CFOs - Confined Feeding Operations

What is a Confined Feedi​ng Operation?

PDFWhat 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; IDEM 2014).

At the U.S. Meat Animal Research Center in Clay Center, Nebraska, animal scientists Cal Ferrell and Mindy Spiehs evaluate cattle for growth performance and feed efficiency after dietary treatments.  

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:

  1. 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 period; and
  2. 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 state level.

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:

  1. a subset of CFOs;
  2. larger in terms of animals numbers; and
  3. treated for the most part simply as CFOs in Indiana by IDEM due to changes in regulatory requirements.

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 numbers)
Animal and/or Operation System CFO CAFO
Growers, Finishers, Sows (> 55 lbs.) ​≥600 ≥2,500
Nursery Pigs (< 55 lbs.) ≥600 ≥10,000
Cattle ≥300 ≥1,000
Cow/Calf Pairs ≥300 ≥1,000
Mature Dairy Cow ≥300 ≥700
Other than Mature Dairy Cowsa ≥300 ≥1,000
Layers/Broilers (Liquid Manure System) ≥30,000 ≥30,000
Non-layers (Non-Liquid Manure System) ≥30,000 ≥125,000
Layers (Non-Liquid Manure System) ≥30,000 ≥82,000
Liquid Manure System ≥30,000 ≥50,000
Non-Liquid Manure Systems ≥30,000 ≥30,000
Other Animals
Turkeys ≥30,000 ≥55,000
Horses ≥500 ≥500
Sheep/Lambs ≥600 ≥10,000

aDairy heifers and calves, veal calves.


Indiana Administrative Code [IAC] 327. Article 19. 2012. Confined Feeding Operations. Available online at:

Indiana Department of Environment Management [IDEM]. 2014. Guidance Manual for Indiana's Confined Feeding Program. Available online at:

United States Fifth Circuit Court. 2011. National Pork Producers Council et al. vs. United States EPA: WL 871736.


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