Concentrated Animal Feeding Operations
EPA Needs More Information and a Clearly Defined Strategy to Protect Air and Water Quality Gao ID: GAO-08-1177T September 24, 2008Concentrated animal feeding operations (CAFO) are large livestock and poultry operations that raise animals in a confined situation. CAFOs may improve the efficiency of animal production, but the large amounts of manure they produce can, if improperly managed, degrade air and water quality. The Environmental Protection Agency (EPA) regulates CAFOs and requires CAFOs that discharge certain pollutants to obtain a permit. This testimony summarizes the findings of a September 4, 2008 GAO report (GAO-08-944) on (1) trends in CAFOs, (2) amounts of waste they generate, (3) findings of key research on CAFOs' health and environmental impacts, (4) progress made in developing CAFO air emissions protocols, and (5) the 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 accurate and consistent data on the number, size, and location of CAFOs, GAO could not determine the exact trends for these operations. 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, from about 3,600 in 1982 to almost 12,000 in 2002. The number of animals raised on large farms also increased during this 20-year period, but the rate of increase varied by animal type. Moreover, EPA does not have comprehensive, accurate data on the number of permitted CAFOs nationwide. As a result, the agency does not have the information that it needs to effectively regulate these CAFOs. EPA is currently working with the states to establish a new national data base. The amount of manure generated by large farms that raise animals depends on the type and number of animals raised, but these operations can produce from 2,800 tons to 1.6 million tons of manure a year. Some large farms that raise animals can generate more manure annually than the sanitary waste produced by some U.S. cities. Manure can be used beneficially to fertilize crops; but according to some agricultural experts, when animal feeding operations are clustered in certain geographic areas, the manure they produce may not 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 pollutants from animal feeding operations may be impairing human health and the environment because it lacks key data on the amount of pollutants being discharged by these operations. Considered a first step in developing air emission protocols for animal feeding operations, a 2-year nationwide air emission monitoring study, largely funded by the industry, was initiated in 2007. However, the study, as currently structured, may not provide the scientific and statistically valid data it was intended to provide and that EPA needs to develop these protocols. In addition, EPA has not yet 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 decision required EPA to abandon the approach that it had proposed for regulating CAFOs in 2003. Similarly, the Rapanos decision has complicated EPA's enforcement of CAFO discharges because EPA believes that it must now gather more evidence to establish which waters are subject to the Clean Water Act's permitting requirements.
GAO-08-1177T, Concentrated Animal Feeding Operations: EPA Needs More Information and a Clearly Defined Strategy to Protect Air and Water Quality
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Testimony:
Before the Subcommittee on Environment and Hazardous Materials,
Committee on Energy and Commerce, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Wednesday, September 24, 2008:
Concentrated Animal Feeding Operations:
EPA Needs More Information and a Clearly Defined Strategy to Protect
Air and Water Quality:
Statement of Anu K. Mittal, Director:
Natural Resources and Environment:
GAO-08-1177T:
GAO Highlights:
Highlights of GAO-08-1177T, a testimony before the Subcommittee on
Environment and Hazardous Materials, Committee on Energy and Commerce,
House of Representatives.
Why GAO Did This Study:
Concentrated animal feeding operations (CAFO) are large livestock and
poultry operations that raise animals in a confined situation. CAFOs
may improve the efficiency of animal production, but the large amounts
of manure they produce can, if improperly managed, degrade air and
water quality. The Environmental Protection Agency (EPA) regulates
CAFOs and requires CAFOs that discharge certain pollutants to obtain a
permit.
This testimony summarizes the findings of a September 4, 2008 GAO
report (GAO-08-944) on (1) trends in CAFOs, (2) amounts of waste they
generate, (3) findings of key research on CAFOs‘ health and
environmental impacts, (4) progress made in developing CAFO air
emissions protocols, and (5) the 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.
What GAO Found:
Because no federal agency collects accurate and consistent data on the
number, size, and location of CAFOs, GAO could not determine the exact
trends for these operations. 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, from about 3,600 in
1982 to almost 12,000 in 2002. The number of animals raised on large
farms also increased during this 20-year period, but the rate of
increase varied by animal type. Moreover, EPA does not have
comprehensive, accurate data on the number of permitted CAFOs
nationwide. As a result, the agency does not have the information that
it needs to effectively regulate these CAFOs. EPA is currently working
with the states to establish a new national data base.
The amount of manure generated by large farms that raise animals
depends on the type and number of animals raised, but these operations
can produce from 2,800 tons to 1.6 million tons of manure a year. Some
large farms that raise animals can generate more manure annually than
the sanitary waste produced by some U.S. cities. Manure can be used
beneficially to fertilize crops; but according to some agricultural
experts, when animal feeding operations are clustered in certain
geographic areas, the manure they produce may not 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
pollutants from animal feeding operations may be impairing human health
and the environment because it lacks key data on the amount of
pollutants being discharged by these operations.
Considered a first step in developing air emission protocols for animal
feeding operations, a 2-year nationwide air emission monitoring study,
largely funded by the industry, was initiated in 2007. However, the
study, as currently structured, may not provide the scientific and
statistically valid data it was intended to provide and that EPA needs
to develop these protocols. In addition, EPA has not yet 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
decision required EPA to abandon the approach that it had proposed for
regulating CAFOs in 2003. Similarly, the Rapanos decision has
complicated EPA‘s enforcement of CAFO discharges because EPA believes
that it must now gather more evidence to establish which waters are
subject to the Clean Water Act‘s permitting requirements.
What GAO Recommends:
In the September 2008 report, GAO recommended that EPA complete its
inventory of permitted CAFOs, reassess the air emissions monitoring
study, and establish a strategy and timetable for developing a process-
based model for measuring CAFO air emissions. EPA partially agreed with
GAO‘s recommendations.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-1177T]. For more
information, contact Anu K. Mittal, (202) 512-3841, mittala@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
We are pleased to be here today to discuss our recently issued report
on concentrated animal feeding operations (CAFO).[Footnote 1] As you
know, CAFOs are large animal livestock and poultry operations that
raise animals in confined situations. While CAFOs have improved the
efficiency of the animal production industry, they have also raised
environmental and health concerns because the large amounts of manure
they can produce, if not properly managed, may degrade air and water
quality. Animal manure can be, and frequently is, used beneficially on
farms to fertilize crops and restore nutrients to soil. However, if
manure and wastewater from animal feeding operations are improperly
managed, pollutants such as nitrogen, phosphorus, bacteria, and organic
matter could enter nearby water bodies and could potentially impair
human health and damage the environment. Improperly managed manure can
also result in emissions to the air of particles and gases, such as
ammonia and hydrogen sulfide, which could also result in potentially
harmful environmental and human health effects.
The Environmental Protection Agency (EPA) has the authority under
several federal laws to regulate water and air pollutants from CAFOs.
EPA has specific authority under the Clean Water Act to regulate CAFOs
like any other industry if they discharge into federally regulated
waters.[Footnote 2] Such CAFOs must obtain permits, from EPA or the
states that EPA has authorized to administer this act, that stipulate
how they will manage their discharges. In contrast, three other laws--
the Clean Air Act, the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERLCA), and the Emergency
Planning and Community Right-to-Know Act of 1986 (EPCRA)--while not
specifically citing CAFOs as regulated entities, provide EPA with
certain authorities related to air emissions from these operations.
Our testimony today summarizes the following five issues that we
examined in our recent report: (1) trends in CAFOs; (2) the amount of
waste they generate; (3) the findings of recent key academic, industry,
and government research on the impacts of air and water pollutants from
CAFOs on human health and the environment, and the extent to which EPA
has assessed the nature and severity of such impacts; (4) the progress
that EPA and the states have made in regulating and controlling the
emissions of, and in developing protocols to measure, air pollutants
from CAFOs that could affect air quality; and (5) the extent to which
recent court decisions have affected EPA and the states' ability to
regulate CAFO discharges that impair water quality. In conducting this
work, we reviewed laws and regulations, federal and state agencies'
documents, and met with officials from EPA and the U.S. Department of
Agriculture (USDA), industry, citizen and environmental groups, and
academia. We also spoke with state officials and visited CAFOs in eight
states.[Footnote 3] In addition, we analyzed USDA data for large farms
as a proxy for CAFOs, conducted library and Internet searches to
identify key studies completed since 2002 on air and water pollutants
from animal waste, and contacted state officials in all 50 states to
determine which states had developed air emission regulations
applicable to CAFOs and how recent court decisions had affected their
ability to regulate CAFO discharges that impair water quality. We
conducted our work between July 2007 and August 2008 in accordance with
generally government auditing standards. These standards require that
we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe the evidence obtained
provides a reasonable basis for our findings and conclusions based on
our audit objectives.
In summary we found the following:
* Determining the trends in the number of CAFOs over time is difficult
because no federal agency collects consistent, reliable data on CAFOs.
However, USDA data for large farms that raise animals can serve as a
proxy for estimating trends in the number and size of CAFOs. Using
these data, we found that the number of these operations appears to
have increased by about 230 percent from 1982 through 2002, from about
3,600 to almost 12,000. Moreover, the number of animals per farm
increased, but the increase varied by animal type, with hog farms
showing the largest increase at 37 percent. Although EPA has been
compiling data from its regional offices in an effort to develop
information on the number of permitted CAFOs nationwide, we found that
the data are inconsistent and inaccurate and do not provide necessary
information on the number and characteristics of permitted CAFOs. We
recommended that the agency develop a complete and accurate inventory
of permitted CAFOs and incorporate appropriate internal controls to
ensure the quality of the data. EPA concurred with this recommendation
and stated that it is currently working with its regional offices and
the states to develop and implement a national data system to collect
and record facility-specific information on permitted CAFOs.
* While the amount of manure generated by large farms that raise
animals depends on the type and number of animals raised, such farms
can produce from over 2,800 tons to more than 1.6 million tons of
manure a year. In order to provide a perspective on how much manure
these operations produce, we compared the manure from some large farms
that raise animals with sanitary waste produced by the populations of
some U.S. cities. For example, a very large hog farm raising as many as
800,000 hogs--of which there are at least two in the United States--
could generate more than 1.6 million tons of manure annually, or more
than one-and-a-half times the sanitary wastes produced by the about 1.5
million residents of Philadelphia, Pennsylvania. While we recognize
that manure can be a valuable resource used as fertilizer, some
agricultural experts and government officials have raised concerns
about the amount of manure produced by large feeding operations located
within a specific geographic area. When such clustering of large
operations occurs, the manure they produce may not be effectively used
as fertilizer on adjacent cropland and could increase the potential for
pollutants to reach nearby waters and degrade water quality.
* At least 68 government-sponsored or peer-reviewed studies have been
completed on air and water pollutants from animal feeding operations
since 2002. Of these 68 studies, 15 directly linked air and water
pollutants from animal waste to specific health or environmental
impacts, 7 found no impacts on human health and the environment, and 12
identified indirect linkages. Thirty-four other studies focused on
measuring the amount of water or air pollutants from animal feeding
operations that are known to cause harm to humans or the environment.
However, EPA has not yet assessed the extent to which air and water
pollutants from CAFOs may be impairing human health and the environment
because it lacks key information on the amount of pollutants discharged
by these operations.
* The ongoing national air emissions monitoring study is considered a
first step in developing protocols for measuring and quantifying air
pollutants emitted by animal feeding operations. While EPA believes
that this 2-year study, initiated in 2007, will provide a scientific
basis for estimating air emissions from animal feeding operations,
concerns have been raised that the study, as currently structured, may
not provide EPA with the scientific and statistically valid data that
it needs to develop these protocols. For example, the study does not
include all of the combinations of animal types and geographic regional
pairings recommended by EPA's expert panel that would be representative
of the animal feeding operations in the United States. Furthermore, EPA
has not yet established a strategy or timetable for developing a more
sophisticated process-based model that the National Academy of Sciences
believed is needed to ensure that the interaction and implications of
all emission sources at an animal feeding operation are accounted for.
Finally, some EPA actions have made it unclear at this time how the
agency intends to regulate air emissions from animal feeding operations
once the current air emissions study is complete. For instance, EPA has
not decided if it will aggregate the emissions occurring on an animal
feeding operation or if the emissions from barns and manure storage
areas will be considered separately when determining if an operation
has exceeded air emissions thresholds. Moreover, in December 2007, EPA
proposed a rule to exempt all releases of hazardous substances, such as
ammonia and hydrogen sulfide, to the air from manure on farms,
including animal feeding operations, from reporting requirements of
certain federal laws. We recommended that EPA take a number of actions
to address the concerns that we identified with the ongoing air
emissions study. EPA partially agreed with our recommendations and
described a number of actions that it has underway to address them.
* Two recent federal court decisions have affected EPA's ability to
regulate water pollutants discharged by CAFOs. First, in the 2005
Waterkeeper Alliance Inc. v. EPA decision, the U.S. Court of Appeals
for the Second Circuit set aside a key provision of a CAFO rule EPA had
issued in 2003. This rule would have provided EPA with comprehensive
information on the universe of CAFOs and their operations and would
have subjected a large number of previously unregulated CAFOs to
monitoring and reporting requirements as well as periodic inspections.
However, the court concluded that EPA did not have the authority under
the Clean Water Act to require CAFOs that were not discharging, or
proposing to discharge, pollutants into federally regulated waters to
apply for permits. The decision has forced EPA to revise its 2003 rule
for permitting CAFOs and return to its approach in which CAFO operators
determine for themselves whether they need to apply for a federal
permit. To help identify unpermitted discharges, EPA must rely on other
means to acquire information about CAFOs that are illegally discharging
pollutants, such as following up on citizen reports of potential
pollutants. Second, the 2006 Supreme Court decision--Rapanos v. United
States--has complicated EPA's enforcement of CAFO discharges. This
decision has made determination of Clean Water Act jurisdiction over
certain types of waters more complex and, according to EPA, has
required the agency to gather significantly more evidence to establish
which waters are considered federal waters and subject to the Clean
Water Act's permitting requirements. EPA enforcement officials told us
that since the Rapanos decision the agency may be less likely to take
enforcement actions since it may be more difficult to prove that a
water body is federally regulated.
Background:
The livestock and poultry industry is vital to our nation's economy,
supplying meat, milk, eggs, and other animal products. However, the
past several decades have seen substantial changes in America's animal
production industries. As a result of domestic and export market
forces, technological changes, and industry adaptations, food animal
production that was integrated with crop production has given way to
fewer, larger farms that raise animals in confined situations. These
large-scale animal production facilities are generally referred to as
animal feeding operations. CAFOs are a subset of animal feeding
operations and generally operate on a much larger scale.
Most agricultural activities are considered to be nonpoint sources of
pollution because the pollution that occurs is in conjunction with soil
erosion caused by water and surface runoff of rain or snowmelt from
diffuse areas such as farms or rangeland. However, the Clean Water Act
specifically designates point sources of pollution to include CAFOs,
which means that under the act, CAFOs that discharge into federally
regulated waters are required to obtain a National Pollutant Discharge
Elimination System (NPDES) permit. These permits generally allow a
point source to discharge specified pollutants into federally regulated
waters under specific limits and conditions. EPA, or the states that
EPA has authorized to administer the Clean Water Act, are responsible
for issuing these permits.[Footnote 4]
In accordance with the Clean Water Act's designation of CAFOs as point
sources, EPA defined which poultry and livestock facilities constituted
a CAFO and established permitting requirements for CAFOs. According to
EPA regulations, first issued in 1976, to be considered a CAFO a
facility must first be considered an animal feeding operation. Animal
feeding operations are agricultural operations where the following
conditions are met:
* animals are fed or maintained in a confined situation for a total of
45 days or more in any 12-month period, and:
* crops, vegetation, forage growth, or post harvest residues are not
sustained during normal growing seasons over any portion of the lot.
If an animal feeding operation met EPA's criteria and met or exceed
minimum size thresholds based on the type of animal being raised, EPA
considered the operation to be a CAFO. For example, an animal feeding
operation would be considered a CAFO if it raised 1,000 or more beef
cattle, 2,500 pigs weighing more than 55 pounds, or 125,000 chickens.
[Footnote 5] In addition, EPA can designate an animal feeding operation
of any size as a CAFO if it meets certain criteria, such as being a
significant contributor of pollutants to federally regulated waters.
[Footnote 6]
In January 2003, we reported that although EPA believed that many
animal feeding operations degrade water quality, it had placed little
emphasis on its permit program and that exemptions in its regulations
allowed as many as 60 percent of the largest operations to avoid
obtaining permits.[Footnote 7] In its response to our 2003 report, EPA
acknowledged that the CAFO program was hampered by outdated
regulations. The agency subsequently revised its permitting regulations
for CAFOs to eliminate the exemptions that allowed most animal feeding
operations to avoid regulation. The revisions, issued in February 2003,
also known as the 2003 CAFO rule, resulted, in part, from the
settlement of a 1989 lawsuit by the Natural Resources Defense Council
and Public Citizen. These groups alleged that EPA had failed to comply
with the Clean Water Act. EPA's 2003 CAFO Rule included the following
key provisions:
* Duty to apply. All CAFOs were required to apply for a permit under
the Clean Water Act unless the permitting authority determined that the
CAFO had no potential to discharge to federally regulated waters.
* Expanded CAFO definitions. All types of poultry operations, as well
as all stand-alone operations raising immature animals, were included
in the 2003 CAFO Rule.
* More stringent design standard for new facilities in the swine,
poultry, and veal categories. The 2003 rule established a no-discharge
standard for new facilities that could be met if they were designed,
constructed, and operated to contain the runoff from a 100-year, 24-
hour storm event.
* Best management practices. Operations were required to implement best
management practices for applying manure to cropland and for animal
production areas.
* Nutrient management plans. CAFO operations were required to develop a
plan for managing the nutrient content of animal manure as well as the
wastewater resulting from CAFO operations, such as water used to flush
manure from barns.
* Compliance schedule. The 2003 rule required newly defined CAFOs to
apply for permits by April 2006 and existing CAFOs to develop and
implement nutrient management plans by December 31, 2006.[Footnote 8]
According to EPA officials, the 2003 rule was expected to ultimately
lead to better water quality because the revised regulations would
extend coverage to more animal feeding operations that could
potentially discharge and contaminate water bodies and subject these
operations to periodic inspections.
Three laws provide EPA with certain authorities related to air
emissions from animal feeding operations, but, unlike the Clean Water
Act, they do not specifically cite CAFOs as regulated entities. The
Clean Air Act[Footnote 9] regulates any animal feeding operation,
regardless of size, that exceeds established air emission thresholds
for certain pollutants. For example, in certain specific situations,
hydrogen sulfide, ammonia, or particulate matter may be regulated. In
addition, Section 103 of CERCLA and Section 304 of EPCRA[Footnote 10]
require owners or operators of a facility to report to federal, state,
or local authorities when a "reportable quantity" of certain hazardous
substances, such as hydrogen sulfide or ammonia,[Footnote 11] is
released into the environment. Together, CERCLA's and EPCRA's reporting
requirements provide government authorities, emergency management
agencies, and citizens the ability to know about the source and
magnitude of hazardous releases.
EPA also works with USDA to address the impacts of animal feeding
operations on air and water quality and human health. In 1998, EPA
entered into a memorandum of understanding with USDA that calls for the
agencies to coordinate on air quality issues related to agriculture and
share information. In addition, in 1999, the two agencies issued a
unified national strategy aimed at having the owners and operators of
animal feeding operations take actions to minimize water pollution from
confinement facilities and land application of manure. To help minimize
water pollution from animal feeding operations and meet EPA's
regulatory requirements, USDA, through its Natural Resources
Conservation Service, provides financial and technical service to CAFO
operators in developing and implementing nutrient management plans.
The Number of Large Farms Raising Animals Has Increased, but Specific
Data on CAFOs Are Not Available:
Because no federal agency collects accurate and consistent data on the
number, size, and location of CAFOs, it is difficult to determine
precise trends in CAFOs. According to USDA officials, the data USDA
collects for large farms raising animals can be used as a proxy for
estimating trends in CAFOs nationwide. Using these data, we determined
the following:
* Between 1982 and 2002, the number of large farms raising animals
increased from about 3,600 to almost 12,000, or by about 234 percent.
Growth rates varied dramatically by animal type. For instance, broiler
chickens farms showed the largest increase, almost 1,200 percent,
followed by hogs at more than 500 percent. In comparison, beef cattle
farms grew by only 2 percent and layer chicken farms actually declined
by 2 percent.
* The size of these farms also increased between 1982 and 2002. The
layer and hog sectors had the largest increases in the median number of
animals raised per farm, both growing by 37 percent between 1982 and
2002. In contrast, large farms that raised either broilers or turkeys
only increased slightly in size, by 3 and 1 percent, respectively, from
1982 to 2002.
* The number of animals raised on large farms increased from over 257
million in 1982 to over 890 million in 2002--an increase of 246
percent. Moreover, most of the beef cattle, hogs, and layers raised in
the United States in 2002 were raised on large farms. Specifically, 77
percent of beef cattle and 72 percent of both hogs and layers were
raised on large farms.
We also found that EPA does not systematically collect nationwide data
to determine the number, size, and location of CAFOs that have been
issued permits nationwide. Instead, since 2003, the agency has compiled
quarterly estimates obtained from its regional offices or the states on
the number and types of CAFOs that have been issued permits. However,
these data are inconsistent and inaccurate and therefore do not provide
EPA with the reliable data that it needs to identify permitted CAFOs
nationwide. Without a systematic and coordinated process for collecting
and maintaining accurate and complete information on the number, size,
and location of CAFOs nationwide, EPA does not have the information it
needs to effectively monitor and regulate these operations. In our
report, we recommended that EPA develop a national inventory of
permitted CAFOs and incorporate appropriate internal controls to ensure
the quality of the data it collects. In response to our recommendation,
EPA stated that it is currently working with its regional offices and
states to develop and implement a new national data system to collect
and record facility-specific information on permitted CAFOs.
Large Farms That Raise Animals Can Produce Thousands of Tons of Manure
Each Year, and Regional Clustering of Farms Can Exacerbate Manure
Management Problems:
The amount of manure a large farm that raises animals can generate
primarily depends on the types and numbers of animals raised on that
farm, but can range from over 2,800 tons to more than 1.6 million tons
a year.[Footnote 12] To further put this in perspective, the amount of
manure produced by large farms that raise animals can exceed the amount
of sanitary waste produced by some large U.S. cities.[Footnote 13] For
example:
* A dairy farm meeting EPA's large CAFO threshold of 700 dairy cows can
create about 17,800 tons of manure annually, which is more than the
about 16,000 tons of sanitary waste generated per year by the almost
24,000 residents of Lake Tahoe, California.
* A large farm with 800,000 hogs could produce over 1.6 million tons of
manure per year, which is one and a half times more than the annual
sanitary waste produced by the city of Philadelphia, Pennsylvania--
about 1 million tons--with a population of almost 1.5 million.[Footnote
14]
Although manure is considered a valuable commodity, especially in
states with large amounts of farmland, like Iowa, where it is used as
fertilizer for field crops, in some parts of the country, large farms
that raise animals can be clustered in a few contiguous counties.
Because this collocation can result in the separation of animal from
crop production, there is less cropland on which manure can be applied
as a fertilizer. A USDA report first identified this concern as early
as 2000, when it found that between 1982 and 1997, as livestock
production became more spatially concentrated, when manure was applied
to cropland, crops were not fully using the nutrients in manure, and
this could result in ground and surface water pollution from the excess
nutrients.[Footnote 15] According to the report, the number of counties
where farms produced more manure nutrients, primarily nitrogen and
phosphorus, than could be applied to the land without accumulating
nutrients in the soil increased. As a result, the potential for runoff
and leaching of these nutrients from the soil was high, and water
quality could be impaired. Agricultural experts and government
officials who we spoke to during our review echoed the findings of
USDA's report and provided several examples of more recent clustering
trends that have resulted in degraded water quality. For example,
according to North Carolina agricultural experts, excessive manure
production from CAFOs in five contiguous counties has contributed to
the contamination of some of the surface and well water in these
counties and the surrounding areas.
USDA officials acknowledge that regional clustering of large animal
feeding operations has occurred, but they told us that they believe
producers' implementation of nutrient management plans and use of new
technologies, such as calibrated manure spreaders and improved animal
feeds, have resulted in animal feeding operations more effectively
using the manure being generated and reducing the likelihood that
pollutants from manure are entering ground and surface water. However,
USDA could not provide us with information on the extent to which these
techniques are being used or their effectiveness in reducing water
pollution from animal waste.
Studies Have Identified Impacts of Pollutants from Animal Waste, but
EPA Has Not Assessed the Extent of Such Impacts:
Since 2002, at least 68 government-sponsored or peer-reviewed studies
have been completed on air and water pollutants from animal feeding
operations. Of these 68 studies,
* 15 directly linked pollutants from animal waste generated by animal
feeding operations to specific health or environmental impacts. Eight
of these 15 studies were water quality studies and 7 were air emissions
studies. Academic experts and industry and EPA officials told us that
only a few studies directly link CAFOs with health or environmental
impacts because the same pollutants that CAFOs discharge also often
come from other sources, including smaller livestock operations; row
crops using commercial fertilizers; and wastes from humans,
municipalities, or wildlife, making it difficult to distinguish the
actual source of the pollution.
* 7 found no impacts on human health or the environment from pollutants
emitted by CAFOs. Four of these 7 studies were water quality studies
and 3 were air emissions studies. According to EPA and academic experts
we spoke with, the concentrations of air and water pollutants
discharged by animal feeding operations can vary for numerous reasons,
including the type of animal being raised, feed being used and the
manure management system being employed, as well as the climate and
time of day when the emissions occur.
* 12 made indirect linkages between air and water pollutants and health
and environmental impacts. While these studies found that animal
feeding operations were the likely cause of human health or
environmental impacts occurring in areas near the operations, they
could not conclusively link waste from animal feeding operations to the
impacts, often because other sources of pollutants could also be
contributing.
* 34 of the studies focused on measuring the amounts of water or air
pollutants discharged by animal feeding operations that are known to
cause human health or environmental impacts at certain concentrations.
Of the 34 studies, 19 focused on water pollutants and another 15
focused on measuring air emissions from animal feeding operations.
While EPA recognizes the potential impacts that water and air
pollutants from animal feeding operations can have on human health and
the environment, it lacks the data necessary to assess how widespread
the impacts are and has limited plans to collect the data that it
needs. For example, with regard to water quality, EPA officials
acknowledged that the potential human health and environmental impacts
of some CAFO water pollutants, such as nitrogen, phosphorus, and
pathogens, are well known. However, they also stated that EPA does not
have data on the number and location of CAFOs nationwide and the amount
of discharges from these operations. Without this information and data
on how pollutant concentrations vary by type of operation, it is
difficult to estimate the actual discharges occurring and to assess the
extent to which CAFOs may be contributing to water pollution. Although
EPA has recently taken some steps that may help provide some of these
data, agency officials told us that EPA currently has no plans to
conduct a national study to collect information on CAFO water pollutant
discharges because of a lack of resources.
Similarly, with regard to air quality, more recently, EPA has
recognized concerns about the possible health and environmental impacts
from air emissions produced by animal feeding operations. In this
regard, prompted in part by public concern, EPA and USDA commissioned a
2003 study by the National Academy of Sciences (NAS) to evaluate the
scientific information needed to support the regulation of air
emissions from animal feeding operations.[Footnote 16] The NAS report
identified several air pollutants from animal feeding operations, such
as ammonia and hydrogen sulfide, that can impair human health. The NAS
report also concluded that in order to determine the human health and
environmental effects of air emissions from animal feeding operations,
EPA and USDA would first need to obtain accurate estimates of emissions
and their concentrations from animal feeding operations with varying
characteristics, such as animal type, animal feed, manure management
techniques, and climate. In 2007, the 2-year National Air Emissions
Monitoring Study was initiated to collect data on air emissions from
animal feeding operations as part of a series of consent agreements
that EPA entered into with individual CAFOs. This study, funded by
industry and approved by EPA, is intended to help the agency determine
how to measure and quantify air emissions from animal feeding
operations. The data collected will in turn be used to estimate air
emissions from animal feeding operations with varying characteristics.
According to agency officials, until EPA can determine the actual level
of air pollutants being emitted by CAFOs, it will be unable to assess
the extent to which these emissions are affecting human health and the
environment.
It Is Unclear if EPA's Efforts to Develop Air Emissions Protocols for
Animal Feeding Operations Will Be Effective and Whether EPA Intends to
Regulate These Emissions in the Future:
The National Air Emissions Monitoring Study is intended to provide a
scientific basis for estimating air emissions from animal feeding
operations and to help EPA develop protocols that will allow it to
determine which operations do not comply with applicable federal laws.
According to EPA, although it has the authority to require animal
feeding operations to monitor their emissions and come into compliance
with the Clean Air Act on a case-by-case basis, this approach has
proven to be time and labor intensive. As an alternative to the case-
by-case approach, in January 2005, EPA offered animal feeding
operations an opportunity to sign a voluntary consent agreement and
final order, known as the Air Compliance Agreement. Almost 13,900
animal feeding operations were approved for participation in the
agreement, representing the egg, broiler chicken, dairy, and swine
industries. Some turkey operations volunteered but were not approved
because there were too few operations to fund a monitoring site, and
the beef cattle industry chose not to participate. In return for
participating in this agreement and meeting certain requirements, EPA
agreed not to sue participating animal feeding operations for certain
past violations or violations occurring during the National Air
Emissions Monitoring Study.[Footnote 17]
Although EPA told us that the National Air Emissions Monitoring Study
is the first step in developing comprehensive protocols for quantifying
air emissions from animal feeding operations, we found that the study
may not provide EPA with the data that it needs for the following three
reasons.
* The monitoring study may not be representative of the vast majority
of participating animal feeding operations and will not account for
differences in climatic conditions, manure-handling methods, and
density of operations because it does not include the 16 combinations
of animal types and geographic regional pairings recommended by EPA's
expert panel. EPA approved only 12 of the 16 recommended combinations,
excluding southeastern broiler, eastern layer, midwestern turkey, and
southern dairy operations.
* Selection of monitoring sites has been a concern since the selection
plan was announced in 2005. At that time, many agricultural experts,
environmental groups, and industry and state officials disagreed with
the site selection methodology. They stated that the study did not
include a sufficient number of monitoring sites to establish a
statistically valid sample. Without such a sample, we believe that EPA
will not be able to accurately estimate emissions for all types of
operations. More recently, in June 2008, the state of Utah reached an
agreement with EPA to separately study animal feeding operations in the
state because of the state's continuing concerns that the National Air
Emissions Monitoring Study will not collect information on emissions
from operations in Rocky Mountain states and therefore may not be
meaningful for those operations that raise animals in arid areas.
* Agricultural experts also have raised concerns that the National Air
Emissions Monitoring Study does not include other sources that can
contribute significantly to emissions from animal feeding operations.
For example, the monitoring study will not capture data on ammonia
emissions from feedlots and manure applied to fields. According to
these experts, feedlots and manure on fields, as well as other excluded
sources account for approximately half of the total ammonia emissions
emitted by animal feeding operations.
Furthermore, USDA's Agriculture Air Quality Task Force has recently
raised concerns about the quantity and quality of the data being
collected during the early phases of the study and how EPA will
eventually use the information.[Footnote 18] In particular, the task
force expressed concern that the technologies used to collect emissions
data were not functioning reliably. At its May 2008 task force meeting,
the members requested that the Secretary of Agriculture ask EPA to
review the first 6 months of the study's data to determine if the study
needs to be revised in order to yield more useful information.
EPA acknowledged that emissions data should be collected for every type
of animal feeding operation and practice, but EPA officials stated that
such an extensive study is impractical. Furthermore, they stated that
the selected sites provide a reasonable representation of the various
animal sectors. EPA has also indicated that it plans to use other
relevant information to supplement the study data and has identified
some potential additional data sources. However, according to
agricultural experts, until EPA identifies all the supplemental data
that it plans to use, it is not clear if these data, together with the
emissions study data, will enable EPA to develop comprehensive air
emissions protocols.
EPA has also indicated that completing the National Air Emissions
Monitoring Study is only the first part of a multiyear effort to
develop a process-based model for predicting overall emissions from
animal feeding operations. A process-based model would capture
emissions data from all sources and use these data to assess the
interaction of all sources and the impact that different manure
management techniques have on air emissions for the entire operation.
For example, technologies are available to decrease emissions from
manure lagoons by, among other things, covering the lagoon to capture
the ammonia. However, if an operation spreads the lagoon liquid as
fertilizer for crops, ammonia emissions could increase on the field.
According to NAS, a process-based model is needed to provide
scientifically sound estimates of air emissions from animal feeding
operations that can be used to develop management and regulatory
programs. Although EPA plans to develop a process-based model after
2011, it has not yet established a timetable for completing this model
and, therefore, it is uncertain when EPA will have more sophisticated
approaches that will more accurately estimate emissions from animal
feeding operations.
Moreover, two recent EPA decisions suggest that the agency has not yet
determined how it intends to regulate air emissions from animal feeding
operations. Specifically:
* In December 2007, EPA proposed exempting releases to the air of
hazardous substances from manure at farms that meet or exceed the
reportable quantities from both CERCLA and EPCRA notification
requirements. According to EPA, this decision was in part a response to
language in congressional committee reports related to EPA's
appropriations legislation for 2005 and 2006 that directed the agency
to promptly and expeditiously provide clarification on the application
of these laws to poultry, livestock, and dairy operations. In addition,
the agency received a petition from the several poultry industry
organizations seeking an exemption from the CERCLA and EPCRA reporting
requirements for ammonia emissions from poultry operations on the
grounds that ammonia emissions from poultry operations pose little or
no risk to public health, and emergency response is inappropriate. In
proposing the exemption, EPA noted that the agency would not respond to
releases from animal wastes under CERCLA or EPCRA nor would it expect
state and local governments to respond to such releases because the
source and nature of these releases are such that emergency response is
unnecessary, impractical, and unlikely. It also noted that it had
received 26 comment letters from state and local emergency response
agencies supporting the exemption for ammonia from poultry operations.
However, during the public comment period ending on March 27, 2008, a
national association representing state and local emergency responders
with EPCRA responsibilities questioned whether EPA had the authority to
exempt these operations until it had data from its monitoring study to
demonstrate actual levels of emissions from animal feeding operations.
This national association further commented that EPA should withdraw
the proposal because it denied responders and the public the
information necessary to protect themselves from dangerous releases.
[Footnote 19] Furthermore, the proposal also seems to be a departure
from EPA's past regulatory enforcement actions that have included
charges of failing to comply with the release reporting requirements
when bringing claims against producers for violating several
environmental laws and is also contrary to one of the stated goals of
the Air Compliance Agreement. We believe that the timing of this
proposed exemption, before the National Air Emissions Monitoring Study
has been completed, calls into question the basis for EPA's decision.
* EPA has also recently stated that it will not make key regulatory
decisions on how certain federal air regulations apply to animal
feeding operations until after 2011, when the National Air Emissions
Monitoring Study is completed. For example, according to EPA, the
agency will not issue guidance for several more years defining the
scope of the term "source" as it relates to animal agriculture and farm
activities. According to EPA, it has not yet decided if it will
aggregate the emissions occurring on an animal feeding operation as one
source or if the emissions from the barns, lagoons, feed storage, and
fields will each be considered as a separate source when determining if
an operation has exceeded air emissions' reportable quantities.
Depending on the approach EPA takes, how emissions are calculated could
differ significantly. For example, according to preliminary data EPA
has received from an egg-laying operation in Indiana, individual
chicken barns may exceed the CERCLA reportable quantities for ammonia.
Moreover, if emissions from all of the barns on the operation are
aggregated, they might be more than 500 times the CERCLA reportable
quantities.
To address the various concerns that we identified with the ongoing air
emission monitoring study, we recommended that EPA (1) reassess the
study to ensure that it will provide valid data which the agency can
use to develop air emissions protocols and (2) provide stakeholders
with information on the additional data that it plans to use to
supplement the study. In addition, we recommended that EPA establish a
strategy and timetable for developing a process-based model that will
provide more sophisticated air emissions estimating methodologies for
animal feeding operations. EPA responded that it has developed a
quality assurance plan for the study but did not address other issues
that we identified in our report, such as the validity of the study's
sample and the omission of other sources that can contribute
significantly to the air emission from animal feeding operations.
Furthermore, although EPA concurred with the need to identify
supplemental data and establish a strategy and timetable for developing
a process-based model and described actions that it has underway, the
agency provided no indication of when it will complete its plans to
either identify the data it will use to augment the monitoring study or
develop a process-based model.
Two Federal Court Decisions Have Affected EPA's and Some States'
Ability to Regulate Water Pollutants Discharged by CAFOs:
Two federal court decisions--Waterkeeper Alliance Inc. v. EPA and
Rapanos v. United States--have affected EPA and some states' abilities
to regulate CAFOs for water pollutants.
Waterkeeper Alliance Inc. v. EPA (Waterkeeper):
In its 2005 Waterkeeper decision, the U.S. Court of Appeals for the
Second Circuit set aside a key provision of EPA's 2003 CAFO rule
requiring every CAFO to apply for a permit. Under the 2003 rule, large
numbers of previously unregulated CAFOs were required to apply for
permits and would have been subject to monitoring and reporting
requirements imposed by the permit as well as periodic inspections.
According to EPA, the 2003 rule would have expanded the number of
regulated CAFOs from an estimated 12,500 to an estimated 15,300, an
increase of about 22 percent, and would have provided EPA with more
comprehensive information on the number and location of CAFOs, enabling
the agency to more effectively locate and inspect these operations
nationwide.
However, in 2003, both environmental and agricultural groups challenged
EPA's 2003 rule. The court agreed with the environmental groups'
arguments that, among other things, EPA's 2003 rule did not adequately
provide for public review and comment on a CAFO's nutrient management
plan and instructed EPA to revise the rule accordingly. The court also
agreed with the agricultural groups' arguments that EPA had exceeded
its authority under the Clean Water Act by requiring CAFOs that were
not discharging pollutants into federally regulated water to apply for
permits or demonstrate that they had no potential to discharge and
therefore set aside the rule's permitting requirements for those CAFOs
that did not discharge.
The Waterkeeper decision, in effect, returned EPA's permitting program
to one in which CAFO operators are not required to apply for a NPDES
permit unless they discharge, or propose discharging, into federally
regulated waters. As a result, EPA must identify and prove that an
operation has discharged or is discharging pollutants in order to
require the operator to apply for a permit. To help identify
unpermitted discharges from CAFOs, EPA officials told us that they have
to rely on other methods that are not necessarily all-inclusive, such
as citizens' complaints, drive-by observations, aerial flyovers, and
state water quality assessments that identify water bodies impaired by
pollutants associated with CAFOs. According to EPA officials, these
methods have helped the agency identify some CAFOs that may be
discharging as well as targeting inspections to such CAFOs.
As a result of the Waterkeeper decision, EPA proposed a new rule in
June 2006 requiring that (1) only CAFO operators that discharge, or
propose to discharge, apply for a permit, (2) permitting authorities
review CAFO nutrient management plans and incorporate the terms of
these plans into the permits, and (3) permitting authorities provide
the public with an opportunity to review and comment on the nutrient
management plans. According to EPA officials, the final rule is
currently being reviewed by the Office of Management and Budget, but at
the time we issued our report, these officials were uncertain when this
review would be completed and the final rule issued.
State water pollution control officials have expressed some concerns
that EPA's new 2006 rule will place a greater administrative burden on
states than the 2003 rule would have. In an August 2006 letter to EPA,
the Association of State and Interstate Water Pollution Control
Administrators noted that the "reactive" enforcement that EPA will now
follow will require permitting authorities to significantly increase
their enforcement efforts to achieve the level of environmental benefit
that would have been provided by the 2003 rule. These officials believe
that requiring EPA and the states to identify CAFOs that actually
discharge pollutants into federally regulated water bodies will consume
more resources than requiring all CAFOs to apply for a permit.
Moreover, although the Waterkeeper decision has affected EPA's ability
to regulate CAFOs' water pollutant discharges, state officials we
contacted indicated that this decision has not had the same impact on
their ability to regulate these operations. As table 1 shows, the
impacts of the Waterkeeper decision have ranged from having little
impact on state regulation to impairing state CAFO programs.
Table 1: State Officials' Views of the Impact of the Waterkeeper
Decision on Their CAFO Programs:
Impact of Waterkeeper: Waterkeeper had little or no impact;
Number of states reporting impact: 16.
Impact of Waterkeeper: Reduced the number of CAFOs with permits;
Number of states reporting impact: 15.
Impact of Waterkeeper: Impaired state program;
Number of states reporting impact: 10.
Impact of Waterkeeper: Waiting for EPA to issue revised rule;
Number of states reporting impact: 9.
Impact of Waterkeeper: Prompted state legislature to require permits
for CAFOs;
Number of states reporting impact: 1.
Source: GAO analysis of state officials' responses.
[End of table]
Rapanos v. United States (Rapanos):
Although the Rapanos case arose in the context of a different permit
program, the scope of EPA's pollutant discharge program originates in
the same Clean Water Act definition that was at issue in the case. As a
result, the decision has complicated the agency's enforcement of CAFO
regulations. According to EPA enforcement officials, the agency will
now be less likely to seek enforcement against a CAFO that it believes
is discharging pollutants into a water body because it may be more
difficult to prove that the water body is federally regulated.
According to EPA officials, as a result of the Rapanos decision, EPA
must spend more resources developing an enforcement case because the
agency must gather proof that the CAFO has not only illegally
discharged pollutants, but that those pollutants have entered federally
regulated waters. The difficulties EPA has experienced were highlighted
in a March 4, 2008, memorandum in which EPA's Assistant Administrator
for Enforcement and Compliance Assurance stated that the Rapanos
decision and national guidance issued by EPA to ensure "nationwide
consistency, reliability, and predictability in their administration of
the statute" in light of the Supreme Court's decision has resulted in
significant adverse impacts to the clean water enforcement program.
According to the memorandum, the Rapanos decision and guidance
negatively affected approximately 500 enforcement cases, including as
many as 187 cases involving NPDES permits.
In conclusion, Mr. Chairman, EPA has regulated CAFOs under the Clean
Water Act for more than 30 years, and during this time it has amassed a
significant body of knowledge about the pollutants discharged by animal
feeding operations and the potential impacts of these pollutants on
human health and the environment. Nevertheless, EPA still lacks
comprehensive and reliable data on the number, location, and size of
the operations that have been issued permits and the amounts of
discharges they release. As a result, EPA has neither the information
it needs to assess the extent to which CAFOs may be contributing to
water pollution, nor the information it needs to ensure compliance with
the Clean Water Act. More recently, EPA has also begun to address
concerns about air pollutants that are emitted by animal feeding
operations. The nationwide air emissions monitoring study, along with
EPA's plans to develop air emissions estimating protocols, are
important steps in providing much needed information on the amount of
air pollutants emitted from animal feeding operations. However,
questions about the sufficiency of the sites selected for the air
emissions study and the quantity and quality of the data being
collected could undermine EPA's efforts to develop air emissions
protocols by 2011 as planned. A process-based model that more
accurately predicts the total air emissions from an animal feeding
operation is still needed. While EPA has indicated it intends to
develop such a model, it has not yet established a strategy and
timeline for this activity.
Mr. Chairman, this concludes my prepared testimony. I would be happy to
respond to questions that you or Members of the Subcommittee may have.
Contact and Staff Acknowledgments:
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this testimony. For further
information about this testimony, please contact Anu Mittal, Director,
Natural Resources and Environment (202) 512-3841 or mittala@gao.gov.
Key contributors to this testimony were Sherry McDonald, Assistant
Director; Kevin Bray, Paul Hobart; Holly Sasso; Carol Herrnstadt
Shulman; James Turkett; and Greg Wilmoth.
[End of section]
Footnotes:
[1] GAO, Concentrated Animal Feeding Operations: EPA Needs More
Information and a Clearly Defined Strategy to Protect Air and Water
Quality from Pollutants of Concern, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-944] (Washington, D.C.: Sept. 4, 2008).
[2] Section 502(14) of the Clean Water Act specifically defines point
sources of pollution to include CAFOs.
[3] These states were Arkansas, California, Colorado, Iowa, Maryland,
Minnesota, North Carolina, and Texas.
[4] Currently, 45 states are authorized to administer the NPDES permit
program and their programs must be at least as stringent as the federal
program. EPA has retained program authority for Alaska, Idaho,
Massachusetts, New Hampshire, and New Mexico. Oklahoma has been
authorized to issue permits for most sources, but not CAFOs.
[5] 40 C.F.R. § 122.23(b).
[6] Federally regulated waterways include waters of the United States
as defined in 33 C.F.R. §328.3(a)(1)-(7) and may include rivers,
wetlands, impoundments, the territorial seas, and waters used in
interstate commerce.
[7] GAO, Livestock Agriculture: Increased EPA Oversight Will Improve
Environmental Program for Concentrated Animal Feeding Operations,
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-285] (Washington,
D.C.: Jan. 16, 2003).
[8] In July 2007, EPA extended these deadlines to February 27, 2009.
[9] The Clean Air Act, 42 U.S.C. §§7401-7671q.
[10] CERCLA, Pub. L. No. 96-510, 94 Stat. 2767 (codified as amended at
42 U.S.C. §§9601-9675)and EPCRA, Pub. L. No. 99-499, Tit. III, 100
Stat. 1728 (codified as amended at 42 U.S.C. §§11001-11050).
[11] Each of these hazardous substances has a reportable quantity of
100 pounds in a 24-hour period.
[12] The amounts of manure reported are estimates. The actual amount of
manure produced by an animal will vary based on, among other things,
feeding programs, feed used, climatic conditions, production
techniques, and animal genetics.
[13] Human sanitary waste includes urine and feces only; it does not
include any other household sewage wastes such as water from washing
dishes or clothes or water used for showers or flushing.
[14] EPA officials told us that the agency has identified a hog farm of
this size and USDA officials told us that they are aware of two hog
farms of this size.
[15] R. L. Kellogg, C.H. Lander, D. C. Moffitt, and N. Gollehon. Manure
Nutrients Relative to the Capacity of Cropland and Pastureland to
Assimilate Nutrients: Spatial and Temporal Trends for the United
States. (Washington, D.C.: December 2000).
[16] National Academy of Sciences, Air Emissions from Animal Feeding
Operations: Current Knowledge, Future Need. (Washington, D.C.: National
Academies Press, 2003).
[17] EPA placed certain conditions and limits on its agreement not to
sue animal feeding operations participating in the Air Compliance
Agreement. For example, EPA can continue to pursue cases that present
an imminent and substantial endangerment to public health, welfare, or
the environment. In addition, EPA's covenant not to sue only covers
emissions from agricultural livestock and livestock waste and does not
extend to generators or land application of animal waste.
[18] The Agricultural Air Quality Task Force, created in accordance
with the 1996 farm bill, is charged with advising the Secretary of
Agriculture with respect to providing oversight and coordination
related to agricultural air quality, and consists of leaders in
farming, industry, health, and science.
[19] The National Association of SARA Title III Program Officials. The
Superfund Amendments and Reauthorization Act (SARA) amended CERCLA on
October 17, 1986, after the first 6 years of the program.
[End of section]
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