INTRODUCTION

In 2001, Nicolette Hahn Niman organized the first Summit for Sustainable Hog Farming, gathering experts from around the country in Bern, North Carolina.1 Among the many guests who attended was Don Webb, a tall, broad shouldered man with a persuasive southern accent.2 Don Webb, a well-known teacher and activist, once owned a factory farm. His story began with his need to supplement his income as a teacher.3 Persuaded by both land-grant universities and agribusinesses, Don developed an interest in hog farming.4 He decided it was best to “[dig] a huge hole for liquefied manure, [erect] a hog shed with slatted floor, and [fill] it with pigs.”5 Not until the place began to excrete odors unlike any Don had ever smelled before did his transformation from a commercial farmer to a known activist take place.

Don explained to the participants at the summit, “I kep’ callin’ the company who’d sold me the equipmen’ an’ askin’ them how I could make it stop stinkin’ so bad.”6 He explained how a customer service clerk, whom he spoke with on the phone that day, sold him a chemical to add to his lagoon that would help in eliminating the odor.7 Don goes on, “So, I put my boat in the cesspool an’ rowed it way out to the middle of that slot. Then I poured the chemical in there and stirred it up like a giant pot o’chili with one of them oars.”8 The fumes were so strong while Don was on the water that he recounted tears rolling down his eyes throughout the entire experience.9 Don soon found that the chemicals proved a failure and had in fact exacerbated the odor, which spread throughout his entire community.10

Soon after this incident, Don shut down his operation. As Niman describes, Webb had a “Come-to-Jesus moment” when he met a very nice young man in a grocery store one day.11 The nice young man said, “Well, Mister Webb, I don’t mean to be rude, but it’s bout your hog lagoon. My family and I, we were jes’ wonderin’ if there’s any way you could stop it from stinkin’ so bad.”12 Shortly thereafter, Don closed down his facility and gave up raising confined swine as a supplemental career path.

BACKGROUND

Ethical Concerns

Confined animal feeding operations (CAFOs), as the name suggests, restrain animals in indoor facilities or very tight pens, where the animals are forced to stand in their own feces day in and day out.13 As Eric Schlosser, author of Fast Food Nation, describes, “At times the animals are crowded so closely together it looks like a sea of cattle, a mooing, moving mass of brown and white fur that goes on for acres.”14 Confined indoors, these animals never see sunlight and spend their lives on slatted metal floors, through which their excrement is flushed and then piped into large waste lagoons, until it is processed into fertilizer.15 These lagoons, sometimes the size of several football fields, hold the feces and urine of hundreds of thousands of animals, confined head to jowl.

Besides being packed in metal barns, the animals in these facilities receive dirty food and water from their careless providers. At least seventy-five percent of American cattle are fed livestock waste as protein supplements.16 Bone and meat meal, among the most popular supplements, are produced from the ground and cooked leftovers of the slaughtering process, a practice detrimental to both humans and livestock. In 2004, The United States Food and Drug Administration announced a proposal to end the use of cattle blood, restaurant scraps, and poultry litter as feed in response to the outbreak of bovine spongiform encephalopathy in the United Kingdom.17 The proposal, like many others, has yet to be implemented. This outbreak showed a positive correlation between those animals being fed livestock waste and those who suffered from disease. Mixing nervous tissue with mince and other beef during the slaughtering process and then feeding this scrap product to cattle had caused rapid spread of disease throughout the European Union.18In addition to the dangers associated with this practice, the consumption of blood along with waste containing high cellulose content makes it difficult for animals’ digestive systems to function properly.19

In addition to being fed waste, cattle within these operations are often given growth hormones.20 The combination of high protein grain and anabolic steroids implanted in their ears ensures they are ready for slaughter in the correct amount of time.21 Cattle, for example, consume around three thousand pounds of grain in a feedlot in order to gain the four hundred pounds needed for slaughter.22 This consumption causes each steer to deposit around fifty pounds of urine and manure daily.23 As a government official explained, “the sanitary conditions in a modern feedlot [can be compared] to those in a crowded European city during the Middle Ages, when people dumped their chamber pots out the window, raw sewage ran in the streets, and epidemics raged.”24

Environmental Problems

Indoor confinement systems break the natural nutrient and biogeochemical cycles of our planet including its nitrogen and phosphorus cycles.25 Heavy metals, feed-additive chemicals, pesticide residues, fecal bacteria, pesticides, and residues of medications in animal feed contaminate both the land and nearby water supplies.26 According to an article in The Animals’ Agenda by Michael W. Fox, livestock and poultry in the United States excrete about 158 million tons of dry weight basis manure per year.27 As Fox says, “If we put this much manure in boxcars, the train would stretch around the world four and a half times.”28 Around forty percent of the nitrogen and forty five percent of the phosphates in our nation’s rivers are due to confined animal feeding operations. Phosphate contamination has led to algal blooms, low dissolved oxygen content and increasing numbers of dead zones, and eutrophication.

Land application is the process of storing manure and then directly applying it to crops as fertilizer.29 Though the use of manure as fertilizer is a seemingly green way to recycle earth’s nutrients, over-application of manure on land, leaking or overflowing of CAFO’s cesspools, and the redeposition of airborne pollutants into our nation’s waterways can contribute to both surface and groundwater contamination.30 In 1997 farmers in the United States produced 1.37 billion tons of animal manure.31 Most of this manure was then applied directly as fertilizer to fields or was stored in lagoons for future spraying of crops. Agrichemical runoff from fields and concentrated animal wastes produced by these industries allow fecal bacteria to contaminate our nation’s waterways; a prime example is the contamination of the Chesapeake Bay Watershed.32 At the Summit for Sustainable Hog Farming, Joann Burkholder, the scientist who discovered Pfiesteria (a dinoflagellate associated with algal blooms), says, “[the] spiking nutrient levels in North Carolina’s waterways coincided with the rise in industrial animal production.”33 It is a simple problem: too many animals being confined leads to too much manure for neighboring land to utilize. As Lauren Bush notes: “confined farmed animals produce three times the amount of waste that is produced by all humans in the United States according to the EPA.”34

In addition to problems of runoff, gases produced by the manure in the lagoons lead to acid rain and the release of excessive amounts of methane into the environment, resulting in the exacerbation of global climate change. Bush outlines how between 1995 to 1998 factory farms were responsible for 1,000 spills of liquefied manure or other instances of pollution in at least ten states.35 This manure, often oversaturating the soil with nitrogen, percolates into the soil as rainfall occurs.36 Increased nitrate content in the water table is a leading environmental problem connected with CAFOs. The Worldwatch Institute notes, “As environmental science has advanced, it has become apparent that the animal agricultural sector is a driving force behind virtually ever major category of environmental damage now threatening the human future—deforestation, erosion, fresh water scarcity, air and water pollution, climate change, biodiversity loss, social injustice, the destabilization of communities and the spread of disease.”37

Food Safety Issues

The most recent statistics, published by the Centers for Disease Control and Prevention - 2013 - indicate 19,056 confirmed cases of bacterial and parasitic infection, 4,200 hospitalizations, and 80 deaths among 48 million residents of ten states, all as a result of foodborne illness.38 According to Bush, “Studies have linked farmed animal waste to pathogenic outbreaks of Campylobacter, Salmonella, Listeria Monocytogenes, Helicobacter pylori, E.Coli 0157:H7, [and Shigella Dystenteiae]”, all found in sources of drinking water.39 As a result of increased runoff, seafood also can become contaminated and cause food safety concerns that lead to long-term problems including heart disease, inflammatory bowel disease, neurological problems, autoimmune disorders, and kidney damage.40 Huge feedlots and the increased use of factory farms have provided the necessary means for these pathogens to incorporate themselves in our nation’s food supply. Now confirmed by the Food and Drug Administration and California’s Department of Health Services, the 2006 outbreak of E.Coli in Dole’s baby spinach was a direct result of feces into our nation’s waterways, and a prime example of how our nation’s agricultural practices can cause serious food safety concerns.41

RESEARCH AND ANALYSIS

Argument #1: Judicial Processes

Judicial processes and decisions made by the United States Courts of Appeals have made the EPA ineffective in regulating waste. In 1972, The Federal Water Pollution Act was implemented and created a procedure for a National Pollutant Discharge Eliminated System Permit.42 This permit helped the Environmental Protection Agency to regulate the discharge of any single pollutant or combination of pollutants. With this permit, companies could discharge given certain effluent constraints, and confined animal feeding operations would now be defined as a point source of pollution.43 Failure to obtain this permit or adhere to its requirements could result in monetary sanctions ranging from $50,000 per violation to $100,000 for repeated violations.44 This was a clear attempt made by the Environmental Protection Agency to implement an effective strategy to regulate factory farms. Beginning in 1976, any CAFO with 1,000 animals or more was required to have an NPDES permit. Most medium sized CAFO with 1,000 animals or more was required to have an NPDES permit. Most medium sized CAFOs with 300 to 1,000 animals were required to have a permit if they emitted certain discharges. Small CAFOs with 300 or fewer animals were exempt.45

2001: Federal District Court Battle

The first challenge to the Environmental Protection Agency’s regulations came in 1988, with the federal judiciary’s decision in the Natural Resource Defense Council, Inc. v. EPA. In this decision, the District of Colombia circuit court held that the EPA’s jurisdiction is under the operative statutes and is therefore limited to regulating the discharge of pollutants only.46 According to provisions set forth in the Clean Water Act, the EPA has the duty to regulate pollution of surface waters.47 In addition, farmers were required by law to obtain and install manure-handling systems.48 New and existing facilities were also directed to submit an Environmental Impact Statement to the EPA for review.49 Following the circuit court’s decision on these provisions, the United States Department of Agriculture and the EPA held public listening sessions on the draft of the United National Strategy for Animal Feeding Operations. In 1999 the final draft was released, and in 2001 the Environmental Protection Agency took an additional step and held nine public meetings on the proposed CAFO regulations.50

This same year, 2001, Nicolette Hahn Niman criticized industries that were failing to meet these established provisions. Niman, with the help of Robert Kennedy, Jr., issued a certified letter against CAFOs for breaking a federal environmental law.51 She argued that hog facilities were breaking the Clean Water Act by failing to obtain pollution permits and by both directly and indirectly contaminating groundwater, streams, and rivers.52 The Waterkeeper Alliance, along with other clean water advocates, joined her in this battle by filing amicus curiae briefs in the federal district court.53 Niman gathered experts in Bern, North Carolina, for the first Summit for Sustainable Hog Farming to advocate against liquid manure systems, confinement buildings, and sow crates.54 On September 7, 2001, The District Court held an oral argument between Niman and Smithfield Foods. Niman’s main argument was that Senator Robert Dole had clearly intended to regulate CAFOs by means of the Clean Water Act. Judge Malcolm J. Howard ruled in favor of Niman and the Waterkeeper Alliance, one of the few victories environmental advocates have had against CAFOs.55 As a result of this decision, issues of CAFOs would become mainstream and federal judiciaries across the country would hear cases at both the Circuit Court and District Court of the United States.

2003: Provisions and Response

In 2003, the Environmental Protection Agency administered the final National Pollutant Discharge Eliminated System Permit program and the Effluent Limitations Guideline for Confined Animal Feeding Operations.56 Signed on December 15, 2002, the CAFO final rule was published in the Federal Register on February 12, 2003.57 This provision assumed that all CAFOs have the potential to discharge pollutants and required each operation to obtain a NPDES permit.58 In addition, the act expanded the definition of exempt agricultural stormwater discharge to now include land application discharge.59 Farmers were also required to create site specific Nutrient Management Plans to ensure proper manure and wastewater storage, proper management of mortalities and chemicals, and appropriate site-specific protocols for land application.60

Soon after the 2003 provisions were enacted, the second circuit court of appeals ruled in Waterkeeper Alliance v. the United States Environmental Protection Agency that the Clean Water Act was applicable only to regulate present or actual discharges made by CAFOs, and, according to the court, it was unconstitutional to require companies to apply for a permit based on the mere potential to discharge.62 In addition, the court ruled that the Nutrient Management Plans had to be included in the NPDES permit for them to be ruled constitutional.63 This court reversed all provisions implemented by the EPA in regulating CAFOs. Little ground had been gained in regulating factory farms.

2008: Provisions and Response

In 2008, the EPA made a final attempt to regulate factory farms. Given the court’s decision in Waterkeeper, the Clean Water Act was updated to require CAFO owners to seek coverage under a National Pollutant Discharge Elimination System Permit.64 This permit would be issued to any company that was currently or was planning to discharge waste.65 As an incentive to obtain a permit, CAFOs could now be held liable for failing to apply for a permit and permitting discharge.66 This Supplement Proposed Rule provided that a CAFO’s status of non-discharging will be based on an objective assessment of conditions at the CAFO. This assessment analyzes whether a CAFO is designed, constructed, operated, and maintained in a manner such that the CAFO will not discharge. In any instance where a CAFO can successfully pass this assessment, the operator may apply for a voluntary certification so that in the event of a discharge, a CAFO without a permit will not be liable for violation of the duty to apply, but only be in violation of the CWA’s prohibition against unpermitted discharges.67 In an instance where a CAFO chooses to discharge and not apply for a permit, law enforcement may prosecute farmers for failing to apply for a permit and charge them with failure to apply liability.68 Following a supplemental proposal made in 2006, the issue of whether or not CAFOs should be made to apply for a permit on the mere proposal to discharge reached the United States Supreme Court for the first time in S.D. Warren Company v. Maine Board of Environmental Protection. The court declined to uphold the EPA’s requirement that factory farms apply for a permit if they proposed to discharge, based on the definition of “propose.”69 The court ruled that the EPA’s authority under the Clean Water Act was strictly limited to the discharge of pollutants in navigable rivers.70 Three years later, the Eighth Circuit Court of appeals made a decision in Service Oil Inc. v. The United States Environmental Protection Agency.71 In this decision, the judges held that the EPA needed to obtain detailed data from a new point source applicant in order to fashion and issue an appropriate permit.73They ruled that before any discharge occurs, a CAFO should not be considered a point source and cannot be required to obtain a permit.73 In addition, they stripped the EPA of its authority to assess penalties for failure to apply for the proper permit.74Once again, all revisions implemented by the Environmental Protection Agency had been struck down by the judicial branch.

In Carr v. Alta Verde Industries, the Fifth Circuit Court ruled that feedlots discharging waste from stored manure and holding ponds during heavy rains did not need to apply for a NPDES permit.75 (Clearly, as long as there is enough rain to wash the discharge into our nation’s waterways or percolate far enough into the soil to contaminate our groundwater, regulation is far from needed.) In 2011 the Fifth Circuit reached another decision in National Pork Producers Council v. The United States Environmental Protection Agency, ruling again that the EPA lacked the authority to impose liability for failure to apply for a permit regulating CAFOs merely proposing to discharge pollutants.76 The court’s rational was based on strict scrutiny of the Clean Water Act.

Argument #2: The Role of State and Local Governments

Another argument stems directly from our nation’s system of federalism: the separation of powers between the national and state governments. As we have examined above, based on current standards implemented by the Environmental Protection Agency, farmers can determine whether or not they think they are polluting the environment and can apply for a permit only if they believe they will do so.77 Factory farms themselves are no longer considered polluters according to the Clean Water Act and therefore are not regulated by the Environmental Protection Agency’s standards.78 Janet Pelley notes that of the 15,000-20,000 concentrated animal feed operations that were operating in 1998, only 200 dairy, hog, and chicken farm operations had the required.79 According to recent estimates by the National Resource Defense Council, only twenty-five percent of existing factory farms have obtained a Clean Water Act permit.80

State legislators have attempted to give pollution enforcement power to local governments, who could slow the proliferation of farms.81 The Environmental Protection Agency requires that farmers disclose information about emissions of ammonia and hydrogen sulfide from manure pits, material nearly impossible to regulate at the national level.82 In delegating this task to the state, the EPA has found that little has been accomplished in dealing with the lagoons. The National Resource Defense Council notes that lagoons are still being placed on land located above water sources such as floodplains, coastal waters, wetlands, and near wildlife refuges.83 States are not allocating an adequate number of employees and resources to enforce existing regulations. Simply put, there are not enough inspectors.84 Robert Kennedy, Jr. notes that few states are even attempting to enforce the pollution permits mandated by federal statute.85 Jeff Vonk, the head of Department of Natural Resource in Iowa, says, “We just don’t get enough funding from the legislature to do these permits.”86 The Environmental Protection Agency has established the laws, but as Nicolette Hahn Niman explains, “An unfunded law is as good as no law.”87

Argument #3: Outside Influences on the Environmental Protection Agency

Congress and the Presidency

As if opposition from the federal courts and state governments were not enough, the EPA also faces serious challenges from presidential administrations. During the Reagan Administration, the Justice Department, along with the Grain Inspection, Packers, and Stockyards Administration, backed large meatpackers who gained control of one local cattle market after another.88 Among the mega industries who benefited from the challenges to the EPA regulations were: ConAgra, IBP, Excel, and National Beef. Today, these companies slaughter 84% of our nation’s cattle and control 20% of live cattle through captive supplies.89 Captive supply means the cattle are maintained in company owned feedlots or purchased in advance through contracts.90 In supporting such industries, not only did the Reagan administration encourage the increased use of factory farms, but it also created an issue of environmental justice by displacing smaller subsistence and commercial farmers.

More recently, the Bush administration allowed thousands of factory farms to escape penalties for fouling the air and water.91 In exchange, these operations served as a source of data to help curb future pollution by mega-operations.92 The Environmental Protection Agency was forced to agree to these negotiations, allowing operations to escape the payment of fines until the year 2010.93 Since this study was completed, the Obama administration has made little progress in trying to regulate CAFOs. In response to National Pork Producers Council v. The United States Environmental Protection Agency, a rule was proposed in 2011 altering the NPDES CAFO Reporting Rule, but was withdrawn by the EPA.94 In addition, a decision was made by the EPA in 2012 to review the 2003 CAFO Rule, allowing public comments through March 1, 2013.95

In addition to resistance from the presidency, the EPA also faced resistance in Congress. In 1996, the Farm Bill gave over twenty million dollars annually to factory farms to aid in establishing contaminant lagoons. It is questionable whether this money is being spent properly. In 2001, Congress eviscerated the EPA’s enforcement budget and allowed corporate hog factories to proliferate with their pollution-based profits. By imposing their own limitations on the EPA’s enforcement of pollution standards, each of the three branches of government has compromised the effectiveness of the EPA.

Lobbying and Special Interest Groups

The interconnectedness of politicians and regulators in the agribusiness and food industrial complex makes reform difficult.96 It is no surprise that politicians are bought off by intensive livestock industries. Free-market environmentalists tend to speak with their money rather than with reason. Unlike deep ecologists, who ascribe to nature intrinsic value, free market environmentalists rely on humans to place an extrinsic value on their environment. As a result of the rise of factory farms, small producers are being displaced. In addition, factory farms are being issued fast track permits known as “general permits” under the Clean Water Act. These permits are not site-specific and do not inform citizens living nearby about proposed construction of a factory farm.97 These permits also allow CAFOs exemption from required monitoring.98 Environmental justice is certainly threatened by factory farms. The geographic location of factory farms often results in the displacement of local populations, and those people, as well as those who suffer from their polluting discharges, are generally poor, minority populations.

The relationship between consumers, industry, and factory farms also complicates the ability to regulate CAFOs, and makes the passing of legislation very unlikely. As described in Fast Food Nation, McDonalds reduced its beef suppliers to five during the 1970s in order to achieve product uniformity99 To do this, fast food industries limited the number of producers from whom they buy their products. This uniformity is dangerous, as it results in the spreading of pathogens, and, what is more, a few large corporations have gained control of the market and use unfair tactics to drive down the price of cattle.100 When cattle prices rise, mega-corporations simply flood the market with their own captive supplies.101

In the Waterkeeper decision, which ruled that the Clean Water Act applied solely to regulating the discharge of pollutants, the amicus curiae briefs filed were announced publically. Among the environmental petitioners fighting on behalf of the Environmental Protection Agency were the Waterkeeper Alliance Inc., Sierra Club, Natural Resource Defense Council Inc., and the American Littoral Society.102 On the opposing side, the farm petitioners included the American Farm Bureau Federation, the National Chicken Council, and the National Pork Producers Council.103In describing the decisions made by the Bush administration to exclude CAFOs from paying fines in exchange for research data, Ed Hopkins, the environmental quality director of the Sierra Club notes, “This decision is a great disservice for people who live around large factory farms. It basically gives these farms a free ride on the backs of the public. There’s really nothing in this that holds the polluters accountable for the toxic air emissions they release.”104

CONCLUSION

With the various obstacles the Environmental Protection Agency has had to deal with and overcome, it comes as no surprise that it has been ineffective in regulating confined animal feeding operations. First, the EPA’s regulations have been inefficient due to judicial processes and decisions made by the United States Circuit Court of Appeals. Second, the states’ authority to regulate provisions of the Clean Water Act that apply to CAFOs has been ineffective. Finally, environmental and farm petitioners along with lobbyists and other interest groups influence the public’s opinion and the government’s response to regulating factory farms. In order to improve the EPA’s effectiveness, two things need to occur. First, the United States Supreme Court must reverse decisions made in the circuit courts. Second, a shift towards localism and sustainable agriculture needs to occur. The time for reform has come.

NOTES

1Nicolette Hahn Niman, Righteous Porkchop: Finding a Life and Good Food beyond Factory Farms (New York, NY: Harper, 2010), 73.
2Ibid, 77.
3Ibid.
4Ibid.
5Ibid.
6Ibid.
7Ibid.
8Ibid, 78.
9Ibid.
10Ibid.
11Ibid.
12Ibid.
13Concentrated Animal Feeding Operations, Confined Animal Feeding Operations, and Factory Farms will be used synonymously with one another throughout this analysis; all three will be abbreviated as CAFOs.
14Eric Schlosser, Fast Food Nation: The Dark Side of the All-American Meal (Boston: Mariner Books/Houghton Mifflin Harcourt, 2012), 150.
15Anonymous, “Alternative to Pork Factory Farms Garners Support,” Journal of Environmental Health 65, no. 3 (October 2002): 52–53.
16Schlosser, Fast Food Nation, 202.
17David Kirby, “You Want Chicken Poop With That Steak? Why FDA Should Ban Feces From Feed,” Huffington Post, April 9, 2010
18Ibid.
19Schlosser, Fast Food Nation, 202.
20It is because of the practices that the export of meat to the European Union cannot occur. Such practices are banned following the outbreak of Creutzfeldt–Jakob disease in 2009.
21Anonymous, “Alternative to Pork Factory Farms Garners Support.”
22Schlosser, Fast Food Nation.
23Ibid.
24Ibid, 201.
25Michael W. Fox, “Manure, Minerals, and Methane: How Factory Farms Threaten the Environment,” The Animals’ Agenda 18, no. 3 (June 1998): 30–32.
26Ibid.
27Ibid.
28Ibid.
29Rachel Bleshman, “National Pork Producers Council v. U.S. EPA: Striking Down Clean Water Act Rule for Factory Farms, the Fifth Circuit Strips the EPA of Effective Regulatory Power,” Tulane Environmental Law Journal 25 (2012 2011): 207.
30Moby and Miyun Park, Gristle: From Factory Farms to Food Safety (thinking Twice about the Meat We Eat) (New York: New Press, distributed by Perseus Distribution, 2010), 17.
31Janet Pelley, “EPA Moves to Make Corporations Responsible for Disposal of Mountains of Manure,” Environmental Science & Technology 33, no. 19 (October 1, 1999): 402A–403A, doi:10.1021/es993027v.
32Ibid.
33Niman, Righteous Porkchop,79.
34Lauren Bush, as noted in Moby and Park, Gristle, 16.
35Ibid, 18.
36Erik Marcus, Meat Market: Animals, Ethics, & Money (Boston, Mass.: Brio Press, 2005), 194.
37Moby and Park, Gristle, 21.
38“Trends in Foodborne Illness in the United States | Estimates of Foodborne Illness in the United States | CDC,” accessed April 25, 2014, http://www.cdc.gov/foodborneburden/trends-in-foodborne-illness.html.
39Moby and Park, Gristle, 19.
40Schlosser, Fast Food Nation, 195.
41Office of the Commissioner, “2007 - FDA Finalizes Report on 2006 Spinach Outbreak,” WebContent, accessed April 10, 2014, http://www.fda.gov/newsevents/newsroom/pressannouncements/2007/ucm108873.htm.
42Federal Register. “National Pork Producers Council v. United States Environmental Protection Agency.”
43Ibid.
44Ibid.
45Ibid.
46Ibid.
47Fox, “Manure, Minerals, and Methane”, 30-32.
48Ibid.
49Ibid.
50“CAFO Rule History.” EPA -. http://cfpub.epa.gov/npdes/afo/aforule.cfm (accessed April 10, 2014).
51Niman, Righteous Porkchop, 83.
52Ibid, 64.
53Ibid.
54Ibid, 73.
55Ibid, 87.
56“CAFO Rule History.”
57Ibid.
58Federal Register. “National Pork Producers Council v. United States Environmental Protection Agency.”
59Ibid.
60Ibid.
61Ibid.
62Ibid.
63Ibid.
64Bleshman, “National Pork Producers Council v. U.S. EPA.”
65Ibid.
66Ibid.
67Federal Register. “National Pork Producers Council v. United States Environmental Protection Agency.”
68Ibid.
69Ibid.
70Ibid.
71Ibid.
72Bleshman, “National Pork Producers Council v. U.S. EPA.”
73Federal Register. “National Pork Producers Council v. United States Environmental Protection Agency.”
74Bleshman, “National Pork Producers Council v. U.S. EPA.”
75Ibid.
76“CAFO Rule History.”
77“EPA Goes Soft on Factory-Farm Operators,” Pantagraph.com, accessed April 10, 2014, http://www.pantagraph.com/news/opinion/editorial/epa-goes-soft-on-factory-farm-operators/article_6e87ae2a-3e05-570e-b5cc-f4475cdb81d0.html.
78Ibid.
79 Pelley, “EPA Moves to Make Corporations Responsible for Disposal of Mountains of Manure.”
80Schlosser, Fast Food Nation, 202.
81“EPA Goes Soft on Factory-Farm Operators.”
82R. Jeffrey Smith, “EPA Issues Exemptions for Hazardous Waste, Factory Farms,” The Washington Post, December 13, 2008, http://www.washingtonpost.com/wp-dyn/content/article/2008/12/12/AR2008121203826.html.
83Anonymous, “Alternative to Pork Factory Farms Garners Support.”
84Ibid.
85Niman, Righteous Porkchop, 90.
86Ibid.
87Ibid.
88Schlosser, Fast Food Nation, 137.
89Ibid.
90Ibid, 138.
91John Heilrpin. “EPA strikes pollution deal with factory-style animal farms.” Associated Press (January 30, 2006), (accessed February 05, 2014).
92Ibid.
93Ibid.
94“CAFO Rule History.”
95“CAFO Rule History.”
96Niman, Righteous Porkchop, 65.
97Anonymous, “Alternative to Pork Factory Farms Garners Support.”
98Ibid.
99Schlosser, Fast Food Nation, 137.
100Ibid.
101Ibid, 138.
102Federal Register. “National Pork Producers Council v. United States Environmental Protection Agency.”
103Ibid.
104Heilrpin. “EPA strikes pollution deal with factory-style animal farms”

Photo of Corey Harlow

Corey Harlow is a Masters of Arts student at Virginia Tech. In December, he graduated from Virginia Tech with a Bachelor of Arts in Political Science. His graduate research deals with the academic disciplines of environmental politics/policy, food politics, eco-violence, and political ecology. Corey has completed a great deal of research on concentrated animal feeding operations (factory farms) and why the United States Environmental Protection Agency has been ineffective in regulating such industries.

Corey is looking forward to continuing his journey as a graduate student at Virginia Tech, furthering his studies in environmental and food politics and policy along with public ecology. Corey is also a member of the Residential Leadership Community. Corey plans to graduate Spring 2016 with a Masters of Arts in Political Science from the Virginia Tech Political Science Department.

Corey would also like to thank Doctor Courtney I.P. Thomas, for the unconditional love and support that she provided throughout this journey. As an undergraduate mentor and now graduate committee chair, she has pushed Corey to excel in his career at Virginia Tech and provided him with numerous opportunities for growth. Corey thanks Dr. Thomas for always listening to him, supporting him, and encouraging him to be better. As both a friend and colleague, there is no other teacher as special and dedicated to their students.