CAFO Confusion and Other Bewildering Acronyms
Posted: November 9, 2004
Pennsylvanian animal farmers usually think that CAFO (Concentrated Animal Feeding Operation) refers to somebody else, maybe even some other state. This is not true. The number of CAFOs in Pennsylvania is steadily increasing for two main reasons: 1) Management, economics and technology are allowing, and some would say forcing, animal farmers to become more specialized and care for more animals in one location. 2) The definition of a CAFO is changing, becoming more inclusive and in many cases covering smaller numbers of animals. This is confusing for farmers and those of us advising farmers. Too often we are temped to try and ignore the whole issues of regulations. Maybe like the ostrich we are sticking our heads into the ever growing pile of manure so we won’t see anything.
There are three acronyms that we must be familiar with. They may be related but are not synonymous or interchangeable and are often confused.
AFO – animal feeding operation. An AFO has no size. Any farm that brings feed to an animal on a regular basis can be considered to be an AFO.
CAFO- concentrated animal feeding operation. This term came on the scene in the early 70s as a result of federal legislation along with the term NPDES Permit (National Pollutant Discharge Elimination System). Any AFO that met certain size requirements, had a direct manure discharge to a ditch or stream or was designated by a federal or state agency was by definition a point source of pollution (CAFO) and was covered by the NPDES permit program. In most states this regulation was soon forgotten. In the 90s the EPA with some legal encouragement from citizen interest groups began to resurrect this program and took various enforcement actions and strongly encouraged states to take actions. As larger animal units began to appear, neighbors and others opposed to
changes in farming practices became interested in CAFO regulations. Eventually a court order resulted in EPA and states updating and increasing enforcement of these regulations. More Pennsylvania AFOs will be considered CAFOs based on proposed Pennsylvania regulations now in the final stages of review.
CAO – concentrated animal operation is a term in Pennsylvania that refers to any size AFO based on density of animals in relation to land receiving manure. A CAO is required to have a PA NMP (Nutrient Management Plan). http://panutrientmgmt.cas.psu.edu/
As if all of this was not causing enough consternation and confusion for the agricultural community we are now facing the CAA (Clean Air Act), CERCLA (Comprehensive and Emergency Environmental Response Compensation and Liability Act) and EPCRA (Emergency Planning and Community Right-to-Know Act). These laws were written and However, court challenges have resulted in expectations that agricultural emissions, especially ammonia and hydrogen sulfide will be regulated under these laws.
At this point one begins to feel more than a little bit of regulation overload and litigation lethargy. However, the fact of life is that anyone feeding or advising those feeding animals will have to become knowledgeable and remain vigilant to environmental quality concerns and regulations relating to AFOs and their surrounding air, water and soil. Farmers have always faced uncontrollable and usually unpredictable variables of weather, disease and the market place. Expanding and changing environmental quality expectations and regulations can be added to the list of variable. There are more people with a greater interest in what’s going on down on the farm. Those working with farmers must help them to make the transition to this new business environment.
Robert E. Graves, Agricultural, Biological, and Engineering Extension