Is your farm a CAFO?

Simplified terms to determine if your farm is classified as a CAFO

In an on-going effort to educate farmers about the Illinois EPA Livestock Rules, information is being provided by the collaborative work of the Illinois Agricultural Coalition which includes: Illinois Beef Association, Illinois Farm Bureau, Illinois Milk Producers’ Association, and Illinois Pork Producers Association. Farmers may contact any of these organizations to request a free copy of a Resource Guide on the EPA Rules.


You have probably heard the term “CAFO” used many times. Do you know if your farm is one?


Concentrated Animal Feeding Operations (CAFOs) are defined by the Illinois EPA Livestock Rules, which became effective in August 2014. It is important for you to know if your farm meets the CAFO definition so you can determine if your farm is in compliance with these Rules.


To be a CAFO, a farm must first be an Animal Feeding Operation (AFO). If a farm does not meet the definition of an AFO, the EPA Rules do not apply to it.


The AFO definition has two parts:

Part 1 - A lot or facility where animals have been, are, or will be confined and fed or maintained for a total of 45 days or more in any 12 month period

Part 2 - Where vegetation (crops, forage, post-harvest residues) is not sustained in the normal growing season over any portion of the lot or facility.  


Most situations in which pigs are raised will likely be defined as an AFO.


If your farm is an AFO, then you must determine if you are a Small, Medium or Large CAFO, which factors in the number of animals that are confined on the farm and whether pollutants are being discharged into Waters of the U.S (WOTUS).


Large swine CAFOs must have 2,500 or more swine weighing 55 lbs. or more OR 10,000 or more swine weighing less than 55 lbs. on a single site. Keep in mind, when determining whether a farm meets the Large CAFO definition, the number of animals actually confined on the farm is used, not the capacity of the barns. For example: A farmer has a 2,500 head wean to finish barn, but only keeps 2,400 head of pigs in the barn at any given time. The farm would NOT meet the Large CAFO definition.


Also, if there are pigs on a farm that are above 55 pounds and below 55 pounds, the numbers of pigs are not combined. Instead, determine whether either size group is over its respective threshold and use that to determine the size definition. For example: A farmer with 1,000 sows and 9,000 pigs under 55 pounds on the same farm would NOT meet the Large CAFO definition.


Medium CAFOs must meet the size thresholds of 750 - 2,499 swine weighing 55 pounds or more OR 3,000 – 9,999 swine weighing less than 55 pounds AND be discharging pollutants through man-made conveyances to WOTUS.


When determining if an AFO has any discharges, a farmer must look at the entire production area including manure storage, feed storage and dead animal composting to determine if there is a discharge. For example: A Medium AFO could be containing all their manure in a deep pit, but have a discharge to WOTUS from the dead animal composter, which could be the determining factor that defines the farm as a Medium CAFO.


Small CAFOs have 1-749 swine weighing 55 pounds or more OR 1-2,999 swine weighing less than 55 pounds. For a small AFO to be a CAFO, the IL EPA must do an on-site investigation and determine that the AFO is a significant contributor of pollutants to WOTUS.


Another factor to consider when determining the size of your CAFO is if a farmer has multiple sites where animals are confined, they must determine if those sites are separate AFOs or should be combined. Under the IL EPA Livestock Rules, two or more AFOs under common ownership would be considered to be a single AFO if:

  • The AFOs are adjacent to each other OR
  • The AFOs utilize a common area or system for handling or disposing of manure


Common ownership means facilities where animals are confined that are owned by the same person. A person is not only an individual, but also includes a partnership, company, corporation, etc.


There’s no official IL EPA definition of adjacent. However, barns that are located within close proximity to each other would typically qualify as adjacent. For example, barns located across the road from each other, sharing one common border, or located on a contiguous parcel of land are all likely to be considered adjacent.


There are many factors to consider when determining if your farm is a CAFO. Bottom-line –  manage your farm in a way that ensures no discharges to WOTUS.


More detailed information is included in the Resource Guide. Contact the IPPA office for your free copy to help your farm be in compliance with these Rules.