The Priority of a Concentrated Animal Feeding Operation Cafo is to

Index

What is a CAFO?
What pollutants do CAFOs produce?
Are there are different kinds of CAFOs?
What's in CAFO waste?
How do CAFOs pollute water?
How do CAFOs pollute air?
How do CAFOs impact human health?
Are CAFOs sustainable?
Do CAFOs need taxpayer subsidies?
How are CAFOs regulated and permitted?
About CAFO Waste & Spreading
Water Quality Issues
CAFO Basics
CAFO Regulations & Government Subsidies
Get Help

What is a CAFO?

A CAFO, or Concentrated Animal Feeding Operation , is an industrial-sized livestock operation.

The quantity of urine and feces from even the smallest CAFO is equivalent to the urine and feces produced by 16,000 humans.
A CAFO can house anywhere from hundreds to millions of animals.
The animals in CAFOs are most often dairy cows, hogs, or chickens.
CAFO animals are confined at least 45 days or more per year in an area without vegetation.
CAFOs include open feedlots, as well as massive, windowless buildings where livestock are confined in boxes or stalls.
Other terms used to describe a CAFO: mega farm, animal factory, hog motels, poop factories, industrial farms.

(Also see CAFO in the glossary and CAFO Basics below.)

What pollutants do CAFOs produce?

CAFOs produce huge amounts of animal sewage and other pollutants.
Brown liquid enters Lime Lk Drain, with plume clearly visible.
CAFO owners and operators spend millions of dollars on technologies that make it possible to produce massive quantities of milk, eggs, and meat, yet they resist investing in technologies and practices to properly treat the wastes that are by-products of this industry:

The amount of urine and feces produced by the smallest CAFO is equivalent to the quantity of urine and feces produced by 16,000 humans.
CAFO waste is usually not treated to reduce disease-causing pathogens, nor to remove chemicals, pharmaceuticals, heavy metals, or other pollutants.
Over 168 gases are emitted from CAFO waste, including hazardous chemicals such as ammonia, hydrogen sulfide, and methane.
Airborne particulate matter is found near CAFOs and can carry disease-causing bacteria, fungus, or other pathogens.
Animals frequently die in CAFOs. Their carcasses, often in large numbers, must be dealt with.
Infestations of flies, rats, and other vermin are commonplace around CAFOs and therefore around CAFO neighbors.

Often you'll hear owners of CAFOs argue that the wastes produced by the livestock provide nutrients that help them offset the use of synthetic fertilizers. The sheer amount of wastes produced, however, often overwhelms the ability of the land and crops to absorb CAFO wastes.

Are there different kinds of CAFOs?

Yes.

One type of CAFO houses livestock in buildings the animals seldom leave. Removing wastes from these buildings is a major challenge.

Dairy and hog CAFOs often use clean water to wash animal wastes and contaminants from the buildings into waste-storage structures or lagoons.
Poultry CAFOs use dry-waste systems. The waste falls from animal cages to the floor, where it is scraped out of the building periodically or collected on conveyer belts and moved to composting or storage sites.

Another type of CAFO is the feedlot , which keeps the animals outdoors in pens. Here the manure waste accumulates on the ground, often washing off into nearby ditches and streams.

What's in CAFO waste?

In addition to plant nutrients such as phosphorus and nitrogen, CAFO waste is likely to contain:

antibiotic-resistant bacteria
hormones
chemicals used in livestock care
milkhouse wastes
cleaning agents
ammonia and heavy metals
silage leachate
millions of gallons of water contaminated by all of the above.

CAFO waste is often stored untreated in gigantic anaerobic waste storage structures or pits for up to six months. After storage, it is spread on farm fields for disposal. This is where CAFO wastes often enters surface water.
Lime Lake is shown bright green with an algae bloom, downstream from drainn shown in photo above.
Nutrients in this CAFO waste can cause bright-green algae blooms in ditches, streams, and lakes. As these surface-water algae blooms die off, the oxygen in the water is depleted. What does this do? It can lead to fish kills. Additionally, drinking-water plants must remove these nutrients before water is fit for consumption.

Pathogens such as E.coli bacteria, cryptosporidium, and salmonella, all of which can cause sickness or death in humans and animals, may be present in CAFO wastes.

How do CAFOs pollute water?

Water pollution is possible at virtually any point in a CAFO's operation.

In the production area, spills, overflows, and tracking of wastes on tractor and truck tires can cause surface runoff of contaminants.
Stormwater that mixes with manure wastes, silage leachate, or milkhouse wastes can flow into drains.
Pipes or hoses carrying wastes can break or become unattached. Waste storage structures can overflow or burst.
Field tiles or catch basins can be installed that drain wastes directly into surface waters.

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It may take dozens of trips per day by semis or tanker trucks to dispose of CAFO waste. These trucks haul the wastes from the production area waste-storage structures to fields that are often many miles away.

One of the main sources of CAFO-caused pollution in Michigan comes from discharges of manure and other wastes through the soil into field drainage tiles , which carry the wastes directly into county drains and streams.

When CAFO wastes are applied to farm fields, water pollution can be caused by overapplication of wastes, direct runoff into surface waters, or by traveling through the ground- or catch basins into field tiles or drainage ditches that discharge directly into surface waters. Tests have shown that waste applied to the surface of a field can take a little as 45 minutes to reach the field tiles three to four feet below the surface.

Manure wastes are also sprayed from travel irrigators , trucks, tractors, or draglined. This waste can flow directly into surface waters due to wind, by direct discharge from running over a drain or waterway, or through malfunctions of the equipment.

Groundwater pollution can be caused by leaking waste storage structures, and improper or over-application of wastes on fields. The use of injection systems for shooting wastes directly into the soil is encouraged as a method to keep odor from CAFO land application down, however there is significant concern that this could simply lead to quicker travel time through the soils into field drainage tiles. Some CAFO owners have converted field drainage tiles into de facto septic systems by plugging them with gate valves and other devices. These systems at best only delay the pollution and don't keep pollution from flowing to groundwater. They certainly don't remove pathogens. Groundwater is difficult to monitor, so the extent and source of contamination are often harder to pinpoint than surface water contamination.

How do CAFOs pollute air?

Air pollution from CAFOs can come through numerous methods. Some can cause bad odors, but others emit several dangerous gases as manure and biological materials break down in the absence of oxygen such as in the bottom of a manure pit. Methane, ammonia, and hydrogen sulfide are some of the gases. Exposure to hydrogen sulfide can cause neurological problems, including extreme anger, depression, and illness. The image at right shows a family raising the American flag in their yard, while a hydrogen sulfide meter shows concentrations of the contaminant at 2 parts per million in October 2008. The source CAFO can be seen beyond the pine tree. Unfortunately, this home is also surrounded on three sides by fields often used by the CAFO for manure disposal.

Some of the sources of CAFO air pollution are:

Barns where the animals are housed

The air pollution inside the buildings is potentially deadly to the animals and humans inside if the fans ever stop operating. Normally the fans simply blow the contaminated air to the outside where it can pollute the whole community. Poultry operations blow ammonia and particulate matter, including feathers and chicken feces out of the buildings.

Waste storage structures

Hog operations often build the waste storage structure immediately beneath the area where the animals are kept, with slats in the floors to allow wastes to simply drop into the pit.

Handling of the wastes

The CAFO wastes stored in waste storage structures is not treated or aerated, often resulting in extreme off-gassing of pollutants such as hydrogen sulfide (H2S ) when the wastes are transported and sprayed onto farm fields.

Techniques used in land application

For example, once or twice each year many liquid waste CAFO systems will scrape the solids out of the bottom of the waste storage structures and spread these thick, fermented wastes onto farm fields, causing even worse air pollution.

How do CAFOs impact human health?

CAFOs may cause health effects to their neighbors from pollution damage to the air, land and water.
Over 168 gases are emitted from CAFO waste, including hazardous chemicals such as ammonia, hydrogen sulfide, and methane.
Hydrogen sulfide poisoning can cause irreversible brain damage, dizziness, headache, nausea, sore throats, sinusitis, burning eyes, and other illnesses.
When phosphorus and nitrogen are over-applied to fields, the nutrients can move through the soil into field tiles to surface water, or through soil to groundwater and drinking water.
Elevated levels of nitrates in drinking water can cause "blue baby syndrome", a potentially fatal blood disorder.

Are CAFOs sustainable?

No.

CAFOs are resource-intensive and unsustainable.
CAFOs animal-raising practices are neither economically viable or sustainable.
CAFOs use large amounts of electricity for lighting, equipment, milkers, pumps, and irrigators.
CAFOs use fuel in tremendous quantities to run tractors, gas motors, and pumps, and to transport milk, waste, supplies, and chemicals.
CAFOs use millions of gallons of Michigan's clean fresh groundwater every day to dilute waste and to wash manure from milking parlors and CAFO barns.

Do CAFOs need taxpayer subsidies?

Yes.

CAFOs can't survive without taxpayer subsidies. CAFOs receive many subsidies, such as milk price support guarantees, federal EQIP money through the Farm Bill , Development Right Agreements, tax abatements, grants, bonds, even economic development funds for roads.

These taxpayer supports not only encourage the growth of this industry, they undercut the ability of traditional livestock operations to compete with CAFOs. Without the subsidies, CAFOs would fail financially. Sierra Club is a member of the Less=More coalition that aims to end subsidies to polluting factory farms to level the playing field for sustainable livestock farmers. Less support for polluting factory farms means a more sustainable Michigan. Learn more at MoreforMichigan.org.

How are CAFOs regulated and permitted?

Federal laws establish minimum standards for the regulation of any activity that causes air pollution or water pollution. However, through aggressive lobbying by the promoters of CAFOs, federal laws for the environmental oversight of CAFOs are extremely weak.

Currently, the U.S. Environmental Protection Agency provides no regulation of air pollution problems from CAFOs. Under the Right-to-Know provisions of CERCLA 42 U.S.C. §11001 et seq. (1986), also known as Title III of the Superfund Amendments and Reauthorization Act (SARA) , the Emergency Planning and Community Right-to-Know Act - otherwise known as EPCRA (pronounced EP-kra) - was enacted by Congress as the national legislation on community safety. This law is designed to help local communities protect public health, safety, and the environment from chemical hazards. CAFOs are required to report emissions of some pollutants, most notably ammonia. This requirement led to disclosure that the largest emitter of ammonia in the country is a dairy CAFO in Oregon.

The federal Clean Water Act does provide some regulation of CAFOs, although interpretations of the extent of those requirements are being litigated. State laws must be at least as restrictive as the federal law, but in Michigan and some other states it has required citizens to bring challenges to state's delegation under the Clean Water Act to force the agencies to implement the laws. Federal law requires that any CAFO which has had an illegal discharge into surface waters must obtain a National Pollutant Discharge Elimination System (NPDES) permit in order to continue operations. Several states (including Michigan) now require NPDES permits for all CAFOs, including new ones.

It is important to review the regulations in your state in order to understand what is allowed and not allowed. ( EPA links to state program websites. )

State and federal agricultural agencies often play a role in establishing voluntary standards that CAFOs and other livestock operations are expected to abide by. In some instances, the agricultural agencies will act as the gatekeeper for securing any enforcement actions by the state, particularly in the area of air pollution. In Michigan, for example, the Department of Agriculture is given the responsibility for investigating air pollution complaints from CAFOs, although they have no enforcement authority. Except in an emergency, the agriculture director must make a referral to the Department of Environmental Quality before any action can be taken by the environmental agency regarding those complaints.

CAFO Waste & Spreading

Is it illegal to spread CAFO manure on the ground?

No, it is not illegal to spread CAFO manure waste on the ground. While this website describes many different situations in which a CAFO may be spreading their waste on land, and many possibly harmful effects of that activity, it is not of itself illegal. It is illegal if a CAFO spreads waste in such a manner that it moves off the land and into waters of the state, and this "discharge" causes or contributes to a violation of Michigan's water quality standards in waters of the state.

What is in CAFO manure?

CAFO manure contains the animals' feces and urine, plus, the definition also includes other materials such as bedding, compost, and other raw materials. CAFO manure is also loaded with the plant nutrients nitrogen and phosphorus, which can cause algae blooms if released to surface water, and pathogens such as Escherichia coli (E. coli) , and other fecal coliforms.

Manure may also contain:

growth hormones used to increase the production of milk in the cows
antibiotics that keep the animals from getting ill
chemicals used to clean the milkhouse equipment or used as additives to lagoons
milkhouse wastes discharged on the floor while milking
birthing fluids from cows calving
blood from birthing
silage leachate from the chopped corn in bunkers
production area waste from the equipment being washed or used
contaminated stormwater stormwater is considered clean unless it's allowed to come into contact with manure
copper sulfate used in the footbaths for cows before they are led into the milking parlor.

There are 168 chemicals in and around manure according to a 2001 USEPA Report (Appendix A, page 235-244).

Can a methane digester solve the CAFO's waste problem?
Not really. This is like capturing a fart in a jar. It may help reduce some odors, but it has severe limits.

Methane digesters do not :

reduce nitrogen or phosphorus (in most schemes)
reduce liquid in the manure
improve the waste as a fertilizer (it is still distributed on fields)
save taxpayers money

Can composting the manure solve the CAFO's waste problem?

In short, no. And, as you read the bulleted list below, remember that a Michigan CAFO can have a compost pile within 200 feet of its neighbor.

In addition to manure and other materials, CAFO compost piles may have up to 20,000 pounds of dead animals in one pile (and if just one animal had mad cow disease and this pile is spread on the land, the prions could enter the food or milk supply). For more information on prions, see the Center for Disease Control Prion Diseases webpage.
CAFO compost piles draw vermin, rats, flies, coyotes, and vultures.
Most CAFO compost sites do not have runoff containment structures, and the nutrient-rich liquids can cause algae blooms if they reach surface waters.
the odors emitted can become very strong if the composting is not done correctly.

What is a CAFO discharge?

Discharge means any direct or indirect release of any waste, waste effluent, wastewater, pollutant, or any combination thereof into any of the waters of the state or upon the ground. View theDEQ Wastewater Discharge Permit Rules.

A CAFO discharge may be called many things: a spill, accident, terrorist attack, or blamed on birds, cherry trees, deer, horses, geese, raccoons, or the neighbors. But rarely is it called what it is: a mess from the CAFO with 3,500 cows.
A CAFO discharge can be brown and smell like animal waste; it can be white and smell like bad milk; it can be green and sour which may be leachate from the silage (chopped corn that they feed to cows).
A CAFO discharge may also be diluted with stormwater. In this case, the CAFO saying is "dilution is the solution to pollution."

Are CAFO operators allowed to spread animal waste on snow?

spreading manure on snow with ponding The real answer should be "no, not under any circumstance."

Instead the answer to this question is "maybe". How would you find out?

First find out if the CAFO has any restrictions in its NPDES permit or consent order -- if they have one--for spreading waste on snow.
Next learn which fields in each CAFO's Comprehensive Nutrient Management Plan (CNMP) are allowed to have winter application on them, and whether it can be solids or liquids.
Then find out the Manure Application Risk Index (MARI) for each field. This research grant proposal from the Michigan State University to the U.S. Geological Survey (USGS) describes use of the Manure Application Risk Index for evaluating fields for winter manure land application.

Whether or not a CAFO is allowed to spread waste on snow depends either on what is in their Comprehensive Nutrient Management Plan , or on whether the CAFO has an order from the state with specifics for winter application. This may be determined on a field by field basis. Many CAFOs will spread waste on snow just to get rid of it and then hope they don't get caught. The problem is that when the snow melts, the manure will run off into the nearest ditch or stream, because frozen ground cannot absorb water. Often the manure on the snow will even cause the snow and ice to melt. If you observe CAFO operators spreading waste on snow or frozen ground, and you know their CNMP and NPDES permit doesn't allow them to, you should contact the MDEQ district office , or call the Pollution Emergency Alert System (PEAS).

Are CAFO Operators allowed to dump manure in piles on fields?

This is a grey-area question. By dumping manure piles, a CAFO creates an off-site production area of waste. This off-site production area cannot discharge to waters of the state. See page 6 of the DEQ Wastewater Discharge Permit Rules for the official definition of "production area".

How long can manure be piled at a site? The Comprehensive Nutrient Management Plan may contain information on this practice.
A manure pile can cause fly outbreaks, and invite coyotes, vultures, and rats if dead animals are in these piles.
If the piles are placed near homes, the emissions may cause illness to residents.

Are CAFO Operators allowed to spread waste before precipitation or rainfall?

This can also be a cloudy area. See Instructions for Determining Precipitation Forecasts ( pages 55-56 of this CAFO permit guide) to see how weather forecasts are applicable to CAFOs. You may use the instructions along with the CAFO's CNMP to determine if they are spreading waste in violation of their NPDES permit.

The photo at right, taken in Lenawee County just before a predicted rainfall, shows manure waste application on a fairly steep slope.

Is there a time of year when CAFOs can't spread wastes?

Not necessarily, this may be different for each CAFO. Each CAFO's NPDES permit guides what can and cannot be done.

Are there fields CAFOs can never spread waste on?

Yes. Soil testing for phosphorus must be done for fields that will be used for land application of CAFO wastes. If the soil tests indicate high amounts of phosphorus, a CAFO cannot apply waste to that field. That information is included in the Comprehensive Nutrient Management Plan.

How far away does the CAFO waste have to stay from water, lake, wetland, and so on?

This refers to a "setback", and the required setback information would be found in the CAFO's NPDES permit.

Is it legal for CAFO operators to spill the waste in the road?

No. However, you would need to contact your local road commission or police department to file a complaint on this issue. Unless the spill gets into waters of the state, or is an extreme amount, it is necessary to contact the government agency that has jurisdiction over roads.

CAFOs' Impacts on Humans

Do I need to worry about a CAFO going in near my house?

Yes. You need to organize and educate your neighbors as soon as possible. See How to Stop Approval of a New CAFO.

What will happen to my property values with a CAFO nearby?

Property values will drop the closer in proximity to a CAFO that you live. Information can be found from realtor.com and other sources.

How does the CAFO waste end up on my property?

CAFO waste can be sprayed, irrigated, blown by the wind, spread further through surface ponding of rainfall, or from runoff that may reach your property. High powered fans used to cool the hundreds of animals in the buildings often blow out bedding or other contaminated materials.

Are there human health effects from exposure to CAFO manure?

Yes. Many people have become ill living near and working at CAFOs. Some people develop breathing problems, coughs, headaches, hydrogen sulfide poisoning, and ammonia poisoning. Here are some articles from Environmental Health Perspectives :

air pollution

Air pollution from industrial swine operations and blood pressure of neighboring residents
Land application of treated sewage sludge: community health and environmental justice
EHP – Dust Emissions from Cattle Feed Yards: A Source of Antibiotic Resistance?

drug resistance

Multidrug-Resistant and Methicillin-Resistant Staphylococcus aureus (MRSA) in Hog Slaughter and Processing Plant Workers
Antibiotics, Bacteria, and Antibiotic Resistance Genes (Watch the Birth of a Superbug)

What do I do when they are spreading CAFO waste next to my house?

First, this activity may not be illegal. But there are provisions the land applicator must follow to protect your home and property. So first, to be safe - get your children indoors, close your windows, and take down your laundry. Then start documenting your observations, in case the activity is causing a problem.

Take time-stamped pictures of the field where waste is being spread;
Take time-stamped pictures of the application equipment;
Get the weather forecast or report from the National Weather Service and save the report on your computer, or print it. See Instructions for Determining Precipitation Forecasts ( pages 55-56 of this CAFO permit guide) to see how weather forecasts apply to timing of CAFO activities. You may use the instructions along with the CAFO's CNMP to determine if they are spreading waste in violation of their NPDES permit.
Get your notebook, note the date and time and all your observations: if the CAFO is spreading waste over any field tiles , next to county drains , next to any open waterways, near a tile riser , over a catch basin , near a dike , or near your water well. Draw sketches, indicate which way is north, roads, buildings, homes.

Additionally, document:

how far the application is from your property;
if you or your family are feeling ill, which may indicate emissions of a toxic gas. (An odor will not make you ill. An emission will give you a headache, nausea, burning sinuses, sore throat.)
if you smell odor, and what it smells like (for example, it could smell like manure, or like soured milk, or even like diesel fuel.)

How do I document the activities I observe about the CAFO?

In a nutshell, you will take pictures, take water samples, and even smell the water at your own risk (smell it for manure or some other wrong smell). Carry a notebook and keep information, such as a journal or a checklist. Have someone else verify your information, if at all possible.

Can I take photographs of a CAFO?

Yes. Pictures ideally should show the time, date, and location of what is happening. This is especially important if rainfall is predicted and a facility is land-applying waste anyway, perhaps even in violation of its NPDES permit or consent order. (see MDEQ's CAFO website for more information on this situation).

Without trespassing onto private property, and only working from the road-right-of-way, or from the property of a landowner who gave you permission, take photos of:

operations to document their practices. These may show illegal practices such as pumping into a waterway or county drain or into a catch basin.
buildings to show number of buildings and location. Pictures here may also show dead animals.
activities to show land application of waste, types of hauling equipment. Document digging or tiling activities , too.
people only if they are harassing or stalking you, such as following you in your vehicle or blocking your path. If someone is harassing you, you should also call the police or 911. Photos of people may also be taken if they are doing something you believe is illegal that would be a violation of the CAFO's NPDES water discharge permit or consent order , if the CAFO has one.

How can I protect myself while monitoring?

Notify the police or local sheriff that you and a companion will be monitoring water near CAFOs, as explained below.
Bring someone with you if at all possible.
Calibrate any equipment ahead of time to save time while at the monitoring location.
Make sure all your equipment is turned on ahead of time and ready to be used.
Employ the two-minute rule : try to do everything you need to do as fast, but as accurately, as possible. This includes using the dissolved oxygen (DO) meter to measure DO and water temperature, grabbing a water sample, using a meter to measure the pH, using the ammonia strips, taking pictures, and so on.

Send notice to the local sheriff or state police of: which CAFOs you will be monitoring and where, what type and color of vehicle you'll be in, plus the license plate number. Tell them your and other monitors' names, addresses, and phone numbers, and cell phone numbers. Tell them clearly what you are doing and let them know you are monitoring the water or air. This way, if someone complains about your activities, the police will know where to find you, and can call you.

You must never trespass. Check for road right-of-way distances. Realize that state highways are different than local roads. A CAFO operator may file charges against you if you are trespassing on their property. If you plan to access a stream away from the road, you must get permission from the landowner.

What should I do if I see:

a broken lagoon or waste storage pit
waste running out of a pipe, a tube, a truck, an irrigator
ponding or pooling of waste on fields
dead animals
syringes and other related equipment dumped
digging, tiling or dumping at night
earth-moving equipment at work

If you see any of these practices or waste products at a CAFO, you should document it with photos that record the time and date. If you believe a violation has occurred, contact the appropriate agency with your concerns.

Can the CAFO go after me if I report them?

Yes. A CAFO can go after you if you report them. Some agencies take anonymous tips, and you can report them that way. Remember that documentation is extremely important, so be diligent in your investigation before you report a violation. Always document your investigation, and always be credible.

Water Quality Issues

My well water tastes funny? Can I get my well water tested?

If your well water tastes or smells funny, do not drink your water until you have it tested. When testing, document the test and take pictures.

You can test your well yourself. In Michigan, your local health department may furnish free bottles with an instruction sheet and where to send the sample. It costs between $14.00 and $16.00 for to have samples tested. The instruction sheet explains the sampling protocol. Other states likely have similar services.

Why is my lake green? White? Black? Brown?

Lime Lake is green in spring after being subject to discharges all winter of 2004. While there may be other reasons that water can turn different colors, CAFOs are often the culprit if they are located either upstream or up the hill from a lake or stream.

A green lake may be a sign of a silage leachate discharge that has caused an algae bloom. The photo at right shows an example, at Lime Lake near Hudson, Michigan.
A white color may be from milk or milkhouse waste being discharged into water.
Black water may be a sign of a direct discharge of animal waste into the water.
Brown water may be diluted animal waste in the water.

Is the wetland on my property dead because of CAFO waste?
Water testing is needed to verify if there is waste in the wetland. Though water quality standards are slightly different, E. coli and other fecal coliforms may still signal the presence of fecal material in the wetland.

Is it safe to touch the water?

No. Never assume that water is safe near a CAFO or a land application site. Always wear clean rubber gloves. If bloodworms are present in the water, this can be an indicator that you may get hepatitis if you are not wearing gloves. You could also get Cryptosporidium, Giardia, Pfisteria, or other illnesses from the fecal matter in the water. If you have an open cut anywhere, you may want to have your companion take any water samples.

What do I do if I fall in the water?

Depending where and how you fall in, clean up as soon as possible.

Wash as much off before you get into your vehicle.
Go directly to where you can shower.
Monitor your health.
If you become ill or were totally submerged, contact your physician.
If you become ill immediately, go to the emergency room.

Is a roadside ditch considered part of the surface water ?

You would have to contact the proper agency to make this determination. If the roadside ditch connects to waters of the state it may be considered surface water, open drain, or county drain.

What do I do if you see dead fish downstream from the CAFO?

Document the dead fish by taking pictures; count how many and what kind if you can identify them. If there is a large number of dead fish, such as any number above 8 or 10, contact the agency in charge in your state. In Michigan this would be the Department of Natural Resources. You should also notify the MDEQ.

CAFO Basics

How many locations/facilities make up a CAFO?

One facility can be a CAFO. Two or more AFOs under common ownership are considered to be a single AFO for the purposes of determining the number of animals at an operation, if the AFOs adjoin each other, or if they use a common area or system for the disposal of wastes.

In Michigan, satellite barns and satellite lagoons would also be considered as part of a single AFO if they meet the definition under the Rules of DEQ Wastewater Discharge Permits.

Where do CAFOs keep their animals?

All the animals are kept inside large cramped barns, they are not allowed outside to graze.

Where does CAFO waste come from?

The animals within the CAFO produce the majority of the waste. One 1400-pound cow produces approximately 17.7 gallons of feces and urine daily. CAFO waste can also come from the production areas, such as lagoons or other waste storage structures, silage bunkers, the milkhouse, contaminated stormwater, manure piles, and compost.

What kinds of animal wastes or CAFO wastes are there?

There are many different contaminants and materials in CAFO wastes. Milkhouse waste, silage leachate, blood from birthing, antibiotics, chemicals, are just some of the animal wastes. See What pollutants do CAFOs produce? and What's in CAFO waste?

What typically grows in the fields near CAFOs?

Alfalfa, soybeans, corn, wheat, rye, vegetables.

What types of water pollution can come from CAFOs, and what health problems can arise?

Surface and groundwater pollution can come from CAFOs. Groundwater contamination can cause E. coli poisoning and blue baby syndrome. Surface water contamination can cause illness from Cryptosporidium, Giardia, and Pfisteria. See How do CAFOs pollute water?

What kind of air pollution can come from CAFOs, and what health problems can arise?

There are over 168 chemicals in and around manure. Some of the main gases are methane, ammonia, hydrogen sulfide, carbon monoxide, and carbon dioxide. You may have trouble breathing when the CAFO operators are spraying the fields with waste. If you feel ill from waste application, notify your local health department or physician immediately. See How do CAFOs pollute air?

CAFO Regulations & Government Subsidies

What is a CAFO permit and where do I find it?

Michigan CAFOs are required to have only one permit. It is a National Pollutant Discharge Elimination System , or NPDES permit, given to authorize discharges to waters of the state only under particular circumstances. By signing the permit application, a CAFO owner shows good intentions to do the right thing. But the permit is only as good as the management at the CAFO. Permits do not guarantee compliance with the law. They do not protect public health. Remember, from a CAFO's point of view, it is easier to ask forgiveness than to ask permission!

You can find NPDES permits at the Michigan Department of Environmental Quality Concentrated Animal Feeding Operation website. Be sure to see How to apply for a NPDES permit. Also see the U.S. Environmental Protection Agency NPDES webpage and its Animal Feeding Operations section.

There are two categories of NPDES permits for CAFOs. Some CAFOs are required to apply for an Individual NPDES Permit, that is written specifically for that one particular CAFO. Others are allowed to apply for a Certificate of Coverage (COC) to be covered under the CAFO General Permit, where the terms of the permit are applied to all the CAFOs with COCs. The General Permit language assumes all the CAFOs covered are alike, so they all have the same requirements. See the MDEQ CAFO website for more information.

Do CAFOs get money or subsidies from the government?

Most CAFOs receive subsidies in some form. Milk subsidies, road grants through local or state economic development agencies, EQIP , rural development grants, renewable energy grants, bonds, crop subsidies, etc.

The agriculture department says they follow generally accepted agricultural management practices (GAAMPS) and the "MOU". What is this?

See GAAMPS The Michigan Right to Farm Act, P.A. 93, was enacted in 1981 to provide farmers with protection from nuisance lawsuits. This state statute authorizes the Michigan Commission of Agriculture to develop and adopt Generally Accepted Agricultural and Management Practices (GAAMPs) for farms and farm operations in Michigan. These voluntary practices are based on available technology and scientific research to promote sound environmental stewardship and help maintain a farmer's right to farm.

MOU is a Memorandum of Understanding between the Michigan Department of Agriculture and the Michigan Department of Environmental Quality , entered into for the purpose of delineating the respective roles and responsibilities regarding state agency response actions to environmental and nuisance complaints about farm operations.

Get Help

What organizations can help you find information about CAFOs?

There are many organizations that can help:

Sierra Club
Socially Responsible Agricultural Project
Food & Water Watch
Waterkeeper Alliance
Society for Responsible Agriculture
U.S. EPA (Visit state agencies for your state)

Also visit CAFO Help Contact Info for more information.

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Source: https://www.sierraclub.org/michigan/why-are-cafos-bad