Reinventing Regulation of Agriculture: Alternative Performance Standards for Concentrated Animal Feeding Operations

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Concentrated Animal Feeding Operations (CAFOs) are point sources of pollution and require Clean Water Act permits. The 2003 regulations allow Large CAFOs to propose alternative performance standards (APS) that offer equivalent or better environmental performance than the baseline technology. Principal obstacles to APS success include the complexities of demonstrating superior performance, cost uncertainties for obtaining approval, CAFO risks of participation, inter- and intra-organizational barriers of permitting agencies, and potential lawsuits brought by environmental groups. Despite obstacles, APS offers potential for technology innovations and reduced environmental compliance …