MarketConcentrated animal feeding operation
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Concentrated animal feeding operation

In animal husbandry, a concentrated animal feeding operation (CAFO), as defined by the United States Department of Agriculture (USDA), is an intensive animal feeding operation (AFO) in which over 1,000 animal units are confined for over 45 days a year. An animal unit is the equivalent of 1,000 pounds of "live" animal weight. A thousand animal units equates to 700 dairy cows, 1,000 meat cows, 2,500 pigs weighing more than 55 pounds (25 kg), 10,000 pigs weighing under 55 pounds, 10,000 sheep, 55,000 turkeys, 125,000 chickens, or 82,000 egg laying hens or pullets.

Definition
There are roughly 212,000 AFOs in the United States, of which 19,496 met the more narrow criteria for CAFOs in 2016. The Environmental Protection Agency (EPA) has delineated three categories of CAFOs, ordered in terms of capacity: large, medium and small. The relevant animal unit for each category varies depending on species and capacity. For instance, large CAFOs house 1,000 or more cattle, medium CAFOs can have 300–999 cattle, and small CAFOs harbor no more than 300 cattle. The table below provides some examples of the size thresholds for CAFOs: The categorization of CAFOs affects whether a facility is subject to regulation under the Clean Water Act (CWA). EPA's 2008 rule specifies that "large CAFOs are automatically subject to EPA regulation; medium CAFOs must also meet one of two 'method of discharge' criteria to be defined as a CAFO (or may be designated as such); and small CAFOs can only be made subject to EPA regulations on a case-by-case basis." A small CAFO will also be designated a CAFO for purposes of the CWA if it discharges pollutants into waterways of the United States through a man-made conveyance such as a road, ditch or pipe. Alternatively, a small CAFO may be designated an ordinary animal feeding operation (AFO) once its animal waste management system is certified at the site. Since it first coined the term, the EPA has changed the definition (and applicable regulations) for CAFOs on several occasions. Private groups and individuals use the term CAFO colloquially to mean many types of both regulated and unregulated facilities, both inside and outside the U.S. The definition used in everyday speech may thus vary considerably from the statutory definition in the CWA. CAFOs are commonly characterized as having large numbers of animals crowded into a confined space, a situation that results in the concentration of manure in a small area. == Key issues ==
Key issues
Environmental impact The EPA has focused on regulating CAFOs because they generate millions of tons of manure every year. When improperly managed, the manure can pose substantial risks to the environment and public health. In order to manage their waste, CAFO operators have developed agricultural wastewater treatment plans. The most common type of facility used in these plans, the anaerobic lagoon, has significantly contributed to environmental and health problems attributed to the CAFO. Water quality The large amounts of animal waste from CAFOs present a risk to water quality and aquatic ecosystems. States with high concentrations of CAFOs experience on average 20 to 30 serious water quality problems per year as a result of manure management issues.Animal waste includes a number of potentially harmful pollutants. Pollutants associated with CAFO waste principally include: • nitrogen and phosphorus, collectively known as nutrient pollution; • organic matter; • solids, including the manure itself and other elements mixed with it such as spilled feed, bedding and litter materials, hair, feathers and animal corpses; • pathogens (disease-causing organisms such as bacteria and viruses); • salts; • trace elements such as arsenic; • odorous/volatile compounds such as carbon dioxide, methane, hydrogen sulfide, and ammonia; • antibiotics; • pesticides and hormones. The two main contributors to water pollution caused by CAFOs are soluble nitrogen compounds and phosphorus. The eutrophication of water bodies from such waste is harmful to wildlife and water quality in aquatic system like streams, lakes, and oceans. Groundwater and surface water are closely linked, so polluting one often affects the other. Some facility designs, such as lagoons, can reduce the risk of groundwater contamination, but the microbial pathogens from animal waste may still pollute surface and groundwater, harming wildlife and human health. A CAFO is responsible for one of the biggest environmental spills in U.S. history. In 1995, a lagoon ruptured in North Carolina. North Carolina contains a lot of the United States' industrial hog operations, which disproportionally impact Black, Hispanic and Indian American residents. The spill released of effluvium into the New River and killed 10 million local fish. The spill also contributed to an outbreak of Pfiesteria piscicida, which caused health problems in nearby humans, including skin irritation and short-term cognitive problems. Air quality CAFOs reduce ambient air quality. They release several gases harmful to humans: ammonia, hydrogen sulfide, methane, and particulate matter. Larger CAFOs release more gas, mostly by the decomposition of large stores of animal manure. The source is not widely known, but animal feed is suspected.Globally, ruminant livestock are responsible for about 115 Tg/a of the 330 Tg/a (35%) of anthropogenic greenhouse gas emissions released per year. Livestock operations are responsible for about 18% of greenhouse gas emissions globally and over 7% of greenhouse gas emissions in the U.S. Methane is the second most concentrated greenhouse gas contributing to global climate change, with livestock contributing nearly 30% of anthropogenic methane emissions. Only 17% of livestock-related emissions come from manure, whereas most come from enteric fermentation or gases produced during digestion. The Humane Society of the United States (HSUS) argues for reducing use of non-therapeutic antibiotics, especially those that are widely used in human medicine, on the advice of over 350 organizations including the American Medical Association. If no change is made and methane emissions continue increasing in direct proportion to the number of livestock, global methane production is predicted to increase by 60% by 2030. Greenhouse gases and climate change make air worse, causing illnesses such as respiratory disorders, lung tissue damage, and allergies. Reducing the increase of greenhouse gas emissions from livestock could rapidly curb global warming. Also, people near CAFOs often complain of the smell, which comes from a complex mixture of ammonia, hydrogen sulfide, carbon dioxide, and volatile and semi-volatile organic compounds. Waste disposal also makes air worse. Some CAFOs will use "spray fields" and pump the waste of thousands of animals into a machine that sprays it onto an open field. The spray can be carried by wind onto nearby homes, depositing pathogens, heavy metals, and antibiotic resistant bacteria into the air of poor or minority communities. It often contains respiratory and eye irritants including hydrogen sulfide and ammonia. Economic impact Increased role in the market The economic role of CAFOs has expanded significantly in the U.S. in the past few decades, and there is clear evidence that CAFOs have come to dominate animal production industries. The rise in large-scale animal agriculture began in the 1930s with the modern mechanization of swine slaughterhouse operations. The growth of corporate contracting has also contributed to a transition from a system of many small-scale farms to one of relatively few large industrial-scale farms. This has dramatically changed the animal agricultural sector in the United States. According to the National Agricultural Statistics Service, "In the 1930s, there were close to 7 million farms in the United States and as of the 2002 census, just over 2 million farms remain." From 1969 to 2002, the number of family farms dropped by 39%, yet the percentage of family farms has remained high. As of 2004, 98% of all U.S. farms were family-owned and -operated. Most meat and dairy products are now produced on large farms with single-species buildings or open-air pens. Due to their increased efficiency, CAFOs provide a source of low cost animal products: meat, milk and eggs. CAFOs may also stimulate local economies through increased employment and use of local materials in their production. Along with the noted benefits, there are also criticisms regarding CAFOs' impact on the economy. Many farmers in the United States find that it is difficult to earn a high income due to the low market prices of animal products. Such market factors often lead to low profit margins for production methods and a competitive disadvantage against CAFOs. Alternative animal production methods, like "free range" or "family farming" operations are losing their ability to compete, though they present few of the environmental and health risks associated with CAFOs. Negative production externalities The price of meat does not reflect the negative ecological impacts that result from industrial agricultural systems. The negative production externalities (when market prices inappropriately reflect or hide the societal harms incurred in the creation of a product) of CAFOs include damaging effects to the environment caused by, among others, ever-increasing amounts of often poorly managed waste. For instance, researchers found that there is a statistically significant relationship between property values declines and CAFO proximity. Other economic criticisms Critics of CAFOs also maintain that CAFOs benefit from industrial and agricultural tax breaks and subsidies, and the "vertical integration of giant agribusiness firms". The U.S. Department of Agriculture (USDA), for instance, spent an average of $16 billion annually between FY 1996 to FY 2002 on commodity-based subsidies. Lax enforcement of anti-competitive practices may be helping create a market monopoly. Critics also contend that CAFOs cut costs by overusing antibiotics. Public health concerns The direct discharge of manure from CAFOs and the accompanying pollutants (including nutrients, antibiotics, pathogens, and arsenic) is a serious public health risk. The contamination of groundwater with pathogenic organisms from CAFOs can threaten drinking water safety, and contamination of drinking water with pathogens can cause outbreaks of infectious disease. The EPA estimates that 53% of the United States population drinks groundwater. Contamination of water by CAFOs causes various heart problems. Accidental ingestion of contaminated water can result in diarrhea or other gastrointestinal illnesses. Dermal exposure can result in irritation and infection of the skin, eyes or ear. High levels of nitrate in drinking water are associated with increased risk of hyperthyroidism, insulin-dependent diabetes, and central nervous system malformations. Antibiotic resistance can result due to DNA mutations, transformations and conjugations arising from various antibiotics and pharmaceutical drugs found in drinking water. When bacteria in or around animals are exposed to antibiotics, natural selection favours the spread of mutations with greater resistance. Use of antibiotics by CAFOs thus increases antimicrobial resistance. This threatens public health because resistant bacteria generated by CAFOs can be spread to the surrounding environment and communities via waste water discharge or the aerosolization of particles. ] Air pollution caused by CAFOs can cause asthma, headaches, respiratory problems, eye irritation, nausea, weakness, and chest tightness. These affect farm workers and nearby residents, including children. Furthermore, a Dutch cross-sectional study 2,308 adults found decreases in residents' lung function to be correlated with increases of particle emissions by nearby farms. In regards to workers, multiple respiratory consequences should be noted. Although "in many big CAFOs, it takes only a few workers to run a facility housing thousands of animals," the long exposure and close contact to animals puts CAFO employees at an increased risk. This includes a risk of contracting diseases like Novel H1N1 flu, which erupted globally in spring of 2009, or MRSA, a strain of antibiotic resistant bacteria. Studies conducted by the University of Iowa show that the asthma rate of children of CAFO operators is higher than that of children from other farms. Negative effects on minority populations Low income and minority populations suffer disproportionately from proximity to CAFOs and pollution and waste. In addition to financial problems, CAFOs are also protected by "right-to-farm" law that protects them from residents that are living in CAFO occupied communities. Not only are communities surrounded negatively affected by CAFOs, but the workers themselves experience harm from being on the job. In a study done in North Carolina that focused on twenty one Latino chicken catchers for a poultry-processing plant, the work place was found to be forcefully high-intensity labor with high potential for injury and illness including trauma, respiratory illness, drug use and musculoskeletal injuries. Workers were also found to have little training about the job or safety. In the United States, agricultural workers are engaged in one of the most hazardous jobs in the country. CAFO workers have historically been African American but there has been a surge of Hispanic and often undocumented Hispanic workers. Between 1980 and 2000, there was a clear shift in an ethnic and racially diverse workforce, led by Hispanic workforce growth.[7] Oftentimes, CAFO owners will preferably hire Hispanic workers because they are low-skilled workers who are willing to work longer hours and do more intensive work. Due to this, there are increased ICE raids on meat processing plants. Animal health and welfare concerns CAFO practices have raised concerns over animal welfare from an ethics standpoint. Some view such conditions as neglectful to basic animal welfare. According to David Nibert, professor of sociology at Wittenberg University, more than 10 billion animals are housed in "horrific conditions" in more than 20,000 CAFOs across the U.S. alone, where they "spend their last 100–120 days crammed together by the thousands standing in their own excrement, with little or no shelter from the elements." Many people believe that the harm to animals before their slaughter should be addressed through public policy. Laws regarding animal welfare in CAFOs have already been passed in the United States. For instance, in 2002, the state of Florida passed an amendment to the state's constitution banning the confinement of pregnant pigs in gestation crates. As a source for comparison, the use of battery cages for egg-laying hens and battery cage breeding methods have been completely outlawed in the European Union since 2012. Whereas some people are concerned with animal welfare as an end in itself, others are concerned about animal welfare because of the effect of living conditions on consumer safety. Animals in CAFOs have lives that do not resemble those of animals found in the wild. Although CAFOs help secure a reliable supply of animal products, the quality of the goods produced is debated, with many arguing that the food produced is unnatural. For instance, confining animals into small areas requires the use of large quantities of antibiotics to prevent the spread of disease. There are debates over whether the use of antibiotics in meat production is harmful to humans. == Regulation under the Clean Water Act ==
Regulation under the Clean Water Act
Basic structure of CAFO regulations under the CWA The command-and-control permitting structure of the Clean Water Act (CWA) provides the basis for nearly all regulation of CAFOs in the United States. Generally speaking, the CWA prohibits the discharge of pollution to the "waters of the United States" from any "point source", unless the discharge is authorized by a National Pollutant Discharge Elimination System (NPDES) permit issued by the EPA (or a state delegated by the EPA). CAFOs are explicitly listed as a point source in the CWA. Unauthorized discharges made from CAFOs (and other point sources) violate the CWA, even if the discharges are "unplanned or accidental." CAFOs that do not apply for NPDES permits "operate at their own risk because any discharge from an unpermitted CAFO (other than agricultural stormwater) is a violation of the CWA subject to enforcement action, including third party citizen suits." The benefit of an NPDES permit is that it provides some level of certainty to CAFO owners and operators. "Compliance with the permit is deemed compliance with the CWA... and thus acts as a shield against EPA or State CWA enforcement or against citizen suits under... the CWA." History of regulations The major CAFO regulatory developments occurred in the 1970s and in the 2000s. The EPA first promulgated ELGs for CAFOs in 1976. Background laws The Federal Water Pollution Control Act of 1948 was one of the first major efforts of the U.S. federal government to establish a comprehensive program for mitigating pollution in public water ways. The writers of the act aimed to improve water quality for the circulation of aquatic life, industry use, and recreation. Since 1948, the Act has been amended many times to expand programming, procedures, and standards. President Richard Nixon's executive order, Reorganization Plan No. 3, created the EPA in 1970. The creation of the EPA was an effort to create a more comprehensive approach to pollution management. As noted in the order, a single polluter may simultaneously degrade a local environment's air, water, and land. President Nixon noted that a single government entity should be monitoring and mitigating pollution and considering all effects. As relevant to CAFO regulation, the EPA became the main federal authority on CAFO pollution monitoring and mitigation. Congress passed the CWA in 1972 when it reworked the Federal Water Pollution Control Amendments. It specifically defines CAFOs as point source polluters and required operations managers and/or owners to obtain NPDES permits in order to legally discharge wastewater from its facilities. Initial regulations (1970s) The EPA began regulating water pollution discharges from CAFOs following passage of the 1972 CWA. ELGs for feedlot operations were promulgated in 1974, placing emphasis on best available technology in the industry at the time. In 1976 EPA began requiring all CAFOs to be first defined as AFOs. From that point, if the specific AFO met the appropriate criteria, it would then be classified as a CAFO and subject to appropriate regulation. That same year, EPA defined livestock and poultry CAFO facilities and established a specialized permitting program. NPDES permit procedures for CAFOs were also promulgated in 1976. Prior to 1976, size had been the main defining criteria of CAFOs. However, after the 1976 regulations came into effect, the EPA stipulated some exceptions. Operations that were identified as particularly harmful to federal waterways could be classified as CAFOs, even if the facilities' sizes fall under AFOs standards. Additionally, some CAFOs were not required to apply for wastewater discharge permits if they met the two major operational-based exemptions. The first exception applied to operations that discharge wastewater only during a 25-year, 24-hour storm event. (The operation only discharges during a 24-hour rainfall period that occurs once every 25 years or more on average.) The second exception was when operations apply animal waste onto agricultural land. In 1995, the EPA released a "Guide Manual on NPDES Regulations for Concentrated Animal Feeding Operations" to provide more clarity to the public on NPDES regulation after the EPA's report "Feedlots Case Studies of Selected States" revealed there was uncertainty in the public regarding CAFO regulatory terminology and criteria. On March 9, 1999, the agencies released the framework titled the Unified National Strategy for Animal Feeding Operations. In the framework, the agencies recommended six major activities to be included in operations' Comprehensive Nutrient Management Plans (CNMPs): • feed management • manure handling and storage • land application of manure • land management • record keeping • activities that utilize manure. The framework also outlined two types of related programs. First, "voluntary programs" were designed to assist AFO operators with addressing public health and water quality problems. The EPA was also responding to a 1991 court order based on the district court's decision in Natural Resources Defense Council v. Reilly. The EPA allowed authorized NPDES states until February 2005 to update their programs and develop technical standards. The EPA was thus forced to interpret the statutory definition to "identify the conditions under which discharges from the land application area of [waste from] a CAFO are point source discharges that are subject to NPDES permitting requirements, and those which are agricultural stormwater discharges and thus are not point source discharges." The rationale for this requirement was the EPA's "presumption that most CAFOs have a potential to discharge pollutants into waters of the United States" and therefore must affirmatively comply with the requirements of the Clean Water Act. The Second Circuit sided with the farm industry plaintiffs on this point and ruled that this portion of the 2003 rule exceeded the EPA's authority. The court held that the EPA can require NPDES permits only where there is an actual discharge by a CAFO, not just a potential to discharge. The EPA later estimated that 25 percent fewer CAFOs would seek permits as a result of the Second Circuit's decision on this issue. The EPA's 2003 rule required that these new sources meet a "no discharge" standard, except in the case of a 100-year, 24-hour rainfall event (or a less restrictive measure for new CAFOs that voluntarily use new technologies and management practices). The 2008 final rule revised and amended the 2003 final rule. The 2008 rule addresses each point of the court's decision in Waterkeeper Alliance v. EPA. Specifically, the EPA adopted the following measures: • The EPA replaced the "duty to apply" standard with one that requires NPDES permit coverage for any CAFO that "discharges or proposes to discharge." The 2008 rule specifies that "a CAFO proposes to discharge if it is designed, constructed, operated, or maintained such that a discharge will occur." On May 28, 2010, the EPA issued guidance "designed to assist permitting authorities in implementing the [CAFO regulations] by specifying the kinds of operations and factual circumstances that EPA anticipates may trigger the duty to apply for permits." On March 15, 2011, the Fifth Circuit Court of Appeals in National Pork Producers Council v. EPA again struck down the EPA's rule on this issue, holding that the "propose to discharge" standard exceeds the EPA's authority under the CWA. After the Fifth Circuit's ruling, a CAFO cannot be required to apply for an NPDES permit unless it actually discharges into a water of the United States. • The EPA modified the requirements related to the nutrient management plans (NMP). In keeping with the court's decision in Waterkeeper Alliance v. EPA, the EPA instituted a requirement that the permitting authority (either the EPA or the State) incorporate the enforceable "terms of the NMP" into the actual permit. The "terms of the NMP" include the "information, protocols, best management practices (BMPs) and other conditions in the NMP necessary to meet the NMP requirements of the 2003 rule." Recently, the annual amount of the grant totaled $8 million. Lastly, the EPA notes that the USDA offers a "range of support services," including a long-term program that aims to assist CAFOs with NMPs. Even when laws are enforced, there is the risk of environmental accidents. The massive 1995 manure spill in North Carolina highlights the reality that contamination can happen even when it is not done maliciously. The question of whether such a spill could have been avoided is a contributing factor in the debate for policy reform. Environmental groups have criticized the EPA's regulation of CAFOs on several specific grounds, including the following. It is argued that CAFOs have very little incentive to seek an NPDES permit under the new rule. • Requirement for co-permitting entities that exercise "substantial operational control" over CAFOs: Environmental groups unsuccessfully petitioned the EPA to require "co-permitting of both the farmer who raises the livestock and the large companies that actually own the animals and contract with farmers." This modification to EPA regulations would have made the corporations legally responsible for the waste produced on the farms with which they contract. • Zero discharge requirement to groundwater when a direct hydrologic connection exists to surface water: The EPA omitted a provision in its 2003 rule that would have held CAFOs to a zero discharge limit from the CAFO's production area to "ground water that has a direct hydrologic connection to surface water." Environmentalists criticized the EPA's decision to omit this provision on the basis that ground water is often a drinking source in rural areas, where most all CAFOs are located. • Specific performance standards: Environmentalists urged the EPA to phase out the use of lagoons (holding animal waste in pond-like structures) and sprayfields (spraying waste onto crops). Environmentalists argued that these techniques for dealing with animal waste were outmoded and present an "unacceptable risk to public health and the environment" due to their ability to pollute both surface and groundwater following "weather events, human error, and system failures." Environmentalists suggested that whenever manure is land applied that it should be injected into the soil (and not sprayed). • Lack of regulation of air pollution: The revisions to the EPA's rules under the CWA did not address air pollutants. Environmentalists maintain that the air pollutants from CAFOs—which include ammonia, hydrogen sulfide, methane, volatile organic compounds, and particulate matter—should be subject to EPA regulation. Conversely, industry groups criticize the EPA's rules as overly stringent. Industry groups vocally opposed the requirement in the 2008 rule (since struck down by the Fifth Circuit) that required CAFOs to seek a permit if they "propose to discharge" into waters of the United States. Generally speaking, the farm industry disputes the presumption that CAFOs do discharge pollutants and it therefore objects to the pressure that the EPA places on CAFOs to voluntarily seek an NPDES permit. As a starting point, farm industry groups "emphasize that most farmers are diligent stewards of the environment, since they depend on natural resources of the land, water, and air for their livelihoods and they, too, directly experience adverse impacts on water and air quality." Some of the agricultural industry groups continue to maintain that the EPA should have no authority to regulate any of the runoff from land application areas because they believe this constitutes a nonpoint source that is outside the scope of the CWA. According to this viewpoint, voluntary programs adequately address any problems with excess manure. == States' role and authority ==
States' role and authority
The role of the federal government in environmental issues is generally to set national guidelines and the state governments' role is to address specific issues. The framework of federal goals is as such that the responsibility to prevent, reduce, and eliminate pollution are the responsibility of the states. The management of water and air standards follows this authoritative structure. States that have been authorized by the EPA to directly issue permits under NPDES (also known as "NPDES states") have received jurisdiction over CAFOs. As a result of this delegation of authority from the EPA, CAFO permitting procedures and standards may vary from state to state. Specifically for water pollution, the federal government establishes federal standards for wastewater discharge and authorized states develop their own wastewater policies to fall in compliance. More specifically, what a state allows an individual CAFO to discharge must be as strict or stricter than the federal government's standard. This protection includes all waterways, whether or not the water body can safely sustain aquatic life or house public recreational activities. Higher standards are upheld in some cases of pristine publicly owned waterways, such as parks. They keep higher standards in order to maintain the pristine nature of the environment for preservation and recreation. Exceptions are in place for lower water quality standards in certain waterways if it is deemed economically significant. The Arizona state agency tasked with managing permitting is the Arizona Department of Environmental Quality (ADEQ). For the Aquifer Protection Permit, CAFOs are automatically permitted if they comply with the state's BMP outlined in the relevant state rule, listed on the ADEQ's website. Their compliance is evaluated through agency CAFO Inspection Program's onsite inspections. If a facility is found to be unlawfully discharging, then the agency may issue warnings and, if necessary, file suit against the facility. For the AZPDES permit, CAFOs are required to submit a Notice of Intent to the ADEQ. In addition, they must complete and submit a Nutrient Management Plan (NMP) for the state's annual report. If a state has additional state specific rules for water quality standards, the state government maintains the authority for permitting. For instance, New Mexico, also an unauthorized state, requires CAFOs and AFOs to obtain a Groundwater Permit if the facilities discharge waste in a manner that might affect local groundwater. The EPA is not involved in the issuing of this state permit. Massachusetts, however, does not have additional state permit requirements. ==Zoning ordinances==
Zoning ordinances
State planning laws and local zoning ordinances represent the main policy tools for regulating land use. Many states have passed legislation that specifically exempt CAFOs (and other agricultural entities) from zoning regulations. The promulgation of so-called "right to farm" statutes have provided, in some instances, a shield from liability for CAFOs (and other potential nuisances in agricultural). The statutes were enacted at a time when CAFOs and "modern confinement operations did not factor into legislator's perceptions of the beneficiaries of [the] generosity" of such statutes. As of February 2023, 85 Iowa counties, the majority of Iowa counties, had passed a "Construction Evaluation Resolution"; pursuant to Iowa Code section 459 only counties which have adopted such a "construction evaluation resolution" can submit to the Iowa Department of Natural Resources a recommendation to approve or disapprove a construction permit application regarding a proposed confinement feeding operation which the board of supervisors received between February 1, 2023, and January 31, 2024. ==Regulation under the Clean Air Act==
Regulation under the Clean Air Act
CAFOs are potentially subject to regulation under the Clean Air Act (CAA), but the emissions from CAFOs generally do not exceed established statutory thresholds. In addition, the EPA's regulations do not provide a clear methodology for measuring emissions from CAFOs, which has "vexed both regulators and the industry." If the EPA adopts the petition, CAFOs and other sources of ammonia would be subject to the permitting requirements of the CAA. ==See also==
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