPA has not yet established a strategy or 

timetable for developing a more sophisticated process-based model that 

the National Academy of Sciences believed is needed to ensure that the

interaction and implications of all emission sources at an animal feeding

operation are accounted for. Finally, some EPA actions have made it 

unclear at this time how the agency intends to regulate air emissions from 

animal feeding operations once the current air emissions study is 

complete. For instance, EPA has not decided if it will aggregate the 

emissions occurring on an animal feeding operation or if the emissions 

from barns and manure storage areas will be considered separately when 

determining if an operation has exceeded air emissions thresholds. 

Moreover, in December 2007, EPA proposed a rule to exempt all releases 

of hazardous substances, such as ammonia and hydrogen sulfide, to the air 

from manure on farms, including animal feeding operations, from 

reporting requirements of certain federal laws. We recommended that

EPA take a number of actions to address the concerns that we identified 

with the ongoing air emissions study. EPA partially agreed with our 

recommendations and described a number of actions that it has underway 

to address them. 

• Two recent federal court decisions have affected EPA’s ability to regulate 

water pollutants discharged by CAFOs. First, in the 2005 Waterkeeper 

Alliance Inc. v. EPA decision, the U.S. Court of Appeals for the Second

Circuit set aside a key provision of a CAFO rule EPA had issued in 2003.

This rule would have provided EPA with comprehensive information on 

the universe of CAFOs and their operations and would have subjected a 

large number of previously unregulated CAFOs to monitoring and 

reporting requirements as well as periodic inspections. However, the court 

concluded that EPA did not have the authority under the Clean Water Act 

to require CAFOs that were not discharging, or proposing to discharge, 

pollutants into federally regulated waters to apply for permits. The 

decision has forced EPA to revise its 2003 rule for permitting CAFOs and 

return to its approach in which CAFO operators determine for themselves 

whether they need to apply for a federal permit. To help identify 

unpermitted discharges, EPA must rely on other means to acquire 

information about CAFOs that are illegally discharging pollutants, such as

following up on citizen reports of potential pollutants. Second, the 2006 

Supreme Court decision—Rapanos v. United States—has complicated 

EPA’s enforcement of CAFO discharges. This decision has made 

Page 4 GAO-08-1177T 
Concentrated Animal Feeding Operations

determination of Clean Water Act jurisdiction over certain types of waters 

more complex and, according to EPA, has required the agency to gather 

significantly more evidence to establish which waters are considered 

federal waters and subject to the Clean Water Act’s permitting

requirements. EPA enforcement officials told us that since the Rapanos

decision the agency may be less likely to take enforcement actions since it 

may be more difficult to prove that a water body is federally regulated.

The livestock and poultry industry is vital to our nation’s economy, 

supplying meat, milk, eggs, and other animal products. However, the past 

several decades have seen substantial changes in America’s animal 

production industries. As a result of domestic and export market forces, 

technological changes, and industry adaptations, food animal production

that was integrated with crop production has given way to fewer, larger 

farms that raise animals in confined situations. These large-scale animal 

production facilities are generally referred to as animal feeding operations. 

CAFOs are a subset of animal feeding operations and generally operate on

a much larger scale. 

Most agricultural activities are considered to be nonpoint sources of 

pollution because the pollution that occurs is in conjunction with soil 

erosion caused by water and surface runoff of rain or snowmelt from 

diffuse areas such as farms or rangeland. However, the Clean Water Act 

specifically designates point sources of pollution to include CAFOs, which 

means that under the act, CAFOs that discharge into federally regulated

waters are required to obtain a National Pollutant Discharge Elimination 

System (NPDES) permit. These permits generally allow a point source to

discharge specified pollutants into federally regulated waters under 

specific limits and conditions. EPA, or the states that EPA has authorized 

to administer the Clean Water Act, are responsible for issuing these 

permits.4

In accordance with the Clean Water Act’s designation of CAFOs as point 

sources, EPA defined which poultry and livestock facilities constituted a 

CAFO and established permitting requirements for CAFOs. According to 

EPA regulations, first issued in 1976, to be considered a CAFO a facility 

Background 

 4

Currently, 45 states are authorized to administer the NPDES permit program and their

programs must be at least as stringent as the federal program. EPA has retained program

authority for Alaska, Idaho, Massachusetts, New Hampshire, and New Mexico. Oklahoma 

has been authorized to issue permits for most sources, but not CAFOs. 

Page 5 GAO-08-1177T 
Concentrated Animal Feeding Operations

must first be considered an animal feeding operation. Animal feeding 

operations are agricultural operations where the following conditions are 

met: 

• animals are fed or maintained in a confined situation for a total of 45 days

or more in any 12-month period, and

• crops, vegetation, forage growth, or post harvest residues are not 

sustained during normal growing seasons over any portion of the lot. 

If an animal feeding operation met EPA’s criteria and met or exceed

minimum size thresholds based on the type of animal being raised, EPA 

considered the operation to be a CAFO. For example, an animal feeding 

operation would be considered a CAFO if it raised 1,000 or more beef 

cattle, 2,500 pigs weighing more than 55 pounds, or 125,000 chickens.5

 In 

addition, EPA can designate an animal feeding operation of any size as a 

CAFO if it meets certain criteria, such as being a significant contributor of 

pollutants to federally regulated waters.6

In January 2003, we reported that although EPA believed that many animal 

feeding operations degrade water quality, it had placed little emphasis on 

its permit program and that exemptions in its regulations allowed as many 

as 60 percent of the largest operations to avoid obtaining permits.7

 In its 

response to our 2003 report, EPA acknowledged that the CAFO program 

was hampered by outdated regulations. The agency subsequently revised 

its permitting regulations for CAFOs to eliminate the exemptions that 

allowed most animal feeding operations to avoid regulation. The revisions, 

issued in February 2003, also known as the 2003 CAFO rule, resulted, in 

part, from the settlement of a 1989 lawsuit by the Natural Resources 

Defense Council and Public Citizen. These groups alleged that EPA had 

failed to comply with the Clean Water Act. EPA’s 2003 CAFO Rule 

included the following key provisions: 

 5

40 C.F.R. § 122.23(b). 

6

Federally regulated waterways include waters of the United States as defined in 33 C.F.R. 

§328.3(a)(1)-(7) and may include rivers, wetlands, impoundments, the territorial seas, 

andwaters used in interstate commerce. 

7

GAO, Livestock Agriculture: Increased EPA Oversight Will Improve Environmental

Program for Concentrated Animal Feeding Operations, GAO-03-285 (Washington, D.C.: 

Jan. 16, 2003). 

Page 6 GAO-08-1177T 
Concentrated Animal Feeding Operations

• Duty to apply. All CAFOs were required to apply for a permit under the 

Clean Water Act unless the permitting authority determined that the CAFO 

had no potential to discharge to federally regulated waters. 

• Expanded CAFO definitions. All types of poultry operations, as well as all

stand-alone operations raising immature animals, were included in the 

2003 CAFO Rule. 

• More stringent design standard for new facilities in the swine, poultry,

and veal categories. The 2003 rule established a no-discharge standard for 

new facilities that could be met if they were designed, constructed, and 

operated to contain the runoff from a 100-year, 24-hour storm event. 

• Best management practices. Operations were required to implement best 

management practices for applying manure to cropland and for animal 

production areas. 

• Nutrient management plans. CAFO operations were required to develop a 

plan for managing the nutrient content of animal manure as well as the 

wastewater resulting from CAFO operations, such as water used to flush 

manure from barns. 

• Compliance schedule. The 2003 rule required newly defined CAFOs to 

apply for permits by April 2006 and existing CAFOs to develop and 

implement nutrient management plans by December 31, 2006.

8

According to EPA officials, the 2003 rule was expected to ultimately lead 

to better water quality because the revised regulations would extend 

coverage to more animal feeding operations that could potentially 

discharge and contaminate water bodies and subject these operations to 

periodic inspections. 

Three laws provide EPA with certain authorities related to air emissions 

from animal feeding operations, but, unlike the Clean Water Act, they do 

not specifically cite CAFOs as regulated entities. The Clean Air Act9

regulates any animal feeding operation, regardless of size, that exceeds 

established air emission thresholds for certain pollutants. For example, in

certain specific situations, hydrogen sulfide, ammonia, or particulate 

 8

In July 2007, EPA extended these deadlines to February 27, 2009. 

9

The Clean Air Act, 42 U.S.C. §§7401-7671q. 

Page 7 GAO-08-1177T 
Concentrated Animal Feeding Operations

matter may be regulated. In addition, Section 103 of CERCLA and Section 

304 of EPCRA10 require owners or operators of a facility to report to 

federal, state, or local authorities when a “reportable quantity” of certain

hazardous substances, such as hydrogen sulfide or ammonia,11 is released 

into the environment. Together, CERCLA’s and EPCRA’s reporting 

requirements provide government authorities, emergency management 

agencies, and citizens the ability to know about the source and magnitude 

of hazardous releases. 

EPA also works with USDA to address the impacts of animal feeding 

operations on air and water quality and human health. In 1998, EPA 

entered into a memorandum of understanding with USDA that calls for the 

agencies to coordinate on air quality issues related to agriculture and 

share information. In addition, in 1999, the two agencies issued a unified

national strategy aimed at having the owners and operators of animal 

feeding operations take actions to minimize water pollution from 

confinement facilities and land application of manure. To help minimize 

water pollution from animal feeding operations and meet EPA’s regulatory 

requirements, USDA, through its Natural Resources Conservation Service, 

provides financial and technical service to CAFO operators in developing

and implementing nutrient management plans. 

Because no federal agency collects accurate and consistent data on the

number, size, and location of CAFOs, it is difficult to determine precise 

trends in CAFOs. According to USDA officials, the data USDA collects for 

large farms raising animals can be used as a proxy for estimating trends in

CAFOs nationwide. Using these data, we determined the following: 

• Between 1982 and 2002, the number of large farms raising animals 

increased from about 3,600 to almost 12,000, or by about 234 percent. 

Growth rates varied dramatically by animal type. For instance, broiler 

chickens farms showed the largest increase, almost 1,200 percent, 

followed by hogs at more than 500 percent. In comparison, beef cattle 

farms grew by only 2 percent and layer chicken farms actually declined by

2 percent. 

The Number of Large 

Farms Raising 

Animals Has 

Increased, but 

Specific Data on 

CAFOs Are Not 

Available 

 10CERCLA, Pub. L. No. 96-510, 94 Stat. 2767 (codified as amended at 42 U.S.C. §§9601-

9675)and EPCRA, Pub. L. No. 99-499, Tit. III, 100 Stat. 1728 (codified as amended at 42

U.S.C. §§11001-11050). 

11Each of these hazardous substances has a reportable quantity of 100 pounds in a 24-hour

period. 

Page 8 GAO-08-1177T 
Concentrated Animal Feeding Operations

• The size of these farms also increased between 1982 and 2002. The layer 

and hog sectors had the largest increases in the median number of animals 

raised per farm, both growing by 37 percent between 1982 and 2002. In 

contrast, large farms that raised either broilers or turkeys only increased 

slightly in size, by 3 and 1 percent, respectively, from 1982 to 2002. 

• The number of animals raised on large farms increased from over 257 

million in 1982 to over 890 million in 2002—an increase of 246 percent. 

Moreover, most of the beef cattle, hogs, and layers raised in the United 

States in 2002 were raised on large farms. Specifically, 77 percent of beef 

cattle and 72 percent of both hogs and layers were raised on large farms. 

We also found that EPA does not systematically collect nationwide data to

determine the number, size, and location of CAFOs that have been issued

permits nationwide. Instead, since 2003, the agency has compiled quarterly 

estimates obtained from its regional offices or the states on the number 

and types of CAFOs that have been issued permits. However, these data 

are inconsistent and inaccurate and therefore do not provide EPA with the 

reliable data that it needs to identify permitted CAFOs nationwide. 

Without a systematic and coordinated process for collecting and 

maintaining accurate and complete information on the number, size, and 

location of CAFOs nationwide, EPA does not have the information it needs 

to effectively monitor and regulate these operations. In our report, we 

recommended that EPA develop a national inventory of permitted CAFOs 

and incorporate appropriate internal controls to ensure the quality of the

data it collects. In response to our recommendation, EPA stated that it is 

currently working with its regional offices and states to develop and 

implement a new national data system to collect and record facilityspecific information on permitted CAFOs. 

Page 9 GAO-08-1177T 
The amount of manure a large farm that raises animals can generate 

primarily depends on the types and numbers of animals raised on that 

farm, but can range from over 2,800 tons to more than 1.6 million tons a 

year.12 To further put this in perspective, the amount of manure produced 

by large farms that raise animals can exceed the amount of sanitary waste 

produced by some large U.S. cities.13 For example:

• A dairy farm meeting EPA’s large CAFO threshold of 700 dairy cows can 

create about 17,800 tons of manure annually, which is more than the about 

16,000 tons of sanitary waste generated per year by the almost 24,000 

residents of Lake Tahoe, California. 

• A large farm with 800,000 hogs could produce over 1.6 million tons of 

manure per year, which is one and a half times more than the annual 

sanitary waste produced by the city of Philadelphia, Pennsylvania—about 

1 million tons—with a population of almost 1.5 million.14

Although manure is considered a valuable commodity, especially in states

with large amounts of farmland, like Iowa, where it is used as fertilizer for 

field crops, in some parts of the country, large farms that raise animals can 

be clustered in a few contiguous counties. Because this collocation can 

result in the separation of animal from crop production, there is less 

cropland on which manure can be applied as a fertilizer. A USDA report 

first identified this concern as early as 2000, when it found that between 

1982 and 1997, as livestock production became more spatially 

concentrated, when manure was applied to cropland, crops were not fully 

using the nutrients in manure, and this could result in ground and surface 

water pollution from the excess nutrients.15 According to the report, the 

number of counties where farms produced more manure nutrients, 

primarily nitrogen and phosphorus, than could be applied to the land 

Large Farms That 

Raise Animals Can 

Produce Thousands 

of Tons of Manure 

Each Year, and 

Regional Clustering 

of Farms Can 

Exacerbate Manure 

Management 

Problems 

 12The amounts of manure reported are estimates. The actual amount of manure produced

by an animal will vary based on, among other things, feeding programs, feed used, climatic 

conditions, production techniques, and animal genetics. 

13Human sanitary waste includes urine and feces only; it does not include any other 

household sewage wastes such as water from washing dishes or clothes or water used for

showers or flushing. 

14EPA officials told us that the agency has identified a hog farm of this size and USDA

officials told us that they are aware of two hog farms of this size. 

15R. L. Kellogg, C.H. Lander, D. C. Moffitt, and N. Gollehon. Manure Nutrients Relative to 

the Capacity of Cropland and Pastureland to Assimilate Nutrients: Spatial and 

Temporal Trends for the United States. (Washington, D.C.: December 2000). 

Page 10 GAO-08-1177T Concentrated Animal Feeding Operations
Concentrated Animal Feeding Operations

without accumulating nutrients in the soil increased. As a result, the 

potential for runoff and leaching of these nutrients from the soil was high, 

and water quality could be impaired. Agricultural experts and government

officials who we spoke to during our review echoed the findings of 

USDA’s report and provided several examples of more recent clustering 

trends that have resulted in degraded water quality. For example, 

according to North Carolina agricultural experts, excessive manure 

production from CAFOs in five contiguous counties has contributed to the 

contamination of some of the surface and well water in these counties and 

the surrounding areas. 

USDA officials acknowledge that regional clustering of large animal 

feeding operations has occurred, but they told us that they believe 

producers’ implementation of nutrient management plans and use of new 

technologies, such as calibrated manure spreaders and improved animal 

feeds, have resulted in animal feeding operations more effectively using

the manure being generated and reducing the likelihood that pollutants 

from manure are entering ground and surface water. However, USDA 

could not provide us with information on the extent to which these 

techniques are being used or their effectiveness in reducing water 

pollution from animal waste. 

Since 2002, at least 68 government-sponsored or peer-reviewed studies 

have been completed on air and water pollutants from animal feeding 

operations. Of these 68 studies, 

• 15 directly linked pollutants from animal waste generated by animal 

feeding operations to specific health or environmental impacts. Eight of 

these 15 studies were water quality studies and 7 were air emissions 

studies. Academic experts and industry and EPA officials told us that only 

a few studies directly link CAFOs with health or environmental impacts 

because the same pollutants that CAFOs discharge also often come from 

other sources, including smaller livestock operations; row crops using 

commercial fertilizers; and wastes from humans, municipalities, or 

wildlife, making it difficult to distinguish the actual source of the pollution. 

Studies Have 

Identified Impacts of 

Pollutants from 

Animal Waste, but 

EPA Has Not 

Assessed the Extent 

of Such Impacts 

• 7 found no impacts on human health or the environment from pollutants 

emitted by CAFOs. Four of these 7 studies were water quality studies and 

3 were air emissions studies. According to EPA and academic experts we 

spoke with, the concentrations of air and water pollutants discharged by

animal feeding operations can vary for numerous reasons, including the 

type of animal being raised, feed being used and the manure management 

Page 11 GAO-08-1177T 
Concentrated Animal Feeding Operations

system being employed, as well as the climate and time of day when the 

emissions occur. 

• 12 made indirect linkages between air and water pollutants and health 

and environmental impacts. While these studies found that animal 

feeding operations were the likely cause of human health or 

environmental impacts occurring in areas near the operations, they could 

not conclusively link waste from animal feeding operations to the impacts, 

often because other sources of pollutants could also be contributing. 

• 34 of the studies focused on measuring the amounts of water or air 

pollutants discharged by animal feeding operations that are known to 

cause human health or environmental impacts at certain 

concentrations. Of the 34 studies, 19 focused on water pollutants and 

another 15 focused on measuring air emissions from animal feeding 

operations. 

While EPA recognizes the potential impacts that water and air pollutants 

from animal feeding operations can have on human health and the 

environment, it lacks the data necessary to assess how widespread the 

impacts are and has limited plans to collect the data that it needs. For 

example, with regard to water quality, EPA officials acknowledged that 

the potential human health and environmental impacts of some CAFO 

water pollutants, such as nitrogen, phosphorus, and pathogens, are well 

known. However, they also stated that EPA does not have data on the 

number and location of CAFOs nationwide and the amount of discharges 

from these operations. Without this information and data on how pollutant 

concentrations vary by type of operation, it is difficult to estimate the 

actual discharges occurring and to assess the extent to which CAFOs may 

be contributing to water pollution. Although EPA has recently taken some 

steps that may help provide some of these data, agency officials told us 

that EPA currently has no plans to conduct a national study to collect

information on CAFO water pollutant discharges because of a lack of 

resources. 

Similarly, with regard to air quality, more recently, EPA has recognized 

concerns about the possible health and environmental impacts from air 

emissions produced by animal feeding operations. In this regard, 

prompted in part by public concern, EPA and USDA commissioned a 2003 

study by the National Academy of Sciences (NAS) to evaluate the 

scientific information needed to support the regulation of air emissions 

Page 12 GAO-08-1177T 
Concentrated Animal Feeding Operations

from animal feeding operations.16 The NAS report identified several air 

pollutants from animal feeding operations, such as ammonia and hydrogen 

sulfide, that can impair human health. The NAS report also concluded that 

in order to determine the human health and environmental effects of air 

emissions from animal feeding operations, EPA and USDA would first 

need to obtain accurate estimates of emissions and their concentrations 

from animal feeding operations with varying characteristics, such as 

animal type, animal feed, manure management techniques, and climate. In

2007, the 2-year National Air Emissions Monitoring Study was initiated to

collect data on air emissions from animal feeding operations as part of a 

series of consent agreements that EPA entered into with individual 

CAFOs. This study, funded by industry and approved by EPA, is intended 

to help the agency determine how to measure and quantify air emissions 

from animal feeding operations. The data collected will in turn be used to 

estimate air emissions from animal feeding operations with varying 

characteristics. According to agency officials, until EPA can determine the

actual level of air pollutants being emitted by CAFOs, it will be unable to

assess the extent to which these emissions are affecting human health and 

the environment. 

The National Air Emissions Monitoring Study is intended to provide a 

scientific basis for estimating air emissions from animal feeding 

operations and to help EPA develop protocols that will allow it to 

determine which operations do not comply with applicable federal laws. 

According to EPA, although it has the authority to require animal feeding 

operations to monitor their emissions and come into compliance with the 

Clean Air Act on a case-by-case basis, this approach has proven to be time 

and labor intensive. As an alternative to the case-by-case approach, in 

January 2005, EPA offered animal feeding operations an opportunity to 

sign a voluntary consent agreement and final order, known as the Air 

Compliance Agreement. Almost 13,900 animal feeding operations were 

approved for participation in the agreement, representing the egg, broiler 

chicken, dairy, and swine industries. Some turkey operations volunteered

but were not approved because there were too few operations to fund a 

monitoring site, and the beef cattle industry chose not to participate. In

return for participating in this agreement and meeting certain

requirements, EPA agreed not to sue participating animal feeding 

It Is Unclear if EPA’s 

Efforts to Develop Air 

Emissions Protocols 

for Animal Feeding 

Operations Will Be 

Effective and Whether 

EPA Intends to 

Regulate These 

Emissions in the 

Future 

 16National Academy of Sciences, Air Emissions from Animal Feeding Operations: 

Current Knowledge, Future Need. (Washington, D.C.: National Academies Press, 2003). 

Page 13 GAO-08-1177T 
Concentrated Animal Feeding Operations

operations for certain past violations or violations occurring during the 

National Air Emissions Monitoring Study.17

Although EPA told us that the National Air Emissions Monitoring Study is 

the first step in developing comprehensive protocols for quantifying air 

emissions from animal feeding operations, we found that the study may 

not provide EPA with the data that it needs for the following three 

reasons. 

• The monitoring study may not be representative of the vast majority of 

participating animal feeding operations and will not account for 

differences in climatic conditions, manure-handling methods, and density 

of operations because it does not include the 16 combinations of animal 

types and geographic regional pairings recommended by EPA’s expert 

panel. EPA approved only 12 of the 16 recommended combinations, 

excluding southeastern broiler, eastern layer, midwestern turkey, and 

southern dairy operations. 

• Selection of monitoring sites has been a concern since the selection plan

was announced in 2005. At that time, many agricultural experts, 

environmental groups, and industry and state officials disagreed with the 

site selection methodology. They stated that the study did not include a 

sufficient number of monitoring sites to establish a statistically valid

sample. Without such a sample, we believe that EPA will not be able to 

accurately estimate emissions for all types of operations. More recently, in

June 2008, the state of Utah reached an agreement with EPA to separately

study animal feeding operations in the state because of the state’s 

continuing concerns that the National Air Emissions Monitoring Study will 

not collect information on emissions from operations in Rocky Mountain 

states and therefore may not be meaningful for those operations that raise 

animals in arid areas. 

• Agricultural experts also have raised concerns that the National Air 

Emissions Monitoring Study does not include other sources that can 

contribute significantly to emissions from animal feeding operations. For 

example, the monitoring study will not capture data on ammonia 

 17EPA placed certain conditions and limits on its agreement not to sue animal feeding 

operations participating in the Air Compliance Agreement. For example, EPA can continue 

to pursue cases that present an imminent and substantial endangerment to public health, 

welfare, or the environment. In addition, EPA’s covenant not to sue only covers emissions

from agricultural livestock and livestock waste and does not extend to generators or land

application of animal waste. 

Page 14 GAO-08-1177T 
Concentrated Animal Feeding Operations

emissions from feedlots and manure applied to fields. According to these 

experts, feedlots and manure on fields, as well as other excluded sources 

account for approximately half of the total ammonia emissions emitted by 

animal feeding operations. 

Furthermore, USDA’s Agriculture Air Quality Task Force has recently 

raised concerns about the quantity and quality of the data being collected 

during the early phases of the study and how EPA will eventually use the 

information.18 In particular, the task force expressed concern that the 

technologies used to collect emissions data were not functioning reliably. 

At its May 2008 task force meeting, the members requested that the 

Secretary of Agriculture ask EPA to review the first 6 months of the 

study’s data to determine if the study needs to be revised in order to yield 

more useful information. 

EPA acknowledged that emissions data should be collected for every type

of animal feeding operation and practice, but EPA officials stated that 

such an extensive study is impractical. Furthermore, they stated that the

selected sites provide a reasonable representation of the various animal 

sectors. EPA has also indicated that it plans to use other relevant 

information to supplement the study data and has identified some 

potential additional data sources. However, according to agricultural 

experts, until EPA identifies all the supplemental data that it plans to use, 

it is not clear if these data, together with the emissions study data, will 

enable EPA to develop comprehensive air emissions protocols. 

EPA has also indicated that completing the National Air Emissions 

Monitoring Study is only the first part of a multiyear effort to develop a 

process-based model for predicting overall emissions from animal feeding 

operations. A process-based model would capture emissions data from all 

sources and use these data to assess the interaction of all sources and the

impact that different manure management techniques have on air 

emissions for the entire operation. For example, technologies are available 

to decrease emissions from manure lagoons by, among other things, 

covering the lagoon to capture the ammonia. However, if an operation 

spreads the lagoon liquid as fertilizer for crops, ammonia emissions could 

increase on the field. According to NAS, a process-based model is needed 

 18The Agricultural Air Quality Task Force, created in accordance with the 1996 farm bill, is 

charged with advising the Secretary of Agriculture with respect to providing oversight and 

coordination related to agricultural air quality, and consists of leaders in farming, industry, 

health, and science. 

Page 15 GAO-08-1177T 
Concentrated Animal Feeding Operations

to provide scientifically sound estimates of air emissions from animal 

feeding operations that can be used to develop management and 

regulatory programs. Although EPA plans to develop a process-based 

model after 2011, it has not yet established a timetable for completing this 

model and, therefore, it is uncertain when EPA will have more 

sophisticated approaches that will more accurately estimate emissions 

from animal feeding operations. 

Moreover, two recent EPA decisions suggest that the agency has not yet

determined how it intends to regulate air emissions from animal feeding 

operations. Specifically:

• In December 2007, EPA proposed exempting releases to the air of 

hazardous substances from manure at farms that meet or exceed the 

reportable quantities from both CERCLA and EPCRA notification 

requirements. According to EPA, this decision was in part a response to 

language in congressional committee reports related to EPA’s 

appropriations legislation for 2005 and 2006 that directed the agency to 

promptly and expeditiously provide clarification on the application of 

these laws to poultry, livestock, and dairy operations. In addition, the 

agency received a petition from the several poultry industry organizations 

seeking an exemption from the CERCLA and EPCRA reporting 

requirements for ammonia emissions from poultry operations on the 

grounds that ammonia emissions from poultry operations pose little or no

risk to public health, and emergency response is inappropriate. In 

proposing the exemption, EPA noted that the agency would not respond to 

releases from animal wastes under CERCLA or EPCRA nor would it 

expect state and local governments to respond to such releases because 

the source and nature of these releases are such that emergency response 

is unnecessary, impractical, and unlikely. It also noted that it had received 

26 comment letters from state and local emergency response agencies 

supporting the exemption for ammonia from poultry operations. However, 

during the public comment period ending on March 27, 2008, a national 

association representing state and local emergency responders with 

EPCRA responsibilities questioned whether EPA had the authority to 

exempt these operations until it had data from its monitoring study to 

demonstrate actual levels of emissions from animal feeding operations. 

This national association further commented that EPA should withdraw 

the proposal because it denied responders and the public the information 

Page 16 GAO-08-1177T 
Concentrated Animal Feeding Operations

necessary to protect themselves from dangerous releases.19 Furthermore, 

the proposal also seems to be a departure from EPA’s past regulatory 

enforcement actions that have included charges of failing to comply with 

the release reporting requirements when bringing claims against 

producers for violating several environmental laws and is also contrary to

one of the stated goals of the Air Compliance Agreement. We believe that 

the timing of this proposed exemption, before the National Air Emissions 

Monitoring Study has been completed, calls into question the basis for 

EPA’s decision. 

• EPA has also recently stated that it will not make key regulatory decisions 

on how certain federal air regulations apply to animal feeding operations 

until after 2011, when the National Air Emissions Monitoring Study is 

completed. For example, according to EPA, the agency will not issue 

guidance for several more years defining the scope of the term “source” as 

it relates to animal agriculture and farm activities. According to EPA, it has 

not yet decided if it will aggregate the emissions occurring on an animal 

feeding operation as one source or if the emissions from the barns, 

lagoons, feed storage, and fields will each be considered as a separate 

source when determining if an operation has exceeded air emissions’ 

reportable quantities. Depending on the approach EPA takes, how 

emissions are calculated could differ significantly. For example, according

to preliminary data EPA has received from an egg-laying operation in 

Indiana, individual chicken barns may exceed the CERCLA reportable 

quantities for ammonia. Moreover, if emissions from all of the barns on the 

operation are aggregated, they might be more than 500 times the CERCLA 

reportable quantities. 

To address the various concerns that we identified with the ongoing air 

emission monitoring study, we recommended that EPA (1) reassess the 

study to ensure that it will provide valid data which the agency can use to

develop air emissions protocols and (2) provide stakeholders with 

information on the additional data that it plans to use to supplement the 

study. In addition, we recommended that EPA establish a strategy and 

timetable for developing a process-based model that will provide more 

sophisticated air emissions estimating methodologies for animal feeding 

operations. EPA responded that it has developed a quality assurance plan

for the study but did not address other issues that we identified in our 

 19The National Association of SARA Title III Program Officials. The Superfund 

Amendments and Reauthorization Act (SARA) amended CERCLA on October 17, 1986,

after the first 6 years of the program. 

Page 17 GAO-08-1177T 
Concentrated Animal Feeding Operations

report, such as the validity of the study’s sample and the omission of other 

sources that can contribute significantly to the air emission from animal 

feeding operations. Furthermore, although EPA concurred with the need 

to identify supplemental data and establish a strategy and timetable for 

developing a process-based model and described actions that it has 

underway, the agency provided no indication of when it will complete its 

plans to either identify the data it will use to augment the monitoring study 

or develop a process-based model. 

Two federal court decisions—Waterkeeper Alliance Inc. v. EPA and 

Rapanos v. United States—have affected EPA and some states’ abilities to

regulate CAFOs for water pollutants. 

In its 2005 Waterkeeper decision, the U.S. Court of Appeals for the Second

Circuit set aside a key provision of EPA’s 2003 CAFO rule requiring every 

CAFO to apply for a permit. Under the 2003 rule, large numbers of 

previously unregulated CAFOs were required to apply for permits and 

would have been subject to monitoring and reporting requirements 

imposed by the permit as well as periodic inspections. According to EPA, 

the 2003 rule would have expanded the number of regulated CAFOs from 

an estimated 12,500 to an estimated 15,300, an increase of about 22 

percent, and would have provided EPA with more comprehensive 

information on the number and location of CAFOs, enabling the agency to

more effectively locate and inspect these operations nationwide. 

However, in 2003, both environmental and agricultural groups challenged 

EPA’s 2003 rule. The court agreed with the environmental groups’ 

arguments that, among other things, EPA’s 2003 rule did not adequately 

provide for public review and comment on a CAFO’s nutrient management 

plan and instructed EPA to revise the rule accordingly. The court also 

agreed with the agricultural groups’ arguments that EPA had exceeded its

authority under the Clean Water Act by requiring CAFOs that were not 

discharging pollutants into federally regulated water to apply for permits 

Two Federal Court 

Decisions Have 

Affected EPA’s and 

Some States’ Ability 

to Regulate Water 

Pollutants Discharged 

by CAFOs 

Waterkeeper Alliance Inc. 

v. EPA (Waterkeeper) 

Page 18 GAO-08-1177T 
Concentrated Animal Feeding Operations

or demonstrate that they had no potential to discharge and therefore set 

aside the rule’s permitting requirements for those CAFOs that did not 

discharge. 

The Waterkeeper decision, in effect, returned EPA’s permitting program to 

one in which CAFO operators are not required to apply for a NPDES 

permit unless they discharge, or propose discharging, into federally 

regulated waters. As a result, EPA must identify and prove that an 

operation has discharged or is discharging pollutants in order to require 

the operator to apply for a permit. To help identify unpermitted discharges

from CAFOs, EPA officials told us that they have to rely on other methods 

that are not necessarily all-inclusive, such as citizens’ complaints, drive-by 

observations, aerial flyovers, and state water quality assessments that 

identify water bodies impaired by pollutants associated with CAFOs. 

According to EPA officials, these methods have helped the agency identify 

some CAFOs that may be discharging as well as targeting inspections to 

such CAFOs. 

As a result of the Waterkeeper decision, EPA proposed a new rule in June 

2006 requiring that (1) only CAFO operators that discharge, or propose to 

discharge, apply for a permit, (2) permitting authorities review CAFO 

nutrient management plans and incorporate the terms of these plans into 

the permits, and (3) permitting authorities provide the public with an 

opportunity to review and comment on the nutrient management plans. 

According to EPA officials, the final rule is currently being reviewed by the 

Office of Management and Budget, but at the time we issued our report, 

these officials were uncertain when this review would be completed and

the final rule issued. 

State water pollution control officials have expressed some concerns that

EPA’s new 2006 rule will place a greater administrative burden on states 

than the 2003 rule would have. In an August 2006 letter to EPA, the 

Association of State and Interstate Water Pollution Control Administrators

noted that the “reactive” enforcement that EPA will now follow will 

require permitting authorities to significantly increase their enforcement 

efforts to achieve the level of environmental benefit that would have been 

provided by the 2003 rule. These officials believe that requiring EPA and 

the states to identify CAFOs that actually discharge pollutants into 

federally regulated water bodies will consume more resources than 

requiring all CAFOs to apply for a permit. 

Moreover, although the Waterkeeper decision has affected EPA’s ability to

regulate CAFOs’ water pollutant discharges, state officials we contacted

Page 19 GAO-08-1177T 
Concentrated Animal Feeding Operations

indicated that this decision has not had the same impact on their ability to 

regulate these operations. As table 1 shows, the impacts of the 

Waterkeeper decision have ranged from having little impact on state 

regulation to impairing state CAFO programs. 

Table 1: State Officials’ Views of the Impact of the Waterkeeper Decision on Their 

CAFO Programs

Impact of Waterkeeper 

Number of states reporting

impact 

Waterkeeper had little or no impact 16

Reduced the number of CAFOs with permits 15

Impaired state program 10

Waiting for EPA to issue revised rule 9

Prompted state legislature to require permits for 

CAFOs 1

Source: GAO analysis of state officials’ responses 

Although the Rapanos case arose in the context of a different permit 

program, the scope of EPA’s pollutant discharge program originates in the 

same Clean Water Act definition that was at issue in the case. As a result, 

the decision has complicated the agency’s enforcement of CAFO 

regulations. According to EPA enforcement officials, the agency will now 

be less likely to seek enforcement against a CAFO that it believes is 

discharging pollutants into a water body because it may be more difficult 

to prove that the water body is federally regulated. According to EPA 

officials, as a result of the Rapanos decision, EPA must spend more 

resources developing an enforcement case because the agency must 

gather proof that the CAFO has not only illegally discharged pollutants, 

but that those pollutants have entered federally regulated waters. The 

difficulties EPA has experienced were highlighted in a March 4, 2008,

memorandum in which EPA’s Assistant Administrator for Enforcement 

and Compliance Assurance stated that the Rapanos decision and national

guidance issued by EPA to ensure “nationwide consistency, reliability, and 

predictability in their administration of the statute” in light of the Supreme 

Court’s decision has resulted in significant adverse impacts to the clean 

water enforcement program. According to the memorandum, the Rapanos 

decision and guidance negatively affected approximately 500 enforcement 

cases, including as many as 187 cases involving NPDES permits. 

Rapanos v. United States

(Rapanos) 

Page 20 GAO-08-1177T 
Concentrated Animal Feeding Operations

In conclusion, Mr. Chairman, EPA has regulated CAFOs under the Clean 

Water Act for more than 30 years, and during this time it has amassed a 

significant body of knowledge about the pollutants discharged by animal 

feeding operations and the potential impacts of these pollutants on human 

health and the environment. Nevertheless, EPA still lacks comprehensive 

and reliable data on the number, location, and size of the operations that

have been issued permits and the amounts of discharges they release. As a 

result, EPA has neither the information it needs to assess the extent to 

which CAFOs may be contributing to water pollution, nor the information 

it needs to ensure compliance with the Clean Water Act. More recently, 

EPA has also begun to address concerns about air pollutants that are 

emitted by animal feeding operations. The nationwide air emissions 

monitoring study, along with EPA’s plans to develop air emissions 

estimating protocols, are important steps in providing much needed 

information on the amount of air pollutants emitted from animal feeding 

operations. However, questions about the sufficiency of the sites selected 

for the air emissions study and the quantity and quality of the data being 

collected could undermine EPA’s efforts to develop air emissions 

protocols by 2011 as planned. A process-based model that more accurately 

predicts the total air emissions from an animal feeding operation is still 

needed. While EPA has indicated it intends to develop such a model, it has 

not yet established a strategy and timeline for this activity.

Mr. Chairman, this concludes my prepared testimony. I would be happy to

respond to questions that you or Members of the Subcommittee may have. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this testimony. For further 

information about this testimony, please contact Anu Mittal, Director, 

Natural Resources and Environment (202) 512-3841 or mittala@gao.gov. 

Key contributors to this testimony were Sherry McDonald, Assistant 

Director; Kevin Bray, Paul Hobart; Holly Sasso; Carol Herrnstadt Shulman; 

James Turkett; and Greg Wilmoth. 

Contact and Staff 

Acknowledgments 

Page 21 GAO-08-1177T (361013) 
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