What is a Confined Feeding Operation?
Paul Ebner and Yingying Hong - Purdue Animal Sciences
There is often confusion as to the definitions of CFO or CAFO and even
AFO. At the state level, these types of farms are largely regulated by the
Indiana Department of Environmental Management (IDEM). Therefore,
at the state level, AFO, CFO, and CAFO are defined by IDEM (IAC 327;
To start, let’s define “confined feeding”. This is the practice of keeping
livestock or poultry in some manner of confinement for more than 45
days out of a year. “Confinement” generally means indoors, or in a pen in
the case of feedlots. Any type of farm that raises animals in this manner is
considered an AFO, or Animal Feeding Operation (IAC 327; IDEM 2014).
A CFO, or Confined Feeding Operation, is a type of AFO and is defined by
two main characteristics:
- confinement of animals in buildings or lots with less than 50 percent
vegetation or ground cover for 45 days or more over a 12-month
- numbers of animals (Table 1).
Thus, CFOs are AFOs that have above a certain number of animals. CFOs
are regulated by IDEM under its Confined Feeding Program (IDEM 2014).
AFOs with fewer animals are not, except when that farm has a discharge
or spill. In those cases, IDEM may regulate these specific farms as CFOs.
Currently, there are about 1,800 CFOs in Indiana across all species (e.g.,
beef cattle, dairy, swine, poultry). All 1,800 are regulated by IDEM at the
A CFO with very high numbers of animals is considered a CAFO, or
Concentrated Animal Feeding Operation (Table 1). Before 2011, CAFOs
were much more distinct from CFOs in terms of regulation. This was
largely due to the US Environmental Protection Agency requiring CAFOs to obtain a National Pollutant Discharge Elimination
System (NPDES) permit. This is the type of permit
that human waste water treatment systems obtain,
allowing them to discharge or recycle treated/
remediated waste water directly into larger bodies
of water. This is ordinarily the last process in treating
human waste water. Livestock producer groups
have generally objected to this requirement as it is
never their practice to directly discharge manure
into a body of water (manure is generally spread
or injected into soil as fertilizer). Direct discharge is
not even allowed with an NPDES permit. Following
a court ruling in 2011 (National Pork Producers
et al. vs. US EPA), CAFOs in Indiana are no longer
required to obtain NPDES permits for operation
unless they directly discharge into a body of water.
An NPDES permit can still be required of any farm
found to intentionally or unintentionally discharge
wastewater into any waters of the state. While
there are some relatively minor extra regulations
for CAFOs (mainly revolving around storm water management requirements), CAFOs in Indiana are
largely regulated simply as CFOs at the current time.
In short, CAFOs are:
- a subset of CFOs;
- larger in terms of animals numbers; and
- treated for the most part simply as CFOs in
Indiana by IDEM due to changes in regulatory
That being said, CFOs may also be regulated in
terms of siting (where they can locate) at the county
level through a zoning ordinance. In Indiana, the
definitions of AFO vs. CFO vs. CAFO varies somewhat
across counties (e.g., some have lower or higher
animal thresholds). These variations in definition do
not impact which farms are regulated by IDEM and
how they are regulated at the state level. They could,
however, dictate where farms fitting the description
of CFO in the zoning ordinance can locate within
the county. Note that ALL CFOs as defined by IDEM
are required to obtain an IDEM permit and approval prior to any construction, regardless of the county
zoning ordinance. To learn more about county
provisions and standards for CFOs and CAFOs in
Indiana, including summaries of zoning ordinances
for individual Indiana counties, see A Comparison of CFO Provisions and Standards across Indiana.
In articles throughout the site, we will generally use
the term CFO as it encompasses all livestock farms
that are regulated by the State of Indiana.
|Table 1. Definitions of CFO and CAFO based on animal numbers and species. Adapted from IDEM 2014.
|Animal and/or Operation System
|Growers, Finishers, Sows (> 55 lbs.)
|Nursery Pigs (< 55 lbs.)
|Mature Dairy Cow
|Other than Mature Dairy Cowsa
|Layers/Broilers (Liquid Manure System)
|Non-layers (Non-Liquid Manure System)
|Layers (Non-Liquid Manure System)
|Liquid Manure System
|Non-Liquid Manure Systems
aDairy heifers and calves, veal calves.
Indiana Administrative Code [IAC] 327. Article 19. 2012. Confined Feeding Operations. Available online at: www.in.gov/legislative/iac/T03270/A00190.PDF.
Indiana Department of Environment Management [IDEM]. 2014. Guidance Manual for Indiana's Confined Feeding Program. Available online at: http://www.in.gov/idem/cfo/files/guidance_manual_cfo_program.pdf.
United States Fifth Circuit Court. 2011. National Pork Producers Council et al. vs. United States EPA: WL 871736.