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Corporate Agribusiness

and America’s Waterways

The Role of America’s Biggest AgribusinessCompanies in the Pollution of ourRivers, Lakes and Coastal Waters



November 2010

Written by:

Tony Dutzik, Travis Madsen and Elizabeth Ridlington, Frontier Group

John Rumpler, Environment America Research & Policy Center

Corporate Agribusinessand America’s WaterwaysThe Role o America’s Biggest Agribusiness

Companies in the Pollution o our

Rivers, Lakes and Coastal Waters



Environment Maryland Research & Policy Center thanks Stacy James, water resourcesscientist at the Prairie Rivers Network and Michele Merkel, Chesapeake regionalcoordinator or the Waterkeeper Alliance, or their review o this report. Thanks alsoto Luke Metzger o Environment Texas Research & Policy Center, and Rob Kerth,Ben Davis and Susan Rakov o Frontier Group or their editorial support.

Environment Maryland Research & Policy Center thanks the Town Creek Founda-tion and the McKnight Foundation or making this report possible.

The authors bear responsibility or any actual errors. The recommendations arethose o Environment Maryland Research & Policy Center. The views expressed inthis report are those o the authors and do not necessarily reect the views o ourunders or those who provided review.

© 2010 Environment Maryland Research & Policy Center

Environment Maryland Research & Policy Center is a 501(c)(3) organization. Weare dedicated to protecting our air, water and open spaces. We investigate problems,crat solutions, educate the public and decision-makers, and help the public maketheir voices heard in local, state and national debates over the quality o our environ-ment and our lives. For more inormation about Environment Maryland Research

& Policy Center or or additional copies o this report, please visit www.environ-mentmaryland.org/center.

Frontier Group conducts independent research and policy analysis to support a cleaner,healthier and more democratic society. Our mission is to inject accurate inormationand compelling ideas into public policy debates at the local, state and ederal levels.For more inormation about Frontier Group, please visit www.rontiergroup.org.

Cover photos: Manure spreader: Tim McCabe, USDA Natural Resources Conser-

vation Service; cattle eedlot: USDA Natural Resources Conservation Service; cornfeld and ethanol plant: Jim Parkin, istockphoto.com; hog waste lagoon: Bob Nichols,USDA Natural Resources Conservation Service.

Layout: To the Point Publications, www.tothepointpublications.com

Acknowledgments



Table of Contents

Executive Summary 4

Introduction 8

Big Agribusiness: A Big Polluter o America’s Waterways 10

Agribusiness is Polluting America’s Waterways 10

Corporate Agribusiness as an Environmental Threat 12

Pollution rom Corporate Agribusiness: Killing America’s Waterways 17

Big Chicken: Perdue, Tyson, Pilgrim’s Pride and the Fouling o Treasured

American Waterways 17

The Hog Bosses: Smithfeld, Cargill and the Environmental Toll o Pork Production 23

Bee Factories: Pollution rom JBS and Cargill Processing Plants 29

Dairy Dangers: Factory Farms and the Death, Rebirth, and “Redeath” o aGreat Lake 31

King Corn: ADM and the Gul o Mexico Dead Zone 33

Policy Recommendations 38

Notes 42



4 Corporate Agribusiness and America’s Waterways

Executive Summary

Pollution rom agribusiness isresponsible or some o America’smost intractable water quality

problems – including the “dead zones”

in the Chesapeake Bay, Gul o Mexicoand Lake Erie, and the pollutiono countless streams and lakes withnutrients, bacteria, sediment andpesticides.

Farming is not an inherently pol-luting activity. But today’s agribusinesspractices – rom the concentration o thousands o animals and their waste insmall eedlots to the massive planting o chemical-intensive crops such as corn –make water pollution rom agribusinessboth much more likely and much moredangerous.

The shit to massive corporate agri-business operations is no accident. It islargely the result o decisions made inthe boardrooms o some o the world’slargest corporations. When it comes to

agricultural pollution o America’s waterways, thereore, the problem begins at thetop. Major agribusiness frms are directly or indirectly responsible or the degrada-

tion o many American waterways, andmust be held accountable or stopping that pollution and cleaning up the mess.

Big agribusiness is a major polluter o America’s waterways.

Agriculture contributes to making•

more than 100,000 miles o riversand streams and 2,500 square mileso inland lakes too polluted to sustainimportant uses such as swimming,

fshing, drinking,or the maintenance

o healthy populations o wildlie.

The past several decades have seen•

major changes in the nation’s agricul-tural system that have increasedthe power o agribusiness frms andmagnifed the potential or pollution:



Executive Summary 5

A ew companies now controlº America’s ood system. Theour largest frms in each sectorproduce 72 percent o the na-tion’s bee, 63 percent o the na-tion’s pork and 57 percent o the

nation’s chicken – giving thosecompanies vast control over theagricultural marketplace and thepractices armers use to raiseood. In addition, key agribusi-ness industries such as chickenand pork production have movedto a vertically integrated modelthat gives giant corporationsnearly complete control overthe production process rom ananimal’s birth to the delivery o processed meat to store shelves.

Agribusiness frms have re-ºshaped how America pro-duces its ood. Through verticalintegration, control o agricul-tural markets, and their powerto inuence public policy, bigagribusiness frms have reshapedhow America produces its ood.Since 1993, or example, theshare o the nation’s milk cows

on large arms o 200 cows ormore increased rom 31 percent to 67 percent. Similar shitstoward concentrated animaleeding operations (CAFOs) havetaken place in the chicken andpork industries, magniying thepotential or pollution o nearby waterways. Meanwhile, agribusi-ness-supported policy changeshave ueled massive planting o chemical-intensive corn or etha-

nol, corn syrup and animal eed,urther contributing to pollutiono waterways.

As demonstrated by the case stud-ies presented in this report, giant corporate agribusiness frms are at

the center o some o the nation’s most severe water pollution problems.

Chicken arming produces vast •

amounts o nutrient-laden poultry lit-ter that can pollute local waterways.

Perdue’sº operations on the Del-marva Peninsula contribute to thepersistent problems with algaeblooms and low dissolved oxygenin the Chesapeake Bay. The 568million chickens produced on theDelmarva Peninsula each year –many o them raised by Perdue’scontract armers in the region– produce more than 1.1 billionpounds o chicken litter annually.

When nutrients rom chickenmanure fnd their way into thebay, they contribute to the algaeblooms that leave only 12 percent o the Chesapeake Bay with ad-equate levels o dissolved oxygenduring the summer months.

Pollution romº Tyson Foods andother chicken producers has led tothe degradation o water quality in the Illinois River in Arkansas

and Oklahoma. There are 2,800poultry arms in the Illinois River watershed, which produce as much waste as would be produced by 10.7 million people – much o which is spread on agriculturalland without treatment. Excessivepollution rom phosphorus andother nutrients has triggered algaeblooms that aect water quality inthe river.

A chicken processing plant oper-ºated by Pilgrim’s Pride (now owned by the Brazilian frm, JBS)is the largest source o nitrogenpollution that has contributed to water quality problems in north-east Texas’ Lake o’ the Pines. Thelake – a prime recreational re-




source or its region – has sueredin recent years rom fsh kills,algae blooms and beach closures. The Pilgrim’s Pride plant is arepeat violator o its Clean Water Act discharge permits.

Concentrated hog arming opera-•

tions have damaged waterways romNorth Carolina to the Midwest.

Waste rom hogs owned by ºSmithfeld Foods and othermajor hog producers has degraded water quality in North Carolina’sNeuse River, which has experi-enced a series o massive fsh killsin recent years. The 3 millionhogs in the Neuse River basin areresponsible or hal o the phos-phorus and a third o the nitrogenfnding its way into the waterwayso the Neuse River basin. Thesenutrients uel algae blooms that starve the river o oxygen and cantrigger fsh kills.

Despite decades o evidence that ºthe Illinois River in Illinois is su-ering rom nutrient pollution and

is a major source o nutrients tothe Mississippi River and the Gul o Mexico, agricultural giant Car-gill is intensiying its actory pork arming operations in the area andhas released increasing amounts o nitrate pollution rom its slaugh-terhouse along the Illinois River. That slaughterhouse is one o three Cargill-owned acilities torank among the nation’s top 20dischargers o toxic chemicals to waterways in 2008. Nitrate pollu-tion rom the slaughterhouse hasincreased tenold since 1998.

Massive bee processing acilities add•

to the environmental toll o agribusi-ness operations.

Brazilian ood colossusº JBS hasquietly become one o the na-tion’s top bee producers. In sodoing, it has inherited a legacy o environmental pollution. Thecompany recently paid a $1.9

million fne or pollution romits rendering plant located alongPennsylvania’s Skippack Creek, which triggered a series o fshkills. Pennsylvania environ-mental ofcials regularly oundexcessive amounts o E. coli,ammonia, phosphorus and otherpollutants in the creek down-stream o the plant .

The dramatic shit to actory •

dairy arming is polluting local waterways and contributing to there-emergence o old water quality problems.

The emergence o actory dairy ºarms – driven by consolida-tion in the milk industry andthe eorts o companies such as

Vreba-Ho – has had disastrousenvironmental results in Michi-

gan and Ohio, where pollutionrom those arms has pollutedlocal waterways and may be con-tributing to the re-emergence o the dead zone in Lake Erie.

Massive production o chemical-•

intensive corn – driven by publicpolicies that subsidize corn produc-tion – is wreaking havoc on waterways, including the Gul o Mexico.

No company has played a largerº role in creating the nation’smodern corn economy than

Archer Daniels Midland, whichhas used its political clout to winpolicies that subsidize corn pro-duction, promote the manuac-



Executive Summary 7

ture o high-ructose corn syrup,and encourage the use o ethanolas a uel. These policies have ledto the planting o an additional12.1 million acres o corn – anarea twice the size o Maryland

– since 2001. Industrialized cornproduction is highly dependent onchemical ertilizers and pesticides,and is the number one source o nitrogen pollution that uels thegrowth o the dead zone in theGul o Mexico.

Federal and state governmentsshould take immediate steps to protect

America’s waterways rom pollution rom corporate agribusiness – andto restore our already-polluted wa-terways to health. Specifcally, they should:

Ban the worst practices, including•

the creation o new CAFOs andagricultural practices such as theover-application o ertilizer that leadto pollution o waterways.

Guarantee Clean Water Act protec-•

tion to all o America’s waterways.

Hold corporate agribusiness respon-•

sible or its pollution by clariyingthat corporations that own animals

are legally responsible or the wastethey produce.

Enorce existing laws by requir-•

ing agribusiness operations to meet specifc limits on pollution where

necessary to restore a polluted waterway to health, requiring CAFOs that discharge to waterways to obtain water pollution permits or theiroperations, and ensuring that stategovernments properly implement theClean Water Act.

Give environmental laws real teeth•

by beefng up inspections and ensur-ing that repeated or serious viola-tions o water pollution laws are met

with real penalties, not slaps on the wrist.

Ensure environmental transparency •

by giving citizens access to detailedinormation about CAFOs andother agribusiness acilities in theircommunities, including inormationabout discharges o pollution to theenvironment.

Encourage better agricultural•

practices and consider systemic

reorms to ensure that Americanagriculture delivers sae, healthy ood without destroying our waterways.




Introduction

The idea that American agriculture would one day be dominated by “moneyed corporations” would have

been unthinkable to Thomas Jeerson– the man who, more than any other American, defned the nation’s armers asthe paragons o republican virtue.

Over the last several decades, however, Jeerson’s independent yet community-minded “cultivators o the earth” have

“Cultivators of the earth are the most

valuable citizens. They are the most

vigorous, the most independent, the most

virtuous, and they are tied to their country

and wedded to its liberty and interests by

the most lasting bonds.”1

– Thomas Jeerson

“I hope we shall ... crush in its birth the

aristocracy of our moneyed corporations.”2

– Thomas Jeerson

been eclipsed by a ew, large, oten multi-national corporations in deciding how America’s ood will be produced. In towns where amily armers once gathered tomake decisions that shaped the uture o their communities, today it is oten thecase that the most important decisionsare made in corporate boardrooms hun-dreds o miles away – or even on another

continent. The shit to corporate agribusinesshas done more than change the nature o American arming; it has also triggered anenvironmental crisis. Thomas Jeerson’s Monticello home sits near the RivannaRiver, which ows into the James Riverand ultimately the Chesapeake Bay – animportant and once ecologically vital waterway that has been degraded over thecourse o decades by agricultural pollu-tion, in particular waste rom corporate

chicken arming. The Chesapeake is not alone – rom the Gul o Mexico to theGreat Lakes – and in countless lakes andstreams in between – pollution rom agri-cultural activities is ueling algae blooms,threatening wildlie and ouling drinking water supplies.



Introduction 9

That pollution is the result o anagricultural system that increasingly produces the nation’s meat on armsthat pack thousands o animals ontosmall plots o land, producing wasteon the scale o entire cities and making

pollution o nearby waterways a near-certainty. It is a system that increasingly eeds those animals with corn planted in vast plots across the nation – corn that requires pesticides and ertilizers, someo which wash into our waterways, tothrive.

It is also a system that is largely mold-ed to the design, and designed to thebeneft, o a ew massive corporations,one in which amily armers still partici-pate, but in which they are increasingly vulnerable and lack the independencethat Jeerson once praised.

Four decades ago, Americans wereconronted by an environmental crisiso a similar scale – the massive waterpollution problems caused by indus-trial dumping into our nation’s rivers,streams and lakes. Those problems were so intense that the Cuyahoga Rivercaught fre and nearby Lake Erie wasconsidered “dead.”

At the time, ew Americans waxedpoetic about the wholesomeness o theneighborhood sewage treatment plant,

or rhapsodized about the republican virtues o the steel mill. Instead, weacted on the principle that no one –especially not powerul, well-resourcedcorporations – has the right to polluteour waterways with impunity and endan-

ger the public’s health and our naturalresources. We took action, and while the job o stopping industrial pollution isar rom done, we’ve made tremendousprogress.

Today, however, corporate agribusi-ness giants hide behind the wholesomeimage o the American amily armerto evade responsibility or their pollu-tion. Archer Daniels Midland, Cargill,Perdue, Tyson, Smithfeld – these areamong the corporations whose actionshave contributed to the devastation o American waterways. They are alsocorporations with vast resources toimplement better, more sustainable wayso producing America’s ood.

The time has come to hold corporateagribusiness accountable or its pollutiono our environment – just as Americans ageneration ago did with industrial pol-luters. It is up to Americans to insist onbetter practices that repair the damage

already done, and eliminate the mas-sive burden that agricultural pollutioninicts on our waterways.




Farming is not an inherently pollutingactivity. On the contrary, many arm-ers take stewardship o the land and

the environment as a sacred trust.However, as agriculture in Americahas increasingly adopted the structuresand methods o industrial production,it has become a major polluter. In thissection, we review the data on pollu-tion rom agribusiness, document thetrend toward greater concentration inindustrial agribusiness, and show how the shit to industrial agribusiness hasmagnifed the environmental impact o ood production.

Agribusiness Is PollutingAmerica’s Waterways

Corporate agribusiness3 imposes aheavy – and growing – toll on America’s

waterways. From the dead zones in theGul o Mexico, the Chesapeake Bay and Lake Erie to the pollution o count-

less local rivers, streams and lakes withnutrients, ertilizers and pathogens, theimpact o agribusiness on the nation’s waterways is severe.

According to the U.S. EnvironmentalProtection Agency (EPA), pollution romagriculture contributes to poor waterquality in more than 100,000 miles o rivers and streams in the United States,along with 2,500 square miles o lakesand 2,900 square miles o estuaries.4 These waters are so polluted that they

are unsae or fshing, swimming,

or themaintenance o healthy populations o wildlie.

These fgures greatly understate theimpact o agribusiness pollution on America’s waterways, since they includeonly waterways whose quality has been

Big Agribusiness: A Big Polluter ofAmerica’s Waterways



Big Agribusiness: A Big Polluter of America’s Waterways 11

assessed by state governments and thoseor which a cause o pollution was listed.Only 26.5 percent o America’s river andstream miles and 42 percent o our lakesby area have been ully assessed or their water quality.5

The problems extend to America’scoastal waters, where the number o documented areas o low dissolved oxy-gen – oten called “dead zones” becauseoxygen levels are too low to support marine lie – has increased rom 12 in1960 to 300 today. This includes thedead zone in the Gul o Mexico, whichcovered a record area o roughly 8,000square miles in 2008. The increase incoastal dead zones has coincided withthe expansion o industrial agribusinessin the United States.6

Typically, agricultural pollution fndsits way into waterways through runo rom arm felds or discharges rom sub-surace tile drainage systems, which carry pollution rom arm felds into nearby waterways. Animal waste rom actory arms, or example, might be sprayed onnearby felds and wash o into a nearby river, carrying bacteria and pollutingnutrients with it. Or, pesticides applied to

felds might wash o into waterways andimpact the plants, animals, and humansthat use that water.

In addition, concentrated animal eed-ing operations (CAFOs) also have thepotential to pollute via direct dischargeso manure rom leaking, ruptured oroverlowing manure lagoons. Finally,industrial acilities that process armoutputs into consumer products – romslaughterhouses to ethanol plants – may also discharge pollutants into water-

ways. Major orms o agricultural pollution

include: Nutrients: Industrial agribusiness

relies on heavy application o ertilizercontaining nutrients such as nitrogenand phosphorus to promote crop growth.

Whether in the orm o manuacturedertilizer or manure, nutrients can be washed o the land into surrounding wa-terways, where they can uel the growtho algae, depleting waterways o oxygenand sometimes triggering fsh kills. At the most extreme end o the scale, nu-trient runo can lead to the creation o

marine dead zones, as in the ChesapeakeBay, where a section o the bay becomesoxygen deprived each summer as a result o algae blooms. Certain nutrients, suchas nitrates, can also render water unsaeto drink when they are present in highenough concentrations.

Sediment: Sediment pollution resultsrom overgrazing, certain tillage prac-tices, and rom water management prac-tices that allow rainall to run o land tooquickly, carrying valuable topsoil with it.

Washed into rivers and streams, soil cancloud the water and diminish the light received by aquatic plants. It also settlesin the stream, disrupting ecosystems by flling in spawning grounds or otherwisealtering the streambed, and clogs thegills o fsh and other aquatic animals.

Drainage ditches in the Midwest carry nutrient-laden water into larger rivers and ultimately major waterways such as the Mississippi River and Gul o Mexico.

Photo: Lynn Betts, USDA Natural Resources Conservation Service.




Sediment also provides one vehicle ormany other agricultural pollutants, em-bedded in particles o soil, to wash into waterways.7

Pathogens: Animal waste containsbacteria and viruses that are harmul to

humans and animals. When animals arekept in concentrated environments likeCAFOs, large volumes o pathogen-bearing waste are produced. These wastescan fnd their way into waterways throughaccidental spills, ruptures or ooding o manure storage lagoons, or runo romthe spraying o arm felds with liquidmanure. Pathogens can render waterunsae or human consumption or use,contaminate shellfshing areas, and con-tribute to fsh kills and other ecosystemdamage.8

Pesticides: Chemicals applied to killunwanted plants and animals on croplandcan wash into waterways, rendering that water unsae or human consumption anduse and threatening aquatic plants andanimals. Pesticides can also contaminatefsh and shellfsh, rendering them unsaeor human consumption.

Corporate Agribusiness asan Environmental Threat

How did we get to the point wherethe production o our ood became sucha threat to our water?

The root o the problem is the indus-trialization o agriculture in the UnitedStates, a development that has been ad- vanced over the course o the last severaldecades by major agribusiness corpora-tions.

Practiced poorly, even traditionalorms o arming can create problemsor waterways, while there are ways tominimize – and in some cases eliminate– the threat o industrial agribusinessoperations to our water. But the meth-ods o ood production used in industrial

agribusiness make environmental impactsar more likely through their reliance onchemical-dependent monoculture cropsand concentrated animal eeding opera-tions.

Control o America’s system o ood

production has become increasingly concentrated in the hands o a ew largecorporations, which in turn have helpedreshape the way America produces ood,oten to the detriment o our environ-ment.

A Few Corporations ControlAmerica’s Food System

Agribusiness frms have emerged asamong the nation’s richest and most powerul corporations. Archer Daniels Midland ranks 27th on the Fortune 500list o largest U.S. companies, with $69billion in annual revenue, ollowed by Tyson Foods (84 th), Smithield Foods(163rd), ConAgra (178th) and Dean Foods(208th).9 Other agribusiness corporations would rank highly on the list i they wereU.S.-based publicly traded companies.Cargill, or example, is privately held, but would rank in Fortune’s Top 20.10

The consolidation o agribusiness inthe United States has been dramatic. Forexample, the top our frms in each sectornow slaughter 72 percent o the nation’sbee and 63 percent o the nation’s pork, while producing 57 percent o the na-tion’s broiler chickens.12 Even agriculturalmarkets that had once been local or re-gional in scope are becoming increasingly consolidated. Fewer than 200 companiesnow own 95 percent o the laying hens inthe United States, compared with 2,500

companies in 1987.13

The same consolidation has takenplace among the companies that processthe nation’s grain harvest. As o 2002,the our largest frms accounted or 54percent o the nation’s our milling and69 percent o wet corn milling.14




Moreover, some companies – such as Tyson, Cargill and JBS – have establisheddominant positions in several sectors o the agricultural economy. Tyson, orexample, is one o the top fve frms inchicken, pork and bee production, and

also mills its own grain to eed its poul-try. Cargill is known primarily or grainprocessing, but is also a major producero poultry, pork, eggs, oilseeds, sugarand biouel.

How Corporate AgribusinessIs Reshaping America’s FoodSystem

Only a ew o the frms mentionedabove are directly engaged in raisingcrops or tending animals. So how arethese companies contributing to the environmental crisis caused by agricultural water pollution?

There are several tools major corpo-rations have used to reshape America’sagricultural system into one that is reliant on environmentally damaging actory arming and chemical-intensive produc-tion o crops such as corn.

Vertical IntegrationOver time, some corporate agribusi-

ness frms have moved rom acting asthe middlemen between armers andconsumers to controlling larger shareso the process o producing, processingand distributing America’s ood. In aew sectors – especially the chicken andpork industries –“vertically integrated”corporate agribusiness frms now con-trol virtually the entire ood productionprocess, rom the genetic manipulation

o seeds and livestock, through crop andlivestock production, processing, andmarketing o fnal product to the con-sumer. One vertically integrated pork producer, Smithfeld Foods, describes vertical integration as controlling theprocess “rom squeal to meal.”15

1982 2006

Top 4 firms

All others

1982 2006

Top 4 firms

All others

1982 2002

Top 4 firms

All others

1982 2006

Top 4 firms

All others

Figure 1. Share of Production by Four Largest Firmsin Various Agricultural Sectors11

Pork

Beef

Chicken

Milk




In the vertically integrated model, theonly portion o the process that occurs“out o house” is the raising o animalsrom youth to slaughter. This happensto be the part o the process with thegreatest potential environmental impacts.

Nominally independent growers raiseanimals under contract with agribusi-ness corporations – contracts that typi-cally contain strict conditions detailinghow the grower must raise and eed theanimals. The “arm’s length” arrangement between the grower and the corporation,however, means that while the corpora-tion owns the animals, it can disclaimresponsibility or proper disposal o the waste those animals produce, shiting that burden o environmental compliance tothe growers.

The result is an arrangement that isthe best o both worlds or the integratedagribusiness frm. It can ensure the pro-duction o standardized, low-cost meat without bearing the risk o owning andoperating its own acilities. It can alsodisclaim responsibility or the environ-mental damage caused by the rearingo its livestock. It is little surprise that the model has come to dominate the

chicken and pork industries – ueling theprolieration o actory arms and theirassociated environmental impacts – andis making inroads in other sectors o agribusiness.

Market Power

Even in areas o agribusiness in whichindependent armers still play an im-portant role, corporate agribusinessgiants can attain enough market powerto eectively dictate the prices armers

receive or their goods. “Monopsony”and “oligopsony” are the economic termsor a situation in which only one or a ew potential buyers exist or a given product,giving those buyers the ability to dictatethe price a seller may receive.

The consolidation o agribusiness hasreduced the number o potential buyersor certain products. In the dairy industry,or example, one frm, Dean Foods, hasemerged as a dominant player with 38percent o the nation’s uid milk mar-

ket.16 In certain regional markets, thecompany – along with the leading dairy cooperative, Dairy Farmers o America(DFA) – controls an even greater shareo the market.

Farmers in several regions o the coun-try have alleged that large companies suchas Dean and major cooperatives such asDFA have used their market power tocontrol and manipulate the milk market,resulting in lower prices paid to armersor their milk.17 Indeed, in 2008, DFA was orced to pay a $12 million penalty tosettle allegations o market manipulationby the U.S. Justice Department.18 Farm-ers in both the Northeast and Southeast have fled class action lawsuits chargingeorts by Dean, DFA and others to ma-nipulate milk markets.19

What does market power have to do with the environment? By driving downthe prices armers receive, and leavingarmers with ew options or selling their

products, major agribusiness corporationscreate economic conditions that make it nearly impossible or small, independent operators to survive. Large, concentrateddairy operations have somewhat lowercosts o operation – at least when theenvironmental and public health impactso their pollution are not included in theequation.20 But more importantly, they are likelier to have the fnancial resourcesand access to capital that would enablethem to survive a brie but sharp decline

in commodity prices, such as the steepdrop in milk prices that occurred during2009. As a result, small, amily operationsare replaced over time with massive ac-tory arms with outsized environmentalimpacts.




Public Policy Changes

Agribusiness corporations also reshapethe ood system through their inuenceover public policy. Major corporationshave multiple avenues – including cam-paign contributions, lobbying expendi-tures, and personal relationships withpolicy-makers – to inluence publicpolicy. Through public policy, agribusi-ness frms can create markets or theirproducts, gain public subsidies, or evadeenvironmental responsibility – all o which shit the balance o what crops areproduced and how, leading to environ-mental impacts.

Concentrated Farms Lead to

Concentrated EnvironmentalImpacts

In rural areas o America, homeown-ers typically dispose o household sewagein septic tanks. This system works only because population density is low. But thesame system that works well, or example,in rural upstate New York would be anenvironmental and public health disasteri it were applied in New York City.

The same thing is true o waste rom

animals. In the past, most animal arming was widely dispersed across the landscape,mitigating the impact o manure on wa-terways and providing a helpul sourceo ertilizer to armers. The transitionto corporate agribusiness, however, hashelped bring about a wholesale shit toward concentrated animal eeding op-erations (CAFOs), which produce vast amounts o nutrient and bacteria-ladenmanure – sometimes in volumes that ap-proach the sewage production o small

cities – on small plots o land.Concentrated animal eeding opera-

tions confne hundreds to thousands o animals in small areas, where they arelargely ed on commodity grain producedar away, usually grown with the aid o

manuactured ertilizers (and subsidizedby taxpayers). The manure rom theseanimals is oten stored in open-air la-goons and later spread on land, nominally as ertilizer. However, over-spreadingo manure is common – and in some

places, given the vast volume o manureproduced in particular watersheds, in-evitable – resulting in manure washinginto waterways, bringing nutrients andpathogens with it.

At the other end o the cycle, the con- version o vast areas o land to corn or soy production – both or the production o animal eed and other products – requiresthe input o large amounts o chemicalertilizers and pesticides, which also canfnd their way into waterways.

The transition rom small arms toCAFOs has occurred with lightningspeed. Between 1987 and 2007, or ex-ample, the United States lost more thanhal o its dairy arms and nearly 70 per-cent o its pig arms, with an increasingshare o production taking place on the very largest arms – oten CAFOs withhundreds to thousands o animals at asingle site.21 In 1987, it took more than16,000 hog and pig arms to produce hal

o the nation’s sales. By 2007, the sameshare o sales was produced by just over1,700 arms.22

In the dairy industry, the number o arms with 50 or ewer milk cows ell rommore than 104,000 in 1992 to just under34,000 in 2007 – a decline o roughly two-thirds. Over roughly the same period(1993 to 2008), the share o the nation’smilk cows in herds o 200 cows or greatermore than doubled, rom 31 percent to 67percent.23 (See Figure 2, next page)




Between 1987 and 2007, the

United States lost more than half

of its dairy farms and nearly 70

percent of its pig farms.

Vertical integration has also magnifed theimpact o the trend toward larger arms by encouraging the tendency o certain types o agricultural production to cluster togetherin compact regions o the country.

The propensity o similar industries to

cluster in a small area has existed or cen-turies, rom the steel mills o Pittsburgh tothe auto manuacturers o Detroit to thehigh-tech businesses o Silicon Valley. By clustering together, industrial producersshare access to support services and a trainedlabor orce.

The industrialization o agribusiness leadsto similar concentrations.25 The easternshore o Maryland and northwest Arkansasare to chickens what Iowa is to corn, whichis what eastern North Carolina is to pork. These areas not only have lots o arms,but they also possess the slaughterhouses,grain mills and other orms o inrastructurethat make actory arming possible. Unor-tunately, these concentrations also urthermagniy the environmental impact o ac-tory arming on local waterways.

Specialization o arming in a particulararea also undermines the potential beneftso diversifed arms. On a traditional, diver-sifed arm, the waste created on one part

o the arm is used as a productive input onanother – or example, the manure rom apig might be used to ertilize a crop, theinedible waste rom which would then beed back to the pig. Industrialized arming,by contrast, relies on artifcial ertilizer toproduce grain in large monocultures, whichare then ed to animals at CAFOs, whichthen produce manure which is oten overap-plied to nearby arm felds – a process that creates the potential or large-scale pollu-tion at several points in the process.

As the stories in the next section describe,the shit toward industrial agribusiness hastoo oten resulted in the degradation o critical waterways that Americans dependon or recreation, drinking water, and thepreservation o healthy populations o wildlie.

Under 30 head

5%

30-49 head

15%

50-99 head

30%100-199 head

19%

200+ head

31%

1993

Under 30 head

2%

30-49 head

5%

50-99 head

13%

100-199 head

12%

200+ head

68%

2008

Figure 2. Share of the Nation’s Milk Cows by Herd Size24



Pollution from Corporate Agribusiness: Killing America’s Waterways 17

Pollution from Corporate Agribusiness:Killing America’s Waterways

Big Chicken: Perdue,Tyson, Pilgrim’s Pride andthe Fouling o Treasured

American Waterways The chicken industry is an exampleo the consolidation o the agribusinessindustry and its impacts on the environ-ment.

Control o the chicken industry ishighly concentrated among a ew mas-sive corporations – our frms produce57 percent o the chicken that fnds its way to American tables.26 It is vertically integrated, with frms such as Tysonand Perdue controlling virtually every

aspect o the production process – hatch-ing chicks, operating eed mills, andslaughtering, processing, and distribut-ing the fnal product. While the chickengrowers who raise chicks to adulthoodare nominally independent, frms suchas Tyson and Perdue sign restrictive

contracts with those growers that givethe companies great control over theirarmers’ operations.

Those contracts typically leave small,

undercapitalized growers – rather thanmighty corporations such as Tyson,Perdue and Pilgrim’s Pride – with theresponsibility or properly disposing o animal waste. Growers, however, havelittle opportunity to negotiate betterterms or their work, since growers in aparticular area who choose not to con-tract with a major agribusiness frm may have ew other options or marketingtheir product.

Over the past hal-century, chickenarming has become increasingly con-centrated in large operations, clusteredin small areas o the country. Whereasin the middle o the last century, chickenarms dotted the Midwest and existed upand down the Northeast coast, today, theproduction o chickens or meat (as op-




posed to or eggs) is highly concentratedin the southeastern United States andChesapeake Bay region. (See Figure 3.)

Raising large numbers o chickensin a small geographic area concentratesthe production o “chicken litter” –

phosphorus-laden manure mixed withsawdust or other bedding material. Whenthe amount o chicken litter exceeds theamount that can be benefcially appliedto crops in a particular region, the result is oten pollution o local waterways.

The Chesapeake Bay, the Illinois Riverin Arkansas and Oklahoma, and Lake o’the Pines in Texas are three exampleso American waterways that have beenseverely damaged by pollution romchicken arming conducted by corporateagribusiness.

Perdue and the ChesapeakeBay

Perdue is the third largest producer o chickens in the nation, with annual saleso $4.6 billion.28 Through its vertically integrated system, Perdue produced andprocessed more than 600 million chickensin 2007.29

Based in Salisbury, Maryland, Perdueis one o several large chicken producers with major operations on the DelmarvaPeninsula on the eastern shore o Chesa-peake Bay. The Chesapeake Bay is oneo America’s most storied waterways. As the nation’s largest estuary, and oneo the most productive estuaries in the world, the Chesapeake is an important natural resource, serving as a home ormore than 3,600 species o plants andanimals, as well as a cornerstone o both

the mid-Atlantic economy and the re-gion’s culture.30

For decades, however, the bay hasbeen under threat. As long ago as 1983,a congressionally mandated report oundthat the bay suered rom nutrient pol-lution, a decline in seagrasses, pollution

07-M161

1 Dot = 1,000,000 Br

U.S. Department of Agriculture, National Agricultural Statistics Service

United States8,914,828,1

0 100

Miles0 1 00

Miles

Figure 3. Chickens Sold by County, 1949 and 200727

1949

2007

1 dot=100,000 chickens

1 dot = 1 million chickens

United States Total8,914,828,122




rom toxic chemicals, and overfshing.31 While the problems acing the Chesa-peake are complex, many o them canbe traced back to agricultural activities– particularly chicken arming – in thebay’s vast watershed.

Chicken manure contains phos-phorus, nitrogen and other chemicals,such as arsenic (which is an additive insome chicken eed).32 During its 47-day liespan, a typical chicken being raised asa broiler produces 2 pounds o chickenlitter (manure mixed with sawdust andbedding material).33 The 568 millionchickens produced by all chicken com-panies on the Delmarva Peninsula thusgenerate an estimated 1.1 billion poundso chicken litter each year.34

Pollution rom chicken litter canfnd its way into the Chesapeake Bay ina number o ways. Manure that is let in uncovered piles can be washed intonearby waterways in a heavy rain.35 Inaddition, the chicken litter that is pro-duced in great volumes at poultry armsis typically disposed o by spreading it on nearby crops as ertilizer.36 Unor-tunately, however, over-application o chicken litter to arm felds can result

in the felds becoming over-saturated with phosphorus, resulting in the runo o phosphorus to nearby waterways andeventually the bay.

The 1.1 billion pounds o chickenlitter the industry produces each year would, i spread evenly on the 8.5 mil-lion acres o agricultural land in thebay watershed, represent 129 poundso litter per acre.37 The amount o phosphorus in chicken litter generatedin our counties on Maryland’s Eastern

Shore, or example, ar exceeds theamount that can be used by crops inthose counties.38

Nutrient pollution can even reachthe bay via the air. Animal waste suchas poultry manure produces airborneemissions o nitrogen-containing am-

monia, which can all into rivers and thebay with the rain.

Nutrients such as phosphorus andnitrogen uel the growth o algae in the water, triggering algae “blooms” that ourish briey and then die, consuming

oxygen as they decay. As a result, levels o dissolved oxygen in the water drop below the concentration needed to support fsh,crabs and oysters. Animals that are ableto ee leave these areas o low dissolvedoxygen; those who can’t escape suerthrough the stress o inadequate oxygen,making them more prone to disease, ormay suocate i oxygen levels all too low (hence the name “dead zone”).

The chicken industry is a prime con-tributor to pollution o the bay. Accord-ing to the Chesapeake Bay Program, astate and ederal joint eort to study thebay, 26 percent o phosphorus pollutionand 17 percent o nitrogen pollution inthe bay comes rom excessive animal waste in agricultural areas.39 Another 19percent o phosphorus pollution and 15percent o nitrogen pollution comes romchemical ertilizers applied to cropland.Because the majority o the grain pro-duced on Maryland’s Eastern Shore is

sold or chicken eed, some o this chemi-cal ertilizer pollution can be attributedto chicken production.40

The result o this pollution is seri-ous degradation to the Chesapeake Bay ecosystem. From 2007 to 2009, only 12 percent o the Chesapeake Bay hadsufcient levels o dissolved oxygen inthe summer.41 (See Figure 4, next page.) The National Oceanic and Atmospheric Administration (NOAA) describes theChesapeake Bay as “highly eutrophic,”

meaning that it is highly susceptible tonutrient-ueled algae blooms that deprivethe waterway o oxygen.42




In addition to consuming oxygenin the water and creating dead zones,algae blooms can block sunlight that aquatic grasses need to survive. With-out sunlight, the grasses die, triggeringother problems or the Bay’s ecosys-tem. Roots o grasses are no longeravailable to hold sediment in place,

increasing the risk that oysters willbe buried in silt. Blue crabs and fshsuch as menhaden, herring, shad, and white perch lose hiding places and aplace to shelter their young. And thegrasses are no longer available to re-

plenish dissolved oxygen levels as they photosynthesize. In 2009, 86,000 acresin the bay were covered with grass, lessthan hal the amount o grass neededor a healthy bay.44

Years o summertime dead zones,

overfshing, and the death o submergedaquatic vegetation have taken their tollon the bay’s aquatic animals. Popula-tions o rockfsh, or striped bass, havedropped so much that Maryland and Virginia both imposed moratoria on thefshery in the late 1980s. The moratoriahave since been lited, but catch levelsremain low. Oyster and sot shell clampopulations have declined to a ractiono their historic levels, while the ederalgovernment ofcially declared the bluecrab fshery a disaster in 2009, grantingemergency aid to the industry.45

Despite the clear problem o exces-sive chicken litter in the bay watershedand the consequences o this or fsh,shellfsh and the bay’s ecosystem, Per-due denies responsibility or the wasteproduced by its chickens, grown by armers working under strict contract with the company.46 However, in apreliminary ruling in a lawsuit naming

both Perdue and a contract armer orallowing manure to pollute a tributary o the Chesapeake Bay, a judge agreedto keep Perdue as a deendant, poten-tially responsible or the pollution.47 The Clean Water Act, under whichthe lawsuit was fled, applies to ownersor operators o acilities that dischargeor propose to discharge to waterways, with the defnition o “owner or opera-tor” applying to “any person who owns,leases, operates, controls, or supervises

a source [o pollution].”48

Holding Perdue and other chickenproducers in the Chesapeake Bay re-gion accountable or their pollution isthe frst step toward cleaning it up, andrestoring the bay to health.

Figure 4. Most of the Chesapeake Bay Fails to MeetDissolved Oxygen Goals in the Summer43




chicken – 41 million chickens a week, or2 billion per year – as well as 22 percent o its bee and 18 percent o its pork.55 Tyson eeds its chickens an estimated 23billion pounds o eed each year, most o it corn and soybean meal.56

Many o the region’s chicken arms arelocated near Tyson’s Arkansas headquar-ters. Indeed, our counties in northwest Arkansas produce 315 million broilersunder contract per year, more than areproduced annually in all but six states.57

The massive concentration o chickenproduction in a small area imposes aheavy toll on the environment, particu-larly water quality.

Water quality problems abound in Tyson Country. In eastern Oklahoma,nutrient pollution o the Illinois River be-came so bad that the Oklahoma Attorney General’s ofce fled suit against TysonFoods and other chicken processors toreduce the over-application o poultry litter in the region.58 Not ar away, simi-

The scenic Illinois River ows through Arkansas and Oklahoma. It is one o many waterways in the regionthat are adversely aected by pollution rom the region’s thousands o chicken arms.

Photo: Aaron Latty

Tyson and the Illinois River oArkansas and Oklahoma

The Illinois River begins in northwest-ern Arkansas beore traveling througheastern Oklahoma and eventually eed-

ing the Arkansas River. Designated by the state o Oklahoma as a scenic river,the Illinois River is an important recre-ational resource or the region – each year, an estimated 180,000 people canoe,kayak or rat on the river, while another350,000 engage in other orms o outdoorrecreation.49

In recent years, however, water quality has declined along the Illinois River andin Tenkiller Lake, a reservoir that is edby the river. Decreased water clarity, algae

blooms and instances o low dissolvedoxygen have become more requent.50 Portions o the Illinois River and severaltributaries are so polluted with pathogensrom animal eeding operations and othersources that they are no longer sae orswimming.51 There is even evidence that the number o people who oat the riverhas declined.52

The Illinois River and other riversin eastern Oklahoma and northwestern Arkansas are in trouble largely becauseo nutrient pollution rom the area’sthousands o chicken arms. The IllinoisRiver watershed includes 2,300 poultry arms in Arkansas and another 500 inOklahoma.53 Oklahoma’s Attorney Gen-eral estimates that the waste produced by chickens in the Illinois River watershedis equal to that which would be producedby 10.7 million people – more than thecombined human population o the en-tire states o Oklahoma and Arkansas. 54

Unlike human waste, however, it receivesno treatment. While severa l chicken producers

operate in the region, the industry isdominated by Springdale, Arkansas-based Tyson Foods. Tyson Foods and its subsid-iaries produce 20 percent o the nation’s




lar water quality problems have aectedGrand Lake o’ the Cherokees. The lakeis an important recreational resource, at-tracting boaters, jet skiers, fshing enthu-siasts and amilies seeking to take a break rom mid-summer heat. The lake had

once been known or its high water qual-ity, but since the 1980s, Grand Lake hasexperienced algae blooms, which deprivethe lake o oxygen needed to support healthy populations o fsh and maintaina balanced ecosystem. Parts o the lakeitsel – and many o its tributaries – areconsidered “impaired” or aquatic lie dueto low levels o dissolved oxygen.193

Chicken manure is a big contributorto the water quality problems at GrandLake. In 2004, the state o Oklahomaestimated that nearly 19,000 tons o chicken litter is applied to land in the watershed each year, with roughly 27percent o those applications exceed-ing the amount o phosphorus that theland can saely absorb.59 Chicken litterspread just in the Oklahoma part o the watershed is suspected o supplying asmuch as 189,000 pounds o phosphoruseach year to the waterways o the GrandLake watershed.

Tyson was also linked to the pollutiono Oklahoma’s Lake Eucha and LakeSpavinaw – the sources o drinking wa-ter or the city o Tulsa. Pollution rompoultry waste in those watersheds hadbecome so severe that it had spawnedalgae growth in the lakes, leading to tasteand odor problems in drinking water andorcing the city o Tulsa to upgrade itstreatment methods at public expense. A 2003 settlement in Tulsa’s lawsuit against Tyson and other chicken producers re-

quired the companies to transport somechicken waste out o the watershed, amove that has reduced phosphorus load-ing to the lakes.60

Pollution rom chicken waste oulslocal waterways, but it also has morear-reaching eects. The Arkansas River

basin – which drains the poultry-intensiveareas o northwestern Arkansas, southern Missouri and Oklahoma – is responsibleor 4.3 percent o the phosphorus pollu-tion reaching the Gul o Mexico romthe Mississippi and Atchaalaya rivers,

and is the astest-growing source o phos-phorus to the gul.61 As a result, pollutionrom Tyson and other chicken producerscontributes to ecological problems in theGul o Mexico.

The ate o the Illinois River will bea telling indicator o the uture o wa-terways nationwide aected by chicken waste. Oklahoma’s lawsuit against chickenprocessors in the region is now pendingin ederal court.

However, the chicken industry hasalready won one round o the ight.Oklahoma Attorney General Drew Ed-mondson, who fled the lawsuit to protect the Illinois River, was recently upset in hisbid or the Democratic nomination orgovernor. His opponent won narrowly ater receiving more than $20,000 inlast-minute donations rom executives at Tyson Foods and other regional poultry producers.62

Pilgrim’s Pride (JBS) and Texas’Lake o’ the Pines

Lake o’ the Pines is located in thenortheast corner o Texas, about 15miles northwest o Marshall and about 20 northeast o Longview. The lake provides many opportunities or recreation, with camping, boating, hunting, fshingand bird watching, including the ability to see wintering bald eagles.63 The lakealso provides drinking water or a num-

ber o northeast Texas cities includingLongview.64

However, the lake has been plagued with pollution or at least a decade. Ac-cording to the Texas Commission onEnvironmental Quality (TCEQ), the lakesuers rom excess nutrient input which




protection in 2008. In 2009, the Braziliancompany JBS purchased a majority shareo Pilgrim’s Pride, adding to its string o recent acquisitions in the United States.(For more on JBS, see page 29.)

For decades, Pilgrim’s Pride has re-

peatedly and egregiously violated its water quality permits, polluting local waterways.73 It was also in 2007 thelargest discharger o toxic substances to Texas waterways, releasing more than 1.5million pounds o toxic pollution into Tankersley Creek.74

The company’s recent environmen-tal perormance suggests that little haschanged. Over the last three years, thecompany has requently exceeded itslimits or permitted releases o ammonia,and is listed by the U.S. EPA as havingbeen in non-compliance with Clean Water Act requirements every quarterrom the third quarter o 2007 to the frst quarter o 2010.75 In 2010, the TCEQfned Pilgrim’s Pride $43,700 or a stringo violations o clean water laws.76

The Hog Bosses:Smithfeld, Cargill and the

Environmental Toll o PorkProduction

The pork industry, like the chickenindustry, has become highly consolidatedand increasingly vertically integrated, with just a ew large frms dominatingthe industry. The shit to more intensivemethods o pork production has also let a legacy o pollution stretching rom theecologically important estuaries o NorthCarolina to the rivers o the Midwest.

Pork production has historically beencentered in America’s Corn Belt – par-ticularly Iowa. In recent years, howeverNorth Carolina has emerged as a majorpork producing region, with the numbero hogs and pigs in the state doublingbetween 1987 and 1992 and doubling

contributes to “turbid water, episodeso low dissolved oxygen concentration,loating algal blooms, taste and odorproblems [and] ish kills.”65 In 2002,pollution led to the deaths o more than9,000 fsh.66 During the summer o 2010,

high levels o E. coli – bacteria linked toanimal and human ecal matter – led tobeach closures on the lake, costing areabusiness thousands in lost revenue romrecreational visitors to the lake during the4th o July weekend.67

Chicken arming is a big business inthe Cypress Creek watershed that con-tains Lake o’ the Pines. An estimated99 million chickens are produced in theregion annually – one out o every ourproduced in Texas.68 The vast majority o the chicken litter produced in the water-shed – approximately 229 million tons per year, is spread on arm felds in the region,at rates o one to fve tons per acre.69

Lake o’ the Pines is also aected by discharges o nutrients rom industrialacilities, the largest o which is the Pil-grim’s Pride chicken processing acility, which discharges into Tankersley Creek,a tributary o Lake o’ the Pines. The TCEQ identifes the acility as the source

o “88 percent o the total phosphorusand 73 percent o the total nitrogencontributed rom permitted dischargersin the watershed.”70 Indeed, the Pilgrim’sPride acility is estimated to contributemore total nitrogen to Lake o’ the Pinesthan the millions o pounds o chickenlitter spread on local arm felds.71

With net sales totaling $7.1 billion in2009, Pilgrim’s Pride Corporation is oneo the largest chicken companies in theUnited States and Mexico and is ranked

317th on the Fortune 500 list o largest U.S. corporations.72 The company hasbeen part o the consolidation o thechicken industry, purchasing rival brandGold Kist in 2007. However, debt loadrom the Gold Kist acquisition resultedin Pilgrim’s Pride fling or bankruptcy




again – to more than 10 million – by 2007.77 In addition, there has been a na-tionwide shit toward larger hog arms. In1987, less than 10 percent o the nation’shogs and pigs were raised on very largearms o 5,000 animals or more. By 2007,

more than 60 percent o America’s hogsand pigs were raised on these very largearms.78 Over that span o time, the num-ber o hogs and pigs raised on the very largest arms increased nearly 10-old,rom 4.2 million to 40.8 million.79

Cargill and Smithfeld Foods are two o the nation’s largest pork producers. Eachcompany has a legacy o water pollutionrom its pork production operations.

Smithfeld Foods and the NeuseRiver

The Neuse River traverses 248 mileson its way rom central North Carolinato Pamlico Sound. The Neuse is not only an important ecological and recreationalresource in its own right, but it also eeds

some o the nation’s most important andproductive coastal estuaries.

Recently, however, the Neuse has be-come better known or the degradationit has experienced as a result o runo rom eastern North Carolina’s many

concentrated animal eeding operations. The group American Rivers has listedthe Neuse as among the nation’s 10 most endangered rivers in 1995, 1996, 1997and 2007.81

The Neuse has been the site o severalmassive fsh kills. The largest to date oc-curred in 1995, when more than 1 billionfsh in the Neuse died. Scientists tracedthe cause to a toxic organism called pfes-teria.82 A reporter at the Charleston, S.C. Post and Courier wrote that the microor-

ganism “drugs schools o fsh and suckso their skin, sometimes leaving behindmillions o carcasses with blood-redsores and holes the size o hal dollars.”83

Studying the organism, Dr. JoAnn Burk-holder, director o the Center or Applied Aquatic Ecology at North Carolina State

Figure 5. Increase in Share of Hogs and Pigs on Large Farms80

4.29.8

24.631.7

40.8

0

10

20

30

40

50

60

70

80

1987 1992 1997 2002 2007

H o g s a n d P i g s ( m i l l i o n s )

Farms<5,000+ head

Farms> 5,000+ head




Those 10 million hogs generate asmuch ecal waste as 100 million humans92 – or roughly the entire human popula-tion o the United States west o the Mississippi River. Typically, Smithfeld’shog arming subsidiaries or contract hog

growers collect hog manure and urinerom the confnement building and storeit in a nearby open-air lagoon. The com-panies then spray nearby felds with liquid waste, nominally as ertilizer.

University, ound that it tended to thrivein nutrient-loaded waterways, polluted by sewage or runo, “especially runo romthe state’s massive hog arms,” as notedby the Post and Courier . She told the pa-per that “pfesteria has always been here,

but we’ve been adding tons o nutrientsto our estuaries, and we’ve slowly tippedthings in avor o it. Pfesteria is a sign o an estuary that’s out o balance.”84

Fish kills slowed during the years o drought in the early 2000s, but pickedup again in years with heavy rains. Thelatest fsh kill happened in August 2009, when the Neuse Riverkeeper estimatedthat 100 million fsh died.85 The fsh kill was concentrated in the brackish waters inthe lower Neuse estuary, which the state’sDepartment o Natural Resources rates ashaving impaired water quality.86

Water quality in the Neuse declinedseverely ollowing the boom in hog armsin the region. In the 1980s and 1990s,Smithfeld Foods – the world’s largest producer o pork – began a strategy o consolidation and vertical integration inthe hog industry, acquiring competingslaughterhouses and buying hog arms,or entering into restrictive contracts

with growers.87

Through the strategy,Smithield endeavored to control theproduction process rom “squeal to meal”– or rom birth to marketing o the fnalproduct.88

Vertical integration dramatically in-creased Smithfeld’s presence in NorthCarolina. Today, Smithfeld is the leadingowner o hogs in the state’s coastal plain, which is home to about 2,500 hog con-fnement buildings containing 10 millionanimals – a fve-old increase since the

1980s.89 The Neuse River watershed itsel contains more than 450 confned hogeeding warehouses holding more than 3million hogs.90 Just south o the watershed,Smithfeld processes hogs at the world’slargest pork slaughterhouse, opened in1992 in the town o Tar Heel.91

Smithfeld Foods disposes o hog waste by spraying the untreated,liquid manure on felds using a manure spraying system like that pictured here.

However, the excessive spraying o waste disrupts the nutrient balance inthe watershed. Application o liquid hogmanure to nearby felds tends to exceedthe ability o the land to saely absorb all

o the nutrients. Moreover, cattle grazeon the Bermuda grass grown on many sprayfelds, eectively re-depositing thenutrients rom the hog waste as manureand urine, instead o removing it romthe system.93 Ater storms, these excessnutrients run o o the sprayfeld, con-

Photo: Socially Responsible Agriculture Project, www.sraproject.org .




taminating groundwater and increasingnutrient levels in surace waterways.94

Smithield-style concentrated hog warehouses are perpetuating nutrient overloading in the Neuse River wa-tershed. In 2006, Dr. Burkholder and

a group o her colleagues published astudy o nutrient loading in the NeuseRiver estuary rom 1993 to 2005. They ound that:

Confned hog eeding warehouses•

produce more than hal o allestimated phosphorus loading in the watershed, and more than a third o all nitrogen loading.95

The river was in a “eutrophic”•

(nutrient-overloaded) state, withperiodic bursts o activity by algaeand other microorganisms stimulatedto grow in “blooms” by excess levelso nutrients carried into the river by rainall.

Ammonia loading increased by 500•

percent over the study period. Thescientists suspected hog operations as

the most likely source. Lagoon andsprayfeld waste disposal systems addammonia to both land and the air, where it can be washed into the riverduring storms.

Dissolved oxygen levels decreased by •

9 percent in the total water column –and decreased by close to 20 percent in the deepest waters. This is indica-tive o nutrient-driven overgrowtho algae and plants, which consumeoxygen when they decompose,reducing the ability o the waterto support a healthy and diversecommunity o wildlie.96

In response to the problems caused

by Smithfeld’s hog manure lagoons andsprayfelds, in 1997 the North CarolinaGeneral Assembly imposed a moratoriumon the construction o new sprayfelds, orthe construction or expansion o new hogconfnement warehouses larger than 250animals.

97 The moratorium containedloopholes, however, which enabled hogarmers to add hal a million animals,building 73 new hog arms and expanding25 in the decade ater the moratorium was passed.98

To protect its operations in NorthCarolina, in 2000 Smithfeld entered intoa voluntary agreement with the state’sattorney general to und a $15 millionresearch project into better methods o waste disposal and to implement any methods ound to be both environmen-tally advantageous and cost eective.

In its 2010 regulatory ilings, thecompany notes that “none o the tech-nologies evaluated under the Agreement were ound to be economically easibleor existing arms” and that it plans tocontinue using the lagoon and sprayfeld waste disposal system in the state.99 Thisis despite the act that North Carolinais oering (through 2011) to cover 90percent o the cost o a new system, up

Waste rom North Carolina’s hog arms is typically stored inliquid manure lagoons .

Photo: Bob Nichols, USDA Natural Resources Conservation Service




to $500,000, or each arm that commitsto installing better waste treatment.100 In2008, the state made the moratorium onnew lagoon and sprayfeld systems per-manent. Smithfeld Foods noted in 2010that “the moratorium limits us rom ex-

panding our North Carolina productionoperations.”101 While the moratorium will help to keep the problem rom get-ting worse, the challenge o managingSmithfeld’s huge impact on water qual-ity in the Neuse River watershed andother key waterways in North Carolinaremains.

Cargill and the Illinois River oIllinois

The Illinois River in Illinois (not tobe conused with the Illinois River in Arkansas and Oklahoma, see page 21)lows more than 270 miles rom thenortheastern corner o the state to the Mississippi River, draining more than40 percent o the state’s agricultural landand acting as the navigational connectionbetween Lake Michigan and the Missis-sippi River.

The Illinois River exemplifes many o the water quality problems imposed

by large-scale corporate agriculture. Forgenerations, sediment rom arm feldshas choked the Illinois River. PeoriaLake – a broadening o the Illinois Riveradjacent to the city o the same name –has lost 68 percent o its volume since1903.102 A comprehensive study by theU.S. Geological Survey in the late 1990sound that the lower Illinois River basinhad among the highest concentrations o nutrients in the United States, includinglevels o nitrate in some locations that exceeded public health standards ordrinking water.103

The massive low o nutrients intothe Illinois River also has impacts ardownstream. The state o Illinois is theleading contributor o both nitrogen and

phosphorus to the Gul o Mexico viathe Mississippi River, with the IllinoisRiver serving as a main carrier o that pollution.104

There is no one company or activity that is solely responsible or the pollutiono the Illinois River. Scientists believethat the major source o nitrogen tothe Illinois River is drainage rom row

crops such as corn and soybeans, withdischarges rom sewage treatment plantsalso a signifcant contributor.105 However,given the decades o warnings about thepolluted condition o the Illinois Riverand other waterways in the state, thefrst step would appear to be to not makematters worse.

Yet, an increase in pollution is exactly what has happened at a pork slaugh-terhouse run by Cargill, Inc. along theIllinois River, while the company’s plansto expand its hog-arming operations inIllinois could result in additional dam-age.

Cargill has been, along with ADM (seepage 33), a major player in the develop-ment o the modern corn economy that

The Illinois River is a leading contributor o nutrient pollutionto the Mississippi River and the Gul o Mexico.

Photo: Tom Winkle




has contributed to nutrient pollution o the Illinois River and other American waterways. As o the late 1990s, Car-gill was the second-largest producer o high-ructose corn syrup, trailing only ADM.106 The company also owns two

ethanol production plants, in Iowa andNebraska.107

Cargill’s activities reach into many sectors o the agricultural economy. The company produces, processes andmarkets bee, poultry, eggs, oilseeds,sugar and many other ood ingredients.It produces salt and steel and even hasa fnancial services branch engaging inutures trading and risk management.108

For most o the last decade, Forbes magazine has ranked Cargill as the larg-est privately held company in America,rivaled only by Koch Industries.109 I Cargill were publicly owned, it wouldrank in the top 20 o the Fortune 500. In2009, the company brought in more than$110 billion in sales, earning a proft o more than $3 billion.110

In Illinois, Cargill Meat Solutions’Beardstown acility, which dischargesinto the Illinois River, has the capacity to slaughter up to 18,000 head o pigs

per day.111

It is also, according to theU.S. EPA’s Toxic Release Inventory, thesecond-largest industrial discharger o toxic chemicals to waterways in the stateo Illinois and 13th largest industrialdischarger in the United States, dump-ing more than 3 million pounds o toxicchemicals into the Illinois River during2008.112

Virtually all o the plant’s toxic releases were in the orm o nitrates, which areproduced when wastewater contaminated

with blood or other slaughterhouse wasteis discharged into waterways.113 Nitratereleases not only have the potential tooul drinking water supplies, but also addto the problem o nutrient pollution inthe Illinois and Mississippi rivers and theGul o Mexico. Nitrate discharges rom

the plant have increased tenold since1998, and have totaled more than 3 mil-lion pounds per year since 2005.114

The Beardstown pork processingplant isn’t the only Cargill acility that has polluted waterways. Indeed, the

Beardstown plant is one o three Car-gill acilities to rank among the nation’stop 20 industrial dischargers o toxicsubstances to rivers, streams, lakes andcoastal waters in 2008.115 In July 2000, aCargill Pork actory in Missouri (whichhas since been closed) dumped untreatedhog waste into the Loutre River, killingmore than 50,000 fsh along a fve-milestretch.116 The company agreed to pay a$1 million fne or the incident, and oneo its employees was sentenced to fvemonths in jail.117

About a quarter o the hogs processedat the Beardstown plant, along withCargill’s other major slaughterhouse inOttumwa, Iowa, are raised by armersunder contract with Cargill.118 This ver-tical integration arrangement is similarto that employed by Tyson and Perduein the chicken industry and SmithfeldFoods in the pork industry.

In recent years, Cargill has sought

to expand its contract hog arming op-erations in Illinois and other Midwest-ern states. According to one publishedaccount, the company sought to add asmany as 30 hog arms in western Illinois,northern Missouri and southern Iowa – amove that would both extend the com-pany’s control o the supply chain andreduce transportation costs.119

Illinois’ lax laws governing the es-tablishment and regulation o CAFOsare making the company’s job easier. In

2009, or example, a new contract hogarm opened in Sangamon County, Illi-nois, with a capacity to house more than3,700 hogs. Neighbors o the acility fleda lawsuit seeking to block the acility.However, the arm’s owner successully argued that Illinois law allowed him to




proceed with construction without evena public hearing by claiming that the mas-sive new acility was just an “expansion”o his previous 40-cow dairy arm.120

Pork CAFOs, like other concentratedanimal eeding operations, have a long

history o non-compliance with clean water laws. A survey by the Illinois EPA ound that 58 percent o swine CAFOssurveyed had at least one regulatory viola-tion in 2009.121

Continued expansion o concentratedhog arming operations in Illinois by Cargill and other frms – coupled withrising pollution rom hog processingacilities – threatens to exacerbate thenutrient pollution problems already aced by the Illinois River and waterwaysdownstream.

Bee Factories: Pollutionrom JBS and CargillProcessing Plants

Unlike the production o chicken orpork, where individual frms control theentire production process rom an ani-mal’s birth through its appearance in the

supermarket, the bee industry has longavoided vertical integration. Historically,independent ranchers have been respon-sible or breeding cattle and raising themto adolescence, at which time they aresold to eedlots – oten large, actory-scale operations similar to other actory arms. At the eedlot, cattle are “fnished”to slaughter weight by eeding them a diet o grain, and are then sold to bee packers, who slaughter the animals and processthem or sale to consumers.

Packers have long been the most pow-erul players in the bee market, and theirpower has grown in recent years. Today,our companies slaughter 72 percent o the nation’s bee, compared with 30 per-cent in the 1960s.122 Bee packers havealso taken the frst steps into vertical inte-

gration by owning some cattle themselvesor contracting with cattle producers. The our largest packers now obtain 40percent o their cattle through arrange-ments other than the wholesale market,compared with 20 percent in 1986.123 By owning or contracting or their owncattle, packers have the ability to exert

greater control over the marketplace andpossibly to manipulate markets.Cattle ranching and eedlot operations

have the potential to contribute to waterpollution. But the most direct way to seethe impact o large agribusiness frms isto review the track record o water pollu-tion at bee slaughterhouses and packingplants.

JBS and Pennsylvania’s

Skippack CreekLocated northwest o Philadelphia,Skippack Creek eeds the PerkiomenRiver, an important natural resource that provides drinking water and recreationalopportunities or the regional population.Skippack Creek ows into the Perkiomen

Waste rom slaughterhouse operations can be responsible or signifcant water pollution problems, including the routine

discharge o nitrates and ammonia into rivers and streams.

Photo: bluebird13, istockphoto.com




just three miles above its junction withthe larger Schuylkill River – a source o drinking water or more than 1.7 millionpeople.124

Along the banks o Skippack Creek lies a slaughterhouse now owned by the

Brazilian irm, JBS, which processesabout 2,000 cattle a day, producing 180million pounds o boxed bee and 17 mil-lion pounds o ground bee per year.125 The plant also renders letover slaughter waste, including animal at, bone andblood, along with kitchen grease romarea restaurants, to create raw materi-als or manuacturing other products,including animal eed.126

For decades, the plant was operated by Moyer Packing Co. beore it was acquiredby Smithfeld, and then by the Brazilian-based frm, JBS. JBS is still an unamiliarname to many American consumers, but acquisitions such as its purchase o thePennsylvania plant have quietly madethe company the world’s largest bee producer and exporter.127 In the UnitedStates, JBS purchased Swit & Company in 2007, then ollowed up by purchas-ing the poultry operations o Pilgrim’sPride and the bee processing opera-

tions o Smithfeld Foods.128

I the U.S. Justice Department hadn’t intervenedon antitrust grounds, JBS would havealso bought the National Bee PackingCompany, then the ourth-largest bee producer in the United States.129

JBS now controls nearly a quarter o the U.S. bee processing market (tied orfrst), 22 percent o the U.S. poultry pro-cessing market through its majority own-ership o Pilgrim’s Pride (frst), and morethan 10 percent o the U.S. pork process-

ing market (third).130 In the United States, JBS owns 12 slaughterhouses, 11 cattleeedlots, more than 30 poultry process-ing plants, a hide tannery, and nearly twodozen regional distribution centers.131 Inthe United States, the company has thecapacity to slaughter and package nearly

30,000 cattle, nearly 50,000 hogs, morethan 7 million birds, and more than 4,000sheep into meat products every day.132

As JBS has snatched up agribusinesscompanies in the United States, it has alsoinherited a legacy o water pollution let

behind by those companies. The pollutiono Skippack Creek caused by the ormer Moyer packinghouse is just one example.

According to a complaint fled by theU.S. Environmental Protection Agency and the Pennsylvania Department o Envi-ronmental Protection against JBS in 2008,the plant used outdated equipment andregularly discharged water pollution intothe Skippack Creek in excess o permittedamounts – and sometimes without evenhaving a permit.133 Excessive amounts o E.coli, ammonia, phosphorus, oil and grease were ound in the creek downstream o therendering plant.134

In 2007, JBS’s acility along Skippack Creek ranked as the 10th-largest industrialsource o toxic pollution discharged to riv-ers in Pennsylvania that year by weight.135 The company’s rendering plant dumpedmore than 314,000 pounds o pollutantsinto Skippack Creek that year.136

The plant also experienced periodic

major pollution events that triggered fshkills.137 In August 2007, an equipment ailure allowed untreated, ammonia-flled wastewater to enter the creek, causing thelevels o dissolved oxygen in the waterto all drastically, killing on the order o 10,000 fsh along a ull mile o the creek.138 Lynda Rebarchak, a spokeswoman or thePennsylvania Department o Environmen-tal Protection, told the Allentown Morning Call that the spill was “one o the biggest we’ve seen in the region in recent years.”139

Another 15,000 fsh died in spills in De-cember 2007 and June 2008.140

Facing an enorcement lawsuit underthe ederal Clean Water Act, JBS agreedin June 2010 to pay a $1.9 million fne andbuild a $6 million wastewater treatment plant at the acility.141




to waterways than any other industrialacility in Colorado, and is in the top 20nationwide.146

Over the 10 years rom 1999 to 2008,the Cargill Meat Solutions slaughter-house injected more than 27 million

pounds o nitrate compounds into theSouth Platte River – more than 2 millionpounds per year.147

Cargill’s plant has also polluted the wa-terway with bacteria. In 2004 and 2005,the Fort Morgan slaughterhouse releasedmore E. coli bacteria into the SouthPlatte River than allowed by permit. InNovember 2009, a ederal judge fned thecompany $200,000 or the violations, andthe Environmental Protection Agency negotiated upgrades to the company’s wastewater treatment acility.148

Dairy Dangers: Factory Farmsand the Death, Rebirth, and“Redeath” o a Great Lake

The resurrection o Lake Erie wasonce considered to be one o the signalaccomplishments o the modern envi-ronmental movement. Considered to be

a “dead lake” in the late 1960s, by the1980s Lake Erie was once again support-ing thriving populations o fsh – thanksin large part to reductions in the ow o phosphorus to the lake.

Strong environmental regulationsplayed a key role in restoring Lake Erieto health. Phosphorus was banned romdetergents, sewage treatment plants up-graded their operations, and the use o streamside buers and better agriculturalpractices reduced nutrient runo rom

arms.Once a success story, however, Lake

Erie is back in trouble again. The deadzone in the lake has not only returnedbut continually worsened in recent years.During the summer o 2010, massiveblooms o cyanobacteria – or blue-green

As JBS consolidates its purchases in theUnited States, the company aces a choice:continue the environmentally damagingpractices o its predecessors, or turn overa new lea. Residents o eastern Pennsyl- vania hope the company will choose the

latter course.

Cargill and Colorado’s SouthPlatte River

The South Platte River is one o thegreat rivers o the American West, drain-ing thousands o square miles o orestsand grasslands on its way rom the easternank o the Rocky Mountains, through thecity o Denver, and across the Great Plainso Colorado and Nebraska. The SouthPlatte is the principal source o water orcommunities and agriculture in Colorado’seastern plains.142

In the mountains, fshermen considerthe South Platte to be a gold medal trout stream, flled with trophy-sized rainbow and brown trout. But by the time theSouth Platte leaves Denver, its entire volume can consist o treated sewage dis-charge at times o low ow, with elevatedlevels o nutrients including nitrates, phos-

phorus, and ammonia.143

Nutrient levelsin the lower reaches o the South Platteoten exceed U.S. EPA guidelines or con-trolling algae blooms and oxygen deple-tion, and the waterway does not support the ull range o lie that would exist in aclean river.144

The Cargill Meat Solutions slaughter-house in Fort Morgan, 80 miles down-stream o Denver, is a major contributorto the problem. The plant processes 5,000head o cattle and generates 1.5 millions

o gallons o wastewater per day.145 Dur-ing normal operations, this plant emitsmassive amounts o pollution into theSouth Platte River. In act, according tothe Environmental Protection Agency’s Toxics Release Inventory, this acility emits more raw pounds o toxic pollution




algae – occurred in the western basin o Lake Erie. Scientists suspect that algaeblooms and the associated depletion o oxygen may be responsible or decliningpopulations o sport fsh such as walleyeand yellow perch in the lake.149

The cause o the reemergence o the

dead zone has been puzzling. Total phos-phorus loading to the lake has typically been at or below the target level set by the United States and Canada to prevent algae blooms and oxygen depletion in thelake. A recent state task orce in Ohio es-timated that agriculture – when measuredstatewide – is in “phosphorus balance” orthe frst time in many years. And indeed,overall, the number o arm animals inthe state has been on the decline.150 All o these actors would seem to suggest that

agribusiness is not a major contributor tothe reemergence o the dead zone.Over the last ew years, however, sci-

entists have discovered that, while totalphosphorus loads to the lake have heldsteady, there has been a sharp increasein ows o dissolved reactive phosphorus

(DRP), which is particularly readily absorbed by plants, into the lake. Flowso DRP in two key western Lake Erietributaries have increased signifcantly since the mid-1990s and are now higherthan they were in the mid-1970s, when

eorts to reclaim Lake Erie began inearnest. 151

At the same time as DRP ows toLake Erie have increased, Ohio and itsneighboring states have experienceda dramatic shit rom small-scale toactory-scale arming operations, witha particularly proound shit in thedairy industry. Between 1992 and 2007,the state o Ohio shed more than hal o its small dairy armers, while thepercentage o the state’s dairy herd onarms o 200 cows or greater increasedrom 6.7 percent in 1993 to 36 percent in 2007.152

In northwestern Ohio, southeastern Michigan and parts o Indiana, the past two decades have seen a prolierationo large, actory-style dairy operations,many o which can be traced back to asingle frm called Vreba-Ho Dairy Development.

Vreba-Ho was ounded by im-

migrants rom the Netherlands andopened its frst dairy in Michigan in1997. Ater meeting fnancial success with its own dairies, the company began acting as a consultant, luringdozens o other dairy armers romthe Netherlands to set up actory-styledairy CAFOs in Ohio, Michigan andIndiana.153

Ohio, Michigan and Indiana wereconsidered attractive locations or dairy CAFOs at the time because o their

lenient environmental regulations.Beore the economy (and milk prices)collapsed in 2008, the company helpedto broker the construction o more than41 acilities in the three states.154

In Michigan, the two dairies directly owned by Vreba-Ho have a long his-

A harmul algae bloom covers the waters o the western basino Lake Erie. Algae blooms have become more common in

recent years – reversing decades o progress in the restoration o the lake.

Photo: T. Archer, NOAA Great Lakes Environmental Research Laboratory




tion o the arming community is eitherover-applying or applying [phosphorus] without proper consideration to the tim-ing or methods o application.”161 Over-application or mis-application o manureoten results in phosphorus fnding its

way into rivers, streams and lakes.In addition, much o the growth in

dairy CAFOs in the basin – particularly those established by Vreba-Ho – hasbeen in the watershed o the MaumeeRiver, which drains parts o northeast-ern Indiana, southeastern Michigan andnorthwestern Ohio beore owing intoLake Erie at Toledo. Levels o DRP in Maumee River are now at their highest levels since at least 1975.162

Citizens rallied to save Lake Erie oncebeore. But it is becoming apparent that saving it again will require taking actionagainst the prolieration o actory armsin the region, and holding existing ac-tory arms accountable or cleaning upthe pollution they cause.

King Corn: ADM and theGul o Mexico Dead Zone

The Gul o Mexico is home to a hal-billion dollar fshery, as well as a vitaltourism industry. The vast BP oil spill inthe Gul during 2010 caused immeasur-able damage to the Gul’s ecosystems.But long beore the BP spill, the Gul o Mexico was in serious jeopardy.

Each year, the Gul o Mexico de- velops an oxygen-depleted dead zoneroughly the size o Massachusetts – oneo the largest dead zones in the world.163 The occurrence o such dead zones in

the United States has increased 30-oldsince 1960, along with the expansion o industrial agribusiness.164

The culprit in the ormation o thedead zone is the massive ow o nutri-ents rom the Mississippi River and itstributaries.165 As those rivers pass through

tory o environmental violations. The Michigan Department o Natural Re-sources and the Environment (DNRE)ound that the dairies discharged waste tosurace waters at least 49 times between2001 and 2009.155 In response to enorce-

ment action by the state environmentalagency, the dairies installed a wastetreatment system to reduce the impact o their waste on local waterways. However,the system did not operate as expectedand the company continued to spray its manure on local felds in quantities well above those permitted by the state. Vreba-Ho has also ailed to pay penal-ties related to its past environmental vio-lations.156 In October 2010, the DNREasked a state court judge to reduce thenumber o cows that could be housed at the acilities until the dairies’ dischargesmeet state standards.157

Many o the dairies that Vreba-Ho helped establish in the region have alsorun aoul o environmental laws. A south-eastern Michigan group has documentedmore than 1,000 confrmed violations o environmental and other laws by dairy operations, many o them operated orestablished by Vreba-Ho.158 Similar

patterns o violations have occurred at arms in Indiana and Ohio.159 Is the manure produced on concen-

trated dairy arms run by companies like Vreba-Ho partially responsible or there-emergence o Lake Erie’s dead zone? The scientifc jury is still out, but thereis good reason or concern.

Ohio’s Lake Erie Phosphorus Task Force recently concluded that “there arechanges in agriculture having an eect on the delivery o [dissolved reactive

phosphorus] to Lake Erie.”160 Amongthose changes are shits in tillage practices– including the widespread adoption o no-till arming, changes in drainage prac-tices, and changes in how Ohio armersertilize their crops. The task orce report notes that “it is apparent that some rac-




America’s agricultural heartland, they carry nitrogen and phosphorus downriver

to the Gul o Mexico. Those nutrientsin turn drive the growth o algae blooms. When the algae die and decompose, theprocess consumes oxygen dissolved in the water. Once oxygen levels all enough,the water becomes unable to support lie – creating a dead zone.

No crop has greater responsibil-ity or nutrient pollution o the Gul o Mexico than corn. And no company ismore responsible or the development o America’s corn economy than Archer

Daniels Midland.Corn plays an important role in the

ormation o the Gul dead zone. Thedead zone is caused by algae bloomsueled by nutrients – nitrogen and phos-phorus – that are carried downstream intothe Gul rom the Mississippi River. Corn

and soybeans are responsible or morethan hal o the nitrogen and a quarter o the phosphorus that fnds its way into theGul.166 The National Research Councilo the National Academy o Sciences hasound that corn is “the major source o

total nitrogen loading to the MississippiRiver.”167 The NRC also ound that:

Nitrate concentrations in rivers are•

the highest in the Corn Belt in the Midwestern United States, wherenitrogen ertilizers are applied in thegreatest amounts.

Depending on rainall levels, on•

the order o 15 to 36 percent o thenutrients applied to a corn planta-tion in the Midwest end up indownstream rivers and lakes.168

Adding to the challenge is the act that much o America’s corn is grown in partso the Midwest that use subsurace tiledrainage, which improves agriculturalproductivity by lowering the water tableby draining water into ditches. Recent research suggests that intensive armingo ertilized crops on tile-drained landis an important contributor to nitrogen

pollution in the Mississippi River andGul o Mexico.169

These problems are exacerbated by the act that American armers now plant more corn each year than they did in theearly 2000s. In 2010, American arm-ers planted an additional 12.1 millionacres o corn – an area twice the size o Maryland – compared with 2001, addingadditional strain rom nutrient pollutionto waterways in America’s heartland andthe Gul o Mexico.170

Why are American armers plant-ing so much corn? The answer is not necessarily to provide Americans withnutritious ood. Rather, it is a responseto ederal policies that have encouragedthe use o corn-based ethanol as a vehicleuel, increased the amount o high-

This image, generated by NASA, shows the shape o the dead zone in the Gul o Mexico in 2004. The dead zone, a region o low dissolved oxygen levels, is caused by runo o nutrients intothe Mississippi River basin. Excess nutrients uel the growtho algae blooms, which decompose, consuming oxygen rom thewater and threatening the health o the hal-billion-dollar fshery in the Gul.

Photo: NASA/Goddard Space Flight Center Scientifc Visualization Studio




ructose corn syrup in American diets,and provided a cheap source o grain that has ueled the growth o concentratedanimal eeding operations.

One o the companies that has beenmost inuential in crating America’s corn

economy – and that has benefted most rom its emergence – is Archer Daniels Midland, or ADM.

ADM is the leading processor o corn– a crop that covers much o the armlandin America’s Midwest. ADM produces an-imal eed, ethanol uel, and high-ructosecorn syrup. With the partial exception o animal eed, all o these are markets orcorn that did not exist 50 years ago and would likely not exist today were it not or ederal policies. Ethanol, corn-basedsweeteners and other corn “bioproducts”accounted or nearly $1 billion in proft or ADM in 2008.171

With its enormous size, substantialmarket power, and weighty politicalclout, ADM has created a public policy and economic environment that encour-ages many Midwestern armers to grow corn in massive, actory-scale plots. Thecorn market in the United States owes itscurrent shape to three ADM-supported

policies – ederal subsidies or cornarmers, support or ethanol production,and protection or the domestic sugarmarket.

Subsidies for Corn Production

In the 1970s, ADM was run by a po-litically connected executive, Dwayne Andreas, who became well known orcontributing hundreds o thousands o dollars to political campaigns acrossthe ideological spectrum. From 1989 to

2010, Archer Daniels Midland contrib-uted more than $8 million to politicalcampaigns.172

Andreas told the Washington Post in1996 how he and ADM consultant Mar-tin Sorkin worked with Vice President Hubert Humphrey and Illinois Senator

Everett Dirksen to drat legislation that allowed the ederal Food or Peace pro-gram to sell processed ood and not just raw ingredients. He said, “It changedthe whole world, because now it wasthe products we [at ADM] sell, not the

products we buy.”173

Andreas was also one o the earliest promoters o the idea o selling agricul-tural surpluses to Communist nations,an idea that was fnally implemented –to ADM’s great beneft – by the Nixonadministration in 1972.174 Those sales –especially the $700 million sale o grainto the Soviet Union – set the stage or asea change in agricultural policy in theUnited States that gave a major boost to ADM’s proftability.

Since the New Deal, the ederal gov-ernment had worked to stabilize armprices by keeping grain out o the market during years o bumper crops using a va-riety o mechanisms, including fnancialincentives or armers to keep land out o production and to store excess grainas well as direct ederal purchases o surplus crops. The 1972 grain sales tothe Soviet Union, however, coupled witha poor harvest in the United States and

other actors, created a temporary grainshortage that sent supermarket pricesthrough the roo.175

To prevent uture shortages, the Nixonadministration and Congress shited U.S.agricultural policy to encourage – ratherthan discourage – the surplus produc-tion o grains such as corn. To prevent a collapse in prices, the 1973 Farm Billallowed the Department o Agricultureto pay armers directly when market prices or their crops ell below their

production costs. For example, i corncosts $3.50 a bushel to produce, ederalpolicy allows armers to sell (and proces-sors such as ADM to purchase) that cornat $2.50 a bushel on the open market, with the dierence made up through acheck paid directly to the armer by the




ederal government.176 While ADMdoes not receive the money directly, thesubsidy greatly benefts the company by encouraging armers to plant as muchcorn as possible – thereby assuring alow o cheap inputs or processors

such as ADM. Earl Butz, the secretary o agriculture under the Nixon admin-istration and a leading advocate or the1973 Farm Bill, amously urged armersto “plant encerow to encerow,” and to“get big or get out.”177

This was a major shit in arm policy,and the subsidy persists today. Between1995 and 2009, corn drew nearly $76billion in ederal subsidies – more thanany other crop.178 These paymentsensure cheap inputs or actory hogarms and eedlots, while helping hugegrain processors like ADM to engineerlucrative markets or processed oodingredients and ethanol.

Protection for the Domestic SugarMarket

In his book, Against the Grain, authorRichard Manning describes how ADMfnanced a lobbying eort that resultedin policies designed to protect the

American sugar industry rom interna-tional competition – allowing ADM tocut into the domestic sugar market withits corn-based sweeteners.179

In the 1970s, ADM developed aprocess or manuacturing high ruc-tose corn syrup by “wet milling” corn. The company planned to market thisproduct as a ood additive in place o sugar, increasing sales and profts. Theonly obstacle to this plan was that themarket price or sugar was cheaper than

the price or which ADM could producecorn syrup.180

Instead o inding a cheaper way to make corn syrup, Andreas and histeam came up with a strategy to makesugar more expensive – thereby enabling ADM to compete in the sweetener

market. As described by Manning, ADMhelped to fnance a lobbying eort by Florida sugarcane growers to protect themselves rom international competi-tion. The campaign succeeded. In 1982,Congress imposed a cap on the import

o oreign sugar, which raised the priceo sugar two- to three-old above the world market price.181 Suddenly, ADM’scorn syrup product became competitive,prompting processed ood and beveragemanuacturers to switch rom sugar tocheaper corn syrup.

Today, corn-based sweeteners are now the leading additive in processed oodsand beverages. The average Americantoday eats about 50 pounds o highructose corn syrup per year – up romalmost none in 1975.182 Without ADM,and the protectionist sugar policies that persist today, there would be no market or corn-based sweeteners. These policiescontribute to the pressure on Midwesternarmers to grow large amounts o corn.

Ethanol Subsidies

ADM ound that demand or high ruc-tose corn syrup decreased in the winterand increased in the summer, driven by

changes in public demand or sweetenedbeverages. Looking or a way to capitalizeon the excess production capacity createdby this pattern, ADM settled on ethanol– and particularly ethanol rom corn – which it could manuacture through thesame wet milling process used to makecorn syrup.

According to the New York Times ,“ADM spent nearly three decades push-ing relentlessly or the use o ethanolin gasoline, lobbying Congress and the

White House and rousing armers.”183 Ina report called “A Case Study in Corpo-rate Welare,” the Cato Institute relateshow CEO Andreas approached President Carter in 1978 with a plan to promoteU.S. energy independence through a taxbreak on ethanol, achieved in the Energy




Tax Act passed later that year.184 In 1979,

Carter added support or ethanol by cre-ating a loan guarantee program or new ethanol plants and put a tari on Brazilianethanol made rom sugar.

Support or corn ethanol has contin-ued. In the 2005 Energy Bill, Congressrenewed huge tax incentives or ethanolproduction, and ordered producers torefne 7.5 billion gallons o the uel per year by 2012, in the name o reducingdependence on oreign oil.185 Achievingthis mandate will require the planting o

an estimated 3.7 million additional acreso corn in the United States.186

Over the past several decades, ADM’sethanol proits have risen along withgovernment subsidies or the uel – which now exceed 50 cents per gallon.187 ADM’s advocacy eorts have ensured

Federal subsidies and targets or ethanol production have pushed American armers to plant an additional 12 million acres o corn compared with a decade ago.

Photo: Jim Parkin, istockphoto.com

that American ethanol largely comes

rom corn rather than sugar, a cheaperraw ingredient.188 As a result, armers aceincreasing pressure to plant ever-largercorn plantations on available land acrossthe Midwest.

By using its political inuence, ADMhas profted immensely. As a result, ed-eral taxpayers now subsidize the growtho the dead zone in the Gul o Mexico.




Policy Recommendations

Control o America’s system o oodproduction has become increas-ingly concentrated in the hands o

a ew large corporations, which in turnhave helped reshape the way America

produces ood, oten to the detriment o our environment. In particular, theindustrial concentration o livestock op-erations – rom the grain it demands tothe manure it produces to the processingo its end-products – has taken a severetoll on our nation’s waterways.

Fortunately there are important stepsthat local, state and ederal governmentscan take immediately to reduce thethreat corporate agribusiness poses to waterways.

1. Ban the worst practices. Statessuch as North Carolina as wellas local governments around thenation have adopted moratoria onthe opening o new CAFOs. While

enorcement o these moratoria has varied, there is an urgent need toput the brakes on the expansion o CAFOs until key questions regard-ing their impacts on the environment

and public health are addressed andeective systems are put in place toensure that CAFO pollution does not poison America’s waterways.

In addition, states should imposeoutright bans on the worst corporateagribusiness practices, including the winter spreading o manure in cold- weather states, which dramatically increases the potential or runo intorivers and streams.

2. Guarantee protection to all o America’s waterways. A coreprotection o the ederal Clean Water Act is that discharges o pollu-tion to our waterways are strictly limited in permits written to ensureclean water. However, a series o




court decisions, culminating in theU.S. Supreme Court’s 2006 decisionin the case o Rapanos v. United States ,have threatened to strip this protec-tion rom thousands o intermittent and headwaters streams and isolated

wetlands across the country. Conse-quently, where CAFOs or otherindustrial agribusiness operationsbegin dumping pollution into one o these unprotected waters, the U.S.EPA would have little ability to stopthem. Already, EPA reports that more than 500 enorcement caseshave been compromised because o this new legal loophole.189 EitherCongress or ederal agencies canrectiy this problem by clariyingthat the Clean Water Act protectsall o America’s waterways. Signif-cantly, the Farm Bureau and severalagribusiness interests have beenamong the most vocal opponents o legislation to close this loophole.

3. Hold corporate agribusinessresponsible or its pollution. Vertically integrated poultry andpork frms have been allowed to

gain the benefts o control over theproduction process while disclaim-ing responsibility or the pollutiontheir animals produce. Variouslegal eorts around the country are making headway in establishingthese frms’ legal responsibility orkeeping pollution rom their animalsout o our waterways, but the issueis so clear-cut that there should beno ambiguity. State and ederal law should clearly assign joint and severalliability or the waste produced at contract arm operations to vertically integrated frms. This simple clari-fcation o legal responsibility willprovide vertically integrated frms with a powerul incentive to invest in

the pollution controls necessary tokeep animal waste out o our waterways.

4. Enorce existing laws. Existingclean water laws give the state and

ederal governments several power-ul tools to address pollution romagribusiness. Oten, however, thesetools are let unused. Specifcally,governments should:

a. Require agribusiness operationsto implement mandatory, en-orceable, numeric reductions innutrient runo or other orms o pollution as part o comprehensiveplans (known as Total MaximumDaily Loads, or TMDLs) to meet water quality standards in spe-cifc waterways. The U.S. EPA isscheduled to fnalize the TMDLor the Chesapeake Bay, and theBay states’ plans to implement it, by the end o 2010. The openquestion is whether the states’plans will be strong enough torein in agribusiness pollution –including the 1.1 billion pounds o chicken litter generated annually

by the demands o Perdue andother agribusiness operations onthe Delmarva Peninsula.

b. Issue water pollution permitsor all CAFOs that discharge orpropose to discharge to waterways, including those which, uponinspection, demonstrate a likeli-hood o discharging to a waterway. These permits set legal limitsor the amount o pollution that CAFOs may discharge to local waterways. But while permittingis at the core o the Clean Water Act’s system or regulating pol-lution rom large acilities, as o early 2008, less than hal o thenation’s CAFOs had permits.190




States generally bear the respon-sibility or enorcing the Clean Water Act, and should be requiredto issue permits that are strongenough to protect local waterwaysrom pollution.

c. Guarantee uniorm enorce-ment across states. Historically,agribusiness frms have expandedtheir operations in parts o thecountry with lax environmentalstandards – undermining themission o the Clean Water Act, which is to assure clean water orall Americans. The U.S. Environ-mental Protection Agency shouldensure that states take sufcient

action to prevent agribusinesspollution, or withdraw enorce-ment authority rom states that persistently reuse to do so. Thereare signs that this is beginning tooccur: a recent EPA investigationound that the state o Illinoisailed to issue required permits toCAFOs, has ailed to adequately inspect CAFOs to determine theircompliance with environmentallaws, and has ailed to ensure that

CAFOs that violate the law returnto compliance or pay appropriatepenalties.191 The U.S. EPA haslaid out specifc criteria Illinoismust meet in order to retain itsauthority to enorce the law.

5. Give environmental laws realteeth. Even when agribusiness frmsare caught in the act o pollutingour waterways, the penalties andenorcement actions to which they

are subject ail to deter uture pollu-tion or compensate or the additionalprofts received as a result o skirtingenvironmental laws. Firms such asthe Vreba-Ho dairies in Michigan(see page 31) can compile a decade-long record o environmental viola-

tions and still remain in business. Toprovide a real deterrent to pollutionrom corporate agribusiness, stateand ederal governments should bee up enorcement by adding additionalinspectors and enorcement ofcers,

and create tough penalties or majoror repeated violations o environ-mental laws, including mandatory minimum penalties and bans that prevent repeat violators o environ-mental laws anywhere in the nationrom securing new permits.

6. Empower local communities. Several states limit the ability o local zoning boards to ban or imposeconditions on actory arming opera-

tions. Since local communities bearthe brunt o actory arm opera-tions, they should have the authority to prohibit or limit them – as they would with most other land use/ zoning decision in most states. Statesshould eliminate any provisions orpolicies that limit the authority o local governments to regulate landuse related to actory arm opera-tions.

7. Ensure environmental transpar-ency. In 2008, the U.S. Government Accountability Ofce issued a report concluding that “no ederal agency collects accurate and consistent dataon the number, size and location o CAFOs.”192 The lack o inorma-tion about CAFOs makes it virtu-ally impossible or citizens to assesstheir impact on the environment ortheir compliance with environmen-tal standards. With creation o the

Toxics Release Inventory in 1987, theUnited States ensured that citizens were given access to inormationabout the discharge o toxic chemi-cals in their neighborhoods. Giventhe tremendous damage caused by discharge o nutrients, bacteria,




pesticides and other pollutants romagribusiness operations, there is noreason why they should be subject to any less transparency. The ederalgovernment should devise systemsto provide the public with more

inormation about pollution romagribusiness operations.

8. Encourage better practices. Theip side o tightening enorcement o environmental laws is encourag-ing armers to implement betterpractices that are less damaging tothe environment. Federal and stategovernments, acting in coopera-tion with arming organizations andthe extension services o land-grant

universities, should provide outreach,inormation, and resources to helparmers implement practices that reduce the ow o polluted runo to America’s rivers and streams. Thisincentives-based “best practices”approach has proven to be inade-quate as the cornerstone o thenation’s eort to address agribusi-ness pollution, but it remains animportant element o any programto ensure that armers are aware o

better ways to produce crops and areable to implement those solutionsquickly.

9. Look or systemic solutions. At the root o the water pollutionproblem caused by agribusiness isa system o ood production that is heavily subsidized by the publicand controlled by only a ew frms.Public subsidies have arguably shited America’s ood system to one

that is less benefcial both or Ameri-cans’ health and our waterways, andacilitated the emergence o massiveagribusiness frms with tremendouscontrol over the marketplace. Stateand ederal governments shouldconsider deeper policy changes that

shit the nation to a more sustainablesystem o ood production or theuture. The Department o Justiceis currently reviewing anti-trust concerns within the agribusinesssector, and Congress is expected to

take up the Farm Bill in 2012.




Notes1. Letter from Thomas Jefferson to John

Jay, 1785, as quoted in Eyler Robert Coates,

Sr., Thomas Jefferson on Politics and Government,

downloaded from etext.virginia.edu/jeerson/

quotaons/je1320.htm, 20 September 2010.

2. Letter from Thomas Jefferson to George

Logan, 1816, as quoted in Eyler Robert Coates,

Sr., Thomas Jefferson on Politics and Government,

downloaded from etext.virginia.edu/jeerson/

quotaons/je1320.htm, 20 September 2010.

3. There are many potential definitions of

“agribusiness.” The term is sometimes used

as a generic description for business-oriented

farms, or as a catch-all term for the entire

agriculture sector of the economy, including

businesses that manufacture or supply products

used on farms. In this report, we mean the

term “agribusiness” to refer to agricultural

production carried out at a large scale.

“Agricultural production” includes not only the

raising of plants or animals on the farm itself,

but also the processing of raw materials from

farms into consumer-ready products. There are

other economic actors – such as food retailers –

that have potentially great impacts on how food

is produced in the United States, but we do

not address those actors in this report. “Largescale” is an inherently subjective term, but

can be interpreted to refer to production at an

industrial scale.

4. U.S. Environmental Protection Agency,

Watershed Assessment, Tracking, & Environmental

Results: National Summary of State Information,

downloaded from iaspub.epa.gov/waters10/

aains_naon_cy.contro l, 10 September 2010.

5. Ibid.

6. Executive Office of the President of

the United States, Office of Science and

Technology Policy, Interagency Working Groupon Harmful Algal Blooms, Hypoxia, and

Human Health, Scientific Assessment of Hypoxia

in U.S. Coastal Waters, September 2010.


Protecting Water Quality from Agricultural Runoff ,

February 2003.


“5.11: Fecal Bacteria,” in Monitoring and Assessing

Water Quality, downloaded from water.epa.

gov/type/rsl/monitoring/vms511.cfm, 10

September 2010.

9. Fortune, Fortune 500: 2010 List,

downloaded from money.cnn.com/magazines/

fortune/fortune500/2010/full_list/, 17

September 2010.

10. Based on 2009 revenues of $115 billion

from Cargill, Five-Year Financial Summary,

downloaded from www.cargill.com/company/

nancial/ve-year/index.jsp, 17 September

2010, and comparable revenue figures from

Fortune, Fortune 500: 2010 List, downloaded

from money.cnn.com/magazines/fortune/

fortune500/2010/full_list/, 17 September 2010.

11. Government Accountability Office,

Agricultural Concentration and Agricultural

Commodity and Retail Food Prices: Briefing for

Congressional Staff , 24 April 2009.

12. Ibid.

13. Lyndsey Layton, “As Egg Producers

Consolidate, Problems of Just One Company

Can Be Far-Reaching,” Washington Post, 24

August 2010.

14. See note 11.15. Smithfield Foods, Smithfield Foods 2001

Annual Report, undated.

16. “Fitch Assigns Initial IDR of B+ to

Dean Foods; Outlook Stable,” Business Wire, 24

August 2010.

17. Patricia Breakey, “Franklin Farmers File

Lawsuit,” Oneonta Daily Star , 16 June 2010.

18. “DFA and Two Former Execs Hit

with $12 Million Penalty,” Farm and Dairy, 17

December 2008.

19. See note 17.

20. Higher costs: James M. MacDonald, William D. McBride and Eric J. O’Donoghue,

“Low Costs Drive Production to Large Dairy

Farms,” Amber Waves, September 2007.

21. See note 11.

22. Ibid.

23. U.S. Department of Agriculture,



Notes 43

Agricultural Statistics 2009, 2009, as well as

Agricultural Statistics annual reports for 1994,

1999, and 2004.

24. Ibid.

25. Concentration of various livestock

industries has increased in states since

the mid-1970s: Chantal Line Carpentier,

Deepananda Herath and Alfons Weersink,

Winrock International, Environmental and Other

Factors Influencing Location Decisions of Livestock

Operations, 2005.

26. See note 11.


National Agricultural Statistics Service, 2007

Census of Agriculture, 4 February 2009; U.S.

Department of Agriculture, U.S. Census of

Agriculture 1950: Agriculture 1950: A Graphic

Summary, 1952.

28. Third largest: WATT Poultry USA,

February 2010, as cited in Delmarva Poultry

Industry, Facts About Maryland’s Broiler Chicken

Industry, August 2010. Eastern U.S.: “Perdue Is

First and Only Chicken Company to Receive

USDA Process Verified Seal,” PRNewswire, 10

February 2010; $4.6 billion from Perdue, About

Us, downloaded from www.perdue.com/

company/about/index.html, 28 October 2010.

29. Dale Keiger, “Farmacology,” Johns

Hopkins Magazine, June 2009.

30. Chesapeake Bay Program, Bay FAQ,downloaded from www.chesapeakebay.net/

bayfaq.aspx?menuitem=14589#care, 17

September 2010.

31. Chesapeake Bay Program, Bay History,

downloaded from www.chesapeakebay.

net/bayhistory.aspx?menuitem=14591, 17

September 2010.

32. Arsenic: Bette Hilleman, “Arsenic in

Chicken Production,” Chemical and Engineering

News, 9 April 2007.

33. U.S. Poultry and Egg Association,

Industry FAQ, downloaded from www.poultryegg.org/faq/faq.cfm, 2 September 2010.

34. 568 million chickens from Delmarva

Poultry Industry, Inc., Look What the Poultry

Industry Is Doing for Delmarva, January 2010.

Some of this chicken production, particularly

in Delaware, does not occur in the Chesapeake

Bay watershed, but the vast majority occurs in

counties that are inside the watershed.

35. See, for example, U.S. Environmental

Protection Agency, EPA Orders Two Virginia

Farms to Cease Unpermitted Waste Discharges to the

Shenandoah River (press release), 2 June 2010.

36. Chesapeake Bay Foundation, Manure’s

Impact on Rivers, Streams and the Chesapeake Bay:

Keeping Manure Out of the Water, 28 July 2004.

37. 8.5 million acres: Chesapeake Bay

Program, Bay Barometer: A Health and Restoration

Assessment of the Chesapeake Bay and Watershed in

2008, March 2009.

38. Caitlin Kovzelove, Tom Simpson and

Ron Korcak, Water Stewardship, Quantification

and Implications of Surplus Phosphorus and Manure

in Major Animal Production Regions of Maryland,

Pennsylvania and Virginia, February 2010.

39. Chesapeake Bay Program, Sources

of Phosphorus Loads to the Bay and Sources of

Nitrogen Loads to the Bay, downloaded from

www.cheapeakebay.net, 2 September 2010.

40. Delmarva Poultry Industry, Facts About

Maryland’s Broiler Chicken Industry, August 2010.

41. Chesapeake Bay Program,

Dissolved Oxygen, downloaded from www.

chesapeakebay.net/status_dissolvedoxygen.

aspx?menuitem=19675, 2 September 2010.

42. S. Bricker, et al., National Oceanic and

Atmospheric Administration, Effects of NutrientEnrichment in the Nation’s Estuaries: A Decade of

Change, 2007.

43. Ibid.

44. Virginia Institute of Marine Science, Bay

Grasses Up, But Below Goal, 28 April 2010.

45. Chesapeake Bay Program, Maryland

Receives Federal Aid to Help Blue Crab Industry,

January 2009; and National Oceanic and

Atmospheric Administration, NOAA Approves

$10 Million Disaster Assistance Grant for Virginia

Watermen, 19 May 2009.

46. “Denies responsibility,” see:Memorandum, U.S. District Court for the District

of Maryland, Assateague Coastkeeper, et al. v. Alan

and Kristin Hudson Farm, et al., 20 July 2010.

47. Ibid.

48. 33 U.S.C. 1316 (a)(4)

49. Oklahoma Scenic Rivers Commission,




Oklahoma State University and National Park

Service, The Illinois River Management Plan 1999,

December 1998.

50. Oklahoma Conservation Commission,

Illinois River Watershed Monitoring Program,

National Monitoring Project: Post-Implementation

Monitoring Summary Report – Year 2, Evaluation of

Post-Implementation Monitoring , July 2007.

51. U.S. Environmental Protection

Agency, 2008 Waterbody Report for Illinois

River , downloaded from iaspub.epa.gov/

tmdl_waters10/aains_waterbody.control?p_

list_id=&p_au_id=OK121700030010_00&p_

cycle=2008&p_state=OK, 17 September 2010.

52. Justin Juozapavicius, “Expert: Recreation

on Illinois River Has Declined,” Seattle Times,

10 November 2009.

53. James S. Tyree, “Waste Worries, Ag,

AG Square Off,” Tahlequah Daily Press, 15 June

2006.

54. Oklahoma Office of the Attorney

General, AG Sues Poultry Industry for Polluting

Oklahoma Waters (press release), 13 June 2005.

55. Tyson Foods, Fiscal Year 2009 Fact Book,

undated.

56. Average chicken: 5.62 pounds, feed to

weight ratio: 1.92 = 10.8 pounds of feed per

chicken, 442.8 million pounds of feed per week,

23 billion pounds of feed per year. Ibid.

57. Based on data from U.S. Departmentof Agriculture, National Agricultural Statistics

Service, 2007 Census of Agriculture, downloaded

from www.agcensus.usda.gov, 13 May 2010.

58. See note 54.

59. Oklahoma Conservation Commission,

Watershed Based Plan: Grand Lake (Oklahoma

Portion) For Control of Nutrients, Sediment and

Fecal Bacteria, updated August 2004.

60. Ibid.

61. Richard B. Alexander, et al.,

“Differences in Phosphorus and Nitrogen

Delivery to the Gulf of Mexico from theMississippi River Basin,” Environmental

Science and Technology, 42: 822-830, 2008.

Supplemental materials available from U.S.

Geological Survey at water.usgs.gov/nawqa/

sparrow/gulf_ndings/index.html.

62. Robert J. Smith, “Poultry Firms Back

Askins in Oklahoma Governor Run,” Arkansas

Democrat-Gazette, 30 July 2010.

63. U.S. Army Corps of Engineers, Lake o’

the Pines, downloaded from corpslakes.usace.

army.mil/visitors/projects.cfm?Id=M205850,

25 October 2010.

64. Glenn Evans, “Lake o’ the Pines Beaches

Remain Closed for E. coli,” News-Journal

(Longview, Tex.), 22 June 2010.

65. Texas Commission on Environmental

Quality, One Total Maximum Daily Load for

Dissolved Oxygen in Lake o’ the Pines, 7 June 2006.

66. Ibid.

67. Bob Hallmark, “Businesses Struggle After

Beach Closings at East Texas Lake,” KLTV.com,

12 July 2010.

68. See note 65.

69. Ibid.

70. Ibid.

71. Ibid.

72. Fortune, “Fortune 500: 317. Pilgrim’s

Pride,” downloaded from cnnmoney.eu/

magazines/fortune/fortune500/2010/

snapshots/884.html, 25 October 2010.

73. Consumers Union, Animal Factories:

Pollution and Health Threats to Rural Texas, May

2000.

74. Tony Dutzik, Piper Crowell and John

Rumpler, Environment America Research &

Policy Center, Wasting Our Waterways: ToxicIndustrial Pollution and the Unfulfilled Promise of the

Clean Water Act, Fall 2009.

75. U.S. Environmental Protection Agency ,

Enforcement and Compliance History Online:

Detailed Facility Report: Pilgrim’s Pride Mount

Pleasant, Texas, downloaded from www.epa-

echo.gov/cgi-bin/get1cReport.cgi?tool=echo&I

DNumber=110000598844, 25 October 2010.

76. Texas Commission on Environmental

Quality, Executive Summary: Enforcement Matter,

Docket No. 2009-1337-IWD-E, Pilgrim’s Pride

Corporation, downloaded from www7.tceq.state.tx.us/uploads/eagendas/Agendas/2010/4-14-

2010/1337iwd.pdf , 25 October 2010.


National Agricultural Statistics Service, 2007

Census of Agriculture, 4 February 2009, and

similar reports for previous years.



Notes 45

78. Ibid.

79. Ibid.

80. Ibid.

81. North Carolina Office of Environmental

Education, Neuse River Basin, downloaded from

www.ee.enr.state.nc.us/public/ecoaddress/

riverbasins/neuse.150dpi.pdf , 17 September

2010.

82. Tony Bartelme, “Scientists Track the

‘Phantom’,” The Post and Courier (Charleston, SC), 1

September 1996.

83. Ibid.

84. Ibid.

85. Rick Dove, North Carolina Riverkeepers

and Waterkeeper Alliance, Fish Kills of the Neuse,

downloaded from www.riverlaw.us/shkills.htm

on 29 July 2010.

86. Impaired: North Carolina Department of

the Environment and Natural Resources, Division

of Water Quality, Final Neuse River Basinwide Water

Quality Plan, July 2009, Chapter 10.

87. Smithfield Foods, A Look Back at the

Smithfield Foods History, downloaded from www.

smithfieldfoods.com on 13 July 2010; David

Barboza, “Goliath of the Hog World; Fast Rise of

Smithfield Foods Makes Regulators Wary,” New

York Times, 7 April 2000.

88. Lewis Little, president of Smithfield

Packing Company, commented in the company’s

2001 annual report that “vertical integration givesus control over our pork products from squeal to

meal.” See note 15.

89. Leading owner: Neuse Riverkeeper

Foundation, Hogs and CAFOs, downloaded from

www.neuseriver.org/neuseissuesandfacts/

hogsandcafos.html on 27 July 2010. Hog farm

and animal quantities: Rick Dove, Statement of

Richard Dove Community Representative, Testimony

before the United States Senate Committee on

Environment and Public Works, 6 September

2007.

90. JoAnn Burkholder, et al., “ComprehensiveTrend Analysis of Nutrients and Related Variables

in a Large Eutrophic Estuary: A Decadal Study

of Anthropogenic and Climatic Influences,”

Limnology and Oceanography 51: 463-487, doi:

10.4319/lo.2006.51.1_part_2.0463, 2006.

91. Smithfield Foods, A Look Back at the

Smithfield Foods History, downloaded from www.

smithfieldfoods.com on 13 July 2010.

92. Rick Dove, Neuse Riverkeeper

emeritus, quoting Dr. Mark Sobsey, professor

of environmental sciences and engineering

at the University of North Carolina School

of Public Health, in North Carolina

Riverkeepers and Waterkeeper Alliance, Real

Hog Facts, downloaded from www.riverlaw.us/

realhogfacts.html on 26 July 2010.

93. Robbin Marks, et al., Natural Resources

Defense Council and Clean Water Network,

America’s Animal Factories: How States Fail to

Prevent Pollution from Livestock Waste, December

1998.

94. JoAnn Burkholder, et al., “Impacts of

Waste from Concentrated Animal Feeding

Operations on Water Quality,” Environmental

Health Perspectives 115: 308-312, doi: 10.1289/

ehp.8839, 14 November 2006.

95. See note 90.

96. J. Walker, et al., “Trends in

Ammonium Concentration in Precipitation

and Atmospheric Ammonia Emissions at a

Coastal Plain Site in North Carolina, U.S.A.”

Environmental Science and Technology 34: 3527–

3534, 2000.

97. Margaret Lilliard, “Permanent Phase-

Out of Swine Farm Waste,” Associated Press, 26

July 2007.98. Associated Press State and Local Wire,

“Despite Moratorium, More Hog Farms Built

in N.C. in Past 10 Years,” The Charlotte News &

Observer , 23 March 2007.

99. Smithfield Foods, Form 10-K , Securities

and Exchange Commission Document 1-15321,

18 June 2010.

100. See note 97.

101. See note 99.

102. Environmental impacts: Bob Iverson,

Silt: A Problem Turned Solution?, downloaded

from www.istc.illinois.edu/special_projects/il_river/iverson_siltarcle.pdf , 20 September

2010; “68 percent” U.S. Army Corps of

Engineers, Peoria Lake Habitat Rehabilitation and

Enhancement Project, downloaded from www.

mvr.usace.army.mil/EMP/hrep/PeoriaLake.

htm, 20 September 2010.




103. G.E. Groschen, et al., U.S. Geological

Survey, Water Quality in the Lower Illinois River

Basin, Illinois, 1995-98, 2000.

104. See note 61.

105. Mark B. David, Laurie E. Drinkwater

and Gregory F. McIsaac, “Sources of Nitrate

Yields in the Mississippi River Basin,” Journal of

Environmental Quality, 39:1657-1667, 2010.

106. C. Robert Taylor, “Hiding the True

Extent of Concentration and Market Power

with Partial Ownership and Strategic Alliances,”

Agriculture & Resource Policy Forum, July 2002.

107. Renewable Fuels Association, 2010

Ethanol Industry Outlook: Climate of Opportunity,

February 2010.

108. Cargill, Our Businesses: Five Major

Business Segments, downloaded from www.cargill.

com/company/businesses/index.jsp on 27

August 2010.

109. Andrea D. Murphy and John J. Ray,

“America’s Largest Private Companies,” Forbes,

16 November 2009.

110. Cargill, Five-Year Financial Summary,

downloaded from www.cargill.com/company/

nancial/ve-year/index.jsp on 27 August 2010.

111. Cargill Meat Solutions, Beardstown, IL,

downloaded from www.cargillmeatsoluons.

com/about_us/tk_cms_about_loc_pork_il.htm,

20 September 2010.

112. See note 74.113. “Virtually all”: U.S. Environmental

Protection Agency, Envirofacts database, Form R

Report for Cargill Meat Solutions Corp., Beardstown,

IL, for TRI Reporting Year 2007, downloaded

from oaspub.epa.gov/enviro/tri_formr_

partone_v2.get_details?rpt_year=2007&fac_

id=62618XCLCRRR1BO&ban_ag=Y, 5

November 2010.


Agency, Envirofacts database, Toxics Release

Inventory Report for Cargill Meat Solutions, TRI

ID 62618XCLCRRR1BO, downloaded fromwww.epa.gov/enviro/facts/tri/index.html, 20

September 2010.

115. See note 74.

116. Jim Suhr, “Ex-Cargill Manager Given 5

Years,” Associated Press, 16 August 2002.

117. Ibid.

118. Rick Jordahl, “Be the First to Arrive,”

Pork, 1 September 2009.

119. Associated Press, “Corporate Hog

Farms Grow, and Raise a Stink,” Msnbc.com, 31

March 2006.

120. Dusty Rhodes, “Buckhart Hog

Operation Opens While Neighbors Fume,”

Illinois Times, 18 March 2009.

121. Illinois Environmental Protection

Agency, Illinois EPA Livestock Program 2009

Livestock Facility Investigation, undated.

122. 72 percent: Government

Accountability Office, Agricultural Concentration

and Agricultural Commodity and Retail Food Prices:

Briefing for Congressional Staff , 24 April 2009;

30 percent: Western Organization of Resource

Councils, Banning Packer Ownership of Livestock:

Myths & Facts, October 2007.

123. John D. Anderson and Darren

Hudson, “Acquisitions and Integration in the

Beef Industry,” Policy Issues, Agricultural &

Applied Economics Association, September

2008.

124. Matt Birkbeck, “Montco Beef Plant to

Pay $2 Million Fine,” Allentown Morning Call, 17

June 2010.

125. Julia Terruso, “Montgomery County

Beef Processor to Pay $2 Million for Polluting,”

The Philadelphia Inquirer , 17 June 2010.

126. Ibid.127. JBS USA, JBS USA Reinforces

Commitment to Food Safety through Creation of

Food Safety and Quality Advisory Team (News

Release), 3 March 2010.

128. Swift: JBS USA, Swift Celebrates 150

Years of Meat Industry Excellence: Gus Swift’s

Legacy of Meat Industry Innovation Lives On (News

Release), 24 June 2005; Smithfield: Jakon Hays

and Maureen Watts, “Company Timeline,”

Smithfield: The Virginian-Pilot, 18 February

2009; “JBS Said To Be Considering Smithfield

Takeover, Increasing Pace Of Consolidation InMeat Sector,” Business Monitor International, BMI

Americas Food and Drink Insights, 1 August 2010.

129. “JBS Said To Be Considering

Smithfield Takeover, Increasing Pace Of

Consolidation In Meat Sector,” Business Monitor

International, BMI Americas Food and Drink



Notes 47

Insights, 1 August 2010; “JBS Packerland Parent

Ends Bid for National Beef,” The Business Journal

of Milwaukee, 20 February 2009.

February 2009.

130. See note 55.

131. See note 127.

132. Ibid.

133. See note 125.

134. Ibid.

135. Marilyn S. D’Angelo, “Two Companies

Responsible for Bulk of River Pollution,”

Philadelphia Business Journal, 6 November 2009.

136. Ibid.

137. Daniel Patrick Sheehan, “Moyer Packing

Spill Cause of Fish Kill,” Allentown Morning

Call, 23 September 2006; Frank Devlin, “Errant

Ammonia Release Killed Fish,” Allentown Morning

Call, 24 July 2002; Julia Terruso, “Montgomery

County Beef Processor to Pay $2 Million for

Polluting,” The Philadelphia Inquirer , 17 June 2010.

138. Brian Callaway, “MoPac Rendering

Plant Likely to be Fined over Wastewater that

Killed 10,000 Fish,” Allentown Morning Call,

14 August 2007; Pennsylvania Department of

Environmental Protection, MoPac Rendering

Plant Wastewater Spill Causes Mile-Long Fish Kill in

Skippack Creek (News Release), 10 August 2007.

139. Brian Callaway, “MoPac Rendering Plant

Likely to be Fined over Wastewater that Killed

10,000 Fish,” Allentown Morning Call, 14 August2007.

140. See note 125.

141. Ibid.

142. United States Geological Survey, Water

Quality in the South Platte River Basin: Colorado,

Nebraska, and Wyoming, 1992–95, 1998.

143. Ibid.

144. Ibid.

145. “Cargill Fined for Water Violations,”

Fort Morgan Times, 16 November 2009.

146. See note 74.

147. U.S. Environmental Protection Agency,Toxics Release Inventory, report for TRI Facility

#80701XCLCR1505E, February 2010; available

at www.epa.gov/triexplorer/.

148. “Cargill Fined $200,000 over Wastewater

Violations,” The Associated Press State and Local

Wire, 13 November 2009.

149. Ohio Environmental Protection, Ohio

Lake Erie Phosphorus Task Force Final Report,

April 2010.

150. Ibid.

151. Ibid.

152. See note 23.

153. Julie M. McKinnon, “Vreba-Hoff Local

Dairy Firm Plans No More Bankruptcies,”

Toledo Blade, 3 August 2010.

154. Vreba-Hoff, Frequently Asked Questions,

downloaded from www.vrebahoff.com/HTML/

faqs.htm, 17 September 2010.

155. At the time, the Michigan DNRE

was known as the Michigan Department of

Environmental Quality.

156. Michigan Department of

Environmental Quality, Vreba-Hoff Dairy – June

2010 Update, 19 July 2010.

157. Dennis Pelham, “Vreba-Hoff Dairies

Await Court Decision,” Daily Telegram (Adrian,

Mich.), 2 October 2010.

158. Environmentally Concerned Citizens

of South Central Michigan, Confirmed

Violations/Discharges from CAFOs and

Liquid-System Livestock Operations to Bean/

Tiffin Watershed and River Raisin Watershed,

downloaded from www.nocafos.org/violaons.

htm, 17 September 2010.

159. Ohio: Ben Sutherly, Mike Wagner

and Laura A. Bischoff, “Lucrative MegafarmMarket Lures Europeans,” Dayton Daily News,

6 December 2002; Indiana: Carla Knapp,

“Controversial Dairy Planned for Carroll

County,” Logansport (Ind.) Pharos-Tribune, 21

October 2007.

160. See note 149.

161. Ibid.

162. Ibid.

163. Mark Schleifstein, “Dead Zone as Big

as Massachusetts along Coast of Louisiana

and Texas, Scientists Say,” New Orleans Times-

Picayune, 3 August 2010.164. See note 6.


Agency, Mississippi River Basin Watershed

Nutrient Task Force, Hypoxia 101, downloaded

from www.epa.gov/owow_keep/msbasin/

hypoxia101.htm, 5 November 2010.



166. See note 61. Supplemental materials

available from U.S. Geological Survey at water.

usgs.gov/nawqa/sparrow/gulf_ndings/index.

html.

167. U.S. National Academy of Sciences,

National Research Council, Water Implications of

Biofuels Production in the United States, National

Academies Press, 2008.

168. S.A. Miller et al, “Use of Monte Carlo

Analysis to Characterize Nitrogen Fluxes in

Agroecosystems,” Environmental Science and

Technology 40: 2324-2332, 2006.

169. See note 105.

170. National Corn Growers Association,

The 2010 Crop – Iowa, downloaded from www.

iowacorn.org/User/Docs/The%202010%20

Crop-%20IA.pdf , 17 September 2010.

171. Securities and Exchange Commission,

Archer Daniels Midland Form 10-K for the Fiscal Year

Ended June 30, 2010, 27 August 2010.

172. Center for Responsive Politics, Open

Secrets: Archer Daniels Midland, downloaded from

www.opensecrets.org, 22 August 2010.

173. Peter Carlson, “Chairman Across the

Board,” Washington Post, 14 July 1996.

174. Harold Henderson, “Supermarket to the

World,” Illinois Issues, May 2001.

175. Clifton B. Luttrell, Federal Reserve

Bank of St. Louis, The Russian Wheat Deal –

Hindsight vs. Foresight, October 1973.176. Tim Weiner, “Dwayne’s World;

Influence of Archer-Daniels Is Wide as Well as

Deep,” New York Times, 16 January 1996.

177. As quoted in Michael Pollan, The

Omnivore’s Dilemma: A Natural History of Four

Meals, 2006.

178. Environmental Working Group,

Farm Subsidy Database, downloaded

from farm.ewg.org/progdetail.

php?ps=00000&progcode=corn, 28 October

2010.

179. Richard Manning, Against theGrain, (New York, North Point Press), ISBN:

9780865476226, 2004 as described in Tom

Philpott, “A Speculation about Why ADM’s

HFCS Business Is Booming,” Grist.org , 10 May

2006

181. Ibid.


Economic Research Service, High Fructose

Corn Syrup: Estimated Number of Per Capita

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workbook), updated 26 October 2010.

183. Alexi Barionuevo, “A Bet on Ethanol,

With a Convert at the Helm,” New York Times,

8 October 2006.

184. James Bovard, Cato Institute, Archer

Daniels Midland: A Case Study in Corporate

Welfare, 1995.

185. See note 183.

186. Susan Powers, Rosa Dominguez-Faus

and Pedro Alvarez, “The Water Footprint of

Biofuels Production in the USA, Biofuels 1: 255-

260, 2010.

187. See note 183.

188. Ibid.


Agency, Memorandum from Granta Y. Nakayama

to Benjamin Grumbles RE: OECA’s Comments

on the June 6, 2007 Memo, Clean Water Act

Jurisdiction Following the U.S. Supreme Court’s

Decision in Rapanos v. United States & Clarabell v.

United States, 4 March 2008.


Agency, “EPA Targets Clean Water Violations

at Livestock Feeding Operations,” Enforcement

Alert, 10(2), March 2009.191. U.S. Environmental Protection

Agency, Region 5, Initial Results of an Informal

Investigation of the National Pollutant Discharge

Elimination System Program for Concentrated

Animal Feeding Operations in the State of Illinois,

September 2010.

192. U.S. Government Accountability

Office, Concentrated Animal Feeding Operations:

EPA Needs More Information and a Clearly Defined

Strategy to Protect Air and Water Quality from

Pollutants of Concern, September 2008.

193. U.S. Environmental Protection Agency,Section 303(d) List Fact Sheet for Watershed Lake

o’ the Cherokees, downloaded from iaspub.epa.

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huc=11070206&p_huc_desc=LAKE%20

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Documents

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