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What if My Operation is an AFO But Not a CAFO?


Animal Feeding Operations (AFOs) are agricultural operations where animals are housed, fed, and cared for in barns or other confined space. Nationwide, it is estimated there are over 450,00 AFOs. The vast majority of these operations do not confine enough animals to meet the definition of Concentrated Animal Feeding Operations (CAFOs) as defined in the new U.S. Environmental Protection Agency’s (EPA) Rules on CAFOs. All CAFOs must operate under a National Pollutant Elimination System (NPDES) permit. (See CAFO Fact Sheet #2: Do I Need an NPDES Permit for My Livestock or Poultry Operation?)

In contrast to animal operations that use only pasture or free-range production practices, AFOs, by definition, confine animals more than 45 days in a 12-month period. Furthermore, the area of confinement, such as barns or open lots, does not sustain natural vegetation, row crops, or forage crops during the normal growing season. These operations tend to congregate animals, feed, manure, and other waste into small areas. These confinement facilities usually employ mechanical material handling systems to deliver feed to the animals and remove waste.

Despite the tremendous progress made in cleaning up our nation’s inland and coastal waters over the past 30+ years, state assessments report that 40% of our nation’s rivers and streams, 45% of lakes and reservoirs, and 50% of estuaries still do not meet goals for swimming, fishing, or both. Agriculture, including AFOs, is a major source of contaminates to the nation’s inland waters.

In 1999, EPA and USDA formulated a National Unified Strategy to minimize water quality and public health impacts from AFOs. The goal of this unified strategy


This fact sheet reflects the best professional judgment of the contributing authors and is based on information available as of the publication date. Also, your state may have additional, more stringent requirements than EPA’s requirements. Contact your permitting authority for complete information on the regulations that apply to you.


Copyright © 2003. MidWest Plan Service, Iowa State University, Ames, Iowa  50011-3080.

Copyright Permission

For copyright permission, call Mid-West Plan Service (MWPS) at 515- 294-4337. Organizations may reproduce this fact sheet for noncommercial use, provided they acknowledge MWPS as the copy-right owner and include the following required credit statement:


Reprinted from Livestock and Poultry Environmental Stewardship curriculum, fact sheet authored by Stanley (Lee) Telega, Cornell University, and Peg Cook, Cook Consulting, courtesy of MidWest Plan Service, Iowa State University, Ames, Iowa, 50011-3080 and your land-grant universities, Copyright © 2003.


is for AFO owners and operators to take actions to minimize water pollution from confinement facilities and land application of manure. The strategy announces an expectation that all AFOs should develop and implement a site-specific, economically feasible, and technically sound Comprehensive Nutrient Management Plan (CNMP). The owners and operators of AFOs not defined as CAFOs are encouraged to participate in voluntary programs conducted by the federal and state agencies to learn about financial and technical assistance available for developing and/or implementing a CNMP for their operation.

A CNMP identifies practices to be followed to meet defined nutrient management goals for the AFO. As necessary, it should address:

  • Feed management

  • Manure handling and storage
  • Land application of manure
  • Contaminated runoff from the confinement area
  • Land and soil conservation practices
  • Proper mortality disposal
  • Record keeping

Producer Checklists

The following two tables list management practices that may be included in an AFO owner or operator’s CNMP. Some are easy to implement with little or no cost. Others may require significant planning and investment. For additional help in making your farming practices more environmentally sound, consult your local Conservation District, Cooperative Extension, or local USDA Service Center.


Management Practices for Animal Confinement Areas

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Management Practices for Cropland

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Time Line for Voluntary Action

The intent of the USDA-EPA Unified National Strategy for AFOs is for the owners and operators of all AFOs to develop and implement their CNMP by 2009. Both agencies continue to commit resources to build capacity for CNMP development and implementation. Through accelerated, voluntary incentive-based programs and industry leadership, it is expected that the owners and operators of most AFOs will take action to minimize the risk of pollution from their operations.

Definition of Terms

Animal Feeding Operation (AFO)–A lot or facility where animals have been, are, or will be stabled or confined and fed or maintained 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 in the normal growing season over any portion of the lot or facility.

Comprehensive Nutrient Management Plan (CNMP)–Site-specific plan that considers the source and fate of nutrients on the farm and is designed to minimize potential loss of nutrients to the environment while achieving production and economic goals.

Concentrated Animal Feeding Operation (CAFO)– AFO containing animal numbers above a defined threshold or that has been designated as a CAFO after determining it to be a significant contributor of pollutants to waters of the United States. CAFOs are point sources of pollution and must operate under a National Pollutant Discharge Elimination System permit.

Diversions and grass waterways–Water control structures constructed in a field to reduce flow across a field for soil erosion protection.

Phosphorus Index–A risk assessment tool to estimate the potential for phosphorus movement from a field into a nearby waterbody.

Phytase–Enzyme that when added to rations of non- ruminant animals makes the phosphorus in grains and other feed ingredients more available during digestion.

Pre-sidedress nitrogDoneen test–Test taken when corn is less than 12 inches tall to determine if additional nitrogen fertilizer is needed to reach a yield goal for the crop.

Sheet and rill erosion–Type of soil erosion that occurs when soil is removed by water more or less uniformly from every part of the slope in a field.


Stanley (Lee) Telega, a Senior Extension Associate at Cornell University, can be reached at, and Peg Cook, the owner of Cook Consulting, Lowville, NY, can be reach- ed at


The authors wish to thank Joe Harrison, Washington State University; Karl VanDevender, University of Arkansas; Jeff TenEyck, New York Department of Agriculture and Markets; and Peter Wright, Cornell University, for their review of this fact sheet.


Primary Contact Information about Livestock Nutrient Management in Washington State

Washington State Department of Agriculture

Program Manager:

Nora Mena

Administrative Assistant:

Laurie Crose


Lead Inspector and Southwestern Washington

Kirk Robinson

Eastern Washington:

Ginny Prest

Northwestern Washington

Jeff Canaan


Washington State Department of Agriculture

Web site:

Washington State University

Livestock Nutrient Management Specialist

Joe Harrison
WSU – Puyallup Research and Extension Center

Tip Hudson
Rangeland & Livestock Management
Ellensburg, WA

Environmental Regulations Related Resources – To obtain copy of regulations – To obtain state environmental agency contact

Educational Resources – To view the Livestock and Poultry Environmental Stewardship (LPES) curriculum resources

Fact sheet modified by:

Joe Harrison and Tip Hudson, WSU Washington State Department of Agriculture Washington State Department of Ecology


Washington State Livestock Technical, Financial and Educational Assistance

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