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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 September 4, 2008

Concentrated Animal Feeding Operations (CAFO) are large livestock and poultry operations that raise animals in a confined situation. CAFOs can improve the efficiency of animal production but large amounts of manure produce can, if not properly managed, degrade air and water quality. The Environmental Protection Agency (EPA) is responsible for regulating CAFOs and requires CAFOs that discharge certain pollutants to obtain a permit. This report discusses the (1) trends in CAFOs over the past 30 years, (2) amounts of waste they generate, (3) findings of key research on CAFOs' health and environmental impacts, (4) EPA's progress in developing CAFO air emissions protocols, and (5) 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.

Because no federal agency collects consistent, reliable data on CAFOs, GAO could not determine the trends in these operations over the past 30 years. 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, going from about 3,600 in 1982 to almost 12,000 in 2002. Also, during this 20-year period the number of animals per farm had increased, although it varied by animal type. Moreover, GAO found that EPA does not have comprehensive, accurate information on the number of permitted CAFOs nationwide. As a result, EPA does not have the information it needs to effectively regulate these CAFOs. EPA is currently working with the states to establish a new national data system. The amount of manure generated by large farms that raise animals depends on the type and number of animals raised, but large operations can produce more than 1.6 million tons of manure a year. Some large farms that raise animals can generate more raw waste than the populations of some U.S. cities produce annually. In addition, according to some agricultural experts, the clustering of large operations in certain geographic areas may result in large amounts of manure that cannot 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 these pollutants may be impairing human health and the environment because it lacks key data on the amount of pollutants that are being emitted from animal feeding operations. As a first step in developing air emissions protocols for animal feeding operations, in 2007, a 2-year nationwide air emissions monitoring study, largely funded by industry, was initiated. However, as currently structured, the study may not provide the scientific and statistically valid data it was intended to provide and that EPA needs to develop air emissions protocols. Furthermore, EPA has not 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 case required EPA to abandon the approach that it had proposed in 2003 for regulating CAFO water discharges. Similarly, the 2006 Rapanos case has complicated EPA's enforcement of CAFO discharges because EPA believes that it must now gather significantly more evidence to establish which waters are subject to the Clean Water Act's permitting requirements.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Implemented" or "Not implemented" based on our follow up work.

Director: Anu K. Mittal Team: Government Accountability Office: Natural Resources and Environment Phone: (202) 512-9846

Recommendations for Executive Action

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Recommendation: In order to more effectively monitor and regulate CAFOs, the Administrator of the Environmental Protection Agency should complete the agency's effort to develop a national inventory of permitted CAFOs and incorporate appropriate internal controls to ensure the quality of the data.

Agency Affected: Environmental Protection Agency

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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Recommendation: In order to more effectively determine the extent of air emissions from animal feeding operations, the Administrator of the Environmental Protection Agency should reassess the current data collection efforts, including its internal controls, to ensure that the National Air Emissions Monitoring Study will provide the scientific and statistically valid data that EPA needs for developing its air emissions protocols.

Agency Affected: Environmental Protection Agency

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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Recommendation: In order to more effectively determine the extent of air emissions from animal feeding operations, the Administrator of the Environmental Protection Agency should provide stakeholders with information on the additional data that it plans to use to supplement the National Air Emissions Monitoring Study.

Agency Affected: Environmental Protection Agency

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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Recommendation: In order to more effectively determine the extent of air emissions from animal feeding operations, the Administrator of the Environmental Protection Agency should establish a strategy and timetable for developing a process-based model that will provide more sophisticated air emissions estimating methodologies for animal feeding operations.

Agency Affected: Environmental Protection Agency

Status: In process

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
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Publication:General Accounting Office Reports & Testimony
Date:Nov 1, 2008
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