Concentrated animal feeding operations (CAFOs), vertical integration, environmental harms, pollution, air quality, water quality, climate change, regulations

Document Type



Corporate farms, often known as concentrated animial feeding operations ("CAFO'), provide inexpensive animal products but do so by externalizing the cost of their operation in the form of environmental harms and risks to human health. This article explores one possible approach to mitigating CAFO-caused harms. It argues that CAFO regulation under any one of three Clean Air Act ("CAA ") programs will result in net benefits, not just for air quality, but also for other CAFO-caused harms and thus, that CAA regulation of CAFOs is a no-lose strategy. The article then goes further to conclude that, while regulation under any one of these programs would cause industry to internalize some of the costs of its operations, regulation under § 111 of the CAA most fully accomplishes this and will therefore result in the best overall outcomes for human health and the environment.