Coalition to End Factory Farming:
Impact Report on Measure J

Our research team has identified 21 large CAFOs in Sonoma County, which are listed in the Large CAFOs section of this research report. These facilities would have three years to either close down, downsize or otherwise alter their operations to no longer meet the definition of a CAFO. Continue reading for more details on the impact of Measure J on CAFOs, as well as the impact CAFOs have on Sonoma County.

Defining AFOs and CAFOs

To be a Concentrated Animal Feeding Operation (CAFO), a facility must first meet the EPA’s definition of an Animal Feeding Operation (AFO). According to the EPA:
“Animal feeding operation (“AFO”) means a lot or facility (other than an aquatic animal production facility) where the following conditions are met:

  • Animals (other than aquatic 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.”

Source: Title 40 Code of Federal Regulations §122.23(b)(1)

An AFO becomes a CAFO when it meets the regulatory definition of a large CAFO (confining a certain number of animals) or of a medium CAFO (confining a smaller number of animals but also discharging waste into surface water), or when it is deemed a major polluter by regulatory authorities on a case-by-case basis.

Source: EPA.Gov

Small and Medium CAFOs

Any CAFO in the US that discharges waste to surface water is required to obtain a National Pollutant Discharge Elimination System (NPDES) permit from the EPA. Because the definition of a medium CAFO includes discharge of waste to surface water, any medium CAFO would be required to have an NPDES permit. The California State Water Resource Control Board’s NPDES Permit Facility Search system shows that there are no CAFOs in the county permitted to discharge waste, meaning there are no medium CAFOs in Sonoma County. If any AFO within the medium size range was discharging waste into surface water without an NPDES permit, that would already be a violation of either the North Coast or SF Bay Regional Water Quality Control Board rules and EPA guidelines. 

Any AFO can be designated a CAFO by regulatory authorities on a one-off basis, if it is found to be a major risk to the environment, regardless of the number of animals it confines. This is extremely rare. Becky Mitschele, Acting Watersheds Manager at US EPA Region 9, which includes California, said she was only aware of small CAFO designation happening a couple times in the Midwest, and that there are no small CAFOs in Sonoma County.

Given our research and communication with local and federal regulatory agencies, it is our best understanding that there are no small or medium CAFOs in Sonoma County. 

Large CAFOs

While our best understanding is that there are no small or medium CAFOs in Sonoma County, research shows that there are multiple facilities that meet the regulatory definition of large CAFOs. Large CAFOs are defined as any AFO that confines more than a certain number of animals, with that number depending on the species, the product being produced, and whether the facility uses a solid or liquid manure handling system.

Through extensive open source research, we have identified 21 large CAFOs in Sonoma County, which are listed in the table below. This list aims to be overinclusive; we believe it is highly unlikely that large CAFOs are missing from the list based on our review of approximately 100 of the largest animal farms in Sonoma County, obtained by public records and thorough analysis of satellite imagery. All data listed is a best estimate based on available information, with sources linked where possible.

CAFO Research Methodology

The above research was conducted by volunteers based on the best available evidence that could be located. Whenever two sources provided contradicting estimates of animal populations at a facility, we used the higher number sources in order to lean toward over-inclusion of facilities as CAFOs, so that the possible impacts of the CAFO prohibition are not underestimated. It is possible that some population sources we used count animals not relevant to the CAFO number threshold, such as immature heifers on a dairy farm. It should be possible for county officials to make more accurate assessments based on information not available to the public. 

The majority of dairy farms were able to be assessed based on data from regional water boards, found here.

Some poultry/egg facilities were able to be assessed based on USDA reports from the 2023-2024 HPAI outbreaks, found here.

The remainder of poultry/egg facility populations were estimated based on a projected average of birds per square foot of barn space, generated by calculating the average for known facilities of the same type, and owner when possible. These estimates are the least reliable and, hopefully, it should be possible for county officials to make a more accurate assessment. 

How the Measure Addresses CAFOs

This measure would prohibit all CAFOs, including small, medium, and large CAFOs, though as explained above, we believe there are no small or medium CAFOs in the county. The measure would also prohibit new CAFOs from opening, as well as the expansion of existing CAFOs in the county. This measure would apply to unincorporated parts of the county, excluding the Coastal Zone. 

The measure spells out that: “Pre-Existing CAFOs shall be given a phase-out period of no more than three (3) years from the effective date of this Section to modify or terminate their operations such that they are no longer classified as a CAFO.” There are a few ways a large CAFO could make modifications so that it no longer qualifies as a CAFO. 

The facility could: 

  • Downsize the animal population to below the relevant limit, or 

  • Change to a non-liquid manure handling system where applicable, or

  • Stop confining their animals for more than 45 days per year so that the facility no longer qualifies as an AFO

The text of the measure is here.

Animal Welfare

Investigations into Concentrated Animal Feeding Operations (CAFOs) in Sonoma County reveal severe and systemic animal welfare issues. Animals in CAFOs are often subjected to extreme overcrowding and confinement, preventing them from exhibiting natural behaviors and leading to chronic stress and physical ailments. Investigations from multiple animal welfare organizations have documented egregious animal welfare violations in Sonoma County CAFOs.

  • An investigation at Reichardt Duck Farm in Petaluma by Mercy For Animals found ducks being mutilated by workers, and systematically left to die from untreated injuries and illnesses.

  • Repeated investigations of Perdue-run chicken CAFOs in Sonoma County have found chickens growing so fast that their bodies can not keep up, leading to mobility issues, as well as a host of widespread diseases that run rampant in Perdue facilities.

Despite repeated reports to local and state authorities, enforcement actions have been minimal, and animal cruelty laws are frequently violated. These findings highlight the urgent need for Measure J to prohibit the operation of CAFOs, ensuring more humane treatment of farm animals and aligning agricultural practices with the values of Sonoma County residents.

Greenhouse Gas Emissions

According to the Regional Climate Protection Authority’s 2020 Sonoma County Greenhouse Gas Emissions Inventory, livestock manure management is the third largest emissions source county-wide. Reducing agricultural emissions would result in significant progress on the ambitious county goal of achieving net zero emissions by 2030. The county’s current plans to reach carbon neutrality by 2030 heavily rely on carbon capture, which is a more complicated and likely more expensive strategy than reducing the emissions in the first place.

The EPA states that 154 to 264 lbs of methane is produced by an individual cow per year. According to this calculation, closure of the 6 dairy CAFOs in Sonoma County (estimated to confine 6,355 mature dairy cows) would prevent between 978,670 and 1,677,720 pounds of methane emissions per year. These emissions alone, without adding any of the other emissions from other CAFOs, are equivalent to 12,430-21,308 metric tons of Co2 every year, equal to the amount of carbon sequestered by 14,512 - 24,878 acres of US forest.

Water Pollution

CAFOs are defined by the EPA specifically because they pose a threat of water pollution. According to the CDC: 

“The agriculture sector, including CAFOs, is the leading contributor of pollutants to lakes, rivers, and reservoirs. It has been found that states with high concentrations of CAFOs experience on average 20 to 30 serious water quality problems per year as a result of manure management problems.” 

Many important bodies of water in Sonoma County, including the Petaluma River, Laguna de Santa Rosa, Estero Americano, and San Pablo Bay Estuaries are impaired by bacteria and microbes which threaten human and wildlife health, as well as nitrogen and/or phosphorus which create harmful algal blooms or “dead zones,” all of which are commonly caused by CAFO pollution.

While the EPA is theoretically tasked with oversight and regulation of CAFO water pollution, a report from the U.S. Government Accountability Office found that “EPA does not have comprehensive, accurate information on the number of permitted CAFOs nationwide. As a result, EPA does not have the information it needs to effectively regulate these CAFOs.”  The EPA has faced severe criticism and lawsuits from prominent environmental groups including the National Resource Defense Council, Food and Water Watch, Center for Biological Diversity, and Union of Concerned Scientists for their failure to effectively regulate CAFOs. Sadly, the task of challenging CAFOs falls on local jurisdictions like Sonoma County, which has a unique opportunity to lead the battle against these major sources of environmental destruction. 

Water Use

CAFOs are major consumers of water. Irrigated pasture was ranked as the number 1 most water-intensive crop in California in the most recent 2015 analysis. As well as the massive water use of irrigating extensive pasture to feed animals, water is required for every step of industrial animal production, from growing alfalfa (the 3rd most water intensive crop according to the same statewide report), to providing drinking water for animals, flushing feces into manure lagoons for storage, and finally, the water-intensive process of slaughter. 

Extensive data on CAFO water use is not publicly available, which makes it even more imperative that the county use their access to calculate the impacts of CAFOs on the limited supply of fresh and recycled water in Sonoma County.

Public Health

CAFOs, or Concentrated Animal Feeding Operations, can have multiple negative impacts on public health, including:

  1. Air quality issues: According to the NIH, “Toxic gasses, vapors, and particles are emitted from concentrated animal feeding operations (CAFOs) into the general environment. These include ammonia, hydrogen sulfide, carbon dioxide, malodorous vapors, and particles contaminated with a wide range of microorganisms.” Another NIH study focused on poultry CAFOs reports, “Populations exposed to these chemicals may be at risk for a host of adverse health outcomes. Exposure to airborne ammonia and volatile organic compounds can aggravate lung function and may cause chronic lung disease, while hydrogen sulfide can cause inflammation of the eyes, nose, and throat. Particulate matter may worsen lung function and can cause irregular heartbeat, heart attacks, and other cardiac abnormalities.” These pollutants can lead to a variety of health problems including respiratory issues, headaches, eye irritation and can exacerbate asthma. According to the CDC, “There is consistent evidence suggesting that factory farms increase asthma in neighboring communities, as indicated by children having higher rates of asthma (Sigurdarson & Kline, 2006; Mirabelli et al., 2006). CAFOs emit particulate matter and suspended dust, which is linked to asthma and bronchitis. Smaller particles can actually be absorbed by the body and can have systemic effects, including cardiac arrest.”

  2. Water contamination: Manure from CAFOs can run off into nearby water sources, causing high levels of nitrates, pathogens, and pharmaceuticals in the water. This can impact drinking water sources, causing public health concerns. Studies have shown trace antibiotics in drinking water and groundwater near these facilities.

  3. Antibiotic resistance: The overuse of antibiotics in CAFOs can contribute to antibiotic resistance in humans. This could make treatment of certain bacterial infections more difficult and potentially dangerous.

  4. Disease transmission: A zoonotic disease caused the swine flu outbreak in 2009-2010. The CDC estimates the global H1N1 death toll at 284,000. There are still outbreaks happening all over the world. Avian flu is another example of zoonotic disease that ravaged the world in the past and is currently evolving posing a massive threat to human and non-human life. 

  5. Community health: Communities located near CAFOs often report higher levels of stress and lower quality of life due to noise, odor, and concerns about health impacts. Property values also decrease when near CAFOs. 

These issues, as well as a number of other concerns, have led prominent public health groups to sound the alarm about CAFOs, with the American Public Health Association adopting a policy statement calling for a moratorium on the construction and expansion of CAFOs.