EPA's Approach to Controlling Pollution from Animal Feeding Operations: An Economic Analysis

Abstract

The Clean Water Action Plan recognized the importance of nonpoint source pollution as a cause of water-quality problems (EPA and USDA). As part of a follow-up on this plan, the U.S. Department of Agriculture (USDA) and the Environmental Protection Agency (EPA) have issued a USDA-EPA Unified National Strategy (the Joint Strategy) to manage nutrient pollution from animal feeding operations (USDA and EPA). One of EPA's tasks for this effort is to review and update its regulatory requirements for livestock and poultry operations, which were originally promulgated during the 1970s. There are two related sets of regulatory requirements: (a) effluent limitations guidelines (ELG) for animal feeding operations (or feedlots) and (b) requirements for discharge permits for Concentrated Animal Feeding Operations (CAFOs) under the National Pollutant Discharge Elimination System (NPDES). The ELG for the feedlots category are currently specified at 40 CFR 412, and the definitions for CAFOs in the NPDES program regulations are at 40 CFR 122.23. These regulations prohibit the release of wastewater from containment systems that are designed to hold waste and runoff, except during an extreme storm event, but do not specifically address discharges that may occur when wastewater or solid manure mixtures are applied to cropland. The EPA decided to include feedlots in its