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Hiding The Ball: The Sidestepping Of National Pollution Discharge Elimination System Permitting Requirements By Concentrated Animal Feeding Operations, Adam S. Carlesco
Hiding The Ball: The Sidestepping Of National Pollution Discharge Elimination System Permitting Requirements By Concentrated Animal Feeding Operations, Adam S. Carlesco
Adam S Carlesco
Concentrated animal feeding operations (CAFOs) are one of the few point sources under Clean Water Act jurisdiction that are not required to meet more stringent NPDES permitting requirements. After a series of court cases, the EPA proposed rulemaking requiring the submission of information by CAFO operators to create a national database of CAFO locations and operation information, yet that rulemaking was subsequently abandoned. This paper proposes that EPA implement the proposedreporting requirements put forth in their 2010 settlement agreement with environmental petitioners.