Exclusion of CAFOs from DEPs Environmental Justice Policy

May 4, 2022

To: Pennsylvania Department of Environmental Protection


Good evening, my name is Chris Hoffman and I am honored to speak to you tonight on behalf of the Pennsylvania Farm Bureau. As Vice President of the state’s largest agriculture organization, I and our 31,000 members would like to voice our concern over the proposed inclusion of Concentrated Animal Feeding Operations (CAFO’s) as a part of the outlined Environmental Justice Policy requiring public participation trigger permits.

It is difficult to understand why more regulation and bureaucratic interference would be considered as necessary when an already intensive permitting and reporting process exists. Currently, anyone operating as a CAFO must obtain a National Pollutant Discharge Elimination System (NPDES) permit which is administered by the Department of Environmental Protection. As part of an agreement with the EPA, CAFO’s must maintain adequate manure storage, raw material storage, waste containment areas, along with proper setbacks and buffers. All of these requirements are reported, inspected, and approved by, ultimately, by the EPA. Failing to comply with these requirements, and a failure to maintain proper nutrient, sediment, and odor management plans results in penalties that no farmer can afford.

As a representative of the Pennsylvania Farm Bureau, I must ask the following questions.

  • What research or evidence has been presented that provides justification for this proposal?
  • If such a policy would exist, who would provide guidance and oversight? Would the ag sector be represented on the board of any committees or groups formed to provide such oversight?

As it states in Pennsylvania’s Right to Farm Act, “it is the declared policy of the Commonwealth to conserve and protect and encourage the development and improvement of its agricultural land for the production of food and other agricultural products.” The Right to Farm Act does not inhibit farmers from growing or expanding their businesses. Likewise, Pennsylvania’s ACRE (Agriculture, Communities, and Rural Environment) law ensures that local government cannot restrict or limit the ownership structure of a normal agricultural operation. CAFO’s, or any farm, do not just come into existence overnight. Laws and policy processes must be – and are – followed to ensure proper care and attention is given to the soil, water, and air quality of our communities.

Contrary to the belief of many, farmers take great pride in being good stewards of the land and environment. It is the land, after all, that feeds our animals. We all drink the same water and breathe the same air. Why would farmers want to willingly diminish life’s essential resources? Our animals and our farms are our way of life. They are a part of who we are and what we love. In many instances, farms have passed through generations and will continue to do so. Failing to comply with the already intense processes and regulations required of us would result in the loss of our legacy. Adding unjust and unwarranted regulations to an already stacked deck would simply be an overreach of bureaucratic government, and another obstacle thrown in the path of those of us who aim to feed the world.



Chris Hoffman
Vice-President, Pennsylvania Farm Bureau
Farmer, Juniata County