Ag Runoff Aff Neg - UTNIF 2021

UTNIF_Agricultural Runoff
FYI
Terminology
Point source pollution. Refers to any pollution carried by water that is conveyed or passes
through a pipe, ditch, channel, tunnel, conduit, or a well before entering local waters.
Nonpoint source pollution. Refers to any pollution carried by water that is not classified as a
point source.
Polluted urban runoff. Refers to stormwater that flows over an urban area, carrying sediment,
nutrients, and other harmful pollutants into local receiving waters. This term covers stormwater
that is collected, transported, and discharged without treatment from a point source by a
municipal separate storm sewer system (MS4). It also refers to stormwater that flows overland,
carrying pollution directly into local waters without traveling through or along a conveyance.
The latter may also be referred to as “direct drainage” or “direct stormwater discharge.”
Dead zones. Water with low levels of dissolved oxygen (hypoxic water) that causes most fish,
plants, and other aquatic life to die.
Cyanobacteria. Microscopic, single-celled organisms that use sunlight to make their own food.
The organisms produce harmful toxins known as cyanotoxins, which can cause rapid death by
respiratory failure.
NPDES permits - As authorized by the Clean Water Act (CWA), the NPDES Permit Program
controls water pollution by regulating point sources that discharge pollutants into waters of the
United States. Point sources are discrete conveyances such as pipes or man-made ditches.
Examples of pollutants include, but are not limited to, rock, sand, dirt, and agricultural,
industrial, and municipal waste discharged into waters of the United States. See section 122.2 of
40 Code of Federal Regulations (C.F.R.) for the actual definitions of point source, pollutant, and
water of the United States. The NPDES Program is a federal program which has been delegated
to the State of California for implementation through the State Water Resources Control Board
(State Water Board) and the nine Regional Water Quality Control Boards (Regional Water
Boards), collectively Water Boards. In California, NPDES permits are also referred to as waste
discharge requirements (WDRs) that regulate discharges to waters of the United States. Since its
introduction in 1972, the NPDES Program has been responsible for significant improvements to
our nation's and state’s water quality.
AFF
1AC
Plan Text
The United States federal government should require National Pollutant
Discharge Elimination System permits for agricultural runoff.
CAFOs Advantage
Over-reliance on antibitoics in livestock feeds produces antibiotic resistant
bacteria
Lindwall 2019 - writer and editor in NRDC's Communications department
Courtney Lindwall July 31, 2019 “Industrial Agricultural Pollution 101”
https://www.nrdc.org/stories/industrial-agricultural-pollution-101
Antibiotic resistance
The widespread use of antibiotics in meat production in animals that are not sick is contributing
to the public health crisis of antibiotic resistance. Two-thirds of antibiotics important to human
medicine in the U.S. are sold for use in livestock, not people. The regular use of these drugs in
the food and water of farm animals to (poorly) help them survive the often crowded, unsanitary,
and stressful conditions on CAFOs contributes to the rise and proliferation of antibiotic-resistant
bacteria. These bacteria can then spread from CAFOs via air and water, including water used to
irrigate crops, and can end up in animal waste used to fertilize crops. Contaminated meat and
farmworkers’ clothing and shoes can also spread these antibiotic-resistant bacteria into our
communities. Resistant bacteria can even “teach” other bacteria resistance, and this process can
take place anywhere bacteria are found, including in our homes and guts. The exposure of
workers and farm-adjacent communities is particularly high. Antibiotic-resistant bacteria are
among the gravest health threats we face today. It’s estimated that up to 162,000 people die
per year in the United States as a result of antibiotic-resistant infections—that’s more people
than are killed in all types of accidents, and more than double the annual deaths from opioid
overdoses—making it the third-leading cause of death in the United States, behind heart disease
and cancer. And public health officials warn that the crisis will only get worse if we continue
misusing and overusing these drugs.
Manure lagoons at CAFOs spillover and are a direct threat to local water
supplies
Johnson-Weider 2020 – J.D., Stetson University College of Law, worked as an attorney in
the UnitedStates Senate Office of the Legislative Counsel for thirteen years, with primary
responsibility for drafting legislative proposals relating to agriculture and nutrition.
(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

Approach” The Georgetown Envtl. Law Review, Vol. 32:685)
The most obvious and immediate threat that CAFOs present is to clean water and public health,
two significant concerns of the rural communities in which these factory farms are usually
located. CAFOs present such a significant threat to drinking water quality and overall public
health because the effects of CAFOs are so difficult to contain.
Many of CAFOs’ harms are rooted in manure storage and disposal. Manure lagoons at North
Carolina hog CAFOs (most of which are concentrated in the coastal plain) have repeatedly
overflowed in situations of natural disaster, flooding untreated sewage across the countryside
and contaminating crops to the extent that they are considered “adulterated” by the FDA and
cannot be sold for human consumption.59 Animal waste concentrated in manure lagoons has a
much higher nutrient load than raw human sewage and is, therefore, much more likely to result
in dangerous algal blooms when it contaminates ground or surface water.60 This waste often
contains heavy metal, antibiotic, pesticide, and hormone residue, much of which can persist in
watersheds.
Many rural areas depend on groundwater for drinking, and studies have shown that private
wells in areas with CAFOs often contain bacteria, pathogens, veterinary antibiotics, and nitrates
(a particular risk to infants, among whom high levels of nitrates may result in blue baby
syndrome, neural tube defects, and even death). The massive quantities of manure produced in
concentrated areas by CAFOs are difficult to mitigate and can lead to antibiotic-resistant strains
of bacteria being transmitted to humans through air or water contamination of nearby fresh
fruit and vegetable production.63 Additionally, CAFOs are the perfect breeding place for insects,
including those that can spread harmful pathogens to humans.64 These risks can extend far
beyond the rural areas where CAFOs are located, through both food-borne pathogens and
infectious diseases that spread from animals to humans. Despite all of these well-documented
negative effects, agricultural activities are largely exempt from regulation and oversight under
the Federal Water Pollution Control Act (commonly known as the “Clean Water Act”).66 The
threats to clean water and public health are, therefore, particularly compelling reasons for why
federal legislative action is necessary.
That causes super bugs

Helmer 2018 - experienced journalist who writes about food, gardening, farming, the
environment and sustainable living
October 23, 2018 Jodi Helmer “Hurricane-Flooded Hog Farms Could Bring Superbugs to North
Carolina Communities” https://www.nrdc.org/stories/hurricane-flooded-hog-farms-could-bring-
superbugs-north-carolina-communities
Hurricane Florence dropped more than 30 inches of rain in some North Carolina coastal communities in September, killing at least
39 people, toppling trees, downing power lines, and causing extensive flood damage. Now that the waters have receded, hundreds
of thousands of residents are left to rebuild or repair their homes and businesses and replace their destroyed belongings. For those
living near hog farms, the cleanup will need to be even more extensive. That’s because runofffrom huge livestock
operations can spread large amounts of fecal matter throughout the landscap e—and with it the
potential danger of antibiotic-resistant bacteria, or superbugs. North Carolina is home to nearly 10 million
hogs that produce 10 billion gallons of manure each year. Farmers store the pigs’ waste in thousands of pits,
some the size of football fields, called lagoons . During Hurricane Florence, six lagoons suffered structural damage
and 33 have overflowed so far, discharging an enormous amount of hog feces into the surrounding environment. When
thousands of animals live together in close quarters , standing in their own feces, disease happens.
Farmers administer low doses of antibiotics to prevent the spread of illness (and to help spur growth),
but such practices also encourage the development of bacteria that can resist those
medicines. The drug-resistant bacteria colonizing the pigs’ bodies come out in their feces and
eventually get flushed into the lagoons, says Lance B. Price, founding director of the Antibiotic Resistance Action
Center at George Washington University. When the lagoons overflow, the superbugs go wherever the
floodwaters go. This is what happened in 1999 when Hurricane Floyd caused lagoons at 46 operations in eastern North
Carolina to spill their contents. A decade and a half later, a study published by the National Institutes of Health found that there
were still high concentrations of fecal bacteria in surface waters both upstream and downstream from the hog lagoons. More than
40 percent of samples exceeded state and federal water quality guidelines for E. coli. “We know from past hurricanes that the
bacterial threat from these overflowing lagoons sticks around even after the floodwaters go
away,” says Valerie Baron, an NRDC attorney who works on sustainable agriculture issues. “But the waste is a significant
problem even when there’s not a major weather event or lagoon failure.” Residents living near
concentrated animal feeding operations, or CAFOs, where hogs live snout-to-snout, already experience a range of
adverse health conditions ranging from asthma and skin irritation to birth defects and miscarriages. A 2018 study
published in the North Carolina Medical Journal found that people living near hog farms also had lower life expectancies and higher
rates of hospital admissions than other North Carolinians. No government agency currently tracks the possible connections between
lagoon overflows and health issues in CAFO-adjacent communities, but Price suspects hospitals in downstream regions could see
upticks in illnesses such as staph, MRSA, and E. coli infections. Making matters worse, he says, “ If
people get an infection
from the bacteria, the treatment can fail because those pathogens are resistant to antibiotics .”
CAFO-contaminated drinking water is one of the biggest concerns. Well water is prevalent in rural
communities. When sullied floodwaters seep into the ground, the sunlight that can kill some
troublesome bacteria can no longer reach them . Such bacteria can also persist in sediment and
contaminate well water over long periods of time. Jill Johnston, an assistant professor of preventive medicine at
the University of Southern California, says testing and treating drinking water sources can help. Unfortunately, she notes,
industrial hog operations are often located in low-income communities where residents can’t
afford water tests or expensive filtration systems. Many of these communities are
predominantly African-American, and Johnston calls it “an issue of environmental racism .” At least
150 industrial hog operations in North Carolina are located in or near 100-year floodplains. In places like Duplin and Sampson
Counties, where hogs outnumber humans, residents are at ongoing risk from flooded hog lagoons. “We have programs to help
farmers out after these flood events, to help them rebuild and compensate them for their losses,” says Price. “It seems that some of
that money could be spent helping people living in these regions to determine whether their drinking water is safe and then help
them rectify the problem.” Prevention, of course, is key. Relocating hog farms to higher ground could keep them out of a flood’s
reach, but that would not stem the prolific amounts of excrement they produce nor lessen the threats their living conditions pose to
modern medicine. Researchers have been looking into possible technological solutions, such as transforming waste into biofuel, but
so far nothing has proved capable of putting a dent in the state’s hog waste problem. Smaller farms do not require lagoons and use
less, if any, antibiotics, but there’s plenty of room for improvement at large-scale operations. David Wallinga, a physician working on
health policy at NRDC, points out that Denmark and the Netherlands have already succeeded in curbing antibiotic overuse on
industrial pig farms. Providingmore space and better feed, for example, helps to decreases the animals’
stress levels and boosts their immune systems, allowing agricultural antibiotic use in those European
countries to drop nearly 60 percent. The U.S. livestock industry could do the same, but unfortunately it
has not been adequately motivated to do so. And now Baron fears the Trump administration is making a bad
situation worse. A month before Hurricane Florence came barreling through North Carolina, the U.S. Environmental Protection
Agency announced it was changing its National Enforcement Initiative and dropping its focus on CAFOs. The NEI has long gone after
industries that have a poor history of compliance and pose an outsize threat to neighboring communities.
Extinction
Davies 08 - Professor of Microbiology and Immunology @ University of British Columbia [Julian Davies,
“Resistance redux. Infectious diseases, antibiotic resistance and the future of mankind,” EMBO reports 9, S1, S18–S21
(2008), pg. http://www.nature.com.proxy.library.emory.edu/embor/journal/v9/n1s/full/embor200869.html]
For many years, antibiotic-resistant pathogens have been recognized as one of the main threats to
human survival, as some experts predict a return to the pre-antibiotic era. So far, national efforts to exert strict
control over the use of antibiotics have had limited success and it is not yet possible to achieve worldwide concerted action to
reduce the growing threat of multi-resistant pathogens: there are too many parties involved. Furthermore, the problem has not
yet really arrived on the radar screen of many physicians and clinicians, as antimicrobials still work most of
the time—apart from the occasional news headline that yet another nasty superbug has emerged in the local hospital. Legislating
the use of antibiotics for non-therapeutic applications and curtailing general public access to them is conceivable, but legislating the
medical profession is an entirely different matter. In
order to meet the growing problem of antibiotic
resistance among pathogens, the discovery and development of new antibiotics and alternative treatments for infectious
diseases, together with tools for rapid diagnosis that will ensure effective
and appropriate use of existing
antibiotics, are imperative. How the health services, pharmaceutical industry and academia respond in the
coming years will determine the future of treating infectious diseases. This challenge is not to
be underestimated: microbes are formidable adversaries and , despite our best efforts, continue to
exact a toll on the human race.
Requiring NPDES permits establishes performance based standards that solves

runoff from CAFOs
Kenyon 2017 - J.D., 2017, New York University School of Law
Emily Kenyon “Enough Of This Manure: Why The EPA Needs To Define The Agricultural
Stormwater Exemption To Limit The “Runoff” From The Alt Court” New York University Law
Review Vol. 92:1187
The EPA should also establish baseline requirements that CAFOs must comply with to avail
themselves of the exemption. As mentioned above, permitted CAFOs must implement a
Nutrient Management Plan as a part of their NPDES permit.204 The Nutrient Management Plans
include technical standards and site-specific nutrient management practices that the CAFO must
comply with to be eligible for the agricultural stormwater exemption.205 However, most CAFOs
are unpermitted206 because they are not required to obtain a permit unless the EPA
demonstrates that they are discharging.207 Therefore, many operate without a permit—either
because they do not discharge, or because they are willing to take their chances given the
limited enforcement.208 Unpermitted CAFOs are not required to have a Nutrient Management
Plan; instead the precipitation-related discharges from their land application area are eligible for
the agricultural stormwater exemption if the manure, litter, or process wastewater has been
applied “in accordance with site-specific nutrient management practices that ensure
appropriate agricultural utilization of the nutrients,” including certain “nutrient management
practices.”209 This system fails to ensure that the agricultural stormwater exemption is
furthering an agricultural purpose while limiting water pollution for both permitted and
unpermitted CAFOs. First, while the specific technical standards in the Nutrient Management
Plan have the ability to effectively regulate permitted CAFOs, which reduces the potential for
inappropriate use of the agricultural stormwater exemption, the EPA has largely delegated the
standards’ establishment to states and they vary by state.210 For example, some states fail to
enforce their permitting requirements, while others set their requirements below the federal
level.211 Second, without the Nutrition Management Plan’s technical standards, the “best
practices” for unpermitted CAFOs fail to provide substantive standards for the permitting agency
to review when determining whether the CAFO’s discharge is eligible for the agricultural
stormwater exemption. For example, one amorphous best practice is to “[i]dentify appropriate
site specific conservation practices to be implemented.”212
Runoff Advantage
Agricultural runoff is the primary cause of water pollution
Andreen 2016 – University of Alabama - School of Law
William L. Andreen “No Virtue Like Necessity: Dealing with Nonpoint Source Pollution and
Environmental Flows in the Face of Climate Change” 34 Va. Envtl. L.J. 255 (2016).
The CWA's approach to nonpoint source pollution and environmental flows has had dire
consequences. Today, nonpoint source pollution is the leading source of water quality impairment
in the nation, 6 responsible for over seventy-five percent of the rivers and lakes that fail to
meet water quality standards. It is also a leading cause of the degradation of some of our most
significant coastal resources such as the Chesapeake Bay and the waters of the Gulf of Mexico
that lie at the mouth of the Mississippi River. 8 Agriculture is by far the leading source of water quality
impairment, while flow problems produced by hydrologic modifications and habitat alterations take second place. 9 In fact,
natural flow regimes have been altered on eighty-six percent of our rivers and streams in the contiguous United States, and those
anthropogenic changes have produced extensive ecological damage. g Our
growing population and expanding
economic activity would likely amplify these problems in the future, even on their own .41 However,
climate change promises to make reform of the way in which we deal with nonpoint source
pollution and environmental flows an imperative. Heavier rainfall events have been increasingly
common all across the nation, and this trend is expected to intensify in the future.42 In places like
the Northeast, Midwest, and Mountain West , where this effect is expected to be most pronounced, the effect
on water quality will be profound. More intense storms will produce greater erosion and
stormwater runoff, resulting in more nonpoint source pollution in the form of excess nutrients, organic
material, and sediment.43 In the Southwest, drought and increased warming will likely produce more
wildfires,44 which will in turn lead to increased soil erosion and heightened levels of nonpoint
source degradation.45 Warmer temperatures and drier summers will also produce more wildfires in the Northwest.46 In fact,
the amount of land burned by wildfire in parts of western North America is expected to grow by a factor
of two to four for each degree Celsius of global warming ,47 thus significantly increasing nonpoint
source pollution in many of the rivers and streams in the western part of the country." The
Southwest is our hottest region, and it will get even hotter under the impact of climate change. In addition, many areas in the
Southwest have also experienced unusually dry weather, and this is expected only to worsen in the southern half of the region.49
Between increasing evaporative loss due to higher temperatures, less snowpack due to later winters and earlier spring melts, and
less rainfall across broad swaths of the region, the Southwest faces a real threat to the adequacy of its water resources, and its
streams face the prospect of longer low flow conditions and the severe stresses to their aquatic life that follow in the wake of low
flows amid higher temperatures. 5 Other areas, however, are not immune from the problems associated with lengthy dry periods.
All regions, but especially the Northwest and the South, will likely experience longer dry spells. Short-term droughts are projected to
grow worse in most places, but especially in large areas of the Southeast and the southern Great Plains. 51 And everywhere in the
country, the temperature is expected to increase, although more in some areas than others, 52 along with earlier and smaller
snowmelts in the West. 53 Climate change is also expected to increase water use considerably. Withdrawals are projected to rise
twenty-three percent over 2005 levels by the year 2060 due to climate change.54 Seventy-six percent of that increase will be due to
greater demands from irrigated agriculture, because higher temperatures increase evapotranspiration thereby requiring more water
to grow the same crops.5 Although a portion of most water withdrawals are eventually returned to the stream, irrigated agriculture
and the livestock sector actually consume prodigious amounts of water.56 All of this indicates that the U.S. water supply will become
much more vulnerable to shortages in the future. Most of this rise in vulnerability will occur in arid and semi-arid areas, such as
California, the Southwest, the Great Basin, and the central and southern Great Plains. 58 In addition, projected increases in the
acreage devoted to agricultural irrigation in the East 59 may well cause serious problems for instream flow levels in many Eastern
streams, particularly in the Southeast.6 ' This increasing vulnerability to water shortages will exacerbate conflicts over water in the
future as well as increase pressures to mine groundwater and deplete streamflows. 61 There
is still time to adapt the
Clean Water Act and our state and federal water management policies to meet these challenges
before the problems reach crisis proportions. But it will take political courage as well as an increased level of civic
wisdom at all levels of our system. The political obstacles are obvious. Nonpoint source pollution control often generates opposition
from a number of powerful interests, such as the farm lobby.62 In addition, state officials and their supporters frequently assert that
nonpoint source controls are a form of land use planning that ought to remain exclusively in state and local hands.63 Similarly, state
agencies and traditional water users are likely to object to any federal involvement with water matters, including stream flows, that
is perceived to encroach upon the "primary" role of state governments over water management and water allocation.64 The
federal government, however, has strong interests and historic involvement with both water
management and pollution control , and the national perspective must be represented as we
address problems that are truly national in scope . It is time to set aside parochial concerns. The problems
are stark and will grow worse, much worse, unless we summon the will to act in collaborative fashion,
drawing upon the technology and resources of the federal government as well as the specialized
knowledge of state and local governments. We desperately need the synergy that a collective approach would
produce.
That runoff creates aquatic dead zones where life cannot exist
Lennartz 2020 – Department of Agricultural and Environmental Sciences at University of
Rostock
Bernd Lennartz 30th June 2020 “Developing solutions to agricultural runoff and water
contamination” Sustainable Planet https://www.innovationnewsnetwork.com/developing-
solutions-to-agricultural-runoff-and-water-contamination/5887/
Nitrogen- and phosphorus-based fertilisers fuel our agriculture and ensure a stable crop
production. Negative side effects of such an intensive agriculture may, however, compromise
environmental assets, especially soil and water resources. High nutrient concentrations in lakes
and oceans alike boost annual algae blooms with often disastrous consequences. Algae blooms
can be extensive, some of them visible even from space (see Fig. 1). The produced algae biomass
eventually sinks to the seafloor, where its bacterial decomposition consumes oxygen. When the
oxygen is depleted entirely, the sea floor turns into a ‘dead zone’ where it is nearly impossible
for any life to survive. Expanding dead zones as a result of eutrophication processes have been
reported for the Baltic Sea and the Gulf of Mexico alike (van Meter et al., 2018).
The largest one is in the Gulf of Mexico

Erickson and Lyons, 6/3
(Jim and Jennie, “Average-sized ‘dead zone’ forecast for Gulf of Mexico,” 3 June 2021, University
of Michigan, https://news.umich.edu/average-sized-dead-zone-forecast-for-gulf-of-mexico/)
A team of scientists including a University of Michigan aquatic ecologist is forecasting this summer’s Gulf of
Mexico hypoxic area or “dead zone,” an area of low to no oxygen that can kill fish and other marine life, to be
approximately 4,880 square miles, a bit smaller than the state of Connecticut. The 2021 forecasted area is smaller than,
but close to, the five-year-average measured size of 5,400 square miles. However, this year’s predicted dead zone would
still be more than double the long-term goal set by the Interagency Mississippi River and Gulf of Mexico Hypoxia
Task Force, which set a goal of reducing the size of the hypoxic zone to a five-year average measured size of 1,900 square miles.
“Each year, the forecasts are reported to be bigger or smaller than some long-term average, when in fact the long-term average is
not acceptable,” said Don Scavia, professor emeritus at the U-M School for Environment and Sustainability. “Large
reductions
are called for in the federal-state action plans that have been in place for almost 20 years.
Clearly, something different needs to be done in the watershed to actually reduce the nutrient loads and reduce
the size of the dead zone,” said Scavia, who leads one of several research teams partnering with the federal government on the
annual forecasts. The 2021 U-M Gulf of Mexico hypoxia forecast was released today by the National Oceanic and Atmospheric
Administration, which funds the work. This year’s forecasted dead zone is substantially less than the 8,776-square-mile 2017 Gulf
hypoxic zone, which was the largest zone measured since mapping began in 1985. The predictions are based on a suite of models
that incorporate U.S. Geological Survey river flow and nutrient data. “Understanding the effects of hypoxia on valuable Gulf of
Mexico resources has been a long-term focus of NOAA’s research,” said Nicole LeBoeuf, acting director of NOAA’s National Ocean
Service. “These forecasting models inform us of the potential magnitude of the Gulf of Mexico hypoxic zone that might impact living
marine resources and coastal economies.” The annual Gulf of Mexico dead zone is primarily caused by excess nutrient
pollution from human activities in urban and agricultural areas throughout the Mississippi River watershed. When the excess
nutrients reach the Gulf, they stimulate an overgrowth of algae, which eventually die and decompose,
depleting oxygen as they sink to the bottom. The resulting low oxygen levels near the bottom of the Gulf
cannot support most marine life. Fish, shrimp and crabs often swim out of the area, but animals that are unable to swim
or move away are stressed or killed by the low oxygen. The Gulf of Mexico dead zone occurs every summer. River discharge in May
and the associated nutrient load to the Gulf of Mexico has been shown to be a major contributing factor to the size of the dead
zone. In May 2021, discharge in the Mississippi and Atchafalaya rivers was about 2% below the long-term average between 1980 and
2020. The U.S. Geological Survey estimates that this smaller-than-average river discharge carried 90,500 metric tons of nitrate and
15,600 metric tons of phosphorus into the Gulf of Mexico in May alone. These nitrate loads were about 32% below the long-term
average, and phosphorus loads were about 9% below the long-term average. The USGS operates more than 3,000 real-time stream
gauges, 60 real-time nitrate sensors and 38 long-term monitoring sites to measure nutrients in rivers throughout the Mississippi-
Atchafalaya watershed. Data from these networks are used to track long-term changes in nutrient inputs to the Gulf and to help
build models of nutrient sources and hotspots within the watershed. “Recent results from USGS models show that agricultural
sources together are the largest nutrient sources to the Gulf, and that much of that originates in the Upper
Midwest and areas along the Mississippi River. But urban areas, human waste treatment, precipitation and atmospheric dust, and
natural sources also contribute large amounts,” said Don Cline, associate director for the USGS Water Resources Mission Area. While
the hypoxic zone forecast assumes typical coastal weather conditions, the measured dead zone size could be disrupted and its size
changed by major weather events, such as hurricanes and tropical storms, which mix ocean waters, as occurred in 2018, 2019 and
2020. A NOAA-supported monitoring survey, scheduled for later this summer, will confirm the size of the 2021 dead zone and is a
key test of the accuracy of NOAA’s models. This year’s predicted dead zone would be larger than the long-
term goal set by the Interagency Mississippi River and Gulf of Mexico Hypoxia Task Force. The task force strives to reduce the
Gulf dead zone by identifying and implementing collaborative nutrient reduction strategies across the Mississippi River watershed,
and has set a goal of reducing the size of the hypoxic zone to a five-year average measured size of 1,900 square miles. NOAA’s
hypoxia forecast models, together with the USGS’s monitoring of nutrients in rivers, help predict how hypoxia in the Gulf of Mexico
is linked to nutrients coming from throughout the Mississippi River Basin. The task force uses them to help inform nitrogen and
phosphorus reduction targets across the watershed. “The Hypoxia Task Force plays a critical role in managing nutrient loads in the
Mississippi River Basin to reduce over time the size of the hypoxic zone,” said John Goodin, director of U.S. Environmental Protection
Agency’s Office of Wetlands, Oceans and Watersheds. “Through state leadership in implementing nutrient reduction strategies,
support from EPA and other federal agencies, and partnerships with basin organizations and research partners, we will continue to
tackle the challenge of Gulf hypoxia. This annual forecast will continue to inform our collective efforts.” This is the fourth year NOAA
is producing its own forecast, using a suite of NOAA-supported hypoxia forecast models jointly developed by the agency and its
partners—teams of researchers at the University of Michigan, Louisiana State University, William & Mary’s Virginia Institute of
Marine Science, North Carolina State University and Dalhousie University, and the USGS, which provided the Mississippi River
loading data for the models. The NOAA forecast integrates the results of these multiple models into a separate average forecast and
is released in coordination with these external groups, some of which are also developing independent forecasts. NOAA and its
partners continue to develop additional hypoxia forecast capabilities to understand impacts on living marine resources and how
combining multiple modeling approaches can better predict the hypoxic zone.
Biodiversity loss causes extinction – makes life unsustainable

Torres 16 (Phil Torres, Bulletin of Atomic Scientists, Phil is the founder of the X-Risks Institute, an affiliate scholar at the
Institute for Ethics and Emerging Technologies, , “Biodiversity loss: An existential risk comparable to climate change”.
http://thebulletin.org/biodiversity-loss-existential-risk-comparable-climate-change9329)
The sixth extinction. The repercussions of biodiversity loss are potentially as severe as those anticipated from climate
change, or even a nuclear conflict. For example, according to a 2015 study published in Science Advances, the best
available evidence reveals “an exceptionally rapid loss of biodiversity over the last few
centuries, indicating that a sixth mass extinction is already under way.” This conclusion holds,
even on the most optimistic assumptions about the background rate of species losses and the current rate of vertebrate
extinctions. The group classified as “vertebrates” includes mammals, birds, reptiles, fish, and all other creatures with a backbone. The article argues
that, using its conservative figures, the average loss of vertebrate species was 100 times higher in
the past century relative to the background rate of extinction . (Other scientists have suggested that the
current extinction rate could be as much as 10,000 times higher than normal.) As the authors write, “ The evidence is
incontrovertible that recent extinction rates are unprecedented in human history and highly unusual
in Earth’s history.” Perhaps the term “Big Six” should enter the popular lexicon – to add the current extinction to the previous “Big
Five,” the
last of which wiped out the dinosaurs 66 million years ago. But the concept of biodiversity
encompasses more than just the total number of species on the planet. It also refers
to the size of different
populations of species. With respect to this phenomenon, multiple studies have confirmed that wild populations
around the world are dwindling and disappearing at an alarming rate. For example, the 2010 Global Biodiversity Outlook
report found that the population of wild vertebrates living in the tropics dropped by 59 percent between 1970 and 2006. The report
also found that the population of farmland birds in Europe has dropped by 50 percent since 1980; bird populations in the grasslands
of North America declined by almost 40 percent between 1968 and 2003; and the population of birds in North American arid lands
has fallen by almost 30 percent since the 1960s. Similarly, 42 percent of all amphibian species (a type of vertebrate that is
sometimes called an “ecological indicator”) are undergoing population declines, and 23 percent of all plant species “are estimated to
be threatened with extinction.” Other studies have found that some 20 percent of all reptile species, 48 percent of the world’s
primates, and 50 percent of freshwater turtles are threatened. Underwater, about 10 percent of all coral reefs are now dead, and
another 60 percent are in danger of dying. Consistent with these data, the 2014 Living Planet Report shows that the
global population of wild vertebrates dropped by 52 percent in only four decades – from 1970 to 2010. While biologists often avoid
projecting historical trends into the future because of the complexity of ecological systems, it’s tempting to extrapolate this figure
to, say, the year 2050, which is four decades from 2010. As it happens, a 2006 study published in Science does precisely this: It
projects past trends of marine biodiversity loss into the 21st century, concluding that, unless
significant changes are made to patterns of human activity, there will be virtually no more wild-
caught seafood by 2048. Catastrophic consequences for civilization. The consequences of this rapid pruning
of the evolutionary tree of life extend beyond the obvious. There could be surprising effects of biodiversity
loss that scientists are unable to fully anticipate in advance . For example, prior research has shown
that localized ecosystems can undergo abrupt and irreversible shifts when they reach a tipping
point. According to a 2012 paper published in Nature, there are reasons for thinking that we may be
approaching a tipping point of this sort in the global ecosystem, beyond which the
consequences could be catastrophic for civilization. As the authors write, a planetary-scale transition
could precipitate “substantial losses of ecosystem services required to sustain the human
population.” An ecosystem service is any ecological process that benefits humanity, such as food production and
crop pollination. If the global ecosystem were to cross a tipping point and substantial ecosystem services
were lost, the results could be “widespread social unrest, economic instability, and loss of human
life.” According to Missouri Botanical Garden ecologist Adam Smith, one of the paper’s co-authors, this could occur in a
matter of decades – far more quickly than most of the expected consequences of climate change,
yet equally destructive. Biodiversity loss is a “threat multiplier ” that, by pushing societies to the brink of
collapse, will exacerbate existing conflicts and introduce entirely new struggles between state
and non-state actors. Indeed, it could even fuel the rise of terrorism. (After all, climate change has
been linked to the emergence of ISIS in Syria, and multiple high-ranking US officials, such as former US Defense
Secretary Chuck Hagel and CIA director John Brennan, have affirmed that climate change and terrorism are connected.) The reality is
thatwe are entering the sixth mass extinction in the 3.8-billion-year history of life on Earth, and the impact of
this event could be felt by civilization “in as little as three human lifetimes ,” as the aforementioned 2012
Nature paper notes. Furthermore, the widespread decline of biological populations could plausibly initiate
a dramatic transformation of the global ecosystem on an even faster timescale: perhaps a
single human lifetime. The unavoidable conclusion is that biodiversity loss constitutes an existential
threat in its own right. As such, it ought to be considered alongside climate change and nuclear
weapons as one of the most significant contemporary risks to human prosperity and survival.
Federal intervention is key to eliminate manure lagoons


In building larger national support for change, it is important to show that CAFOs also have
negative effects on the economic and social interests of individ-uals located far from the
facilities themselves. Both lagoon-stored manure and poultry waste (which contains carcasses
and bedding in addition to manure) are frequently applied to agricultural fields.71 Fields where
manure has been applied excessively are significant sources of surface runoff that contaminate
drinking water, kill fish and other aquatic life, and produce dangerous levels of algae growth.72
Excess nutrients from the Mississippi Watershed have been linked to the record-setting 2018
Florida red tide, which lasted for more than a year. Estimates of the direct economic and health
effects of such algal blooms are tens of millions of dollars annually. The hypoxic (dead) zones in
the Gulf of Mexico and the Chesapeake Bay have been directly linked to industrialized animal
pro-duction and the resulting nitrogen, phosphorus, and ammonia runoff. The tourism industry,
which is critical to many state economies, suffers losses of nearly $1 billion a year due to the
disruption of fishing, boating, and other aquatic recreational activities due to algal blooms and
other consequences of nutrient pollution.75 As the effects of climate change worsen, these
environmental effects and their resulting economic impacts will worsen as well. The 2017 North
Atlantic hurri-cane season was the most expensive on record, with more than $300 billion in
estimated economic losses.76 Severe flooding in 2019 prevented timely planting for millions of
acres and caused billions of dollars in damages; meanwhile, the National Oceanic and
Atmospheric Administration reported 200 more tornados than are typical for the first half of the
year.77 As the sea level rises and weather events become more unpredictable and extreme, so-
called “hundred-year floods” will become more common, with more manure lagoons
overflowing and more nutrient runoff. Simultaneously, rising temperatures and an increasing
global population will increase the demands on clean drinking water and other resources.
Contrary to the current official positions of the EPA and the USDA,78 voluntary “market-based”
conservation approaches are not sufficient to address nutrient runoff and declining water
quality now, let alone as the problems con-tinue to worsen. Strangling corporate control,
combined with worsening environmental realities, create the perfect storm—one that state and
local action alone are unable to address. Comprehensive federal intervention, both legislative
and regulatory, is necessary to preserve the way of life that rural Americans value for
themselves and their children.
Solvency
Federal action is key – establishing permit requirements is key to overcome
regulatory inconsistencies at the state level
Devine 2019 - Director, Federal Water Policy, Water Division, Nature Program
Jon Devine September 23 2019 “How the Clean Water Act Can Combat Harmful Algal Blooms”
https://www.nrdc.org/experts/jon-devine/how-clean-water-act-can-combat-harmful-algal-
blooms
The Problem: Nitrogen and Phosphorus Runoff Fuel Water Quality Problems The first report is an important effort to track states’
access to, and efforts to make public, information about industrial livestock facilities, known in the Clean Water Act as “concentrated
animal feeding operations,” or “CAFOs.” As my colleague Valerie Baron discusses, our report documents the numerous harms that
livestock operations can inflict on nearby communities, and the resulting need for pollution control officials to have adequate
information to properly regulate the facilities’ management of manure and the nitrogen and phosphorus it contains. Unfortunately,
as we found, the available information about these operations is out of date, grossly incomplete, and highly variable from state to
state These findings call out for a renewed effort to comprehensively understand—and then control—nutrient pollution from animal
factories. The second release is an overview of how states track and communicate the threats associated with events scientists refer
to as “harmful algal blooms.” Algae are photosynthetic organisms that derive energy from the sun and grow wildly when fed by
nutrients like nitrogen and phosphorus, leading to massive “blooms” of organisms. These blooms are fueled, in part, by fertilizer and
manure runoff from farms and other animal facilities. In some cases, these blooms are just gross—they create a slimy muck that you
don’t want to share the water with. In other cases, when the algae die, the decomposition process sucks oxygen from the water and
causes water bodies to become “hypoxic”; the enormous annual Gulf of Mexico “Dead Zone” is an example of a hypoxic area.
Finally, harmful algal blooms can be dangerous because they produce toxins that are harmful to animals and people. This last algae-
related problem is the subject of the recent analysis, as my colleague Arohi Sharma describes. A Major Solution: The Clean
Water Act Can Slash Pollution that Causes Harmful Algal Blooms Together, NRDC’s findings, along with our
work in these areas over several decades, point to a common denominator: the public officials responsible for
implementing and enforcing the Clean Water Act are not doing enough to test for and prevent
nitrogen and phosphorus pollution. This post describes what effective enforcement of the Clean Water Act might look
like. Numeric Nutrient Standards: One of the foundations of pollution control under the Act is the
establishment of state standards identifying levels of pollutants that, if exceeded, will endanger
water quality such that a water body might not be safe for whatever “designated uses” a state has identified for the water.
(Designated uses include things like fishing, swimming, and drinking water supply.) Numeric standards help permit
writers establish discharge limits for facilities that release these pollutants and they also enable
states to identify when water bodies need to be cleaned up. Nearly two decades ago, EPA
instructed states to develop numeric standards or else the agency would step in, but this proved
to be an empty promise. EPA’s own Inspector General issued a report 10 years ago saying states were falling down on the
job and urged EPA to issue standards itself. But when NRDC and our partners petitioned EPA to do just that and sued to get a ruling
on our petition, EPA furiously fought for its ability to dodge this responsibility and —at least to date—has
managed to defend its do-nothing approach in court . This irresponsibility has consequences: EPA
acknowledges that only one state has a full set of numeric nutrient standards for all of its waters
and expects that, in 2021, the vast majority of states will have no numeric standards or will have standards for
just a smattering of waters. EPA needs to act. The evidence is overwhelming that states either lack the political will or
the technical capacity to establish these critically-needed numeric benchmarks . Enhanced Discharge
Limits for Nutrient Sources: The Clean Water Act charges EPA with establishing industry-specific limits
on their pollution, which are typically based on the control technology used by better-performing facilities in the industry. The
agency must update these limits for industries that have significant nutrient discharges but has failed to do so. Sewage treatment
plants: Human waste contains nitrogen and phosphorus. The facilities that treat our sewage, however, are not subject to national
discharge limits for those pollutants. In fact, when NRDC and our partners petitioned EPA to establish such limits, the agency balked.
(Ironically, despite the widespread lack of numeric nutrient standards for water bodies discussed above, EPA claimed that the better
way to handle nutrient pollution from sewage plants was to set case-by-case limits based on water body-specific standards.) Even
worse, EPA plans to make it easier for wastewater plants to release partially-treated sewage during rainstorms. As 69 conservation
groups told EPA, pursuing this rollback makes no sense given how little evidence the agency has that authorizing increased sewage
blending will not cause harm. Livestock factories: As noted above and in NRDC’s report, CAFOs are poorly understood and even
more poorly regulated today. NRDC and numerous organizations have been calling on EPA to strengthen the national regulations for
many years. These facilities’ direct impacts on communities are reason enough for EPA to act, and the prevalence of harmful algal
blooms makes that need even more acute. Meat processing plants: Slaughterhouses contribute to nutrient pollution and the vast
majority of them are not subject to Clean Water Act limits on their discharges. Others must comply with outdated limits. A coalition
of conservation groups have notified EPA of their intent to sue the agency for failing to modernize these pollution limits. Stormwater
systems: Runoff from suburban and urban areas is typically routed straight to water bodies without any treatment. As my colleague
Cori Bell explains, stormwater systems can be important sources of nutrient pollution; rainfall carries lawn fertilizer and other
sources of nutrients (like nitrogen compounds deposited from the air) into rivers, streams, and other waterways. Although we know
how best to handle polluted stormwater – by using green infrastructure to prevent runoff from reaching water bodies – EPA and
state pollution control officials do not often require systems to implement these commonsense solutions. Meaningful Control of
Agricultural Runoff: The Clean Water Act exempts most discharges from normal farming operations from the Act’s permitting
requirements, but it nevertheless provides significant tools for controlling such pollution. EPA and state officials must implement
these requirements in a rigorous manner if we are to sufficiently rein in nutrient pollution to deal with our toxic algae crisis.
Oversight of nonpoint source management programs : In 1987, in recognition of the importance of agricultural
runoff and other so-called “nonpoint source” pollution, Congress adopted a grant program—contained in section 319 of the Clean
Water Act—to fund projects to reduce that pollution. Projects are supposed to be carried out in accordance with a periodically-
updated nonpoint management plan, formulated by states subject to EPA approval. States must demonstrate satisfactory progress
on reducing pollution to be eligible for funding in subsequent years. According to the Government Accountability Office, EPA’s
oversight of these programs, including their success in making meaningful progress, has been
spotty, and the agency has failed to address a number of identified deficiencies. The agency
should insist on accountability for project performance and on states making significant progress
in reducing runoff pollution to impaired waterways as a condition of providing future funding. Strengthen
requirements for addressing impaired waters : Agricultural pollution is the top known contributor to rivers’ and
streams’ failure to meet applicable standards, and the number two known cause for lakes, ponds, and reservoirs. But when
states develop cleanup targets for impaired waters (known in the wonky Clean Water Act world as “total
maximum daily loads” or “TMDLs”), they do not reliably formulate implementation plans to achieve
necessary reductions or include a strategy to adopt legally enforceable controls on agricultural
pollution. In 2000, EPA adopted regulations to make TMDLs more robust, but they were
withdrawn in response to attacks from agribusiness, among others. EPA should revisit that decision, especially given
the experience with the Chesapeake Bay watershed; in that region, there are enforceable plans, and progress has been more
pronounced. Enforce antidegradation requirements: States are required to protect clean waterways from
becoming impaired. In order to do so, they are required to implement “all cost-effective and
reasonable best management practices for nonpoint source control” when taking action that’ll worsen
water quality. However, I’ve been unable to identify any instance in which this requirement has been enforced, even though EPA
has the authority to reject discharge permits that don’t comply with the regulations. The agency
should do so—it should object to proposed permits for new or expanded nutrient discharges unless and
until the states demonstrate that they’ve put in place a suite of management practices on
existing sources of agricultural runoff.
Status quo permitting makes agricultural permitting optional – reversing this

trend by eliminating runoff exemptions is key
Neeley 2017 – DTN Staff Reporter
Todd Neeley 3/13/17 “Enviros Target CAFOs: Environmental Groups Ask EPA to End Ag
Stormwater Exemption”
https://www.dtnpf.com/agriculture/web/ag/livestock/article/2017/03/13/environmental-
groups-ask-epa-end-ag
OMAHA (DTN) -- Environmental groups are asking the Scott Pruitt-led U.S. Environmental Protection Agency to do
something not even the previous pro-regulation administration would do -- tighten Clean Water Act regulations on
concentrated animal feeding operations. A petition filed with EPA by Food and Water Watch and 34 other
environmental groups, essentially is a wish list that includes regulating all CAFOs as pollution point sources, including the spreading
of manure in fields, runoff from CAFO production areas, and not allowing CAFOs to claim the CWA agriculture exemption for
stormwater discharges. The groups said in the petition EPA's
inaction has led to a patchwork of state laws,
many of which have been ineffective in reducing water pollution. In the petition, the groups ask for the
agency to promulgate new CAFO rules. "This petition paves the way for EPA to finally regulate CAFOs as required under the Clean
Water Act, and explains that allowing
CAFO pollution to continue unabated by maintaining the woefully
inadequate status quo would violate federal law ," Wenonah Hauter, executive director at Food and Water Watch,
said in a statement. "Pruitt's record as Oklahoma attorney general shows that he's only looking out for industry interests, including
the interests of polluting factory farms. But the EPA is legally bound to protect communities from pollution, and we intend to hold
the agency accountable for doing its job." Scott Yager, environmental counsel for the National Cattlemen's Beef Association, called
out the groups' petition in a statement to DTN. "EPA's CAFO regulations have been litigated by these radical environmental groups
throughout the 2000s and they (environmental groups) lost, over and over," he said. "It's frivolous and they are now grasping at
straws simply because they do not like the new (EPA) administrator. Instead of trying to force more regulation, these groups would
be better off spending their time and resources working collaboratively with farmers and ranchers who work diligently to care for
our natural resources." The likelihood of success for the petition may be low, as Pruitt has indicated plans to reduce the regulatory
reach of the agency. For example, the agency announced in recent weeks it was reviewing the waters of the United States, or
WOTUS, rule with the possibility of rewriting the rule. CHANGES REQUESTED Among the relief requested in the latest
petition is for the EPA to establish a system that assumes "certain CAFOs" discharge and are either
subject to national pollution discharge elimination system , or NPDES, permitting or "must rebut the
presumption by demonstrating they do not discharge." The groups also ask the agency to revise
the law so that "no discharges resulting from CAFO activities are exempt as non-point source
pollution." EPA also is asked to revise "certain definitions" in the CAFO regulations and to require all CAFOs to
undertake water-quality monitoring. "EPA's current CAFO regulations are failing to achieve the
mandates of the CWA to permit point source dischargers of pollution, require pollution
reductions based on appropriate technology-based standards, and ultimately eliminate point-
source discharges to navigable waters," the petition said. "The CWA prohibits the 'discharge of a
pollutant' by any person from any point source, unless in compliance with a NPDES permit . Nonetheless, as
discussed supra, EPA's CAFO regulations have failed for decades to reliably bring discharging CAFOs
into the NPDES permitting program." The groups said the only way to reduce runoff from CAFOs is
to require all such operations to obtain NPDES permits. "To do so in a way that is consistent with recent case
law, EPA must establish a presumption that certain operations actually discharge, as opposed to
having the potential to discharge or proposing to discharge, " the petition said. JUDICIAL DECISIONS The groups
point to recent judicial decisions related to CAFOs "undermines" the agency's attempts to regulate such operations through the
NPDES permitting system. In Waterkeeper Alliance v. EPA, the U.S. Court of Appeals for the Second Circuit vacated a requirement for
large CAFOs to apply for permits, or to secure a determination that CAFOs have no potential discharges. "In this case, there is
overwhelming evidence that many CAFOs actually discharge, so an evidentiary presumption to that effect is appropriate and
necessary," the groups argue in the petition. "EPA's own data already reflect much more than the 'rational connection' between the
design, construction, and operation of many CAFOs, and their actual discharges, that would be needed to uphold such a
presumption." The groups allege in the petition that science points to a need for EPA to regulate runoff from production areas and
from fields where manure from CAFOs is spread for nutrients benefits. In addition, they suggest ventilation systems on CAFOs "also
lead to surface water discharges" and should be regulated. "The stated objective of the CWA is not merely to reduce, but to
eliminate pollution discharges to navigable waters," the groups said. "Yet the
current regime essentially allows
CAFOs to determine for themselves whether they are subject to regulation, an approach that
has resulted in wildly inconsistent and inadequate permitting at the state level, along with
widespread unregulated pollution from CAFOs. " The groups point to a 2001 preamble to a proposed CAFO rule
from the agency that said about only 2,500 of the 12,000 CAFOs that "should have applied for permits at the time had done so." The
petition alleges the agricultural stormwater exemption does not apply to CAFOs. "Despite the fact that the
environmental impacts from land application of manure are well known, EPA has adopted an
overly broad reading of the agricultural stormwater exemption that has tied its hands from
regulating much of this CAFO pollution," the group said. "The CWA specifically excludes 'agricultural
stormwater' from the definition of point source, but does not define the term, leaving some
discretion to EPA to interpret the exemption's scope in light of the statutory context."
Uniform requirements flatten out the financial cost of adhering to

environmental standards – that’s key to induce behavior change
NRC 1993 - The National Research Council (NRC) is the operating arm of the United States
National Academies of Sciences, Engineering, and Medicine and is overseen by a governing
board that consists councilors from each of the three Academies. The National Academies of
Sciences, Engineering, and Medicine are private, nonprofit institutions that provide expert
advice on some of the most pressing challenges facing the nation and world
National Research Council, Board of Agriculture (1993) “Policies to Protect Soil and Water
Quality” Soil and Water Quality: An Agenda for Agriculture Washington, DC: The National
Academies Press. https://doi.org/10.17226/2132
Although the opportunities to accelerate voluntary adoption of improved farming systems are great when such approaches also lead
to increased profits, reliance
on voluntary change or market-based incentives alone will not always be
sufficient to achieve the improvements in soil and water quality increasingly demanded by the
public. The Chesapeake Bay Program is an example that shows that voluntary change alone has not
been large enough or fast enough to meet environmental goals . By the year 2000, jurisdictions participating
in the Chesapeake Bay program (Maryland, Virginia, the District of Columbia, and Pennsylvania) are to reduce their nutrient loadings
to the bay by 40 percent. In 1990, a
panel of producers, state agency staff, environmentalists, and
academics assembled by the EPA Administrator William K. Reilly reported to EPA that current efforts would not be
enough to meet the 40 percent goal. The panel concluded that voluntary incentives , at least as implemented in the
past, had not been effective enough and that nutrient loadings were much larger than originally
estimated (Nonpoint Source Evaluation Panel, 1990). The panel recommended that greater regulatory authority was
needed to address agricultural as well as other sources of nutrient loadings to the bay
watershed. The panel recommended that livestock operations, particularly large or intensive operations, or operations that were
planning to expand should be targeted (Nonpoint Source Evaluation Panel, 1990). Although comprehensive data on the production
practices and management systems used by producers are not available, most of the data that were reported and discussed in
Chapters 2 and 3 indicate that producers use a wide range of production practices and that there is wide variability in the degree to
which they refine their management systems. These data suggest that a smaller set of problem farms may well be responsible for a
substantial share of soil and water quality problems. If these producers fail to volunteer to participate in programs to improve their
production practices and management systems, then voluntary programs may not improve soil and water quality enough to meet
public demands. State and Local Legislation The inherent limitations in programs to accelerate voluntary change have led to greater
exploration of nonvoluntary approaches to accelerate adoption of improved farming systems. State and local governments have
increasingly turned to more nonvoluntary approaches to changing farming systems in areas where soil and water quality damages
are severe. Ribaudo and Woo (1991) reviewed state water quality laws that affect agriculture and found that states were adopting a
variety of approaches—including input control, land use controls, and economic incentives—to address water quality problems
caused by agricultural production. Because of water quality concerns, 27 states have adopted laws that could affect farm
management decisions (Figure 4-2). Evaluating the Role for Regulation Regulatory
approaches based on clear
planning or performance standards should receive greater attention to achieve more permanent
protection in areas where soil and water quality degradation is severe and for problem farms that are
unacceptably slow in implementing improved farming systems. Regulatory approaches will be needed to provide
more permanent protection when commodity prices are high, damage to soil and water quality
is severe, and voluntary change does not result in adequate improvements. The arguments against
regulatory approaches are well known and have been stated often. Mandating soil and water quality improvements can be
expensive and ineffective if enforcement is inadequate or costly. Critics also claim that such regulations can potentially imperil
private property rights. Furthermore, regulations might alter the relationships between the farming community and soil and water
conservation agencies by turning the latter into ''police officers" and the former into "lawbreakers" if regulations are not met. Others
express concern that regulations cannot be written in a manner that provides the necessary flexibility to reflect the varying soil and
water resources and farming systems found throughout the United States. At the same time, there
are advantages to
grounding U.S. soil degradation and water pollution prevention efforts on a strong regulatory
footing. Regulatory requirements can clearly state the objectives that a producer must meet and
can be applied uniformly to all landowners and operators whose actions might degrade soil and water resources. If
the producer meets certain standards, then compliance can be the basis for providing other
benefits. Clearly defined planning or performance standards can provide the foundation on
which other programs—including educational programs, programs that provide financial incentives, and cost-sharing
programs—can be based. Perhaps the most important benefit offered by using a regulatory approach
is the promise of permanence. If landowners or operators are required to meet soil and water quality
standards, these standards will apply in all circumstances regardless of changes in market prices,
ownership of the land, production systems, the structure of the farm enterprise, or the goals of the producer. The recognition of the
value of including a regulatory approach in U.S. soil and water quality policies is not recent, as seen by the fact that the model state
conservation law, on which all state enactments were originally based, included as a major component of the legal powers of the
districts the power to implement land use regulations to protect soil and water quality. Although the history of the use of that
authority by districts has been limited, there is growing interest in using regulations, as reflected in the innovative approaches being
developed at the district level in many states. Likewise, the importance of regulatory methods for delivering and enforcing soil
conservation policies has long been recognized and debated in the scholarly discussion of soil and water quality policy. Implications
of the Structure of Agriculture for Regulation The processing of many agricultural crops and most livestock is increasingly
concentrated in a few firms (Barkema et al., 1991). Poultry is the most highly concentrated sector, and indications are that the hog
industry is following the same processes of consolidation as the poultry industry (Barkema and Cook, 1993). It is probably not
coincidental that the sectors of agriculture showing the most concentration are those that are not provided risk and income
protection in federal agricultural price support and supply control programs. In many cases, these firms contract directly with
producers to provide crops and livestock. These contracts can specify, often in detail, the quality of the harvest required and, in
some cases, the production practices that must be used. This verticalintegration of contracted producers with
processors has transferred substantial influence over the management of crop and livestock
enterprises to processors. The changing structure of agriculture suggests that regulation may
increasingly be directed at processors and may seek to influence producers through their
contracts with processors. Poultry processors, for example, could be required to specify
requirements for the disposal and use of poultry manure in their contracts with poultry producers. If
regulation required that whoever owned the poultry was to be responsible for appropriate manure disposal, then the liability
for environmental damage would move from the individual poultry producer to the processor .
Producer contracts would of necessity be altered to address the disposal problems associated with manure and dead poultry. Many
individual producers could be affected by regulations directed at a handful of firms in agricultural sectors that are highly
concentrated and integrated. Furthermore, there
would be incentives for processors to develop low-cost
manure disposal alternatives. If the regulation covered the entire poultry sector, no one
processor would be placed at an economic disadvantage to another . Although poultry prices might rise,
depending on increased processor costs, consumers would be making choices based on prices that better represent the true social
costs of poultry production. Similar regulation might be addressed toward other sectors of agriculture that evidence high rates of
concentration.
CAFOs
CAFOs  Antibiotic Resistance
CAFOs also cause anti-biotic resistance
Fiut and Urbaniak 16 – Professors at University of metallurgy and mining in Krakow
Ignacy and Marcin, “Factory Farming Versus Environment and Society. An Analysis of Selected
Problems,” Problems of Sustainable Development, Vol. 12, Iss. 1, pp. 143-156,
http://www.ekorozwoj.pol.lublin.pl/no21/s.pdf
Factory farms base their activity on using huge amounts of pesticides, synthetic fertilizers and
antibiotics, which threatens the health of workers and dwellers from the areas surrounding a
farm, as well as the health of consumers, because it is one of the main sources of oncological
diseases, circulatory system diseases, diabetes and obesity. The outbreaks of these diseases occur especially in the
countries of core states, more seldom in the countries of semi-peripheral areas – using the terms of Immanuel Wallerstein. As we
can read in the American Report of the Pew Commission on Industrial Farm Animal Production , one of the most serious
unintended consequences of industrial food animal production is the growing public health
threat (...) Industrial food animal production facilities can be harmful to workers, neighbors, and even those living far from the
facilities through air and water pollution, and via the spread of disease (A Report…, 2008). Farms and barns housing
thousands of animals crowded in a closed area are often the habitat of serious diseases, which
leads to the administration of irrational, preventive amounts of antibiotic s, which are to stave off a
disease, not to heal animals. Farmers discovered, that adding a small amount of antibiotics to fodder for pigs significantly affects the
tempo of their growth (Lymbery, 2015, p. 148). As a result pigs are
fed with huge doses of penicillin – which may
lead to the progression of new type of bacteria resistant to this drug . In some indefinite point of
future, the tuberculosis infection, pneumonia, typhoid or sexually transmitted disease can
cause an epidemic on the scale of the 14th century extermination , which was triggered by the bacteria of
bubonic plague. All the worse, the afore-mentioned plague bacteria became immune to newer
antibiotics in last twenty years (see: Welch et al., 2007), while salmonella bacteria constantly immunizes against
remedies, posing a lethal danger for people. Although megafarms are the place of disease
incubation, and preventive larding of farm animals all over the world with antibiotics implicates
fatal effects for the public health, (…) factory farming supports pharmaceutical industry, for which more pigs mean more
earned money (Lymbery, 2015, p. 306). Keeping uncountable amount of hens in battery caged farms
results in the outbreaks of newer and newer mutations of avian flu. On the other hand, estrogen and
xenoestrogen are used for poultry fatting, increasing the bulk of chicken meat by accumulating in their breasts. Later, these juicy
chicken breasts are served in millions restaurants and sold in shops all over the world. The problem is that estrogen brings about
men’s infertility. The consequence of increasing estrogen concentration to the suprapsychological level can be changing functions of
many systems, including the male reproductive system (Czupryńska, 2007, p. 323). The author goes on: Reportedly, certain
pharmaceuticals with estrogen or testosterone are still being used during beef cattle growing in the United States, and the
percentage of big farms, which use hormones to boost the gain of muscle mass of animals, is described as 99%. Part of hormones,
which was not metabolized in tissues, get through the soil along with the faeces, and then to rivers as well, inducing hormonal
changes among living organisms, especially fish. Xenoestrogens found in meat are also connected with farming. (…) Meat contains
estrogen esters of fatty acids, which are metabolites of estrogens and can be the source of hormonally active substances, especially
after oral administration (Czupryńska, 2007, p. 325). Owners of megafarms in China discovered a similar way to quickly increase the
pig size and keeping the meat lean. This method involves the use of a bodybuilding steroid klenbuterol; however, when it is
consumed with pork, it causes serious
cardiological side effects. Thus, eating meat which was bought in a
supermarket or fast-food restaurant carries a high level of risk that we consume either meat
infected by viruses and immunized bacteria, or meat laden with chemicals at the level which is
detrimental for health. The clear example of danger resulting from the consumption of factory
farmed meat from are previous epidemics of bovine spongiform encephalopathy (BSE) and the attacks of
super-resistant bacteria MRSA in pig farms . The neurodegenerative cattle disease BSE appears in the situation, when
plant-eating cows are fed with meat and bone meal (MBM) containing prion proteins. Unfortunately, bovine spongiform
encephalopathy is contagious among different species – beef consumers constantly risk infection, for lethal prions are not destroyed
during cooking or heat treating the beef. MRSA bacteria, which are extremely dangerous and invulnerable to most of the known
antibiotics, are now found outside hospitals – a situation different from the one several years ago. The Soil Association report shows
certain unknown strains of this bacteria have been found in factory pig farms over a decade ago
(and also in cow, sheep, hen and horse meat), though pigs are administered with the biggest amounts of
antibiotics (Nunan, Young, 2007). We know factory megafarming is the basic, extramural source of MRSA
proliferation in Western Europe and North America, but we do not still have the full knowledge
of health dangers, which are carried by MRSA bacteria and its new mutations . Although it seems that
the concentration of animals in closed rooms should theoretically protect poultry and pigs against diseases, in
practice the closed space, together with enormous amount of excrements and chemicals create a suitable environment
for the development of new, aggressive strains of bacteria and viruses. The full scale of the threat to
human health from MRSA on farms is clearly not yet known (...) for the general population there remains uncertainty about the scale
of the danger, although Dutch scientists, including Government scientists, have said that pig-MRSA can also be transmitted between
humans (Nunan, Young, 2007, p. 47). Even more fearful, although fully realistic vision, is the possibility of
emergence of new virus strains resulting from the combination of bird, pig and human viruses . As
Aysha Akhtar rightly pointed out, We don’t need a terrorist to wreak havoc. By confining billions of animals on
factory farms, we have created a worldwide natural laboratory for the rapid development of a
deadly and highly infectious form of the virus (Aysha, 2012). Lethal epidemics remain a serious
threat for us as long as factory farming exists . To sum up, husbandry employing different methods of intensifying
farming is the breeding ground for viral and bacterial diseases, which can be contracted by a man quickly and easily. By
consuming meat from factory farming, we risk a contagion of drugresistant germs, which results
in longer hospitalization and a higher mortality rate of sick people.
CAFOs Manure  Air Pollution
Large concentrations of manure cause airborne illnesses
Livestock Air Pollution
Livestock and their manure pollute our air, too: Manure management alone accounts for 14
percent of all agricultural greenhouse gas emissions in the U.S. Manure emits ammonia, which
combines with other air pollutants, like nitrogen oxides and sulfates, to create tiny (and deadly)
solid particles. We humans then inhale these particles, which can cause heart and lung disease
and are said to account for at least 3.3 million deaths each year globally. Additionally, hog waste
in particular has been called out by people living near CAFOs for its foul smell.
AT Permitting Wont Solve CAFOs
The plan eliminates CAFOs – increasing costs makes concentrated operations
untenable

Despite all the evidence showing that CAFOs are a significant source of environmental harm, with negative repercussions to human
and environmental health far from their physical location, U.S.agricultural policy continues to support the
production of cheap monoculture feed grains while limiting the application of key
environmental laws to agricultural operations .44 These policies allow CAFO production costs to
exclude most environmental externalities and , therefore, to be profitable individually while
extremely damaging, on the whole, both socially and environmentally.45 Although CAFOs are often touted as
models of efficiency due to their use of industrialized processing, integrated supply chains, and economies of scale,
research shows that it is actually federal law and enforcement inaction that have made them
successful.46 U.S. farm policy has subsidized the production of commodity crops so much and for so long that feed crops like
corn and soybeans are frequently sold at market below their cost of production, while exemptions from environmental
laws and enforcement mean that CAFOs are rarely held responsible for the actual costs of the
damage they cause. For instance, nitrogen runoff from agricultural produc-tion in the U nited States has
been estimated to cause more than 12,500 cancer cases annually in addition to costing $157 billion a year due to
contamination of drinking water, negative effects on human health, and environmental
damage.47 This cost is not borne by agricultural producers ; instead, municipal water treatment systems pay
billions of dollars to remove the nitrates or toxic cyanobacteria in affected water, resulting in increased utility bills for residents.
Americans who use groundwater wells for their drinking water must choose between paying to treat their wells, dig new wells, or
buy bottled water, and risking negative health effects that include methemoglobinemia (blue baby syndrome), cancer, and thyroid
disease.49 Because the EPA does not regulate private wells, the bur-den of detecting and treating the problem is placed almost
entirely on private citi-zens.50 In total, these externalized waste and water treatment costs have been estimated to be about $2.55
to $4 per hundred weight for a typical hog CAFO, costs which are currently paid by society at large, whether or not society at large
eats supposedly low-cost U.S. pork.51 Put simply, cheap meat is not actually cheap.
AT Already Regulated
Status quo permitting requirements are inadequate – they only apply after they
have been caught
McGarry 2020 - LLM Student
Declan McGarry August 19 2020 “Nobody is Watching How the Sausage is Made: The Failure to
Regulate CAFOs“ Environmental, Natural Resources, & Energy Law Blog
https://www.lclark.edu/live/blogs/133-nobody-is-watching-how-the-sausage-is-made-the
The CWA is limited in two aspects that allow for CAFOs to escape permitting and regulation
under the NPDES: (1) the CWA does not allow EPA to regulate potential discharges , and (2) the Trump
Administration’s limiting definition of waters of the United States under the CWA. The CWA is limited in that it can only
regulate actual discharges into waters of the United States. No Regulation of Potential Discharges The CWA does
not allow for the EPA to require NPDES permits from every CAFO merely because they have the
potential to discharge. The NPDES program allows for an agency, either EPA or an approved State agency, to set effluent
limitation standards as well as qualitative water quality standards when effluent limitations would be insufficient.10 In 2003, EPA
published a final rule that would have required any CAFO to apply for a NPDES permit, unless they were able to secure a
determination from the director of the relevant permitting authority that there was no potential for discharge.11 This regulation
reflected the reality that CAFOs are far more likely than not to have some sort of discharge. However, in Waterkeeper Alliance. v.
EPA, the Second Circuit held that this requirement exceeded EPA’s authority under the CWA.12 The court held that EPA’s
authorization in the CWA to issue NPDES permits for discharges is limited only to point sources that discharge, not ones that may
discharge.13 Discharges require that waste exit a point source into a water of the United States, case law has extended the
definition of discharge to include situations where point source stops short of reaching the water directly but effectively reach
water. CAFOs while a point source can only be regulated when they are discharging directly into
waters of the United States. CAFOs generally spray the waste on fields which can cause runoff or
seep into ground water but is not directly sprayed into waters , this means that despite their
point source status the wording of the CWA does not allow for direct regulation of every
CAFO. The Fifth Circuit extended this logic of the Second Circuit when it evaluated EPA’s 2008 revision of the stricken
2003 regulation. The 2008 revision called for any CAFO that proposed to discharge to apply for an NPDES permit; however, the Fifth
Circuit found this too exceeded EPA’s authority under the CWA.14 The
CWA does not allow for EPA to require
CAFOs to apply for an NPDES permit merely because the CAFO thinks it might discharge . This
ruling effectively means that CAFOs can only be regulated after they are already caught
polluting in the waters of the United States. Constraining the Definition of Waters of the United States The
definition of waters of the United States has a further limiting effect on the EPA’s jurisdictional reach under the CWA. The Trump
Administration proposed regulation would limit the definition of waters of the United States to eliminate any non-perennial streams.
15 This means that any CAFOs that would be discharging into seasonal or intermittent streams would not be covered under the CWA
even if the waste reaches traditionally navigable waters of the United States. This would require EPA to take the further step after
investigating whether or not a CAFO discharged into a water to ensure that receiving water is one covered under the CWA even if it
is a tributary of traditionally navigable waters. This limiting definition of waters of the United States coupled with EPA’s
inability
to regulate potential discharges will likely result in many CAFOs taking the risk of getting caught
as it is difficult for EPA to upkeep investigations on CAFOs especially unpermitted CAFOs.
CAFOs  ABR
CAFOs create antibiotic resistant diseases
Pfankuch 2019 – South Dakota News Watch
Bart Pfankuch “Human health, environmental and antibiotic concerns follow CAFO
development” https://www.argusleader.com/story/news/2019/12/16/human-health-
environmental-and-antibiotic-concerns-follow-cafo-development/2662208001/
The National Association of Local Boards of Health said in a 2010 report that antibiotic use in
animal feed has increased as more animals are being raised in CAFOs. Farmers use antibiotics in
feed to keep animals healthy and to prevent potentially disastrous infections and die-offs of
large numbers of animals kept in confined areas. In the report “Understanding Concentrated
Animal Feeding Operations and Their Impact on Communities,” which was sanctioned by the
federal Centers for Disease Control and Prevention, researchers found that 70% of antibiotics
used annually in America were given to beef cattle, hogs and chickens in their feed at the time
of the study. Furthermore, the researchers noted that nearly half of those antibiotics are the
same as those used to treat human illnesses. They found strong evidence that antibiotics in
animal feed are transferred to humans and leading to a growing number of antibiotic-resistant
organisms. “Resistant strains of pathogenic bacteria in animals, which can be transferred to
humans through the handling or eating of meat, have increased recently,” the report noted.
“This is a serious threat to human health because fewer options exist to help people overcome
disease when infected with antibiotic-resistant pathogens. The antibiotics often are not fully
metabolized by animals, and can be present in their manure . If manure pollutes a water supply,
antibiotics can also leech into groundwater or surface water.”
Scientific consensus
Michalek et al 2016 – Pre-Veterinary Sciences
Jessica Michalek, Pre-Veterinary Sciences John McCluskey, Plant and Soil Sciences Kelsey
Beauregard, Natural Resource Conservation “IMPACT OF ANTIBIOTIC USE IN CONCENTRATED
ANIMAL FEEDING OPERATIONS ON HUMAN HEALTH” APRIL 20, 2016
https://blogs.umass.edu/natsci397a-eross/impact-of-antibiotic-use-in-concentrated-animal-
feeding-operations-on-human-health/
Salmonella is a disease that is becoming increasingly more common and dangerous . A young boy
named Noah Craten was just 18 months old when he was infected with salmonella. This particular strain of salmonella was antibiotic
resistant and very difficult to treat. He had to be hospitalized and undergo brain surgery due to a large mass of blood forming in his
brain that nearly killed him. He had a line placed directly in his heart and received antibiotics for seven weeks in order to save his
life. As a result the left side of his face now sags and he has a permanent scar on the top of his skull. He also has cerebral spinal fluid
in his brain that must be monitored frequently by a physician. This boy suffered greatly and he is not the only one. This particular
salmonella outbreak led to double the normal hospitalization rates due to the antibiotic resistance (Terry, L., 2015). The
effects
of foodborne diseases are already serious. In the United States alone, salmonella species infections
are responsible for about 1.4 million illnesses, 15,000 hospitalizations and 400 deaths annually
(Voetsch et al., 2004). Increased prevalence of a multidrug resistant type of salmonella has been
found, this poses a major health concern to humans as it is making it harder to treat (Aarestrup et al., 2007). This
type of salmonella is an uncommon cause of salmonella in humans worldwide, however in recent years this type now ranks among
the most frequently identified salmonella type in several countries. It was the fifth most common type isolated from retail meat in
the United States (Aarestrup et al., 2007). This shows that the acquired drug resistance of salmonella enabled it to survive in new
environments. There was a reported increase in the proportion of human infections from this type of salmonella in Thailand, from
0% in 1992 to 2.4% in 2001 (Aarestrup et al., 2007, p. 726). This is significant as it shows an increase
in both prevalence
and potency of a bacteria due to drug resistances , and it is a prime example of how antibiotic
resistance enabled a once irrelevant type of bacteria to become strong enough to pose a threat
to human health. Noah Craten was infected with salmonella from a package of Foster Farms chicken raised on concentrated animal
feeding operation (CAFO). When we think of farms we tend to imagine a lot of land and animals grazing. This is not the case for
CAFOs. CAFOs are operations where large groups of animals are fed specific diets and not grazing on the land. These operations
must have thousands of animals to be considered concentrated. A poultry CAFO would have
over 82,000 animals on site
and a swine operation would have over 2500 animals (“Natural Resources Conservation Service”, n.d.). These
operations have incredibly large numbers of animals going through them and all these animals
are fed a specific diet chosen by the producer. The main goal of these operations is to produce large animals to sell
for slaughter. Since CAFOs have such a high volume of animals the animals are more likely to get
sick. In order to avoid this, producers put subtherapeutic levels of antibiotics in the animals feed. Feeding
subtherapeutic levels of antibiotics means that the producers are not using them to treat an illness, but to
promote growth and production in the animals (Gunther, 2013). When you treat an animal with low
levels of antibiotics it wipes out all the weak bacteria but the levels are not high enough to
destroy the stronger bacteria. This leads to us selecting for only the strongest bacteria that are
naturally resistant and will pass their genes on (Nowakowski, 2015). This is a problem that can affect everyone in some way
regardless of whether or not you eat meat. CAFOs
have been found to create antibiotic resistance . One
study tested over thirty different CAFOs for nine different antibiotic resistant genes and
resistance was found at all locations (Brooks, Adeli, and McLaughlin, 2014). Another study sampled retail ground meat
and found 84% to be resistant to at least one antibiotic and 53% to be resistant to at least three (White et al., 2001, p. 1148). A third
study found bacteria that is not only resistant to the average antibiotic, but is also cross resistant to an antibiotic used as a last resort
to treat multidrug-resistant infections (Chapin, Rule, Gibson, Buckley, and Schwab, 2005). They also tested for resistance of different
antibiotics, some that are used in the swine industry and one that is not (Chapin et al., 2005). Their results show that CAFOs do
indeed create antibiotic resistance because the antibiotics used in CAFOs had resistance whereas the antibiotic that was not used
had no resistance (Chapin et al., 2005, p. 139). One final example of antibiotic feed leading to resistance is the use of a class of
antibiotics, in poultry, which led to the development of resistant strains (Cronin, 2013). Previously, this class of antibiotics were not
used by CAFOs and there was not resistance found; however, once CAFOs began using them, they found resistance (Cronin, 2013).
There is a consensus among scientists that CAFOs create antibiotic resistance. CAFOs are not
only creating antibiotic resistant bacteria but they inevitably spread it to the human population.
Transfer occurs in multiple different ways including through meat and the environment. Samples of ground meat tested positive for
different strains of salmonella and antibiotic resistance. Five different strains of salmonella were identified in the meats that are
resistant to nine different types of antibiotics (White et al., 2001). If someone eats this meat and the salmonella is not killed they
would get very sick with an antibiotic resistant bacteria. This bacteria is difficult to treat and may not respond to a simple round of
antibiotic treatment. These meats all came from different CAFOs and had been processed at different slaughterhouses showing that
this is a widespread problem (White et al., 2001). It is not just one or two operations causing the problem it is the whole system of
feeding antibiotic feed. Research was done to test the quality of air inside a swine CAFO. They found that there were very high levels
of antibiotic resistant bacteria inside the operations themselves (Chapin et al., 2005). Research further proved this by comparing
levels of antibiotic resistant bacteria inside the CAFO to areas upwind from the facility; they found concentrations of multidrug
resistant bacteria to be 2.1 times higher inside the facility (Gibbs et al., 2006, p. 1034). This means that people who work in the
facility are exposed to these high levels of resistance everyday and could easily transmit an antibiotic resistant strain to people
outside the facility. Inhalation of these bacteria could lead to the sick person having almost no treatment options (Chapin et al.,
2005). These multidrug resistant bacteria are not just found inside the operations, they are also found in the air around the facility
and affect the nearby communities. It was found that the same high concentrations of multidrug resistant bacteria can be found 150
meters downwind of the facility (Gibbs et al., 2006). The antibiotic resistance can truly affect anyone. Not eating meat does not
protect you from exposure to antibiotic resistant bacteria. The United States needs to enforce bans on antibiotic feed used in
livestock operations, especially restricting the use of antibiotics that are vital to human medicine. It is important to monitor our
levels of antibiotics and what we are using them for. The United states currently does not keep records on antibiotic usage so
farmers are not being held responsible for what they use. In order to get a handle on our antibiotic use we need to ban the
subtherapeutic use of antibiotics and even regulate what antibiotics are given to livestock to treat diseases. It would be best to use
ones that are not common in human medicine. Most importantly the United States needs to track its usage in order to make a
difference. In Europe antibiotic resistance has already been noticed and steps have been taken towards fixing it. Denmark in
particular has made huge strides in reducing their antibiotic resistance and the United States should follow their lead. The use of
antibiotic feed in CAFOs leads to more antibiotic resistant bacteria being spread and adopting the same standards as Denmark will
help protect human lives in the United States. Denmark is the world’s leading exporter of pork and they banned all subtherapeutic
uses of antibiotics in swine by 1999. Since these bans they have found significant decreases in levels of antibiotic resistant bacteria
(Levy, 2014). “From 1992 to 2008, antibiotic use per kilogram of pig raised in Denmark dropped by more than 50%. Yet overall
productivity increased. Production of weaning pigs increased from 18.4 million in 1992 to 27.1 million in 2008” (Levy, 2014, para.
15). They did not just ban the use of antibiotics for growth promotion, but also limited their use for disease prevention (Charles,
2012). While cost of raising these animals has gone up by about $1.14 the animals have lower disease rates and more efficient
production (Levy, 2014, para. 16). Human health should be prioritized over economic gain. Denmark closely regulates the amounts
of antibiotics used and the types given to the animals. Despite all of the scientific consensus on antibiotic resistance and how it poses
a serious problem for humans humans, there are still some concerns that should be addressed. One major concern is if the use of
antibiotics is stopped then the cost of meat will increase. In 1999 it was estimated that it would have cost CAFOs $45.5 million if the
drug use was banned (PBS, 2014, para. 18). However, this is including their profit, not all of that would be passed on to consumers.
Also, feed that does not contain antibiotics costs 1 penny less per chicken, with the cost also being less in other animals (Parsons,
2007). Unfortunately, the American people may need to accept that they will have to pay a bit more for their meat in order to
properly take care of their health like Denmark has. Denmark also managed to increase their production using their new system and
the same could happen in the United States (Levy, 2014). If no change occurs, drug resistance will become more of a problem then it
already is and we will be unable to find cures for our sickness, which would result in families spending hundreds if not thousands of
dollars trying to find an answer to the sickness. A second concern of sceptics is the ever growing demand for more food. Ultimately,
the use of antibiotics in feed only leads to about a 3 percent increase in size of the animals, which is really not substantial (PBS,
2014). As stated previously, Denmark is still the lead exporter of pork despite banning all subtherapeutic antibiotic use. CAFOs first
came into existence in the 1970’s by chicken producers and were created so they could have a large number of animals and
decrease production costs (History of CAFOs, 2011). However, we do not need them in order to produce enough animals to feed our
population. Denmark evolved their way of farming so that they could still produce large amounts of pork for the population. So,
despite popular belief antibiotic feed is not the answer to how we will feed the growing population. Another concern to address is
people wondering how we will treat sick animals without the use of antibiotic feed. This is actually quite simple to address. The main
concern of antibiotic resistance comes from antibiotic feed, not injections, which is what is used to treat sick animals. Antibiotic feed
is used as a growth hormone and preventative measure, not to treat sickness. As long as the antibiotics are used to treat disease and
this is monitored by a veterinarian to make sure the antibiotics are not misused they can still be used to treat diseases in animals.
One final concern could be whether or not the way Denmark is handling eliminating antibiotic feed and resistance is transferable to
the United States. The answer to that concern is yes, the American people just need to focus their priorities on protecting their
health and their family’s health. Denmark simply changed the way they look at farming. In order to be successful without antibiotic
feed they had to move away from the CAFO style of production. When animals are all kept close together there is a higher risk of
disease spread, therefore they have moved into a more spacious style of farming (Kennedy, 2011). The United States could easily do
this as we have significantly more land than Denmark that we could put towards farming. Instead of containing lots of animals in
small spaces we could allow them to have space and significantly decrease the need for antibiotics in the first place. Antibiotic
resistant bacteria are a major health threat because they make it harder to treat illnesses
caused by these bacteria. CAFOs are closed off, high volume operations and the animals in them are more likely to get sick.
The sub-therapeutic levels of antibiotics which are put into these animals feed has led to an increase in antibiotic resistant bacteria,
this is why the US needs to adopt the same standards as Denmark and ban all sub-therapeutic use of antibiotics in livestock
operations. Doing so will decrease antibiotic resistant bacteria levels and make livestock products safer for humans.
! – disease terminal
Global antibiotic resistance is increasing rapidly – the ability to treat diseases at
all is close to collapsing – ending modern medicine
Fukuda 14 - Assistant Director-General Health Security, World Health Organization
(Keiji, “Antimicrobial resistance: global report on surveillance 2014” April,
http://www.who.int/iris/bitstream/10665/112642/1/9789241564748_eng.pdf?ua=1)
Antimicrobial resistance (AMR) within a wide range of infectious agents is a growing public
health threat of broad concern to countries and multiple sectors. Increasingly, governments
around the world¶ are beginning to pay attention to a problem so serious that it threatens the
achievements of modern¶ medicine. A post-antibiotic era —in which common infections and
minor injuries can kill—far from being an apocalyptic fantasy, is instead a very real possibility for
the 21st century.¶ Determining the scope of the problem is essential for formulating and
monitoring an effective response to AMR. This WHO report, produced in collaboration with
Member States and other partners, provides as accurate a picture as is presently possible of the
magnitude of AMR and the current state of surveillance globally. The report focuses on
antibacterial resistance (ABR) in common bacterial pathogens. Why? There is a major gap in
knowledge about the magnitude of this problem and such information is needed to guide urgent
public health actions. ABR is complex and multidimensional. It involves a range of resistance
mechanisms affecting an ever-widening range of bacteria, most of which can cause a wide
spectrum of diseases in humans and animals. ¶ One important finding of the report, which will
serve as a baseline to measure future progress, is that there are many gaps in information on
pathogens of major public health importance. In addition, surveillance of ABR generally is
neither coordinated nor harmonized, compromising the ability to assess and monitor the
situation.¶ Nonetheless, the report makes a clear case that resistance to common bacteria has
reached alarming levels in many parts of the world indicating that many of the available
treatment options for common infections in some settings are becoming ineffective.
Furthermore, systematic reviews of the scientific evidence show that ABR has a negative impact
on outcomes for patients and health-care expenditures.
Mutating diseases lead to extinction

Darling 12 – astronomer
David, “9 Strange Ways the World Really Might End”, Seattle's Big Blog, 3-18,
http://blog.seattlepi.com/thebigblog/2012/03/18/9-strange-ways-the-world-really-might-end/?
fb_xd_fragment, Washington State University
Our body is in constant competition with a dizzying array of viruses, bacteria, and parasites,
many of which treat us simply as a source of food or a vehicle for reproduction. What’s troubling
is that these microbes can mutate and evolve at fantastic speed – the more so thanks to
the burgeoning human population – confronting our bodies with new dangers every year. HIV,
Ebola, bird flu, and antibiotic-resistant “super bugs” are just a few of the pathogenic threats to
humanity that have surfaced over the past few decades. Our soaring numbers, ubiquitous
international travel, and the increasing use of chemicals and biological agents without full
knowledge of their consequences, have increased the risk of unstoppable pandemics arising
from mutant viruses and their ilk. Bubonic plague, the Black Death, and the Spanish Flu are vivid
examples from history of how microbial agents can decimate populations. But the consequences
aren’t limited to a high body count. When the death toll gets high enough, it can disrupt the
very fabric of society. According to U.S. government studies, if a global pandemic affecting at
least half the world’s population were to strike today, health professionals wouldn’t be able
to cope with the vast numbers of sick and succumbing people. The result of so many deaths
would have serious implications for the infrastructure, food supply, and security of 21st century
man. While an untreatable pandemic could strike suddenly and potentially bring civilization to
its knees in weeks or months, degenerative diseases might do so over longer periods. The most
common degenerative disease is cancer. Every second men and every third women in the
western world will be diagnosed with this disease in their lifetime. Degeneration of our
environment through the release of toxins and wastes, air pollution, and intake of unhealthy
foods is making this problem worse. If cancer, or some other form of degenerative disease, were
to become even more commonplace and strike before reproduction, or become infectious (as
seen in the transmitted facial cancer of the Tasmanian Devil, a carnivorous marsupial in
Australia) the very survival of our species could be threatened.
That risks extinction

Greger 8 – M.D., is Director of Public Health and Animal Agriculture at The Humane Society of
the United States
(Michael Greger, Bird Flu: A Virus of Our Own Hatching, http://birdflubook.com/a.php?id=111)
Senate Majority Leader Frist describes the recent slew of emerging diseases in almost biblical
terms: “All of these [new diseases] were advance patrols of a great army that is preparing way
out of sight.”3146 Scientists like Joshua Lederberg don’t think this is mere rhetoric. He should
know. Lederberg won the Nobel Prize in medicine at age 33 for his discoveries in bacterial
evolution. Lederberg went on to become president of Rockefeller University. “Some people
think I am being hysterical,” he said, referring to pandemic influenza, “but there are
catastrophes ahead. We live in evolutionary competition with microbes—bacteria and viruses.
There is no guarantee that we will be the survivors.”3147 There is a concept in host-parasite
evolutionary dynamics called the Red Queen hypothesis, which attempts to describe the
unremitting struggle between immune systems and the pathogens against which they fight,
each constantly evolving to try to outsmart the other.3148 The name is taken from Lewis
Carroll’s Through the Looking Glass in which the Red Queen instructs Alice, “Now, here, you see,
it takes all the running you can do to keep in the same place.”3149 Because the pathogens keep
evolving, our immune systems have to keep adapting as well just to keep up. According to the
theory, animals who “stop running” go extinct. So far our immune systems have largely retained
the upper hand, but the fear is that given the current rate of disease emergence, the human
race is losing the race .3150 In a Scientific American article titled, “Will We Survive?,” one of
the world’s leading immunologists writes: Has the immune system, then, reached its apogee
after the few hundred million years it had taken to develop? Can it respond in time to the new
evolutionary challenges? These perfectly proper questions lack sure answers because we are in
an utterly unprecedented situation [given the number of newly emerging infections].3151 The
research team who wrote Beasts of the Earth conclude, “Considering that bacteria, viruses, and
protozoa had a more than two-billion-year head start in this war, a victory by recently arrived
Homo sapiens would be remarkable.”3152 Lederberg ardently believes that emerging viruses
may imperil human society itself. Says NIH medical epidemiologist David Morens, When you
look at the relationship between bugs and humans, the more important thing to look at is the
bug. When an enterovirus like polio goes through the human gastrointestinal tract in three days,
its genome mutates about two percent. That level of mutation—two percent of the genome—
has taken the human species eight million years to accomplish. So who’s going to adapt to
whom? Pitted against that kind of competition, Lederberg concludes that the human
evolutionary capacity to keep up “may be dismissed as almost totally inconsequential.”3153 To
help prevent the evolution of viruses as threatening as H5N1, the least we can do is take away a
few billion feathered test tubes in which viruses can experiment, a few billion fewer spins at
pandemic roulette. The human species has existed in something like our present form for
approximately 200,000 years. “Such a long run should itself give us confidence that our species
will continue to survive, at least insofar as the microbial world is concerned. Yet such optimism,”
wrote the Ehrlich prize-winning former chair of zoology at the University College of London,
“might easily transmute into a tune whistled whilst passing a graveyard.”3154
! – disease terminal – AT burnout
Drug resistance overcomes burnout – horizontal gene transfer associated with
drug-resistance enables optimal virulence, which maximizes disease fitness
Schroeder et al 17 – Meredith Schroeder, PhD candidate, Department of Microbiological
Sciences; North Dakota State University, Benjamin D. Brooks, PhD, Department of Electrical and
Computer Engineering; North Dakota State University, and Amanda E. Brooks, PhD, Department
of Pharmaceutical Sciences, North Dakota State University (“The Complex Relationship between
Virulence and Antibiotic Resistance,” Genes, Vol. 8, No. 1, page 39, January 2017,
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5295033/)
Antibiotic resistance, prompted by the overuse of antimicrobial agents, may arise from a variety
of mechanisms, particularly horizontal gene transfer of virulence and antibiotic resistance
genes, which is often facilitated by biofilm formation. The importance of phenotypic changes
seen in a biofilm, which lead to genotypic alterations, cannot be overstated. Irrespective of if the
biofilm is single microbe or polymicrobial, bacteria, protected within a biofilm from the external
environment, communicate through signal transduction pathways (e.g., quorum sensing or two-
component systems), leading to global changes in gene expression, enhancing virulence, and
expediting the acquisition of antibiotic resistance. Thus, one must examine a genetic change in
virulence and resistance not only in the context of the biofilm but also as inextricably linked
pathologies. Observationally, it is clear that increased virulence and the advent of antibiotic
resistance often arise almost simultaneously; however, their genetic connection has been
relatively ignored. Although the complexities of genetic regulation in a multispecies community
may obscure a causative relationship, uncovering key genetic interactions between virulence
and resistance in biofilm bacteria is essential to identifying new druggable targets, ultimately
providing a drug discovery and development pathway to improve treatment options for chronic
and recurring infection.
1. Introduction
Until recently, conventional “antibiotic wisdom” suggesting the presence of a fitness cost
associated with the development of antibiotic resistance that would eventually allow
susceptible species to overtake resistant species was the predominating dogma in infectious
diseases [1]. However, the ever-increasing threat of antibiotic resistant bacteria contradicts
dogma and insinuates that the evolution of resistance may be associated with a fitness
advantage, including enhanced virulence [2,3]. Although virulence has now been directly
related to multidrug resistance in several animal infection models [2], the mechanism of
virulence regulation in this climate of antibiotic resistance remains elusive. This review will
explore the relationship between the mechanisms of acquired antibiotic resistance and
enhanced virulence, a critical link in our war on the emergence of multidrug resistant bacteria.
AT Small Farms Are Worse
CAFOs are uniquely harmful because they produce concentrated areas of
manure – small farms are comparatively better

To produce animal-based protein in the large quantities and at the low prices demanded by the
growing global population, corporations have turned to CAFOs, a method of industrialized
livestock production more similar to factories than to farms. The EPA defines a CAFO as an
animal feeding operation that either has “more than 1,000 animal units confined on site for
more than 45 days during the year” or that “discharges manure or wastewater into a natural or
man-made ditch, stream or other waterway.” An animal unit is equivalent to 1,000 pounds of
live weight, which means “1,000 head of beef cattle, 700 dairy cows, 2,500 swine weighing more
than 55 lbs., 125 thousand broiler chickens, or 82 thousand laying hens or pullets.”19 CAFOs
concentrate thousands of animals in as small a space as possible to allow them to be rapidly and
cheaply converted to protein for human consumption, threatening the surrounding ecosystem
while posing health risks for the workers and untold misery for the animals themselves.20
According to the Union of Concerned Scientists, only five percent of U.S. live-stock operations
are CAFOs, but those nearly 10,000 CAFOs produce fifty percent of U.S. food animals, which in
turn produce more than 300 million tons of manure a year.21 That is twice as much fecal waste
as American humans produce each year; in fact, one of the largest CAFOs can alone produce
more sanitary waste than all the humans in Philadelphia, the fifth most populated city in the U.S.
Concentrating livestock in CAFOs exponentially increases environmental and health risks. As one
report notes, “Pound for pound, pigs produce four times the waste of a human. Consequently, a
single [CAFO] housing 5,000 pigs produces the same volume of raw sewage as a town of 20,000,
but the [CAFO] does not have a sewage treatment plant.”23 If you were, however, to
decentralize those 5,000 pigs across twenty farms, each farm would only need to manage the
waste of 250 pigs, and any unexpected runoff or flooding from the much smaller manure
lagoons would have a less detrimental effect on surrounding watersheds. The same is true for
human health effects. A poultry broiler CAFO with four houses produces about 340 tons of litter
(manure and poultry bedding) each year.24 The concentrated waste in those long, low houses
crowded with chickens creates almost unmanageable ventilation difficulties, resulting in
dangerous working conditions for CAFO employees, who frequently suffer from respiratory
diseases.25
Warming Add On
Restricting CAFOs solves a key contributor to warming

Humanity is facing a critical moment if we intend to address global climate change while there is still
time to do so. The scientific community is united in its understanding of the consequences of
continuing activities as usual: increasing air temperatures, rising sea levels, growing weather instability with more
frequent and more severe disasters, and associated unfavorable effects on the overall habit-ability of the planet for our species.4
International efforts to address climate change have focused on the necessity of reducing greenhouse gas emissions such as carbon
dioxide, methane, and nitrous oxide.5 Of these, reduction of methane is believed to be one of the best ways
to (relatively) quickly make positive atmospheric changes. However, the main source of methane
emissions—agriculture— has not yet been targeted for change the same way that energy,
industry, and transportation sources have .6 In fact, agricultural production, including related
deforestation and other land clearing, is the source of as much greenhouse gas emissions as all of
global industry and more than all sources of transportation combined . Scientists, activists, and journalists have
recently begun highlighting agricul-tural contributions to climate change, noting that “at the present rate, cattle and
other livestock will be responsible for half of the world’s greenhouse gas emissions by 2030.”
Growing the quantity of crops needed to feed the animals raised for human consumption
requires land and forests to be cleared for agriculture, which threatens global biodiversity and
worsens greenhouse gas emissions.9 Additionally, livestock production, particularly the raising of cattle for
beef, is a heavy user of global freshwater, an increasingly stressed resource that is critical for
human survival.10 At the same time, the continuing growth of the world’s pop-ulation means that there is heightened pressure
to produce more food just as rising global wealth means that more people are able to afford to eat meat regularly, something once
reserved for luxury consumption.11 If, as many claim, the benevolent objective of U.S. agriculture is to “feed
the world,” animal-based protein is an extremely inefficient way to achieve that goal. Given the
calories lost in converting feed grains to animal-based protein, if the total number of calories produced on U.S.
farmland to feed animals were used to feed humans directly instead , U.S. agriculture would be
able to feed nearly three times more people than it currently does. Due to these environmental and
nutritional facts, many scientists and environmental advocates have called on consumers to shift their dietary choices to plant-based
protein or, at a minimum, to less resource-intensive animal-based protein. In addition to straining the health of the planet, research
shows that large-scale availability and consumption of cheap animal-based protein and highly processed calorie-dense foods are
devastating to public health.15 Although focus is deserv-edly placed on the 815 million people worldwide who are undernourished,
there are also more than 2 billion who are overweight or obese and are, therefore, at great risk of negative health effects such as
cardiovascular disease, type II diabetes, chronic kidney disease, and cancer, causing millions of otherwise avoidable deaths each
year.16 As one article reports, “Poor diets are responsible for more of the global burden of ill health than sex, drugs, alcohol and
tobacco combined.”
Rural Economies Add On
CAFOs crowd out small farms and decimate rural economies

Meanwhile, the increased industrialization and concentration of U.S. agricul-ture is crowding out
midsized, diversified farms. Based on the 2012 Census of Agriculture, the USDA proudly
proclaimed that ninety-seven percent of all U.S. farms were family-owned, but the report also
showed that more than half of all vegetable and dairy sales came from just three percent of
farms, all large or very large.26 The 2017 Census of Agriculture showed a decline in both the
number and profitability of U.S. farms, with increases only among the very large and very small
farms; the largest farms, representing less than one percent of farms, accounted for thirty-five
percent of all sales. Industrialized agriculture has had a powerful impact on modern farming, as
the upfront capital expenditures required to buy the high-tech equipment, buildings, and
automated systems used to mini-mize inputs and maximize yields (by, for example, tracking
irrigation, planting, and harvest) are out of reach for all but the largest producers.28
These changes have significantly impacted U.S. rural communities: reducing employment
opportunities as farms consolidate into larger and more mechanized operations, swallowing up
less-profitable smaller operations, driving down the wages at the jobs that remain, causing out-
migration of younger generations, and benefiting large national or international agricultural
suppliers to the detriment of small retailers.29 As farms get larger, the percentage of their
income that they spend in their local area decreases significantly. Research has shown that rural
areas with a larger number of diversified livestock producers benefit more eco-nomically than
those with primarily large CAFOs, even if those CAFOs are pro-ducing a larger total number of
animals.31
CAFOs decimate rural economies – causes labor migration


U.S. CAFOs tend to be geographically concentrated; for instance, most hog CAFOs are located in
North Carolina and Iowa, while most poultry CAFOs are in Arkansas and Georgia.38 There are
only about 240 U.S. poultry processing facili-ties, and almost all chickens raised for meat in the
United States are produced within thirty miles of one of these facilities.39 The surrounding
communities, however, do not benefit economically from this consolidation. In fact, research
shows that industrialized agriculture has led to negative economic effects on the U.S. rural
economy, from greater income inequality to decreased employment opportunities.40 Vertically
integrated corporate-controlled supply chains mean that CAFO growers acquire their inputs
(feed, animals, even veterinary services) from distant corporations, not local retailers and
providers.41 Moreover, the types of jobs that are available in these factory farms are inherently
more dangerous to worker health.42 Additionally, the harmful impacts of CAFOs on water and
air quality significantly decrease outdoor recreation, home values and sales (and, therefore,
property tax assessments), and overall quality of life.43
Runoff
Agriculture  Runoff
Agriculture is the primary cause of nonpoint pollution in the US

DeGood 2020 - director of Infrastructure Policy at American Progress.
By Kevin DeGood October 27, 2020 “A Call to Action on Combating Nonpoint Source and
Stormwater Pollution” Center for American Progress
https://www.americanprogress.org/issues/economy/reports/2020/10/27/492149/call-action-
combating-nonpoint-source-stormwater-pollution/
Clean water is an essential element of a healthy and productive society. Unfortunately, federal
water pollution control policy is deficient in two fundamental ways. First, the federal
government does not prioritize combating nonpoint source (NPS) water pollution and polluted
urban runoff.1 Second, the federal government provides insufficient grant funding to state and
local authorities for NPS pollution and polluted urban runoff control, choosing instead to provide
the majority of federal assistance in the form of low-cost financing to municipal wastewater
treatment authorities to improve point source pollution control.
Prioritizing low-cost financing for municipal wastewater point source control—while incredibly
important—has allowed the problem of nonpoint source pollution and polluted urban runoff to
grow over time.2 According to the U.S. Environmental Protection Agency (EPA), NPS pollution
“is the leading remaining cause of water quality problems,”3 and the New Hampshire
Department of Environmental Services found that about half of all water pollution comes from
nonpoint sources.4 Nutrient runoff and sediment from agricultural land is the largest source of
NPS pollution. According to the EPA, more than 80,000 miles of rivers and streams are labeled
as impaired due to nutrient pollution.5 And this estimate certainly undercounts actual
impairment, since only 31 percent of the nation’s streams are tested .6 More than 2.5 million
acres of lakes, reservoirs, and ponds are impaired due to nutrient pollution.7 In addition,
polluted urban runoff is the fourth-largest source of pollution for rivers and streams and the
third-leading source for lakes, ponds, and reservoirs.8
Agriculture is the largest contributor

Altieri and Diaz 19 (Andrew H. Altieri, Department of Environmental Engineering Sciences,
Engineering School of Sustainable Infrastructure & Environment, University of Florida. Robert J.
Diaz, Virginia Institute of Marine Science, College of William and Mary, “Dead Zones: Oxygen
Depletion in Coastal Ecosystems. World Seas: An Environmental Evaluation,” 453–473, 2019,
doi:10.1016/b978-0-12-805052-1.00021-8, WC)
Evidence from around the world suggests that excess nutrient inputs are the leading factor
responsible for the formation of dead zones (Diaz & Rosenberg, 2008; MEA, 2005; NRC, 2000;
Rabalais et al., 2010). Since primary productivity by phytoplankton is typically nutrient limited,
excessive nutrients fuel the high phytoplankton biomass responsible for the microbial
decomposition that depletes oxygen. As a consequence, much of the conservation and
management concern regarding the eutrophication of coastal ecosystems is actually due to the
associated effects of hypoxia (Caddy, 1993; Cloern, 2001; Nixon, 1995). In general, nitrogen is
the limiting nutrient in marine ecosystems, whereas phosphorous is the limiting nutrient in
lower salinity systems (Diaz, Rabalais, & Levin, 2009).
Rivers and terrestrial run-off are the dominant sources of nutrients and organic matter to many
hypoxic coastal ecosystems, but atmospheric deposition and upwelled ocean water can play a
significant role as well (Diaz, Rosenberg, Rabalais, & Levin, 2009; Howarth et al., 1996; Levin et
al., 2009; Rabalais, Turner, & Wiseman, 2002). Septic systems and wastewater treatment plants
can make significant direct contributions, particularly in areas with dense human settlements
(Diaz, Rosenberg, et al., 2009). The availability of nitrogen and phosphorus may also be modified
within a dead zone by both microbial activity and by the redistribution of particles and water by
bioturbators and bioirrigators (Middelburg & Levin, 2009; Zhang & Li, 2010). This balance
between sequestration and release of nutrients from the sediment is dependent on oxygen
concentration, with the potential for feedbacks between oxygen, nutrients, and primary
producers.
While there are natural sources of nutrients and organic matter to coastal ecosystems, such as
erosional products and run-off from terrestrial ecosystems, nutrients have dramatically
increased above natural background levels due to anthropogenic sources which has contributed
to the prevalence of hypoxia (Boesch, 2002; Howarth, Sharpley, & Walker, 2002). For example,
nitrogen inputs from the Mississippi River that feed the Gulf of Mexico dead zone have
increased 20-fold since the late 19th century (Rabalais et al., 2010). Agricultural sources
including excess fertilizer from fields and livestock waste are now the dominant sources of
nutrients and organic matter (Cloern, 2001; Karlson et al., 2002; Nixon, 1995). Additional
anthropogenic sources include effluent from sewage treatment plants and household septic
systems, urban run-off, paper mills, seafood processing plants, and aquaculture pens (Christie &
Moldan, 1977; Diaz & Rosenberg, 2011; Gillibrand, Turrell, Moore, & Adams, 1996; Pearson &
Rosenberg, 1978). mills, seafood processing plants, and aquaculture pens (Christie & Moldan,
1977; Diaz & Rosenberg, 2011; Gillibrand, Turrell, Moore, & Adams, 1996; Pearson & Rosenberg,
1978).
The relative importance of these sources is location-specific, and varies with land-use practices,
regulations, and human densities in the watershed. However, there are two clear trends linking
human activity and dead zone prevalence: a spatial relationship in which hypoxia is more
prevalent near major population centers and watersheds with intensive inputs of nutrients and
organic material, and a temporal relationship in which hypoxia has become more widespread
and severe with the intensification of agricultural practices and an overall increasing rate of
nutrient delivery (Conley et al., 2009; Diaz & Rosenberg, 2008; Rabalais et al., 2002).
Nitrate runoff from agriculture is the largest source of pollution in the Gulf of
Mexico
Swoboda 2015 - Editor, Wallaces Farmer , at Farm Progress Companies based in Irving, Texas
Rod Swoboda January 13 2015 “Farmers Need To Voluntarily Reduce Fertilizer Runoff”
https://www.farmprogress.com/story-farmers-need-voluntarily-reduce-fertilizer-runoff-9-65610
Farm pollution from fertilizer and manure is the source of 70% of the nitrate that is creating a
large hypoxic area in the waters of the Gulf of Mexico, entering from the mouth of the
Mississippi River. The hypoxic or "dead zone" as it is called doesn't have enough oxygen to
support aquatic life. Iowa and Illinois are two of the biggest sources of nitrate and phosphorus
runoff.
Agricultural runoff is one of the primary sources of pollutants in water quality

EPA 2015
Environmental Protection Agency March 2015 “Protecting Water Quality from Agricultural
Runoff” https://www.epa.gov/sites/production/files/2015-
09/documents/ag_runoff_fact_sheet.pdf
The United States has more than 330 million acres of agricultural land that produce an abundant
supply of food and other products. American agriculture is noted worldwide
for its high productivity, quality, and efficiency in delivering goods to the consumer. When
improperly managed however, activities from working farms and ranches can affect water
quality.
In the 2000 National Water Quality Inventory, states reported that agricultural nonpoint source
(NPS) pollution is the leading source of water quality impacts on surveyed rivers and lakes, the
second largest source of impairments to wetlands, and a major contributor to contamination of
surveyed estuaries and ground water. Agricultural activities that cause NPS pollution include
poorly located or managed animal feeding operations; overgrazing; plowing too often or at the
wrong time; and improper, excessive, or poorly timed application of pesticides, irrigation water,
and fertilizer.
Agricultural runoff is the largest contributor to water pollutants – that causes

deadzones in the Gulf of Mexico
Swanson 2013 - reporter for Harvest Public Media, a public radio reporting collaboration that
focuses on agriculture and food production
Abbie Fentress Swanson “What Is Farm Runoff Doing To The Water? Scientists Wade In”
July 5, 20135:17 PM ET https://www.npr.org/sections/thesalt/2013/07/09/199095108/Whats-

In-The-Water-Searching-Midwest-Streams-For-Crop-Runoff
America's hugely productive food system is one of its success stories. The nation will export a projected $139.5 billion in
agricultural products this fiscal year alone. It's an industry that supports "more than 1 million jobs," according to Agriculture
has taken a toll on the environment, especially rivers and
Secretary Tom Vilsack.¶ But all that productivity
lakes: Agriculture is the nation's leading cause of impaired water quality , according to the U.S.
Environmental Protection Agency.¶ Scientists want to get a better sense of how all that agricultural runoff is affecting
water quality. So this summer, three dozen scientists from the EPA and U.S. Geological Survey are wading into some 100 streams,
from Ohio to Nebraska. Their mission: Test for hundreds of pesticides and nutrients used in farming, and check for possible effects
on what's living in the streams.¶ This is the first time scientists have tested for so many chemicals in a whole region's waters or
considered the impact of agricultural runoff on fish, frogs, bugs and algae at this scale. The study is costing the USGS $6 million and
the EPA $570,000.¶ "These aren't the kinds of studies that are done routinely, because they are pretty difficult to do," says USGS
biologist Diana Papoulias. "But we know that some of these chemicals that we're finding in the runoff from the ag fields can affect
[aquatic] reproduction and egg production. Whether they are at the concentrations that can do that or not — we don't know yet." ¶
Some tests being conducted can measure even the tiniest amounts of mercury, livestock hormones and pesticides, including the
weed killer glyphosate — better known by its trade name, Roundup.¶ Farm runoff
has become an even more
pressing concern this year because of the Midwest's extremely wet spring. In between the frequent storms,
farmers had only brief stretches of weather dry enough to apply pesticides and fertilizers. ¶
"Whether we want to blame it on climate change or just variability in the weather conditions, anytime you have these heavier
rainfalls during the spring, after a drier period when you could have got something put in the field, you're going to see, in most
cases, a large amount of runoff," says Bob Broz, a water quality specialist with the University of Missouri Extension. ¶ "It's been
happening for years," he says. "The problem is now we seem to be seeing more of these more
intense rainfalls. And that, in
turn, creates a huge amount of nutrient loss."¶ Nutrients like nitrogen and phosphorus are essential for
growing crops, but they can also trigger algal growth in rivers, lakes and bays. ¶ Because last year's
drought prevented some parched fields from absorbing fertilizers, an extra load of nutrients is
flowing into Midwest waterways and will end up in the Gulf of Mexico . Once there, the
chemicals can threaten aquatic life, says Bob Lerch, a USDA soil scientist.¶ "There's the direct impact on
the aquatic ecosystem," Lerch says. "And then there's the downstream impacts on say, drinking
water, or a reservoir, or a recreational [body of water]."
Manure Lagoons  Runoff
Waste from CAFOs causes runoff that contaminates water supplies – that
creates algae blooms
Cows, pigs, chickens, and turkeys do what all other animals do: poop. In 2012 livestock and
poultry grown in the largest CAFOs in the United States produced 369 million tons of manure, or
almost 13 times the waste of the entire U.S. population, according to an analysis of USDA
figures done by Food & Water Watch. All of that farm animal waste needs to go somewhere. But
CAFOs don’t treat animal waste in the same way we treat human waste, by sending it to a
wastewater treatment plant via a municipal sewer system. Instead, this waste is disposed of by
spreading it, untreated, on land. Operators are supposed to apply only the amount that crops
can use, but in reality, there is often too much manure—so it is applied beyond the ground’s
natural absorption rate, leading to runoff into water sources. To make matters worse, before it
is applied it to land, the manure usually sits on-site in vast manure lagoons that can grow to the
size of a football field. The lagoons contain a toxic stew of antibiotics residue, chemicals, and
bacteria decomposing the waste, a medley that can take on a sickly hue. They’re often unlined
and are prone to overflows, leaks, and spills, often causing the contents to leach into the soil
and groundwater. (Big storms, like Hurricane Florence, which devastated North Carolina’s coast,
make wide-scale spills and contamination more likely.) And once this mixture, chock-full of
phosphorus and nitrogen, gets into a water body, it causes a cascading reaction called
eutrophication, or the destructive overgrowth of algae. Similar problems arise with poultry
waste, which is mostly dry litter, a combination of the birds’ bedding materials (such as
shavings), their feces, and loose feathers, which is stored in exposed, giant mounds. Because
chicken manure contains a higher percentage of phosphorus than other animal manure, it’s also
prone to harming waterways with phosphorus runoff.
CAFOs are a primary source of nitrogen pollution

Ribaudo et al 2014 – an Economist at U.S. Department of Agriculture based in Washington,
D.C.
by Marc Ribaudo, Jeff Savage, and Marcel Aillery July 7 2014 “Managing the Costs of Reducing
Agriculture’s Footprint on the Chesapeake Bay” https://www.ers.usda.gov/amber-
waves/2014/july/managing-the-costs-of-reducing-agriculture-s-footprint-on-the-chesapeake-
bay/
One particularly difficult issue is what to do about confined animal operations. Poultry houses,
dairies, and hog facilities tend to produce more manure than their farm’s cropland can use
agronomically. As a result, there is a tendency to overapply manure nutrients to cropland,
increasing the risk of nutrient losses to the environment. Compounding this problem is that
confined animal operations tend to be concentrated geographically in the watershed , creating
regional ”hot spots” of excess nutrients. As a result, the solution is not simply adopting better
nutrient management practices on cropland. Achieving a farm-level balance of nutrients
requires that excess manure be spread on more land, which may mean moving manure off the
farm, or using it for other purposes.
CAFOs cause nitrogen runoff from overapplication to croplands

D.C.
bay/
* Bay = Chesapeake Bay
Animal operations in the Bay watershed produce roughly 99,400 tons of recoverable manure
nitrogen and 44,200 tons of recoverable manure phosphorus annually, most of which is applied
to available cropland on the source operation (see “Confined Livestock Operations Account For a
Majority of the Chesapeake Bay Area’s Farmland With Applied Manure,” in the April 2014 issue
of Amber Waves). However, confined animal feeding operations often produce far more manure
nutrients than can be used by crops grown on the land managed by the operation. This has likely
led to over-application of manure nutrients in areas of the watershed where animal production
is concentrated and problematic arrangements for storage of surplus manure, with resulting
nutrient losses to the environment. An estimated 17 percent of the nitrogen and 26 percent of
the phosphorus entering the Bay has been attributed to animal operations. Merely requiring
livestock operators to implement improved feed guidelines together with recommended
manure storage and field-level management practices will not adequately address this nutrient
imbalance. Much of the manure will have to be moved to cropland not currently receiving
manure (replacing inorganic commercial fertilizer as a nutrient source) or be used for non-
cropland purposes.
Nutrient Runoff Key
Nutrient runoff from agriculture is the primary driver of harmful algae blooms
Gatz 2020 – Analyst in Environmental Policy
Laura Gatz July 8, 2020 “Freshwater Harmful Algal Blooms: Causes, Challenges, and Policy
Considerations” Congressional Research Service https://crsreports.congress.gov
Scientific research indicates that in recent years, the frequency and geographic distribution of
harmful algal blooms (HABs) have been increasing nationally and globally. Because the impacts
of HABs can be severe and widespread—often with interstate implications—these issues have
been a perennial interest for Congress. While algal communities are natural components of
healthy aquatic ecosystems, under certain conditions (e.g., increased temperatures and nutrient
concentrations), algae may grow excessively, or “bloom,” and produce toxins that can harm
human health, animals, aquatic ecosystems, and the economy. In 2014, a cyanobacterial HAB in
Lake Erie affected the drinking water for more than 500,000 people in Toledo, Ohio. In 2016, a
massive HAB in Florida’s Lake Okeechobee negatively impacted tourism and aquatic life. HABs
have been recorded in every state and have become a concern nationwide. Many types of algae
can cause HABs in freshwater systems. The most frequent and severe blooms involve the
proliferation of cyanobacteria. Some cyanobacteria species can produce toxins—cyanotoxins—
that can cause mild to severe health effects in humans and kill aquatic life and other animals.
HABs can also contribute to deteriorating water quality and ecosystem health. As masses of
cyanobacteria or other algae die and decompose, they consume oxygen, sometimes forming
“dead zones” where life cannot survive. These areas can kill fish and organisms, such as crabs
and clams, and have detrimental economic effects. Scientists widely consider nutrient
enrichment to be a key cause of HAB formation. While nutrients are essential to plants and
natural parts of aquatic ecosystems, excessive amounts can overstimulate algal growth. Sources
include point sources (e.g., municipal wastewater discharges) and nonpoint sources (e.g.,
fertilizer runoff from agricultural and urban areas).
Nutrient runoff from intensive farming practices – causes algae blooms that
decimate marine ecosystems
Nutrient Runoff The climate impacts alone are enough of a reason to wean ourselves off
synthetic fertilizers, but these chemicals have another major environmental downside: nutrient
runoff. Runoff occurs when nutrient-rich material like fertilizer or manure, chock-full of nitrogen
and phosphorous, makes its way into nearby rivers, oceans, and lakes, wreaking havoc on our
freshwater and marine ecosystems. Heavy rains can trigger runoff, as can soil erosion. Here’s
how it works: An excess of nutrients in a water system causes an overgrowth of algae. As algae
then die off, aerobic bacteria decompose them, consuming oxygen in the process and starving
other marine life. Algae overgrowth can also block sunlight, disrupting the ecosystem below that
relies on the sun for energy. The results can be dramatic: Nutrient runoff decimated the once-
thriving Chesapeake Bay, killing off large numbers of the estuary’s fish and shellfish. Each
summer, high levels of manure and fertilizer from the Mississippi River make their way into the
Gulf of Mexico, causing a recurring “dead zone” thousands of kilometers wide. And in recent
years, persistent algal blooms, like red tides that produce toxins, have devastated coastal
communities in Florida, staying long past their typical seasons and killing marine life en masse.
Pollution via runoff (known as agricultural nonpoint source pollution) is the leading source of
harm to water quality for surveyed rivers and streams, the third-largest for lakes, and the
second-largest for wetlands. But stemming it is in our control. Farmers can reduce nutrient
runoff significantly through improved soil health practices like planting cover crops, water
quality practices like planting streamside buffer crops, and by following fertilizer best practices.
Algae Blooms  Dead zones
Algae blooms cause deadzones
Nutrient pollution often triggers major harmful algal blooms. These blooms are more than an
unsightly nuisance, as the algae can produce deadly toxins that can threaten drinking water
safety. Additionally, algae and other aquatic plants that thrive on excess nutrient pollution can
quickly deplete their surrounding waters of dissolved oxygen, which leads to aquatic hypoxia, or
dead zones of water that have insufficient dissolved oxygen to support most aquatic life.9 The
EPA has identified more than 166 dead zones across the country, including in water bodies such
as the Great Lakes, the Chesapeake Bay, and the Gulf of Mexico.
Dead zones Collapse Biodiversity
Dead zones collapse biodiversity
Bryant, 2015
(Lee – PhD from Virginia Tech in Civil and Environmental Engineering, “Ocean ‘dead zones’ are
spreading – and that spells disaster for fish,” 7 April 2015, https://theconversation.com/ocean-
dead-zones-are-spreading-and-that-spells-disaster-for-fish-39668)
Falling ocean oxygen levels due to rising temperatures and influence from human activities such as agrochemical
use is an increasingly widespread problem. Considering that the sea floors have taken more
than 1,000 years to recover from past eras of low oxygen, according to a recent University of California study,
this is a serious problem. Ocean regions with low oxygen levels have a huge impact on aquatic
organisms and can even destroy entire ecosystems . Areas of extremely low oxygen, known as oxygen minimum
zones or “dead zones”, are estimated to constitute 10% and rising of the world’s ocean. This expansion has been attributed to a
warming climate, which increases water temperature, changes ocean circulation, and decreases the solubility of oxygen in sea
water. At the same time fertiliser and pesticide run-off from farming and other human activities leads to rising levels of nutrients
such as nitrogen and phosphorous reaching the sea. Together, these two processes speed up the release of chemicals from ocean
sediments and promote algal blooms. Subsequent algal death and decay result in increased consumption of oxygen in the water. The
result is that other aquatic species such as invertebrates on the seafloor and fish suffocate for lack of oxygen. Due to
circulation and runoff effects, dead zones are especially severe around large cities on the western continental coasts such as the
coast of Peru, and within enclosed or semi-enclosed regions like the Baltic Sea or Gulf of Mexico. Looking to the past What effects
will these changes have? We don’t yet know how great the effects of human-caused climate change will be, nor how much can be
done to try and mitigate the effects on the environment. Even if oceanic oxygen levels rise again, will the world’s ocean ecosystems
be able to recover? The University of California study, published in the Proceedings of the National Academy of Sciences, studies
fossils of over 5,400 sea animals including seed shrimps, molluscs, and brittle stars in order to try and answer this question. By
examining seafloor sediments the researchers
assessed how global warming affected sealife during the
transition from the last ice age to the more-recent interglacial period, between 17,000-3,000 years ago. What the study
found was that within only 130 years the oceans underwent devastating changes that led to complete
collapse of invertebrates on the seafloor. More worryingly, the fossil records show that ecosystem recovery
took at least 1,000 years. So the current growth of dead zones could leave drastic and long-lasting
changes to marine life biodiversity. Climate change caused by human activity has already caused significant environmental
damage over a relatively short time – the vast increase in pollution, ocean acidification, overfishing and deforestation in just the last
50-100 years, for example. However long it takes us to reverse the effects of global warming, if indeed we can, it will likely take
ocean ecosystems many orders of magnitude longer to recover. Headed for collapse? Though microscopic organisms residing in the
ocean and on the seafloor might seem to have little relevance to us, even small
changes in ocean ecosystems can
have enormous effects on the entire ocean food chain , from the smallest bacteria to the largest fish. Any
impact on the creatures higher up in the food chain will have a massive impact on the human
communities that rely on them economically and as a food source. Studies have shown that populations of
mid-water fish such as Pacific hake decreased by up to 60% during periods of low oxygen off the
coast of Southern California. Conversely, numbers of Humboldt squid, which are more tolerant of low-oxygen waters, have increased
significantly in the same location. Even
the fish that can survive in dead zones are not faring well : large
numbers of female Atlantic Croaker have been found to be growing testes-like organs instead of
ovaries, a sexual deformation which causes infertility. Feedback loop Any shifts in ecosystem biodiversity can
lead to a vicious feedback loop: dead zone seafloors turn into biodiversity deserts, where little but
methane- and hydrogen sulphide-producing bacteria survive. Paired with changes in nutrient cycling which result in the release of
nitrogen gas, levels of greenhouse gases being released from the ocean to the atmosphere increase and contribute to further global
warming. To
prevent the possibility of a 1,000-year (or longer) recovery period from a dead zone
seafloor, we need to be much more aware of how the various environmental aspects are
connected. An understanding of how de-oxygenation has affected the ocean in the past and how our actions are affecting the
ocean in the present is critical to either preventing a recurrence or at least minimising effects of what we have already done.
Biodiversity Loss Internal
Biodiversity loss unpredictably cascades – stemming loss is key to maintain
ecosystems
Koumoundouros 2021 - Editorial Assistant and Journalist at ScienceAlert
Tessa Koumoundouros 19 MARCH 2021 “The Threat of Cascading Extinctions on Earth Could Be
Greater Than We Thought” https://www.sciencealert.com/humans-may-be-impacted-by-
ripples-of-cascading-extinctions-sooner-than-expected
In the delicately tangled web of an ecosystem, snapping certain anchor lines can bring the whole
thing tumbling down faster than severing other threads. Now, researchers have found that the
species we see as most valuable and worth protecting often aren't the 'threads' most critical to
maintaining the complex ecological webs we rely on. Ecologist Aislyn Keyes from the University
of California and colleagues used data from three coastal food webs to simulate a dozen
extinction sequences to gain a better understanding of how the connections anchor ecosystem
services and the stability of the entire webs themselves. Ecosystem services are the ways in
which nature contributes to humanity's wellbeing, such as fresh water resources, pollination, or
plants mitigating soil erosion. The contribution of services from insects alone is worth billions of
dollars a year just in the US. These services are interwoven with everything we do. For example,
even financial institutions' investments are highly dependent on ecosystem services, and over
half of all global GDP is thought to depend on goods and services provided by the natural world.
Yet, many of our activities are severing the threads that support these ecosystem services at
random and at an accelerating rate. When the loss of one species cascades into the loss of other
species that once depended on it (secondary extinctions), this creates more threats to the
ecosystem services we rely on. Earlier this month, a team of researchers found support for a
strong connection between rapidly vanishing species diversity and ecosystem services. "These
connections need to be made more visible in assessments of nature's contributions to human
wellbeing in order to fully understand how to manage and protect these benefits to humans,"
urged co-author and ecologist Silvia Ceaușu from University College London. Now, in an effort
towards better understanding these contributions, modeling in the study from Keyes and team
has found "species providing services do not play a critical role in stabilizing food webs -
whereas species playing supporting roles in services through interactions are critical to the
robustness of both food webs and services." This means that ecosystem services are under
greater threat than anticipated because more species support these services than we've
accounted for. And it is a huge problem when it comes to how we prioritize conservation.
"There's not nearly enough money for conservation," explains Keyes. "[The] traditional
approaches that assess ecosystem services might be missing a lot of this stuff. "A lot of
ecosystem service assessments focus on only the species that directly provides the service, but
we know that impacts can cascade through an ecosystem, and so we show that these secondary
extinctions represent an increased vulnerability for services that hasn't necessarily been
considered." The loss of highly connected species has already been shown to cause more
secondary extinctions, at least in grassland ecosystems, and the new study's findings support
this. What's more, not all levels of the ecosystem are as vulnerable to this unraveling effect.
Those at the top of the food chain, like large fish, were more likely to be negatively impacted by
secondary extinctions than those on lower trophic levels, like plants. "Protecting certain species
that are disproportionately contributing to services either by supporting them or directly
providing them can potentially help mitigate any indirect threats," suggests Keyes. "I think this
approach could be a way to better allocate resources to protect multiple species and services."
The researchers caution their model does not yet incorporate many interacting factors - it is only
a first step in understanding the impacts of secondary extinctions. There's also a lot of work to
do to identify key species and their complicated tapestries of interactions in the field, especially
for large-scale interactions. A recent report from the Biodiversity and Ecosystem Services Index
suggested loss of "ecosystem services could be significantly slowed down or even reversed if the
role of biodiversity and its full contribution to economic production were an integrated part of
decisions made by governmental entities, companies, and other stakeholders." Keyes and team
are planning to investigate if the same factors that make food webs more resilient against
extinction also help maintain ecosystem services.
Biodiversity Loss  Extinction
Biodiversity Loss Causes Extinction – Small Losses Cascade
Dirzo et al 2014 - Department of Biology, Stanford University
Rodolfo Dirzo, Hillary S. Young,2 Mauro Galetti,3 Gerardo Ceballos,4 Nick J. B. Isaac,5 Ben
Collen62014 “Defaunation in the Anthropocene” Science 345, 401 (2014)
We live amid a global wave of anthropogenically driven biodiversity loss : species¶ and population
extirpations and, critically, declines in local species abundance. Particularly, human impacts on animal biodiversity
are an under-recognized form of global environmental change. Among terrestrial vertebrates, 322
species have¶ become extinct since 1500, and populations of the remaining species show 25% average decline in abundance.
Invertebrate patterns are equally dire: 67% of¶ monitored populations show 45% mean abundance decline. Such
animal declines¶ will cascade onto ecosystem functioning and human well-being. Much
remains unknown about this “Anthropocene defaunation”; these knowledge gaps hinder our
capacity¶ to predict and limit defaunation impacts. Clearly, however, defaunation is both a
pervasive component of the planet’s sixth mass extinction and also a major driver of global
ecological change. In the past 500 years, humans have triggered a wave of extinction, threat, and
local population declines that may be comparable in both rate and magnitude with the five
previous mass extinctions of Earth’s history (1). Similar to other mass extinction events, the effects of this
“sixth extinction wave” extend across taxonomic group s, but they are also selective, with some taxonomic
groups and regions being particularly affected (2). Here, we review the patterns and consequences of contemporary anthropogenic
impact on terrestrial animals. We aim to portray the scope and nature of declines of both species and abundance of individuals and
examine the consequences of these declines. So profound is this problem that we have applied the term “defaunation” to describe
it. This recent pulse of animal loss, hereafter referred to as the Anthropocene defaunation, is not only a conspicuous
consequence of human impacts on the planet but also a primary driver of global environmental
change in its own right. In comparison, we highlight the profound ecological impacts of the much
more limited extinctions, predominantly of larger vertebrates, that occurred during the end of
the last Ice Age. These extinctions altered ecosystem processes and disturbance regimes at
continental scales, triggering cascades of extinction thought to still reverberate today (3, 4).¶ The
term defaunation, used to denote the loss of both species and populations of wildlife (5), as well as local declines in abundance
of individuals, needs to be considered in the same sense as deforestation , a term that is now readily
recognized and influential in focusing scientific and general public attention on biodiversity issues (5). However, a lthough
remote sensing technology provides rigorous quantitative information and compelling images of
the magnitude, rapidity, and extent of patterns of deforestation, defaunation remains a largely
cryptic phenomenon. It can occur even in large protected habitats (6), and yet, some animal species are able to persist in
highly modified habitats, making it difficult to quantify without intensive surveys. ¶ Analyses of the impacts of global
biodiversity loss typically base their conclusions on data de- rived from species extinctions (1, 7, 8),
and typically, evaluations of the effects of biodiversity loss draw heavily from small-scale
manipulations of plants and small sedentary consumers (9). Both of these approaches likely
underestimate the full impacts of biodiversity loss. Although species extinctions are of great evolutionary
importance, declines in the number of individuals in local populations and changes in the composition of species in a community will
generally cause greater immediate impacts on ecosystem function (8, 10). Moreover, whereas the extinction of a species often
proceeds slowly (11),
abundance declines within populations to functionally extinct levels can occur
rapidly (2, 12). Actual extinction events are also hard to discern, and International Union for Conservation of
Nature (IUCN) threat categories amalgamate symptoms of high risk, conflating declining population and small populations so that
counts of threatened species do not necessarily translate into extinction risk, much less ecological impact (13). Although the
magnitude and frequency of extinction events remain a potent way of communicating conservation issues, they are only a small part
of the actual loss of biodiversity (14).¶ The Anthropocene defaunation process¶ Defaunation: A pervasive phenomenon¶ Of a
conservatively estimated 5 million to 9 million animal species on the planet, we are likely losing ~11,000 to 58,000 species annually
(15, 16). However, this does not consider population extirpations and declines in animal abundance within populations. ¶ Across
vertebrates, 16 to 33% of all species are estimated to be globally threatened or en- dangered (17, 18), and at least 322 vertebrate
species have become extinct since 1500 (a date representative of onset of the recent wave of extinction; formal definition of the
start of the Anthropocene is still being debated) (table S1) (17, 19, 20). From an abundance perspective, vertebrate data indicate a
mean decline of 28% in number of individuals across species in the past four decades (fig. S1, A and B) (14, 21, 22), with populations
of many iconic species such as elephant rapidly declining toward extinction (19).¶ Loss of invertebrate biodiversity has received
much less attention, and data are extremely limited. However, data suggest that the rates of decline in numbers, species extinction,
and range contraction among terrestrial invertebrates are at least as severe as among vertebrates (23, 24). Although
less than
1% of the 1.4 million described invertebrate species have been assessed for threat by the IUCN ,
of those assessed, ~40% are considered threatened (17, 23, 24). Similarly, IUCN data on the status of 203 insect species
in five orders reveal vastly more species in decline than increasing (Fig. 1A). Likewise, for the invertebrates for which trends have
been evaluated in Europe, there is a much higher proportion of species with numbers decreasing rather than increasing (23). Long-
term distribution data on moths and four other insect orders in the UK show that a substantial proportion of species have
experienced severe range declines in the past several decades (Fig. 1B) (19, 25). Globally, long-term monitoring data on a sample of
452 invertebrate species indicate that there has been an overall decline in abundance of individuals since 1970 (Fig. 1C) (19).
Focusing on just the Lepidoptera (butterflies and moths), for which the best data are available, there is strong evidence of declines
in abundance globally (35% over 40 years) (Fig. 1C). Non-Lepidopteran invertebrates declined considerably more, indicating that
estimates of decline of invertebrates based on Lepidoptera data alone are conservative (Fig. 1C) (19). Likewise, among pairs of
disturbed and undisturbed sites globally, Lep- idopteran species richness is on average 7.6 times higher in undisturbed than
disturbed sites, and total abundance is 1.6 times greater (Fig. 1D) (19).¶ Patterns of defaunation¶ Although
we are
beginning to understand the patterns of species loss, we still have a limited understanding of
how compositional changes in communities after defaunation and associated disturbance will
affect phylogenetic community structure and phylogenetic diversity (26). Certain lineages appear to be
particularly susceptible to human impact. For instance, among vertebrates, more amphibians (41%) are currently considered
threatened than birds (17%), with mammals and reptiles experiencing intermediate threat levels (27). Although defaunation is a
global pattern, geographic distribution patterns are also decidedly nonrandom (28). In our evaluation of mammals (1437 species)
and birds (4263 species), the number of species per 10,000 km2 in decline (IUCN population status “decreasing”) varied across
regions from a few to 75 in mammals and 125 in birds (Fig. 2), with highest numbers in tropical regions. These trends persist even
after factoring in the greater species diversity of the tropics (29, 30). Similarly, most ¶ of 177 mammal species have lost more than
50% of their range (9).¶ The use of statistical models based on life history characteristics (traits) has gained traction as a way to
understand patterns of biodiversity loss (31). For many vertebrates, and a few invertebrates, there has been excellent research
explaining the extent to which such characteristics correlate with threat status and extinction risk (32–34). For example, small
geographic range size, low reproductive rates, large home range size, and large body size recur across many studies and diverse taxa
as key predictors of extinction¶ risk, at least among vertebrates. However, these “extinction models” have made little impact on
conservation management, in part because trait correlations are often idiosyncratic and context- dependent (31). ¶ We are
increasingly aware that trait correlations are generally weaker at the population level than at the global scale (31, 35). Similarly, we
now recognize that extinction risk is often a synergistic function of both intrinsic species traits and the nature of threat (32, 34–37).
For example, large body size is more important for predicting risk in island birds than mainland birds (34) and for tropical mammals
than for temperate ones (36). However, increasingly sophisticated approaches help to predict which species are likely to be at risk
and to map latent extinction risk (38), holding great promise both for managing defaunation and identifying likely patterns of
ecological impact (39). For instance, large-bodied animals with large home ranges often play specific roles in connecting ecosystems
and transferring energy between them (40). Similarly, species with life history characteristics that make them robust to disturbance
may be particularly com- petent at carrying zoonotic disease and therefore especially important at driving disease emergence (41,
42).¶ The relatively well-established pattern of correlation between body size and risk in mammals creates a predictable size-
selective defaunation gradient (Fig. 3) (19, 36, 43). For instance, there are strong differences in body mass distributions among
mammals that (i) became extinct in category “threatened” and above), and (iv) ex- tant species not currently threatened (Fig. 3), all
showing greater vulnerability of larger- bodied species. The myriad consequences of such differential defaunation have been quanti-
fied via the experimental manipulation of the large wildlife in an African savanna (Fig. 4 and table S3), revealing substantial effects
on biodiversity, ecological processes, and ecosystem functioning.¶ Multiple unaddressed drivers of defaunation¶ The long-
established major proximate drivers of wildlife population decline and extinction in terrestrial ecosystems—namely,
overexploitation, habitat destruction, and impacts from invasive species—remain pervasive (18). None of these major drivers have
been effectively mitigated at the global scale (14, 18). Rather, all show increasing trajectories in recent decades (14). Moreover,
several newer threats have recently emerged, most notably anthropogenic climate disruption, which will likely soon compete with
habitat loss as the most important driver of defaunation (44). For example, ~20% of the landbirds in the westernthe Pleistocene
[<50,000 years before the present (B.P.)], (ii) went recently extinct (<5000 years B.P., Late Holocene and Anthropocene), (iii) are
currently threatened with extinction (IUCN hemisphere are predicted to go extinct because of climate change by 2100 (45). Disease,
primarily involving human introduced pathogens, is also a major and growing threat (46).¶ Although most declining species are
affected by multiple stressors, we still have a poor understanding of the complex ways in which these drivers interact and of
feedback loops that may exist (7, 11). Several examples of interactions are already well documented. For example, fragmenta- tion
increases accessibility to humans, compounding threats of reduced habitat and exploitation (47). Similarly, land-use change is
making it difficult for animals to expand their distributions into areas made suitable by climate change (25, 48). Feedbacks among
these and other drivers seem more likely to amplify the effects of defaunation than to dampen them (11). ¶ Consequences of
defaunation¶ Because
animal loss represents a major change in biodiversity, it is likely to have
important effects on ecosystem functioning . A recent meta-analyses of biodiversity-ecosystem
function studies suggests that the impact of biodiversity losses on ecosystem functions is
comparable in scale with that of other global changes (such as pollution and nutrient deposition) (9). However,
most efforts to quantify this relationship have focused largely on effects of reduced producer diversity, which may typically have
much lower functional impacts than does consumer loss (49, 50). Efforts to quantify effects of changes in animal diversity on
ecosystem function, particularly terrestrial vertebrate diversity, remain more limited (19, 51). ¶ Impacts on ecosystem functions
and services¶ We examined several ecosystem functions and services for which the impacts of defaunation have been documented
that are either a direct result of anthropogenic extirpation of service- providing animals or occur indirectly through cascading effects
(Fig. 5).¶ Pollination¶ Insect pollination, needed for 75% of all the world’s food crops, is estimated to be worth ~10% of the economic
value of the world’s entire food supply (52). Pollinators appear to be strongly declining globally in both abundance and diversity
(53). Declines in insect pollinator diversity in Northern Europe in the past 30 years have, for example, been linked to strong declines
in relative abundance of plant species reliant on those pollinators (54). Similarly, declines in bird pollinators in New Zealand led to
strong pollen limitation, ultimately reducing seed production and population regeneration (Fig. 5H) (55). ¶ Pest control¶
Observational and experimental studies show that declines in small vertebrates frequently lead to multitrophic cascades, affecting
herbivore abundance, plant damage, and plant biomass (56). Cumulatively, these ubiquitous small-predator trophic cascades can
have enormous impacts on a wide variety of ecological functions, including food production. For example, arthropod pests are re-
sponsible for 8 to 15% of the losses in most major food crops. Without natural biological control, this value could increase up to 37%
(57). In the United States alone, the value of pest control by native predators is estimated at $4.5 billion annually (58). ¶ Nutrient
cycling and decomposition¶ The diversity of invertebrate communities, particularly their functional diversity, can have dramatic
impacts on decomposition rates and nutrient cycling (59–61). Declines in mobile species that move nutrients long distances have
been shown to greatly affect patterns of nutrient distribution and cycling (62). Among large animals, Pleistocene extinctions are
thought to have changed influx of the major limiting nutrient, phosphorus, in the Amazon by ~98%, with implications persisting
today (3). Defaunation can also affect water quality and dynamics of freshwater systems. For instance, global declines in amphibian
populations increase algae and fine detritus biomass, reduce nitrogen uptake, and greatly reduce whole- stream respiration (Fig.
5E) (63). Large animals, including ungulates, hippos, and crocodiles, prevent formation of anoxic zones through agitation and affect
water movement through trampling (64). Defaunation will affect human health in many other ways via
reductions in ecosystem goods and services (65), including pharmaceutical compounds, livestock
species, biocontrol agents, food resources, and disease regulation . Between 23 and 36% of all birds,
mammals, and amphibians used for food or medicine are now threatened with extinction (14). In many parts of the world,
wild-animal food sources are a critical part of the diet, particularly for the poor . One recent study in
Madagascar suggested that loss of wildlife as a food source will increase anemia by 30%, leading to increased mortality, morbidity,
and learning difficulties (66). However, although some level of bushmeat extraction may be a sustainable service, current levels are
clearly untenable (67); vertebrate populations used for food are estimated to have declined by at least 15% since 1970 (14). As
previously detailed, food production may decline because of reduced pollination, seed dispersal, and insect predation. For example,
loss of pest control from ongoing bat declines in North Amer- ica are predicted to cause more
than $22 billion in lost agricultural productivity (68). Defaunation can also affect disease transmission in myriad
ways, including by changing the abundance, behavior, and competence of hosts (69). Several studies demonstrate increases in
disease prevalence after defaunation (41, 42, 70). However, the impacts of defaunation on disease are far from straightforward
(71), and few major human pathogens seem to fit the criteria that would make such a relationship pervasive (71). More work is
urgently needed to understand the mechanisms and context-dependence of defaunation-disease relationships in order to identify
how defaunation will affect human disease.¶ Impacts on evolutionary patterns¶ The effects of defaunation appear not to be merely
proximally important to the ecology of affected species and systems but also to have evolutionary consequences. Several studies
have detected rapid evolutionary changes in morphology or life history of short-lived organisms (72) or human-exploited species
(73). Because defaunation of vertebrates often selects on body size, and smaller individuals are often unable to replace fully the
ecological services their larger counter- parts provide, there is strong potential for cascading effects that result from changing body-
size distributions (74). Still poorly studied are the indirect evolutionary effects of defaunation on other species, not directly
affected by human defaunation. For example, changes in abundance or composition of pollinators or seed dispersers can cause
rapid evolution in plant mating systems and seed morphology (75, 76). There is a pressing need to understand the ubiquity and
importance of such “evolutionary cascades” (77).¶ Synthesis and ways forward¶ This Review indicates that a widespread and per-
vasive defaunation crisis, with far-reaching consequences, is upon us. These consequences have been better recognized in the case
of large mammals (78, 79). Yet, defaunation is affecting smaller and less charismatic fauna in similar ways. On-
going
declines in populations of animals such as nematodes, beetles, or bats are considerably less evident to
humans yet arguably are more functionally important. Improved monitoring and study of such taxa,
particularly invertebrates, will be critical to advance our understanding of defaunation. Ironically, the cryptic nature of defaunation
has strong potential to soon become very noncryptic, rivaling the impact of many other forms of global change in terms of loss of
ecosystem services essential for human well-being.¶ Although extinction remains an important evolutionary impact on our planet
and is a powerful social conservation motivator, we emphasize that defaunation is about much more than species
loss. Indeed, the effects of defaunation will be much less about the loss of absolute diversity than about local shifts in species
compositions and functional groups within a community (80). Focusing on changes in diversity metrics is thus unlikely to be effective
for maintaining adequate ecological function, and we need to focus on predicting the systematic patterns of winners and losers in
the Anthropocene and identify the traits that characterize them because this will provide information on the patterns and the links
to function that we can then act on.¶ Cumulatively, systematic
defaunation clearly threatens to fundamentally
alter basic ecological functions and is contributing to push us toward global-scale “tipping
points” from which we may not be able to return (7). Yet despite the dramatic rates of
defaunation currently being observed, there is still much opportunity for action . We must more
meaningfully address immediate drivers of defaunation: Mitigation of animal overexploitation and land-use change are two feasible,
immediate actions that can be taken (44). These actions can also buy necessary time to address the other critical driver,
anthropogenic climate disruption. However, we must also address the often nonlinear impacts of continued human population
growth and increasingly uneven per capita consumption, which ultimately drive all these threats (while still fostering poverty
alleviation efforts). Ultimately, both reduced and more evenly distributed global resource consumption will be necessary to
sustainably change ongoing trends in defaunation and, hopefully, eventually open the door to refaunation. If
unchecked,
Anthropocene defaunation will become not only a characteristic of the planet’s sixth mass
extinction, but also a driver of fundamental global transformations in ecosystem functioning.
AT Resilience
Not resilient – biodiversity loss snowballs once its passed a threshold
Vandette 2018 – Earth.com Staff Writer
Kay Vandette 02-19-2018 Biodiversity loss can cause snowball extinction effect
https://www.earth.com/news/biodiversity-loss-extinction-effect/
Biodiversity loss is occurring faster than ever due to habitat loss caused by human activity and
anthropogenic climate change. In fact, one 2016 study found that biodiversity loss is reaching
unsafe levels. Biodiversity loss can cause a snowball effect where the extinction of one species
leads to the extinction of others. This effect is known as an extinction cascade because one
extinction can cause more due to the gap in the ecosystem. Now, new research has found that
extinction cascades have a higher likelihood of happening in areas where the loss of a species
can’t be substituted by any others at the same level of the food chain. In other words, no other
species can fill the empty slot. Researchers from the University of Exeter conducted the study,
and their findings show that even if one species loss doesn’t snowball into a cascade effect, the
loss of biodiversity creates a higher risk of extinctions. “Interactions between species are
important for ecosystem (a community of interacting species) stability,” said Dirk Sanders, an
author of the study. “And because species are interconnected through multiple interactions, an
impact on one species can affect others as well.” This new study shows that loss of one species
through human activities isn’t the only concern, but that one species loss could lead to more.
The researchers wanted to see if more complex food webs provided a buffer against extinction
cascades. “It has been predicted that more complex food webs will be less vulnerable to
extinction cascades because there is a greater chance that other species can step in and buffer
against the effects of species loss,” said Sanders. “In our experiment, we used communities of
plants and insects to test this prediction.” For the study, the researchers removed a species of
wasp from their plant and insect ecosystem. The loss of the wasps led to other species’ loss. The
results showed that smaller webs were more acutely affected compared to complex food webs.
“Our results demonstrate that biodiversity loss can increase the vulnerability of ecosystems to
secondary extinctions which, when they occur, can then lead to further simplification causing
run-away extinction cascades,” said Sanders. It’s a dangerous snowball effect that could wreak
havoc on crucial ecosystems. This study shows the necessity of preserving biodiversity and
trying to reduce the instances of species loss during a time when extinction is peaking higher
than ever.
Fertilizer Reduction Solves Dead Zones
Reverse causal and regional spills up to global ecosystem
Altieri and Diaz 19 (Andrew H. Altieri, Department of Environmental Engineering Sciences,
Engineering School of Sustainable Infrastructure & Environment, University of Florida. Robert J.
Diaz, Virginia Institute of Marine Science, College of William and Mary, “Dead Zones: Oxygen
Depletion in Coastal Ecosystems. World Seas: An Environmental Evaluation,” 453–473, 2019,
doi:10.1016/b978-0-12-805052-1.00021-8, WC)
The number of dead zones and their severity has increased exponentially in recent decades and
now impacts over 500 coastal ecosystems. Its effects compromise ecosystem functions and
services including habitat provision, water filtration, biogeochemical cycling, and fisheries
harvests.
This stark assessment should motivate efforts to confront the dead-zone threat for the sake of
ecosystem health and human well-being. Encouragingly, there is evidence that human action
can reverse hypoxia and dead-zones formation . Oxygen conditions improved in most of several
dozen ecosystems where nutrient inputs were reduced (Kemp et al., 2009). Sometimes,
nutrient remediation and the improvement of oxygen are intentional, as along the coast of
Sweden where sewage treatment was enhanced, and other times incidental, as in the Black Sea
where the collapse of the Soviet Union reduced fertilizer subsidies (Mee et al., 2005; Rosenberg,
Agrenius, Hellman, Nilsson, & Norling, 2002). Additional effort in several areas is needed to build
this positive momentum to improve the assessment and treatment of dead zones, including:
increased surveillance of ecosystems, sustained support of long-term monitoring programs,
deployment of advanced technology to detect changes in oxygen and associated water-quality
parameters, development of cyber infrastructure for enhanced data sharing, and assessment of
socio-economic factors (Altieri et al., 2017; Breitburg et al., 2009; Levin & Breitburg, 2015;
Rabalais et al., 2002).
Syntheses that integrate across multiple study systems and timescales are needed to generate
realistic expectations for both the scope of improvement and the timeline for reaching
management goals (Kemp et al., 2009). Coastal ecosystems show considerable background
variability, and it can take decades to verify sustained improvement of oxygen conditions.
Moreover, there is an emerging concern that climate change can counteract some gains to the
oxygen regime expected from reductions in eutrophication (Altieri & Gedan, 2015; Levin &
Breitburg, 2015). System-specific models for predicting the effects of nutrient abatement and
climate forecasts on hypoxic conditions are urgently needed to guide management (Cloern,
2001). This holistic approach will require studying the interactions between hypoxia and other
factors such as ocean acidification and temperature in a multiple-stressor framework.
Although dead zones are a worldwide phenomenon, management of eutrophication and organic
pollution at the watershed scale can improve oxygen conditions in many coastal ecosystems.
Therefore, dead zones are an environmental problem that can be addressed by grassroots
organization and local management efforts when supported with robust research. Regional
governance, such as the Chesapeake 2000 Agreement and the Convention on the Protection of
the Marine Environment of the Baltic Sea, can support these efforts (Rabalais et al., 2010).
Individual communities, institutions, and nations have the potential to lead by example in
challenging the scourge of hypoxia and contributing to our growing understanding of the dead
zone phenomenon.
40-45% reduction in N2O could solve the gulf’s dead zone

Raloff 2004 – editor for Science News
Janet Raloff, editor for Science News for students with awards from the National Association of
Science Writers, June 5 2004, Science News vl 165 #17 “Dead waters”,
https://www.sciencenews.org/article/dead-waters)
Accounts describing occasional bouts of hypoxia in the Gulf of Mexico date back to 1884 , when a
Mobile, Ala., newspaper reported a "jubilee"—a prolonged, anomalous run of fish and crabs into the shallows at Mobile. According to
Diaz, although the reporter recommended that local citizens avail themselves of this "gift from God," it and subsequent jubilees almost
certainly stemmed from the runoff of plant nutrients from farms and towns, which led to marine organisms' fleeing a new dead zone.
For U.S. ecologists, a nagging question today is how much reduction in nutrient inputs to the Gulf
of Mexico must occur for its dead zone to shrink substantially . Over the past few years, Don Scavia of the
National Ocean Service in Silver Spring, Md., has developed a computer model of the annual Gulf dead zone. By correlating river
inputs with the dead zones that Rabalais has mapped since 1985, Scavia's team calculated relationships between freshwater flow, the
Mississippi's nitrate content, and the Gulf's oxygen concentrations. Then, the team ran the model backward, plugging in annual
measurements for the past half-century of nitrate concentrations, the annual cycle of the Mississippi's flow, and weather data. The
calculations indicate that dead zones didn't become large, annual phenomena until the mid-1970s ,
says Scavia, who is currently the director of the Michigan Sea Grant program in Ann Arbor. But now that it's perennial, the
hypoxia phenomenon will be hard to vanquish, the model also indicates. By running the model forward
in time, Scavia's team analyzed how much farmers and other polluters in the Gulf watershed —an
area covering 41 percent of the lower 48 states' area—would have to scale back their nitrogen releases to limit
the zone to an annual average of just 5,000 square km., a target set by the federal government 3
years ago. The researchers' conclusion: a 40 to 45 percent annual cutback in the nutrient releases.
That nitrogen reduction is daunting, says Robert W. Howarth of Cornell University. "Over the past 20 years, nitrogen
pollution in coastal waters has increased pretty steadily, about 1 percent per year," he notes. A biogeochemist, Howarth chaired a
National Academy of Sciences committee that studied nutrient pollution in coastal waters and 4 years ago issued a report finding that
the problem, affecting almost all U.S. coastal waters to some degree, was so serious that urgent national action was imperative. To
date, Howarth tells Science News, because
the federal government currently seeks only voluntary controls
on nutrient runoff, there hasn't been much action. In fact, budget cuts are reducing the already-scheduled
monitoring.
Fertilizer efficiency alone solves for 2/3 of gulf’s dead zone

Mestre and Benson 2015 – environmental defense fund
Cristina Mestre and Julie Benson, the Environmental Defense Fund, February 2015, “Study:
Adding Wetlands in the Corn Belt Can Shrink Gulf of Mexico Dead Zone”,
https://www.edf.org/media/study-adding-wetlands-corn-belt-can-shrink-gulf-mexico-dead-zone
Fertilizer efficiency measures and planting of cover crops can reduce nutrient pollution delivered
to the Gulf of Mexico by 30 percent, finds a new Environmental Defense Fund (EDF) led study released today in the
Journal of the American Water Resources Association (JAWRA). Yet when combined with filter practices such as
wetlands, the study found that nitrogen pollution in the Upper Mississippi and Ohio River basins
can be reduced by 45 percent – the Environmental Protection Agency (EPA) established target that will
shrink the Gulf’s dead zone to a manageable size. The JAWRA study, “Reducing Nitrogen Export from the Corn
Belt to the Gulf of Mexico: Agricultural Strategies for Remediating Hypoxia,” is the first to quantify the impact of agricultural
strategies for reducing hypoxia at such a large scale. Researchers used an advanced water-quality model developed by the U.S.
Geological Survey (USGS) to quantify the benefits of agricultural practices on croplands. “The good news is that adopting
soil health and fertilizer efficiency measures across the Corn Belt can get us two-thirds of the way
to the tipping point,” said the study’s lead author and EDF senior scientist Eileen McLellan. “But by strategically placing
wetlands on less than 1 percent of the region’s croplands, we’ll be able to reverse the trend of significant losses in aquatic life, and
improve flood resiliency for downstream communities with minimal impact to crop production.” Over
400 hypoxic or
“dead” zones, ocean areas where low oxygen concentration causes marine life to suffocate and
die, have been identified in estuaries and coastal waters worldwide . Studies have shown the number and
extent of these zones is increasing, and experts agree that the majority of dead zones are caused by nutrient pollution. Among the
findings: Optimizing fertilizer use in the Upper Mississippi and Ohio River Basins can reduce nitrogen pollution by 12 percent, less
than one-third of EPA’s goal. Combining cover crops with nitrogen efficiency practices on all cropland acres can reduce nitrogen loss
by 30 percent, representing two-thirds of EPA’s target. Restoring and adding wetlands to the region’s croplands can further reduce the
nitrogen loss to 45 percent, thereby reaching the tipping point. “Over time, we’ve changed the plumbing of the Corn Belt landscape in
such a way that some nitrogen loss is inevitable,” added McLellan. “But the chemical process that takes place in wetlands traps and
treats nitrogen lost from farm fields, and turns nitrogen fertilizer into harmless nitrogen gas. Wetlands are a key part of the
conservation equation.” In addition to wetlands, other nitrogen removal practices include drainage ditch enhancements, stream channel
restoration, and floodplain reconnection. These filter practices can be implemented on marginal land with low yields, thereby
minimizing impacts to crop production. Furthermore, the authors highlight the economic benefits of fertilizer efficiency measures and
planting cover crops, both of which are likely to offset the loss of any cropland. Other filter practices can be implemented within the
footprint of existing ditches and streams, without any loss of productive land. “Results from this study help expand our understanding
of the importance of considering a variety of conservation practices applied throughout the entire watershed,” said Dale Robertson,
research hydrologist with the USGS and co-author of the paper. “Improving water quality is a community-wide effort that should save
money, clean up local streams, and benefit the Gulf.”
AT: Hypoxia is good for shrimp/fish in general
that study is the exception – multiple Gulf studies plus other US and Baltic
studies demonstrate hypoxia unquestionably bad
Boehm, 2020
(Rebecca- PhD from the Tufts University Friedman School of Nutrition Science and the
Agriculture, Food, and Environment program - economist in the Union of Concerned Scientists
Food and Environment Program, “Reviving the Dead Zone Solutions to Benefit Both Gulf Coast
Fishers and Midwest Farmers, Union of Concerned Scientists, June 2020, you can access the
report here: https://www.ucsusa.org/resources/reviving-dead-zone#ucs-report-downloads)
How the Gulf dead zone affects landings and catch rates, and other economic indicators of the fishing industry, is less clear. This is
partly attributable to the fact that marine life can adapt by moving out of harm’s way. One
study found that shrimp
catches increased despite the formation of the seasonal dead zone (Zimmerman, Nance, and Wiams
1996), although the same authors later found that that in years when hypoxia was extensive,
some shrimp species could not migrate to offshore waters and instead came nearshore, which
made them easier to catch (Zimmerman and Nance 2001). Other research has found that shrimp employ compensatory
mechanisms in their respiratory capacity to survive hypoxia (Rosas et al. 1998). Newer research has found beneficial impacts on
some fish catches from increased nitrogen loading in the Gulf, since relatively small amounts of additional nitrogen promotes growth
of marine plants and species (de Mutsert et al. 2016; de Mutsert et al. 2017). But some studies have more definitively
shown declines in fish catches due to Gulf hypoxia. In the early 1980s, shrimp and finfish catch rates were lower
in the most severely hypoxic areas (Leming and Stuntz 1984; Renaud 1986). Later, an assessment by the National Oceanic and
Atmospheric Admin-istration found that brown shrimp catches declined significantly from 1992 to 1997, coinciding with a
substantial decrease in dissolved oxygen concentrations in Gulf waters (Diaz and Solow 1999). More recent studies have found that
menhaden populations, for example, have shifted due to hypoxia, increasing the effort needed to catch them in the most severely
hypoxic Gulf waters (Langseth et al. 2014; Langseth et al. 2016). The biological complexity of the Gulf ocean ecosystem has made
researching how the dead zone affects the fishing industry a major challenge for decades. Despite these challenges, the
economic consequences of the dead zone for Gulf fisheries are beginning to emerge , largely due
to increasingly interdisciplinary and sophisticated research efforts. Two studies stand out in this
regard. In the first, Gulf hypoxia was found to be negatively correlated with the relative price of
large and small brown shrimp catch (Smith et al. 2017). The study found that as the hypoxic zone reaches peak
size, smaller shrimp migrate closer to shore to avoid it, making them easier to catch and, as a
result, the price that shrimpers earn for them goes down and fewer shrimp are able to grow to
larger and more valuable sizes. Another Gulf-based study found that shrimpers must exert more
effort—defined as the amount and intensity of time spent catching shrimp—to catch shrimp when hypoxia occurs
(Purcell et al. 2017). Without doubt, more research detailing the economic consequences of Gulf hypoxia on the fishing and
shrimping industries is needed. Yet studies of other hypoxic waters in the United States and globally provide
additional insights about the economic dangers of the Gulf dead zone. For example, in North Carolina, seasonal
hypoxia—due in large part to agricultural nitrogen losses—in the Neuse River and Pamlico Sound has resulted in a 13
percent annual decrease in brown shrimp landings from 1999 to 2005, while shifting the optimal
shrimp harvest season to much earlier in the year (Huang, Smith, and Craig 2010; Huang and Smith 2011),
disrupting normal fleet operations. When shrimp landings are down, imported shrimp make up the shortfall, further
hurting shrimper revenues (Huang et al. 2012; Keithly and Poudel 2008). For North Carolina’s blue crab fishers, research
indicates that reducing hypoxia there could result in millions of dollars in economic benefits to it, while
bringing additional co-benefits to recreational fisheries (Smith et al. 2007). Research has also documented the harm
caused by hypoxia on commercially important fisheries elsewhere. This includes the Chesapeake Bay and one of its main
tributaries, the Patuxent River. Summer
flounder catch rates there have been reduced by as much as 20
percent due to hypoxia, while striped bass fisher and blue crabber revenues have been
collectively reduced by hundreds of thousands of dollars in a single year due to this problem (Lipton
and Hicks 2003; Massey, Newbold, and Gentner 2006; Mistiaen, Strand, and Lipton 2003). Hypoxia’s economic consequences have
also been extensively studied in
the Baltic Sea (Compton 2020). Researchers there have found that reducing
eutrophication and related water quality problems could bring as much as $10 billion (1999 dollars) more in
economic benefits than the costs of reducing nitrogen loads (Gren 2001; Gren, Jannke, and Elofsson 1997; Rabotyagov et al.
2014b; Turner et al. 1999).
Coral Reefs Internal
Dead zones cause mass coral reef death
Smithsonian, 2017
(Smithsonian Insider, “Dead Zones May Threaten Coral Reefs Worldwide,” 21 March 2017,
https://insider.si.edu/2017/03/dead-zones-may-threaten-coral-reefs-worldwide/)
Dead zones affect dozens of coral reefs around the world and threaten hundreds more according to
a new study by Smithsonian scientists published in the Proceedings of the National Academy of Sciences. Watching a
massive coral reef die-off on the Caribbean coast of Panama, they suspected it was caused by a dead zone—a
low-oxygen area that snuffs out marine life—rather than by ocean warming or acidification. “Ocean warming and acidification are
recognized global threats to reefs and require large-scale solutions, whereas the newly
recognized threats to coral
reefs caused by dead zones are more localized,” said Andrew Altieri, staff scientist at the Smithsonian Tropical
Research Institute and first author of the study. “Fortunately dead zones can be reduced by controlling sewage and
agricultural runoff into the ocean.” In September 2010, coral reefs in Almirante Bay, Bocas del Toro Province, showed
severe signs of stress. In addition to corals turning white and dying, which is typical during coral bleaching associated with warming
events, there were other clues suggesting that more was involved than high temperatures. Many unusual observations pointed to
something else as the culprit. There
were thick mats of bacterial slime, and the dead bodies of crabs,
sea urchins and sponges lay scattered on the ocean floor. Even more odd, there was a clear depth line above which the
reefs looked OK, and below which something had gone terribly wrong. Even single colonies of corals that straddled the line were fine
above and dying below. Scientists went to work, measuring several aspects of water quality. One set of measurements came back as
a shock. Extremely
low oxygen levels in deeper waters contrasted with high oxygen levels in
shallow waters where corals were still healthy. This is the hallmark of a dead zone . The team thinks
that such dead zones may be common in the tropics but have gone largely unreported, simply
because scientists never looked. “The number of dead zones currently on our map of the world is 10 times higher in
temperate areas than it is in the tropics, but many marine biologists work out of universities in Europe and North America and are
more likely to find dead zones close to home,” Altieri said. “We were lucky that there was already a reef-monitoring program in
place as part of ongoing work at the Smithsonian’s Bocas del Toro Research Station,” said Rachel Collin, station director. “Based on
our analyses, we think dead zones may be underreported by an order of magnitude .” said Nancy Knowlton,
coauthor and Sant Chair for Marine Science at the Smithsonian’s National Museum of Natural History. “For every one dead zone in
the tropics, there are probably 10—nine of which have yet to be identified.” The researchers
found 20 instances
when dead zones were implicated in the mass mortality of coral reefs worldwide. “Hypoxia (low
oxygen) isn’t even mentioned in several of the most important academic reviews of threats to coral reefs and is rarely discussed at
scientific meetings,” Altieri said. “Even worse, many coral-reef monitoring efforts do not include measurement of oxygen levels,
making it nearly impossible to identify low oxygen as the cause of mass coral mortality after the fact.” For example, the
cause of
a 2016 mass mortality at the Flower Garden Reefs in the Gulf of Mexico remains unclear, but
some of the photographs look strikingly similar to what was observed in Panama. The authors argue that
building capacity to monitor oxygen on reefs will help people to improve coral-reef health and understand how dead zones
might interact with other forces such as global warming in a one-two punch, which put reefs in even greater danger.
Fisheries Internal
Dead zone threatens gulf fisheries
Hannaford ’14 (Alex Hannaford, writer for the Texas Observer, January 27 2014, Texas
Observer “Life in the Dead Zone”, https://www.texasobserver.org/life-dead-zone/)
Though it fluctuates (largely due to rainfall), the Dead Zone has doubled in size since the late 1980s, encroaching into Texas waters
and devastating those who make their living from the ocean. The Dead Zone in the Gulf of Mexico is caused by
fertilizer run-off from farms in the Midwest sluicing into the Mississippi River and onward to the
Gulf. Because it’s rich in nutrients designed to make plants grow, this fertilizer turbo-boosts the microscopic plants in the seawater,
and small marine animals feed on this vegetation. That marine life inevitably produces a lot of fecal matter and these pellets drop to
the ocean floor, along with dead animals and plants, which are then consumed by microbes. Those microbes require oxygen, and
there’s the rub. What,
in theory, is initially life-giving, ultimately ends up causing hypoxia—areas of
oxygen depletion that have become known as the Dead Zone. Last summer a Texas A&M University team
surveyed the Texas-Louisiana coast and found large swathes of hypoxia, covering around 3,100 square miles—about the size of
Delaware and Rhode Island combined. The largest was off the coast of Louisiana, but the team also found “significant amounts” near
Galveston and elsewhere off the southeast Texas coast. For
hypoxia to occur, fresh and salt water can’t mix . In
the Gulf, because fresh water from the Mississippi is lighter than seawater , it gushes into the ocean,
forming a lens over the brine, and when the oxygen gets used up, it can’t be replenished. Until,
that is, you get big, dramatic winter storms blowing in —or better still, hurricanes—that serve as a gigantic natural
whisk, churning the waters and breaking up the hypoxia. The ocean can breathe again, but it’s a temporary relief. Come Spring, the
hypoxia re-establishes itself, and according to Peter Thomas, a biologist at the University of Texas’ Marine Science Institute in Port
Aransas, in years with large rainfall, that hypoxic area dramatically increases in size. The Dead Zone has grown from about three to
four thousand square kilometers in the early 1950s to up to 22,000 square kilometers today. “It’s actually got larger all over the world,
particularly in the developed world,” Thomas says from his office overlooking the Gulf, just a stone’s throw from the beach in Port
Aransas. “It’s increased into 300 sites around the globe, and (on average) by about three-fold over the last 15 or 20 years.” The
reason for the dramatic increase, he says, is the introduction of intense agricultural practices
throughout the world that use a vast amount of fertilizer . The problem is, our most important
fisheries are coastal fisheries and the agricultural run-off impacts precisely these fishing grounds .
When you get vast areas of low oxygen like this, some marine life will move elsewhere because they can’t tolerate it. Those that stay
have to make adjustments. This is the area where Thomas and his colleagues in Texas have focused their research, and the results are
disturbing: In order to conserve energy in these de-oxygenated waters, the marine life they’ve studied simply stop reproducing.
Ultimately, that’s going to mean fewer fish and shrimp, which could spell disaster for the fishing
industry and our food supply. Thomas likens this reaction to how our own bodies react when we run long distances: Our
muscles start aching, we build up lactic acid, and we use glucose less efficiently than we would if we had plenty of oxygen. To limit
their use of energy, some of these marine animals go into an almost hibernation-like state, Thomas says. “The way many of these
marine organisms survive as a population is to have millions of eggs. The tuna fish, for example, will make 50 million. But making
millions of eggs is hugely energy dependent and so animals that face severe stress through things like hypoxia stop reproduction.” In
croaker, the fish species Thomas studied, the female fish even become masculinized, with sperm appearing in their ovaries. “These
fish think, if they survive till next year, they’ll reproduce in another year. The problem is, the hypoxia occurs every year,” he says.
Long-term, Thomas says, hypoxia will cause a population decline. His team worked with Dr. Kenneth Rose, a
scientist at Louisiana State University, who produced a 100-year model of what the croaker population would do. “And he showed
there will be a quite considerable decline, even by conservative estimates,” Thomas says. Two porpoises breach from the water off the
rain-lashed harbor of Port O’Connor as the C. Lorraine approaches its berth. A pelican watches from a wooden pylon. Right now,
Mauricio Blanco says the live bait shrimp he catches fetch a dollar per pound and he must catch 100 pounds to make enough to pay
for the fuel he’ll use. In previous years the shrimp have sold for as little as 25 cents per pound.
Commercial fishing industry is key to the economy

Consortium of Ocean Leadership April26th, 2014 (Washington, DC-based nonprofit
organization that represents more than 100 of the leading public and private ocean
research and education institutions, aquaria and industry with the mission to advance
research, education and sound ocean policy.)http://oceanleadership.org/
These reports are an excellent example of the environmental intelligence NOAA uses and
provides every day,” said Eileen Sobeck, assistant NOAA administrator for fisheries. “Fishing is
big business and culturally important in our country. On top of that, it supports a lot of
jobs.”According to the economics report, commercial and recreational fishing supported
approximately 1.7 million jobs in 2012, the most recent year for which data are available, a gain
over 2011’s 1.6 million. The commercial fishing industry — harvesters, processors and dealers,
and wholesalers and retailers — generated $141 billion in sales, $39 billion in income, and
supported 1.3 million jobs in 2012 in fishing and across the broader economy.Recreational
fishing generated $58 billion in sales, $19 billion in income, and supported 381,000 jobs in 2012
in fishing and across the broader economy.The annual economics report also breaks down the
sales, income and job figures for each coastal state. The five states that generated the most
commercial fishing jobs in 2012 were California, Massachusetts, Florida, Washington and
Alaska. The five states that generated the most recreational fishing jobs were Florida, North
Carolina, Louisiana, Texas and New Jersey.
Coastal economies drive the US economy

Center for the Blue Economy at the Monterey Institute of International Studies, “State of
the U.S. Ocean and Coastal Economies” 2014
http://maine.sierraclub.org/NOEP_National_Report_2014.pdf
The coastal economy of the United States is big by any absolute or relative standard, and the
economy of the coastal states largely drives the US economy. Coastal states contributed 81% of
US employment in 2012 and 84% of total US GDP. Within these states, the shore adjacent
counties comprise 37% of overall employment on just 17.5% of US land area, indicating that the
concentration of the nation’s economy is found near the oceans and Great Lakes.
Spills over to impact all of the economy – ocean economy is a multiplier effect
Center for the Blue Economy at the Monterey Institute of International Studies, “State of
the U.S. Ocean and Coastal Economies” 2014
http://maine.sierraclub.org/NOEP_National_Report_2014.pdf
The people and organizations in the ocean economy affect the total U.S. economy to a greater
extent than is indicated by the employment and output measures discussed so far. The firms in the
industry buy inputs from other industries whose sales are thus indirectly dependent on the ocean
economy’s success. The employees in the ocean industries spend their incomes and these sales to
employees are said to be “induced” activity from the ocean economy. Together these effects are
known as the “multiplier effect”.
Coastal Economies Internal
Dead zones devastates coastal economies
Population growth and economic development threaten to swamp the progress that states and
the federal government have made on water quality since the passage of the Clean Water Act
(CWA). Over the next 40 years, the Census Bureau estimates that the U.S. population will pass
400 million people.11 As the population expands, the EPA states that “the rate and impact of
nitrogen and phosphorus pollution will accelerate—potentially diminishing even further our
progress to date.”12 There is no comprehensive national estimate of the negative economic
impacts of water pollution. However, more geographically focused studies that look at health
expenditures, reduced economic productivity, and lost tourism indicate that the cost runs into
the billions of dollars each year.13 For instance, a recent paper found that lost productivity and
health care expenditures due to waterborne illness from recreational water activities such as
swimming and boating costs the economy roughly $2.9 billion each year.14 A conservative
estimate by the EPA found that tourism industry losses exceed $1 billion each year due to
nutrient pollution and harmful algal blooms.15 In 2015 and 2016, harmful algae blooms
devastated the Dungeness crab industry on the West Coast, causing an estimated $100 million
in economic losses.16 The risks for tourism-dependent states are especially acute. For instance,
more than 70 million people visit Florida each year, spending roughly $90 billion on services,
entertainment, and recreation.17 A massive red tide algal bloom in 2018 along the southern
Gulf Coast hit local businesses hard, resulting in $90 million in lost sales as well as reduced tax
collections and layoffs.
Reducing nitrogen benefits coastal and Midwest economies

Boehm, 2020
For more than 30 years, scientists have investigated an area of deep water in
the Gulf known as a “dead zone,” which
contains so little oxygen that fish and other marine life flee from it or die (Hazen et al. 2009). In the
summer of 2017, it swelled to the size of New Jersey. The size of this area experiencing often fatally low levels of
oxygen—what scientists call hypoxia— varies depending upon spring rains and snow melt. These carry large
quantities of excess soil nutrients, largely nitrogen, down the Mississippi and Atchafalaya rivers to the
Gulf. There, this polluted water sets off a chain reaction of ecological and economic
consequences straining the resilience of diverse fishing operations and local communities that
depend upon a healthy Gulf for their livelihoods . EXCESS NITROGEN FUELS THE DEAD ZONE Most of the
nitrogen that contributes to the dead zone— between 60 and 80 percent—originates on farms and
livestock operations in the Midwest, largely in the form of synthetic fertilizers that run off fields of corn and other
crops. The significant expansion of agricultural production in some parts of the Midwest over the last many decades (Fausti 2015; Lin
and Huang 2019) adds to this concern. The excess nitrogen in rivers can cause algae overgrowth and deplete
the oxygen supply available to healthy marine life, creating vast dead zones that make it harder for the region’s fishers to make a
living. The challenge of the dead zone is made worse by other closely inter-twined environmental stressors. Climate change is
increasing the frequency of heavy rains and floods in the Midwest, which could wash even more nitrogen off farms and into rivers
feeding the Gulf (Altieri and Gedan 2015). Ocean temperature changes are expected to exacerbate Gulf pollution effects, which will
make shrinking the dead zone even more challenging in the years ahead (Laurent et al. 2018; Reidmiller et al. 2018). What is more,
oil drilling in the Gulf of Mexico and the potential for oil spills—such as the 2010 British Petroleum Deepwater Horizon disaster—
threaten the Gulf fishing industry as long as our economy stubbornly relies on fossil fuels. With all these challenges bearing down on
the Gulf and the people who fish in it, straightforward solutions are needed. Reducing
nitrogen losses from farms is
such a
solution—with the added bonus of many co-benefits for farmers and rural communities upstream—that could
head off much more serious damage to Gulf ecosystems and fishing industries in the future. While
many studies have estimated how much it would cost to reduce nitrogen losses from Midwest farms in order to meaningfully shrink
the dead zone (Kling et al. 2014; Rabotyagov et al. 2014a), the potential economic benefits of such action have not yet been
quantified. Gulf
fisheries and marine habitat are the foundation for fishing and coastal industries.
These industries in turn are important economic engines for the region. In 2016 alone, commercial
fishing industries generated between $17 billion and $57 billion in economic impacts and
200,000 jobs for the region (NMFS 2016). Reducing nitrogen losses from farms could generate a large return on
investment through healthier, more productive fisheries in the Gulf. REDUCING NITROGEN FOR THE BENEFIT OF FARMERS AND
FISHERS ALIKE Fortunately, there are already ways to make this return on investment a reality. Farmers
and scientists
have developed a suite of agricultural practices that reduce synthetic nitrogen fertilizer use and
keep what is applied to fields out of waterways. The resulting soils contain more living organic
matter and are kept covered year-round to resist erosion and hold more water and nutrients. These practices
can simultaneously reduce farmers’ costs and make farmland more resilient to floods and droughts,
while improving the long-term fertility of soil (Basche 2017; Basche and DeLonge 2019; Hunt, Hill, and Leibman 2019;
Mulik 2017; Myers, Weber, and Tellatin 2019; Stillerman and DeLonge 2019). Thus, these two important food production and
economic forces in our country—the Midwest farming industry and the Gulf Coast fishing industry—can
jointly benefit from one set of practices. To show how improved agricultural practices in the Midwest can offer economic
benefits to the Gulf fishing industry, we used publicly available data to estimate how much avoidable nitrogen pollution has made its
way from farm fields and into the two main rivers that feed the Gulf of Mexico. We next estimated in economic terms the damage
that nitrogen pollution from farms, which fuels the dead zone, causes to the ecosystem services that fisheries and marine habitat
provide for the Gulf of Mexico. We further explored the value of the damage costs that could be averted if nitrogen pollution and
the dead zone were reduced through changes in agricultural practices upstream. Our analysis found that on average the
equivalent of 3,100 standard-sized shipping containers per year of excess nitrogen has washed
off Midwest cropland into the Mississippi and Atchafalaya rivers, and ultimately into the Gulf of Mexico. This
nitrogen has contributed up to $2.4 billion in damages to ecosystem services generated by fisheries and
marine habitat every year since 1980. We also found that significant economic benefits could be
realized by reducing these damages through changes in agriculture upstream . These benefits cannot
be realized without policy support. We recommend policy actions that can help Gulf Coast fishing industries and communities while
supporting a thriving, sustainable agricultural economy in the Midwest through science-based solutions that provide farmers with
tools to build healthy, living soil. Healthy
Fisheries Are Economically Important to Diverse Gulf Coast
Communities Commercial fisheries, recreational fishing, and coastal tourism along the Gulf
Coast play an important role in the region’s economy. Gulf of Mexico fisheries have the
second highest commercial landings—the quantity of fish caught and unloaded on shore—in the United States,
just behind Alaska (NMFS 2018). In 2016, commercial fishing along the Gulf Coast generated at least $17 billion
in economic impacts (Box 1, p. 4) and nearly 200,000 jobs (NMFS 2016). Recreational fishing together with
coastal tourism along the Gulf Coast (which includes non-fishing recreational boating excursions) generated an additional
$57 billion in economic impacts in sales and nearly 500,000 jobs in 2016 (Kosaka and Steinback 2018; NMFS
2018).1 Yet some reporting indicates that commercial fish landings have declined in the Gulf (Karnauskas et al. 2017), and economic
impact data show that commercial and recreational fishing industries in the Gulf have experienced little growth over the past decade
(Figure 1, p. 5; Figure 2, p. 6). Additional challenges to the commercial fishing industries in the Gulf Coast region stem from both
human-caused and environmental stressors (Chen 2017; Johnson 2019), such as competition from imported seafood (Karnauskas et
al. 2017). While imports are affected by a variety of drivers, cleaning
up the dead zone could make the region’s
fishing operations more competitive and present potential economic benefits. The recreational
fishing industry is also put at risk by the dead zone, as some tourists may be turned off by the thought of a
“dead” ocean ruining a fishing trip, even if those concerns may be overstated or misunderstood (Felsher 2013). Consequently,
reducing nitrogen loadings and hypoxia in the Gulf could be a way to boost the economic impact of both
commercial and recreational fishing industries (see Box 1), bringing additional jobs and tax revenue to the
region and making the commercial industry more competitive against imports. The shrimp industry—which is
particularly vulnerable to the formation of the dead zone—is an important economic and
cultural feature of life along the Gulf Coast. In 2016, the total value of shrimp caught in the Gulf was
estimated at $412 million, and shrimp is arguably the most valuable fishery in the region, bringing in
nearly half the revenue of the top 10 commercial fishery catches in that year (NMFS 2018). Commercial shrimp operations in the
Gulf have caught nearly 200 million pounds of shrimp every year since the late 1990s. However, annual total catch has been
decreasing steadily over this time period, partly due to increased pressure from inexpensive imported shrimp but also due to other
human and environmental stressors (Tabarestani, Keithly, and Marzoughi- Ardakani 2017; Asche et al. 2012). These challenges have
made it increasingly difficult for Gulf shrimpers to remain profitable, and many are
going out of business (Box 2, p. 7).
In Texas, two-thirds of shrimper licenses have been repurchased by the state since the mid-1990s, and the
number of
shrimp boats going farther offshore in search of a viable catch has declined by one-fourth since 2010 (Subra-
manian 2018). Our analysis of commercial fishing and shrimping licenses issued by the Louisiana Department of Fish and Wildlife
indicates a significant decline over a similar time period (LDWF 2019; see Appendix 1, online at www.ucsusa.org/resources/ reviving-
dead-zone).
Key to coastal economies

Tereck 2011 – President of The Nature Conservancy
Mark Tereck “Gulf ‘Dead Zone’ Threatens Seafood, Tourism Industries,” October
2, http://www.huffingtonpost.com/mark-tercek/gulf-dead-zone-threatens-
_b_916389.html
Despite earlier predictions, scientists this week reported that the Gulf of Mexico’s “dead zone” did not hit an all-time
record size. But the news was nothing to celebrate. The dead zone — an area of water where oxygen is depleted, preventing any
marine life from surviving — is now 6,765 square miles wide. That’s bigger than the state of Connecticut and one of
the largest dead zones ever recorded in the Gulf (the dead zone has continued to grow since measuring began in 1985). The report
by Louisiana Universities Marine Consortium is just the latest evidence for the need to invest in our natural resources or risk
severe consequences to our jobs, economies and communities . Scientists had predicted this year’s
dead zone would be the largest on record due to the historic floods this spring that washed nutrients, particularly
nitrogen and phosphorus, from farm land, lawns, sewage treatment plants and other sources along the Mississippi River into the
Gulf of Mexico. If Tropical Storm Don hadn’t hit the Gulf last week, whipping up waves and wind to temporarily re-supply oxygen to
the water, the dead zone would likely have broken previous records. When floods hit the Mississippi River this spring, the immediate
damage was obvious — ruined homes, inundated farm lands and disrupted businesses costing hundreds of millions of dollars. But
the impacts of the floods are now being felt by even more people and communities than originally thought. The
dead zone
poses a real threat to the Gulf’s seafood and tourism industry which generates more than
600,000 jobs and $9 billion in wages annually . Because fish and other commercial species usually move out to sea in
order to avoid the dead zone, fishermen are forced to travel farther from land — and spend more time and money — to make their
catches, adding stress to an industry already hurt by hurricanes and the oil spill. Those species that can’t move — or can’t move fast
enough — die off, leading to the name “dead zone.” The
Gulf produces roughly 40 percent of all the seafood in
the lower 48 states. The National Oceanic and Atmospheric Administration has previously estimated that the dead zone
costs the U.S. seafood and tourism industries $82 million a year . The record size of this year’s dead zone
could be even more costly. This year’s floods and the resulting dead zone remind us that our lands and waters are interconnected;
damage to a natural system in one part of the country can impact communities thousands of miles away. It’s an important lesson
that our elected leaders should not forget in this time of cutting the Federal budget. Investing in our nation’s lands and water is a
direct investment in America’s communities and economy. But proposed spending bills that have been taken up by Congress over
the last few months and will now be affected by the debt ceiling agreement, have included deep cuts to conservation programs that
have kept our natural resources strong and productive for decades. Among the programs now in jeopardy are Farm Bill Conservation
Title provisions that encourage farmers and forest land owners to conserve and manage their land in ways that minimize soil
erosion, improve water quality by reducing polluted runoff, mitigate the risks of flood damage and provide wildlife habitat. The dead
zone is just one of the threats that poses financial hardship to the Gulf region — and the nation as a whole. It has been more than a
year since the oil spill disaster that poured 205 million gallons of crude into the Gulf’s waters, and it is now time to take more
decisive action to restore the Gulf of Mexico back to health. Legislation called the RESTORE Act has been introduced in the Senate
that would dedicate 80 percent of the money that could result from oil spill fines to restoring the Gulf’s communities, economies
and environments. Without Congressional action, current law would have most of the money toward general government spending
rather than helping the Gulf recover. This fall, a federal task force appointed by President Obama will unveil a comprehensive plan
for restoring the Gulf. Funding from potential oil spill fines is needed to ensure that plan is implemented and that we, as a nation,
can work together to restore the Gulf of Mexico. Ahealthy Gulf is vital to the well-being of communities
around the region and across the nation . This year’s massive dead zone is just the latest challenge
facing this incredible natural resource that provides us with jobs, income, food, shelter and diverse wildlife .
And, as we look toward reducing the cost of government we should recognize that environmental investment should not be cut
disproportionately. The
health of our land, freshwater and oceans is not a luxury — it is a foundation
for the economic and social well being of our society .
Ethanol Internal
Laundry list of reasons ethanol is bad
Manglik, 2017
(Vrinda, “Ethanol’s Contribution to a Record-Breaking Dead Zone in the Gulf of Mexico,” 18 Aug.
2017, https://www.sierraclub.org/compass/2017/08/ethanol-s-contribution-record-breaking-
dead-zone-gulf-mexico)
Earlier this month, the National Oceanic and Atmospheric Administration observed the largest “dead zone” in the Gulf of Mexico since record-keeping
began in 1985. At 8,776 square miles, the dead zone is the second largest in the world and approximately the size of New Jersey. Dead zones, also
known as hypoxic zones, are areas in the ocean where algal blooms caused by pollution lead to low oxygen concentrations – causing marine life to
suffocate and die. The algal blooms prevent sunlight and oxygen from reaching below the water’s surface, and are fatal to most aquatic life, including
plants, fish, marine mammals, and shorebirds. Contributors leading to these inhospitable conditions include
excessive nutrient pollution, which often comes from nitrogen-based fertilizer runoff used in
agricultural production. In particular, corn production is notorious for its significant contribution to
the dead zone. Unlike other crops, corn cannot grow without fertilizer and thus has high
volumes of nitrogen fertilizer runoff associated with its production. Notably, scientists have been warning for years that
increased production of corn-based ethanol would lead to a larger dead zone in the Gulf of Mexico. Corn
production in the U.S. was at an all-time high in 2016, with domestic production reaching 15,148,038 bushels. The top corn-producing
states in 2016 were Iowa, Illinois, Minnesota, Nebraska, South Dakota, Wisconsin, Texas, Ohio, North Dakota, Missouri, Kansas, Indiana, and
Kentucky. All of these states are located within the Mississippi watershed. This means that nitrogen
fertilizer runoff in these states flowing into local waterways will drain into the Gulf of Mexico.
It is likely that increased production of corn , including corn for ethanol, has been a major factor in this year’s enormous
dead zone. Of the total 2016 U.S. corn production, 36.5 percent (or 5.325 million bushels) was used for ethanol fuel and ethanol distillers dry grains
(DDGs). Indeed, production of corn-based ethanol has increased in the US since the Renewable Fuel Standard (RFS)
was created in 2005. Although the goal of the RFS, which mandates increased volumes of renewable fuels, was to replace carbon intensive petroleum-
based transportation fuels with lower emission renewable fuels to address climate change, it
has not achieved its climate change
impact reduction goals and has had vast unintended adverse environmental impacts.
Biomass-based diesel is one component that is not actually sustainable. In addition to the impact that
corn production has on the dead zone in the Gulf of Mexico, producing corn for ethanol also has other
adverse environmental impacts. Ethanol production is causing land conversion from other uses such as native grasslands
and forests to cropland for corn production, leading to habitat and biodiversity loss. This
includes loss of habitat for pollinators such as bees . In addition, a pesticide used in ethanol
production, atrazine, is a suspected endocrine disruptor. The EPA has violated its legal duty to consult with the U.S.
Fish and Wildlife Service and the National Marine Fisheries Service on the impacts to federally protected species in connection with the agency’s
annual setting of renewable fuels volumes. For this reason, the Sierra Club has filed its notice of intent to sue the EPA over these issues. The U.S.
Environmental Protection Agency has the capacity to address its violations. It also has the authority to reduce the mandated ethanol blend.
Reducing the production of corn-based ethanol can restore habitats, protect biodiversity, and
lessen the size of the dead zone in the Gulf of Mexico.
Solvency
Solvency – Permitting Solves CAFOs
Requiring permits closes the stormwater exemption that enables CAFOs to
over-apply manure – that solves the primary source of runoff pollution
Review Vol. 92:1187
Limiting the agricultural stormwater exemption to ensure that it actually furthers agricultural
pursuits is crucial because CAFO operators are incentivized to abuse the exemption in
environmentally destructive ways. CAFOs over-apply manure to their fields for disposal, 193
rather than agricultural purposes, because their manure production vastly exceeds their
fertilization needs194 and manure is expensive to transport.195 The concentration of CAFOs in
certain regions compounds this problem.196 To dispose of manure as quickly and cheaply as
possible, CAFOs over-apply manure to their fields.197 The over-application of manure to fields
solely for disposal does not serve any valid agricultural purpose and wreaks havoc on the
environment.198 To ensure the exemption furthers an agricultural purpose, the EPA should limit
its availability to situations where the manure is applied to crops that will be harvested and
utilized for agronomic purposes. 199 This will force CAFO operators to internalize the costs of
their manure production and ensure that it serves a valid agricultural purpose, rather than over-
applying it without concern for the externalized repercussions.200 Cost internalization will
incentivize CAFO owners to pursue new technology and reduce reliance on environmentally
unsound disposal methods. Hoop houses and composting are two examples of more
sustainable methods.201 Additionally, spurring technological innovation effectuates
Congressional intent.202
The affirmative solves – permitting closes regulatory loopholes

Review Vol. 92:1187
CAFOs are a major contributor to the environmental degradation of our water bodies. The
precedent set by the Alt court broadens the agricultural stormwater exemption to allow further
water pollution. As a result, the EPA must step up to the plate and close the loophole in the
agricultural stormwater exemption. Limiting the agricultural stormwater exemption to the land
application area and insti tuting requirements that ensure it furthers an agricultural purpose
while limiting water pollution will help the EPA to effectuate Congressional intent to restore the
integrity of the Nation’s waters.
Solvency – Plan Causes Behavior Change
Permits induce behavior change through restrictions around farm practices –
that’s key
Boehm, 2020
Millions of tons of nitrogen continue to wash off Midwestern farmland each year, fueling the annual Gulf dead zone. This excess
nitrogen, as we documented in this report, causes a range of serious problems for the fishing industry and people along the Gulf
Coast who rely on healthy ocean waters for their livelihoods and cultural traditions. However, our analysis reveals that
significant economic benefits could be realized 14 through reducing Gulf nitrogen loading
attributable to agricultural losses upstream. The fishing industry stands to benefit from increased ecosystem services provided by
healthier waters in the Gulf. Hypoxia is being addressed successfully elsewhere in the United States.
For example, efforts to reduce total daily loads of nitrogen in the Chesapeake Bay and thus reduce hypoxia
have had a positive impact, providing up to an estimated $88 million in annual benefits to the commercial and
recreational fishing industries in the region (Massey et al. 2017). However, for these benefits to materialize for the
Gulf of Mexico, farmers in the Midwest need to adopt agricultural practices that reduce nitrogen losses.
Such practices also benefit farmers, preserving agricultural soils and protecting the water
supplies for countless communities. To achieve these benefits , we offer several policy recommendations
that focus on expanding the adoption of these practices in Midwest agriculture and that bring greater awareness and understanding
to the Gulf Coast fishing industry’s need for healthy ocean waters. INCREASE ADOPTION OF HEALTHY SOIL PRACTICES We
recommend increased funding to expand the adoption of agricultural practices that improve soil
health and keep nutrients such as nitrogen out of our waterways . Large quantities of nitrogen have
accumulated in the Mississippi River basin over the past three decades, and, as our analysis has shown, nitrogen continues to flow to
the Gulf in large quantities. Consequently, action to reduce nitrogen levels in the Gulf are urgently needed.
We stress that additional funding must be spent in ways that cause the largest and most immediate reductions to nitrogen flowing
to the Gulf. The
following federal policy changes are crucial: Establish performance-based
standards or discounts within the federal crop insurance program to incentivize large-scale reduction in
nitrogen losses from farming through improved soil management . As this report has demonstrated, crop
agriculture in the Midwest is the primary source of the nitrogen pollution that makes its way into the Gulf, fueling the dead zone.
Conservation compliance programs have worked in the past to incentivize crop farmers to
adopt practices that benefit soil and water quality (Claassen et al. 2017). As a result, we recommend that crop
insurance programs incentivize the adoption of soil health–building practices that have proven to significantly reduce nitrogen
losses. The
US Department of Agriculture’s Risk Management Agency should give a premium discount to
farmers who use the following agricultural management practices: cover cropping,
conservation tillage, riparian buffers, and perennial plantings.
Solvency – Eliminating the Ag Exemption Key
Eliminating the agriculture exemption is key – status quo incentives rely on
voluntary adoption of new practices that lack funding to be effective
Kasperson 2014 - former editor of Erosion Control and Stormwater magazines
Janice Kaspersen Sep 23rd, 2014 “Reexamining the Ag Exemption”
https://www.stormh2o.com/bmps/article/13013145/reexamining-the-ag-exemption
The discrepancy in how stormwater is regulated–strictly for urban areas and construction sites,
less so or not at all for agricultural lands–has been a sore spot for stormwater managers for
years, but one we rarely talk about because it seems impossible to change. At Stormwater
magazine, we’d like to open that discussion. Many urban stormwater managers feel their
programs’ incremental and costly efforts are undermined by unregulated ag discharge. An often-
cited example is the dead zones in the Gulf of Mexico and elsewhere; the one in the Gulf this
year is about the size of Connecticut, and that’s an improvement from previous years.
Researchers have shown that the source of most of the nutrients causing the dead zones is
agricultural runoff. Compared to that, a city’s illicit discharge detection and elimination program,
no matter how successful, can seem a paltry undertaking. StormCon this past August in Portland
included a program update and Q&A session with representatives from EPA. One question from
the audience–it comes up almost every year in some form–was “Why isn’t runoff from
agricultural land regulated in the same way urban stormwater runoff is?” The EPA folks,
understandably, declined to give a detailed answer, though one of them did say it would take an
act of Congress for things to change. And this is true: Although National Pollutant Discharge
Elimination System (NPDES) permits are required for a few agricultural endeavors, such as
concentrated animal feeding operations, most agriculture is exempt through longstanding
precedent. In a recent rule to clarify what the Clean Water Act covers, EPA and the US Army
Corps of Engineers were very careful to note that the proposed rule preserves current
agricultural exemptions. “Voluntary and regulatory programs serve complementary roles in
providing agricultural producers with the assistance and certainty they need to achieve
individual business and personal goals, and in ensuring protection of water quality and public
health,” states EPA on its website. We’ve mentioned a number of these voluntary programs in
Stormwater and in Erosion Control, such as the Conservation Innovation Grants available
through the Department of Agriculture’s Natural Resources Conservation Service–available for
projects that promote nutrient management and soil health, among other things–as well as the
NRCS’s Conservation Partnership Initiative and the Conservation of Private Grazing Land
Program. The problem is, federal funding to support these voluntary programs has been
shrinking. And although some farmers, ranchers, and landowners willingly participate in such
programs–improving their irrigation practices, using different tillage techniques, or limiting the
amount of fertilizer applied, for example–ensuring that these efforts are truly effective takes
time, effort, and money. The government has set up water-quality monitoring stations in some
states to demonstrate which practices are most effective, and some of the techniques can
actually save money–getting more benefit from well-timed applications of smaller amounts of
fertilizer, say. But as long as participation is voluntary, many of these programs just won’t seem
worth it to many large agricultural producers. There is some precedent for reversing these types
of exemptions. Oil and gas production sites were briefly exempt from Clean Water Act
regulations through a provision in the Energy Policy Act of 2005, but lawsuits by environmental
groups brought that to an end, and such sites are now essentially covered under the same rules
that govern discharges from any other construction site. The agricultural exemption is of longer
standing, however, and arguably more steeped in tradition.
Solvency - CAFOs
Permitting is key to eliminate runoff from CAFOs – corporate farmers will either
adopt more sustainable methods to be eligible or they would be eliminated
entirely

The proposed legislation, the Farm And Rural Model for Sustainable Agriculture through Federal
Enforcement (“FARM SAFE”) Act, would direct taxpayer dollars towards supporting sustainable
agricultural and environmental practices while requiring federal agencies such as the
Environmental Protection Agency (“EPA”) and the U.S. Department of Agriculture (“USDA”) to
enforce environmental and liability standards on agricultural producers. The FARM SAFE Act
would immediately begin mitigating the damage caused by the most flagrantly polluting
industrialized agricultural operations, removing legal exemptions that allow them to avoid
environmental compliance requirements and thus transfer the actual societal costs of their
production methods to the public and the environment as negative externalities.1 Successive
legislative changes would replace direct and indirect federal support for factory farming with
support for diversified small and midsized farms that use sustainable production methods,
laying the groundwork for long-term U.S. food and environmental safety and security. The
history of U.S. support for industrialized agriculture is long and complicated; untangling all the
intricacies would require a book rather than an article. Suffice it to say that the federal
government has a huge influence over how crops are grown and animals are produced, from
how the Legislative Branch establishes policies and appropriates funding to the ways in which
the Executive Branch enforces, or fails to enforce, regulatory requirements.2 Although U.S.
agriculture as a whole is designed to maximize yields at the expense of almost all other con-
siderations, the worst offenders are unquestionably the egregiously polluting live-stock
operations called CAFOs, which is why they are the focus of this Article. CAFOs are significant
sources of polluting emissions and solid and liquid waste, which threaten human, animal, and
ecosystem health. They also are the most extreme manifestation of an increasingly consolidated
and industrialized agricultural production system that gives control over the worldwide food
supply to a smaller and smaller number of corporations. This consolidation, frequently justified
on the basis of meeting global consumer demand for cheap animal-based pro-tein, concentrates
livestock production in animal-dense locations, putting surrounding communities at risk of
pathogen outbreaks and devastating environ-mental harm. Instead of directly eliminating
CAFOs, the FARM SAFE Act would establish a staggered series of legislative changes directing
taxpayer dollars to support sustainable agricultural practices that benefit human health, the
environment, and the rural economy. Although these changes might lead to the total
abandonment of the CAFO model, it is also possible that the staggered approach, combined
with the estimated fifteen-year lifespan of a typical U.S. CAFO constructed today,3 would finally
motivate industrialized agricultural interests to design new facilities in a way that can meet
environmental standards. Either result would be a meaningful improvement over the current
situation, where federal dollars and agencies are used to underwrite the harmful practices of
large corporate entities, rather than promote agriculture that supports the well-being of U.S.
health, environ-ment, and economy.
AT No Enforcement
Chesapeake Bay proves its enforced by the courts
Blankenship 2020 - editor-at-large of the Bay Journal
Karl Blankenship Jan 14, 2020 “Can the EPA enforce the Chesapeake Bay’s ‘pollution diet’?”
https://www.bayjournal.com/news/policy/can-the-epa-enforce-the-chesapeake-bay-s-
pollution-diet/article_97b4488e-3b9c-11ea-aee3-131df627f5d6.html
Likewise, rules governing TMDLs do not establish deadlines, they only state that goals should be
achieved in a “timely manner.” But courts have held that water quality standards are to be met
“reasonably promptly,” and the Bay cleanup could face a court-imposed deadline if the effort
continues to fail, said Ridgeway Hall, an environmental attorney who has worked on Bay issues and written about its TMDL.
(See the related article, MD threatens to sue EPA, PA over lack of action as regional tensions rise.) While the Bay TMDL sets limits
as all TMDLs do, it has several unique aspects. It includes an “accountability framework,” developed by the
EPA and the states in the Bay watershed that goes beyond what TMDLs traditionally require. The
framework includes a 2025 cleanup deadline that was agreed upon by the state-federal Bay Program partnership in 2007. The
accountability framework also requires states to write plans showing how they will meet cleanup
goals, setting two-year milestones to provide “reasonable assurance” that they will meet their goals. Those milestones were
suggested by the states. The TMDL also outlines steps the EPA can take if states fall short of their goals for
reducing pollution, including unregulated discharges from sources such as farms. Those “consequences,” such as forcing
further reductions from regulated sources, are grounded in the EPA’s authority under the Clean Water Act.
AT Overburdens the EPA
The aff is the best way to solve – establishing permitting requirements provides
a federal baseline for action
Pollans 2016 – Pace University School of Law
Margot J. Pollans 2016 “Drinking Water Protection and Agricultural Exceptionalism” 77 Ohio St.
L.J. 1195 (2016), http://digitalcommons.pace.edu/lawfaculty/1051/.
Here, this Article joins the call for a rollback of the Clean Water Act’s agricultural exceptions. Application
of the NPDES
permit program could bring significant relief to water utilities and to particularly burdened ratepayers. The easiest
way to do this would be to change the definition of point source to include at least some agricultural activities, particularly those
that resemble point sources. Many forms of irrigation return flows and field drainage systems channelize both irrigation and
stormwater runoff, creating the potential for measuring pollution outputs, and, if necessary, for installing on farm runoff filtration
systems. Although many criticize pollution permitting systems , under both the CWA and other critical
environmental statutes such as the Clean Air Act, as
inflexible and outdated regulatory mechanisms that should not be
expanded, a well-designed permitting program for farms could learn from these flaws. Removing
the agriculture exemption would subject millions of farms to the NPDES program but would not
necessarily require that the EPA and state environmental agencies issue millions of new permits .
Instead, relying on the general permitting power, the EPA and state agencies could categorize
farms based on relevant factors such as size, crop type, regional hydrology, and proximity to
drinking water sources. The advantage of general permits is that they do not require each farm to apply
for an individual permit, thus saving farmers the onerous task of drafting applications and state
environmental agencies the time consuming burden of separately evaluating each application.
Issuing category-wide general permits for these categories, EPA could impose permit conditions that
draw from the Agency’s existing best management practices. These conditions would rely on EPA’s authority
to issue process rather than performance standards. The Agency might also carve out certain types of low risk farms. The advantage
of thistype of reform is that it responds to the full scope of agricultural pollution, not just that
affecting drinking water supplies. This kind of Clean Water Act amendment is, however, unlikely to occur in the near
future. Current fights over the scope of EPA’s CWA jurisdiction suggest concern in Congress for any expansion of the Agency’s
authority, particularly with regard to agriculture. EPA’s efforts to redefine “waters of the United States” (those waters subject to
CWA regulation) have led to numerous congressional hearings and several proposed bills to contract EPA’s authority. Although CWA
amendment should remain a part of reform discussion as a long-term goal, it is not politically realistic in the near term.
AT States Wont Comply
Status quo protections enable uncooperative states to skate by with minimum
intervention – permitting requirements are necessary to reverse this trend
The current approach to nonpoint source pollution and polluted urban runoff is insufficient to
restore and maintain the chemical, physical, and biological integrity of the nation’s waters. To
achieve the goals of the Clean Water Act, Congress must provide grant funding and financing to
state and local authorities, as well as private landowners, commensurate with the scope of the
pollution challenge. Additionally, the EPA must leverage its legal authority to push for more
rapid water-quality improvements. All too often, state NPS pollution control plans are designed
to avoid legal challenge by clearing the minimum regulatory threshold rather than achieve
success. And states also delay listing water bodies as impaired and slow-walk remediation plans.
The EPA should reject any state water quality standards that do not include numeric water
quality criteria for major categories of nonpoint source pollution and polluted urban runoff, such
as nitrogen, phosphorus, and sediment, among others. The numeric criteria should ratchet
down over time. For watersheds that cross state lines, the EPA should work with states to
determine the relative share of NPS and polluted urban runoff that each state contributes to the
water body during a three-year baseline period and then require each state to make
proportional reductions. States that fail to make adequate progress would risk losing federal
environmental funds and primacy for enforcement of the CWA.
AT Farmers Say No
Farmers wont say no – the success of the organic market proves will adopt new
farming strategies

Sustainable agriculture has the potential of being a true positive for U.S. agriculture. Consider,
for example, the USDA organic program, which successfully created an entirely new,
internationally recognized brand with ever-growing market power. With USDA organic-certified
food now featured on grocery shelves from Whole Foods to Walmart, the success of the organic
program has demonstrated that agricultural producers are willing to embrace new production
methods when they are compensated for them. In the case of the organic program, this
compensation has come in the form of transition assistance and the ability to label and charge a
premium for food produced under specific production and handling standards, such as
prohibitions on synthetic fertilizers and genetic engineering, as well as proactive management of
soil fertility.
AT Status Quo Solves
lack of mandatory permitting enables CAFOs to continue polluting – they would
rather run the risk of fines rather than pay for permits
Review Vol. 92:1187
In 2008, the EPA promulgated a new CAFO Rule.90 It too was challenged by environmental and
farm groups.91 The 2008 Rule replaced the “potential to discharge” standard with a “propose to
discharge” standard and required CAFOs to apply for an NPDES permit if they discharged or
proposed to discharge.92 After reasoning that it would apply to CAFOs who did not discharge,
and were therefore outside the EPA’s statutory authority, the Fifth Circuit struck down the
“propose to discharge” standard.93 As a result of these decisions, “unpermitted CAFOs enjoy
freedom from required permitting unless [the] EPA can show that they are discharging into the
nation’s waters.”94 Many CAFOs remain unpermitted95 because they would rather risk
apprehension than pay the permitting fees.96 Permitted CAFOs must implement a Nutrient
Management Plan as a part of their NPDES permit and, to be eligible for the agricultural
stormwater exemption, their permit must include “site-specific nutrient management practices”
for their land application area.97 Unpermitted CAFOs do not have to institute a Nutrient
Management Plan. Instead their discharges from the land application area are eligible for the
agricultural stormwater exemption if the manure, litter, or process wastewater has been applied
“in accordance with site-specific nutrient management practices.”98 These cases undermined
the EPA’s diligent attempts in 2003 and 2008 to create a regulatory scheme limiting water
pollution from CAFOs. A subsequent case, Alt v. EPA, further weakened the EPA’s regulatory
authority by expanding the scope of the agricultural stormwater exemption. The next part of
this Note provides an overview and critique of the Alt opinion.
AT Counterplans
AT States CP
Internal leakage – The counterplan causes a race to the bottom
Smith and Mignxin 2014 – Vermont Law School
Rebecca Smith And Xiao Mingxin, “CAFOs In The Us And China: A Comparison On The Laws That
Protect Water Quality From Factory Farming”,Http://Www-Assets.Vermontlaw.Edu/Assets/Us-
Asia-Partnerships/Collaborative-Research-Projects/Rebecca%20smith%20-%20cafos%20in
%20the%20us%20and%20china.Pdf
In the US, the EPA leaves the regulation of CAFOs in the hands of the states where it can turns
into a “‘race to the bottom’ when it comes to permitting facilities, enforcing the rules and
preventing water... pollution.”204 In other words, some states may not strictly monitor, enforce, or
regulate CAFOs so that operators will be encouraged to build CAFOs . For example, the EPA
investigated the Illinois environmental agency and found that of the 12 NPDES permits issued ,
only two were still valid and that there were permit applications still in the office that had been
filed 10 years ago.205 And many states have no problem with weaker CAFO laws -- a program director at an
environmental organization explained that “A lot of the factory farms or CAFOs are owned by or have very close business relationships
with slaughterhouses that are owned by national companies... and they’re the kind of companies that would shop around
when deciding where to locate and would likely to choose a place with a weak regulatory
regime.”
Fed will avoid responsibility in the world of the perm – either the CP links or the
perm shields
Glaser 2014 - environmental law lawyer at Troutman Sanders LLP, Carroll McGuffey, III
Peter Glaser, EPA’s Section 111(d) Carbon Rule: What if States Just Said No?, November 2014,
http://www.eenews.net/assets/2015/06/08/document_cpp_16.pdf
“[W]here the Federal Government directs the States to regulate, it may be state officials who
will bear the brunt of public disapproval, while the federal officials who devised the regulatory
program may remain insulated from the electoral ramifications of their decision .” These words,
quoted with approval by Chief Justice Roberts in the Supreme Court’s recent decision striking down the portions of
the Affordable Care Act that attempted to coerce States to accept a significantly expanded Medicaid program,1 apply
with particular force to the latest proposal of the Environmental Protection Agency (EPA or Agency)
to regulate greenhouse gases from the nation’s coal-fired power plants .2 In that proposal,
promulgated under Section 111(d) of the Clean Air Act (CAA),3 EPA seeks to compel States to
become the enablers of the Administration’s vision of what a “transformed”—and much more costly and
unreliable—electric utility system should be. The question is, what if States refuse to go along? What if States refuse to give EPA the
aggressive carbon-reduction plans the Agency is demanding?
AT Voluntary CP
Only regulation solves – the status quo proves financial assistance alone does
not induce change
Gewin 2018 – free-lance science journalist
By Virginia Gewin May 8, 2018 “Farm Runoff in U.S. Waters Has Hit Crisis Levels. Are Farmers
Ready to Change?” https://civileats.com/2018/05/08/farm-runoff-in-us-waters-has-hit-crisis-
levels-are-farmers-ready-to-change/
For the last two decades, Bill Kellogg hasn’t told many people about the approach he uses to growing 5,000 acres of corn and soybeans in Hardin
County, Ohio. The conventional farmer grows cover crops, tills less often than most of his neighbors, applies fertilizer to his fields 4-6 inches
underground, and has planted several pollinator patches on his acreage—all in an effort to improve his soil and cut down on the amount of nitrogen
and phosphorous that runs off his land in the winter. When the Ohio Farm Bureau first asked him to talk about these practices as part of a multimedia
website designed to educate farmers on how to protect their watersheds, he initially declined. “We’ve tried to stay under the radar, and just do our
thing in our corner of the world,” he says, acknowledging that other farmers in his area will often talk at the local coffee shop whenever someone tries
something new. “I’m not a coffee shop guy,” he added. “It was out of my comfort zone to give up our information.” However, after long talks with his
son, Shane, they decided it was time to share what they do. Kellogg fears that if farmers in this region don’t make progress to improve water quality
soon, they’ll face government regulations. In a video on the demo farm website, Kellogg explains: “We need to be proactive in showing our community
and neighbors that we’re serious about taking care of the world around us.” The website provides 360-degree aerial tours of three farms in the
Blanchard River watershed and gives users an intimate view of their fields. Kellogg and his son have given talks to around 1,400 people and another
1,000 visitors have stopped by the farm. “If I didn’t have Shane pushing me on the technology end, I don’t know whether I’d be doing some of these
things,” he says. “I know we’ve opened some peoples’ eyes.” Across
farm country, local and state governments,
federal regulatory agencies, and farm groups are searching for lasting strategies to keep farm
nutrients out waterways. But despite a robust combination of incentives or “carrots,” such as
subsidies and cost-sharing programs, and increasingly, regulation, the problem remains dire. The Size of the
Problem Kellogg is all too aware that many more eyes need to be opened to realize the Ohio Phosphorous Task Force’s goal of reducing excess
phosphorous flowing off farms by 40 percent—the amount needed to reduce or eliminate algal blooms in Lake Erie. The Blanchard River is one of the
waterways delivering farm runoff to the lake, where it fuels toxic algal blooms. As they do throughout the Corn Belt, Ohio row crop farmers—notably of
corn and soy—typically apply fertilizer on their fields in fall. When winter precipitation arrives, the system of tile drainage pipes used on 46 percent of
farm fields provides a perfect pathway for fertilizer runoff to enter waterways. In fact, Lake Erie’s 2014 algae bloom left more than 400,000 residents of
Toledo, Ohio without drinking water for three days. Nitrogen pollution, in the form of dead zones, algal blooms,
and contaminated drinking water, has gotten to be such a dire problem globally that the five-
year, $60 million International Nitrogen Management System —a research effort patterned after the International
Panel on Climate Change—was launched in 2016 to tackle the issue . In the U.S. alone, billions so far have
been spent to encourage farmers to voluntarily adopt practices to improve water quality in the
Chesapeake Bay and the Gulf of Mexico—yet neither region has seen significant change. State and federal level governments
have introduced a variety of cost-share incentive policies and other “carrots” to convince farmers to adopt
conservation approaches, but few have successfully yielded the kinds of voluntary adoption
necessary to make a lasting dent in the pollution. The 2008 U.S. Hypoxia Action plan, a national strategy to reduce the Gulf of
Mexico’s annual dead zone to 5,000 square kilometers, had an ambitious goal of reducing nitrogen and phosphorous amounts by 45 percent by 2015, a
deadline extended to 2035 amid dismal progress. The 2017 dead zone was the largest ever, at 15,032 square kilometers. When
carrots don’t
work, governments are increasingly turning to the “stick” of regulation . Minnesota’s governor just proposed
the state’s first-ever regulation on farmers’ fertilizer use to protect drinking water. After 12 years spent relying on voluntary
efforts in the Chesapeake Bay region, the U.S. Environmental Protection Agency (EPA) finally resorted, in 2010, to imposing a
total maximum daily load (TMDL), of nitrogen and phosphorous from six of the Bay’s surrounding states. In
Pennsylvania, compliance has been “painful,” says Jim Shortle, director of the Center for Nutrient Pollution Solutions at Pennsylvania State University.
The state has the most farmers (in excess of 30,000) of the six and, “it got the worst grade on agricultural oversight on the EPA 2016 report card,” he
says. The threat of regulation—a concern raised in a recent farmer survey—has been a powerful motivator for
some farmers to start changing their practices, says Kellogg. Farm pollution is a problem in just
about every state (here’s a national map of communities whose drinking water has been threatened from the Environmental Working
Group). But most state agencies struggle to reach the majority of farmers, who are working within a
system that prioritizes crop yield. As Bill Kellogg notes, reluctantly, there are two kinds of farmers: those who practice conservation
with the future in mind and those farmers who are only in the here and now for profit. Self-starters like Kellogg are perhaps the best sign of hope.
“We’re beginning to see farmers say they want to be leaders, rather than be forced into actions by regulations,” says Shortle. And that’s welcome news.
“The most effective pressure will come from fellow farmers,” he says. Rebecca Power, director of the North Central Regional Water Network at the
University of Wisconsin, agrees. She says she has seen “a fundamental cultural change” begin to take effect among farmers. Still, change is slow
considering the formidable obstacles in the path. Chiefly, ongoing research on conservation practices can sometimes yield conflicting findings about
what will work in particular regions, sowing enough uncertainty that landowners avoid taking action. To that end, there is a scramble to get enough
technical skill in place to help farmers identify and adopt the best options for their circumstances. But it’s
unclear whether increased
social pressure and technical skills will be enough to reach the magnitude of change many agree
is necessary. “As long as we rely on voluntary action, it is going to be an uphill battle ,” says Shortle.
“The low-hanging fruit is all picked ,” says Shortle. “[Progress] is going to cost money.”
Only the aff solves – stringent requirements are necessary to force changes in
farming practices
Ribaudo 2014 – Economist at U.S. Department of Agriculture based in Washington, D.C.
Marc Ribaudo, Jeffrey Savage, Marcel Aillery June 2014 “An Economic Assessment of Policy
Options To Reduce Agricultural Pollutants in the Chesapeake Bay” Economic Research Service
Report No. 166, US Dept of Agriculture https://www.ers.usda.gov/publications/pub-details/?
pubid=45209
Meeting the TMDL requires significant reductions in agricultural nonpoint-source pollution. The
history of voluntary approaches for meeting watershed water quality goals is not encouraging. Under a
voluntary approach, it is difficult or expensive to entice those farmers who can provide the most abatement
at least cost to enroll in programs and to adopt the most cost-effective practices for improving
water quality. Our models indicate that when farmers are allowed to select which management
systems to implement, the TMDL goals are usually not met . Farmers adopted those systems that
are least costly to them for meeting the policy, and not necessarily those that reduced pollution
at least cost. It may be possible to address this through changes in the way conservation resources are directed. For example,
our analysis indicated that the Susquehanna watershed can provide much abatement at a relatively low cost. The proactive
development of relationships by resource managers with those farms in the watershed most in need of
improvement (rather than waiting for farmers to ask for assistance) and the provision of
appropriate education, technical, and financial assistance could greatly improve the efficiency of
a voluntary approach. While the administrative costs may be higher, the benefits in terms of increased program efficiency
may be significant.
Lack of information means farmers wont voluntarily shift even if the incentives
exist
Gewin 2018 – free-lance science journalist
By Virginia Gewin May 8, 2018 “Farm Runoff in U.S. Waters Has Hit Crisis Levels. Are Farmers
Ready to Change?” https://civileats.com/2018/05/08/farm-runoff-in-us-waters-has-hit-crisis-
levels-are-farmers-ready-to-change/
One thing is certain—farmers don’t like uncertainty . While some say cover crops will save the world, they come with
complex nutrient management dynamics to untangle, says Robyn Wilson, a behavioral decision scientist at Ohio State University.
U.S. Department of Agriculture (USDA) agricultural engineer Kevin King has shown that cover crops, such as rye, can significantly
reduce nitrogen losses in subsurface tile drainage, but had no effect on phosphorous. Yet not all cover crops act the same. Recent
studies have shown that cover crops that die naturally in winter—such as some radishes—could even increase dissolved
phosphorous concentrations in surface runoff. Wilson’s research suggests there
are additional, legitimate reasons
farmers aren’t adopting some conservation practices more effectively . For example, subsurface fertilizer
placement would help maintain the benefits of reduced tillage and reduce nutrient runoff, but it costs twice as much to apply and
the equipment can be expensive and hard to find. A heavy-handed regulatory approach may help achieve faster progress, says
Wilson, “but unless we fix some of these problems, we’ll get pushback.” It’s also easy for uncertainty to translate
into apathy. To adopt a new practice, farmers need to believe it will be effective , says Wilson. “Motivated
farmers are looking for solutions and we [researchers] haven’t convinced them we know what those are,” he adds.¶ Getting
information to farmers remains a hurdle. “There are not enough boots on the ground to deliver
conservation information,” says McMahon. While National Resource Conservation Service (NRCS) staff and
extension agents do a good deal of that work, their numbers are often very limited, and farmers have come to
rely on private-sector crop advisors for support as well. Wolf argues that arming fertilizer reps with a
better understanding of conservation practices could play an important role , however, since state
and federal agencies are chronically budget-constrained. ¶ “The ag retailers are the dominant
way farmers get information,” says Carlson, adding, “and they overwhelmingly are not giving the
right recommendations for growers of cover crops.” Carlson has been arming growers with information to share
with fertilizer representatives in a bid to change the system from the bottom up.¶ Online Resources Help Fill in the Gaps¶ It’s a
problem increasingly being tackled online as well . A growing group of no-till and cover crop
practitioners share images and videos on YouTube and Twitter. And Practical Farmers of Iowa has a series of
YouTube videos, called Rotationally Raised, which describe how to successfully grow diverse crop rotations.¶ Blanchard Demo
Farms Project lead Aaron Heilers says the goal of web-based outreach is to offer data and personal experiences to farmers who may
not attend traditional Field Day events that are miles away from their own farms. “Farmers
want to see the data, [and
know] that these things are working, ” he says.¶ Many early adopters often find their own ways to minimize risks when
trying something new. Nathan Anderson, an Iowa farmer who grows corn, soybeans, and small grains in addition to beef cattle, uses
cover crops on nearly every acre. The cattle made it easier, he says, to get through the learning curve with cover crops because the
cost spent on cover crop seed could be rationalized as feed for the animals. “We reduced our risk by having cattle that could eat our
mistakes,” he says.¶ There’s a cultural dimension as well. For example, Anderson’s first season of cover crop-grazing cattle was a
source of curiosity among neighboring farmers. “Knowing that people are talking about what you are doing can be intimidating,”
says Anderson, although it didn’t hamper his experimentation. As Anderson and others worked out the kinks, neighbors who
may have once been dismissive of the added management time and risk associated with
conservation practices are increasingly interested. “Farmers that I never thought would be
asking me for cover crop advice are asking those questions,” he adds.
Incentives fail - brings more firms into the industry and creates ransom
behavior.
Jack et al 2008 - Sustainability Science Program, Center for International Development,
Harvard University
B. Kelsey Jack et al, July 2008. Carolyn Kousky and Katharine R. E. Sims. “Designing payments for
ecosystem services: Lessons from previous experience with incentive-based mechanisms,”
Proceedings of the National Academy of Sciences, 105.28,
http://www.pnas.org/content/105/28/9465.full.pdf.
By Changing Prices, Incentive-Based Policies May Unintentionally Enhance the Profitability of an

Environmentally Harmful Activity, Undermining Environmental Effectiveness . Incentive-based
mechanisms work by changing relative prices, making environmentally beneficial activities more
profitable and environmentally harmful activities more costly. However, the subsidy-like structure of
many PES schemes carries with it many of the problems characteristic of subsidies (38, 39). The
pollution control literature has demonstrated theoretically that a subsidy that provides firms
with incentives not to pollute could also make it more profitable in the long run for some firms
to enter the industry or to stay in the industry when they otherwise would not have (40). These
firms produce additional pollution, reducing the environmental effectiveness of the subsidy .
Similarly, the additional environmental benefits provided by a PES scheme may be compromised
by new entry or other responses to subsidies over time . Paying farmers to keep land in forest on
some plots might increase the profitability of farming, leading to the clearing of additional plots
(41, 42). Or, if landowners are creditconstrained, receiving cash payments for good behavior on one
parcel of land may provide the income needed to begin an environmentally harmful use on
another. To the extent that PES programs are small and do not change regional prices, or if there is a fixed-factor of
production, then this type of slippage or new entry is less likely to occur (40). These secondary effects must be taken
into account when trying to measure the environmental benefits gained as a result of PES policies. Incentive-
based mechanisms can also create the conditions for ‘‘ransom behavior’’: threats or undesirable
actions aimed at leveraging additional compensation (43). If pollution reduction requirements for firms
are assigned relative to a baseline, firms may deliberately increase pollution emissions to manipulate
baseline emissions. Ransom behavior is also a major concern for PES programs . The problem of
ransom can be alleviated by basing policies on a clear historical baseline or by basing incentives on levels of activities
rather than on changes. Providing incentives for levels, however, may create tradeoffs between avoiding ransom
behavior and paying landholders for activities that might have occurred in the absence of the program (44).
Incentives fail - cause leakage, escalating costs make them unsustainable, and
shifting away from “polluter pays” locks out key tools for environmental
protection
Jaeger 2011 - Professor, Graduate Program in Applied Economics, Oregon State University
William K. Jaeger, August 2011.. “Ecosystem Services and the Potential Role for Markets,” EM
9033, http://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/22427/em9033.pdf
In recent years, interest has grown in publicly funded payments for ecosystem services (PES).
Internationally, there are many examples of payments from high-income countries to low-income countries as a way
to limit destruction of tropical forests (Antle and Stoorvogel 2008, Horan et al. 2008, Wunder 2008, Pattanayak et al.
2010). PES programs seem especially attractive in developing countries, where poverty alleviation is one of several
motivating factors (see, for example, Corbera et al. 2009, Lipper et al. 2009, Bulte et al. 2008). In light of the fact that
MES proposals are unlikely to generate an optimal supply of ecosystem services, supporters of MES have also become
interested in PES as a potential way to protect ecosystem services in the U.S. In contrast to a competitive market, a
PES program likely would be a monopsony, or single-buyer market, with a government agency or other organization
as the source of demand. For this and other reasons, PES approaches may be vulnerable to a number of
sources of inefficiency. Several of these concerns are discussed here. Additionality: an unobserved baseline
Under PES, governments typically pay for reductions in environmental harm. The baseline
against which improvement is measured, however, is unobservable . Payments are based on the
difference between (a) an observed level of pollution or damage, and (b) an unobservable baseline representing the
level of pollution or damage that would have occurred in the absence of such payments. Uncertainty about the
baseline raises questions about the additionality of actions for which payments are made . In
other words, would the action have happened anyway? If the answer is yes, the action is not “additional,”
i.e., the payment was unnecessary. It can be difficult or impossible to know what individuals would do if payments
were not offered. For example, if a payment is made to prevent cutting a stand of forest, we don’t know whether the
landowner would have cut the stand had the payment not been made. A program that pays for nonadditional
protections represents (a) no gain in ecosystem services, (b) a program with low cost effectiveness, and (c) potentially
large transfers of scarce public funds. Several statistical analyses of PES case studies have been based
on satellite images of changes in forest cover in numerous countries. None has found significant
evidence that PES programs have slowed deforestation , in large part because the lands at high risk of
deforestation were not covered by the programs (Blackman and Woodward 2010, Pattanayak et al. 2010). Indeed,
recent analysis of Costa Rica’s wellknown PES program (“Pago por Servicios Ambientales,” or PSA) estimated that less
than 1 percent of lands enrolled in the payment program would have been deforested annually had there been no
payments (Pfaff et al. 2008, Robalino et al. 2008). In some cases, prospective “sellers” may act in ways that
produce a stated baseline that represents more environmental harm than would actually occur
without payments. For example, landowners might harvest forested lands in order to attract
future payments for replanting. Or they might exhibit less care toward conservation or wildfire
prevention if PES holds the promise of payments to restore degraded lands . Leakage Leakage—or
indirect effects—is another problem. In the case of carbon sequestration, for example, leakage occurs when
the decision to avoid deforestation in one location induces increased deforestation elsewhere, primarily due to price
effects. For the U.S. Conservation Reserve Program (CRP), which pays farmers to leave acreage unplanted, these
effects are referred to as slippage and occur via two mechanisms. First, the farm-household receiving
CRP payments may bring other land into production to replace the fallowed land. Second, if
reduced production results in crop price increases, other farmers may bring additional land
under cultivation. In an empirical study of this phenomenon, Wu (2000) suggested that for every 100 acres retired
under the CRP program, 20 acres of noncropland were converted to cropland, offsetting 9 and 14 percent of the
original reduction in water and wind erosion, respectively. Substitutions could also be induced via product, land, or
labor markets. In a PES program, price effects of this kind can lead not only to leakage, but also to
increased taxpayer costs if they push product and land prices up . In the case of the CRP
program, empirical estimates indicate increases in farmland prices of up to 14 percent in some
regions (Wu and Lin 2010). These increases could feed back into the costs of future CRP contracts. In a study of the
effects of creating Redwood National Park on the market for old-growth redwood lumber in 1968 and 1978, Berck
and Bentley (1997) found that removal of these forests from the private timber supply raised the price of redwood
lumber by 26 percent. With a PES approach, such price increases could result in increased program costs.
Neg
CAFOs Advantage
Plan Cant Solve CAFOs
Multiple other policies incentivize the existence of CAFOs – the plan is
insufficient to cause broad change

Although the proposed topic areas focus on industrialized animal agriculture, it is important to
emphasize that current federal agricultural support extends far beyond making CAFOs possible
and profitable. Comprehensively changing the current U.S. model and supporting sustainable
agriculture will require a holistic approach that addresses everything from how the USDA
subsidizes the produc-tion of row crops, to how the EPA fails to regulate agricultural activities
with sig-nificant environmental effects, to how the Department of the Interior allows livestock
grazing on federal rangeland.55 For example, federal policies directly influence which crops
producers decide to plant, and then schoolchildren are served federally subsidized meals as yet
one more way to support the market prices of these overproduced commodities and specialty
crops.56 Each one of these federal resources, and so many more, can be retargeted to support a
food system that truly serves the U.S. people.57 This Article and the FARM SAFE Act it pro-poses
are just a starting point.
AT ABR !
Status quo solves antibiotic resistant diseases
Keller and Sheen 2-17 - Stratfor Global Intelligence
Rebecca, Ben, “Conversation: The Resurgence of Antibiotic Research”,
https://www.stratfor.com/video/conversation-resurgence-antibiotic-research
Rebecca Keller: We're actually starting to see a resurgence of antibiotic research recently. It's a field that
had been pretty stagnant for decades. And over the course of the past year or so, we've seen several
exciting developments in terms of new methods for discovering potential targets as well as a
few new candidates for antibiotics in the future. Ben: So what do you think the wide reaching
implications of this will be? Because clearly it's something, we are developing resistance to as a
species. So how can this actually improve treatment in the future? Rebecca: So we have to keep ahead of
the bacteria. Bacteria are going to evolve. They're going to develop resistance to the current existing treatments. So, when you think
about antibiotics, they're all the same scaffold. So it's kind of like building a house, you build it on the same frame, but the outside of
the house looks different. But the bacteria learned to adapt that scaffold. So you're looking for a whole new scaffold. You're looking
at a skyscraper versus a house of something like that. And so looking at these new scaffolds, you want to look for ones that can't
develop resistance. So teixobactin, which was, the paper on that was published last month that targets an entirely
different part of the cell. So it doesn’t have the potential to develop resistance the same way
current antibiotics do. So you're looking for a whole new solution. You're thinking outside of the box. And in doing so, that
allows you to sort of stay ahead of the bacteria as they evolve as well. They're just trying to survive. Ben: So what do you think of the broader
geopolitical implications of this? And how we're going to see this expand in the world? Rebecca: So when looking at disease, we're not always going to see a geopolitical impact.
There is certainly the potential. Tuberculosis costs $12 billion globally every year, and malaria certainly hinders the economic development of a continent like Africa or parts of
Asia. But there's not always an implication. Drug development is still expensive and these new techniques that have come out in the last several months, whether it be computer
screening to look at a whole bunch of different candidates or growing them specially in the lab like we couldn’t before, it does open a wider array of possibilities, but it's still
under the same old system where it's academic research or pharmaceutical research. It's still very expensive and still very hard to distribute, so it doesn’t have the potential to
reach the multitudes that would be needed to have a really serious geopolitical impact from the drug itself. But when we think about the spread of disease and why we're
worried about the development of antibiotic resistant bacteria, its, we're looking at trade restrictions. We're looking at reduced productivity of countries. Those all could have
geopolitical impacts in the future. It's just not known. So everyone goes, the big geopolitical disease that everyone comes back to is the 1918 Spanish Flu. And that was a huge
epidemic that had serious implications across the globe. And that could happen again. It's not necessarily that it will happen again, but that's the fear, whether it's through a
virus or whether it's through drug resistant bacteria, preventing that is the ultimate goal. And this is, these new antibiotics do go a long way to help that, but there are still
hurdles to overcome in terms of distribution and in terms of development. Ben: And it's always tricky to gain finding for a potential threat that may or
may not manifest. With something like Ebola, the most recent outbreak we saw in Africa, that fact alone sparked a lot of funding
and research and prompted people to actually give money to the cause. Whereas preparing for some future plague it's a difficult
thing in some ways. What do you think the future applications will actually be? How are we going to see this develop? Rebecca: So
that was part of the reason there was such stagnation in the antibacterial development. There
was just no incentive for the pharmaceutical companies to invest money when they knew that the
bacteria were just going to continually evolve and beat the new drug. The incentive is antibacterial resistance
growing. It's becoming a growing problem as people misuse antibiotics. It allows for development of resistance
faster. So it’s a growing problem. We're seeing more cases in hospitals of drug resistant staph infections. Drug resistant tuberculosis
is a huge problem in poorer areas like Former Soviet Union. And so it is an emerging problem. There is that incentive to
now invest in ones that won't develop resistance . So there's still not the financial incentive to invest in the old
model because you'd just be fighting a losing battle. But there is an incentive to come up with these new
methodologies, these computer screens, these new methods of growing microbes in the lab
that allows you to access more potential targets . That’s where the financial incentives is. That’s where the field is
moving, in terms of finding new targets.
ABR won’t cause extinction

Cara 17 (Ed, Vocativ science writer, 1/27/17, “The Attack Of The Superbugs,”
http://www.vocativ.com/394419/attack-of-the-superbugs/ ] lr
For all the warranted gloom, though, Farewell does think there are reasons to be hopeful. “I don’t think we are doing
enough, but the scientific community along with many governmental and private foundations are
very actively involved in finding not only new antibiotics, but new solutions to this problem,” she said.
There’s been a noticeable change in attitude and increased urgency surrounding antibiotic resistance, she said,
one that she hadn’t seen even five years ago, let alone twenty. Until recently, that attitude change could be seen from places as high up as the U.S.
federal government. In 2014, former President Obama issued an executive order aimed at addressing antibiotic
resistance, the first real acknowledgement of the problem from an administration, devoting funding and outlining a national action for
combatting resistance. Through its federal agencies, the administration pushed to reduce antibiotic use on farms and encouraged doctors to stop using
them in excess. “There has been a lot of work done the last couple of years, much of it spurned by [Obama’s] National Action Plan,” said Dr. David Hyun,
a senior officer for Pew Charitable Trusts’ Antibiotic Resistance Project. The CDC, in particular, has used its funding to open up regional labs that allow
them to better detect and respond to antibiotic-resistant outbreaks like the Nevada case, he said. They ultimately hope to create an expansive
surveillance system that can easily keep track of resistance rates on a national, state and regional level. A parallel system also exists for monitoring
resistance in the food chain, shepherded by the CDC and the U.S. Department of Agriculture. In fact, it was this sort of cooperation
between national and local health agencies that enabled Nevada doctors to stop the worst from
happening, said Dr. Lei Chen. The swift identification of a possible CRE strain by the hospital, coupled with the woman’s medical history, led to a
precautionary quarantine, while also prompting Chen’s public health department and eventually the CDC into action. And it may help prevent
future cases from spilling into the public. According to Chen, the CDC has allocated funding this year to all of Nevada’s state
public health departments so they can better detect CRE and other dangerous resistant strains. Under the Trump administration, there’s no telling how
these small victories will hold up or whether they will advance. All references to antibiotics once found on the Whitehouse.gov site have been removed,
including a link to the Obama administration’s national action plan, and the fact that they’re already tried to bar USDA scientists from discussing their
work with the public while stripping funding from other public health agencies isn’t encouraging. Even
with the best public policy,
however, there’s no clear light at the end of the tunnel. Antibiotic resistance has gradually been
worsening, even within the last 15 to 20 years, when superbugs like methicillin-resistant Staphylococcus aureus (MRSA) first became widely
known, said Hyun. The effort needed to develop new drugs has been in short supply, hamstrung by
pharmaceutical companies’ inability to recoup the costs of bringing new antibiotics to market .
That’s because, unlike the latest heart medication, any new antibiotics will have to be treated like the last drops of water during a drought, used as little
as possible — the exact opposite way to make money off a new product. Yet, much like climate change, the financial toll of not doing anything will total
in the trillions years down the road. And it already numbers in the billions now, according to the CDC. Of course, we need bacteria to survive. And most
need or pay no mind to us in return. Even pan-resistant bacteria don’t really mean harm. Some have been found in perfectly healthy people, a fact
that’ll either comfort you or keep you awake at night, only causing problems when our immune system wavers. There’s no army of
sentient E. coli that will rise up and someday overthrow the human race . But barring the calvary showing
up, a new fear of ours will learn to settle in, almost unnoticed. It’ll creep in when we pick our heads up from a nasty fall that scrapes our skin open or
breaks our bones; when we wave goodbye to our loved ones before they enter an operating room, or when we cradle our newborns into a world
teeming with the living infinitesimal, wishing there was still a way to shield them from it as our parents once could for us. A fear of naked vulnerability.
The antibiotic apocalypse will be gentle , if it fully arrives, but it won’t be any less devastating to the human spirit.
ABR is slow and gradual --- reject their alarmism

Smith 16 [Drew Smith 16, former R&D director at MicroPhage and SomaLogic, 6/14/16, “The
Myth Of The Post-Antibiotic Era,” https://www.forbes.com/sites/quora/2016/06/14/the-myth-
of-the-post-antibiotic-era/#db027696fa83]
Right now, drug resistant infections are mainly a threat to those that are already sick and/or in medical facilities.
But, if we continue down this path, mundane infections in the otherwise healthy could someday morph into life-
threatening ordeals, and simple medical procedures and surgeries may be skipped to avoid risk of infection. However, while this threat is real, it’s
important to keep in mind that this is an ongoing, gradual challenge; it’s extremely unlikely that a single event
will herald with complete certainty the abrupt end of modern medicine as we know it. In this context, those
scary headlines are inappropriate, if not numbing and counterproductive. In May, Ars wrote about some alarmist and inaccurate
news stories dealing with a newly identified type of drug resistance—one that makes bacteria resistant to a last-resort
antibiotic called colistin and can spread between bacteria easily. The headlines blared that it was the “first” time such a dastardly
microbe had seeped into the US—which is not true . And they suggested that it would certainly
mark the end of antibiotics—also not true. This week, scientists provided updates on tracking that type of
resistance, and of course some alarmist headlines followed. Yet, the new data actually suggests that
a tempering of concerns about this particular resistance may be in order. It turns out that this “dreaded,” "scary," “nightmare” of a drug-resistant microbe has
been in the US for more than a year and elsewhere in the world since as far back as 2005—it’s just that nobody noticed it. And nobody noticed it because so far it hasn’t been
the dreaded, scary nightmare some have feared. “ It’s not a huge cause for concern,” Mariana Castanheira, lead author of one of this week's
resistance updates, told Ars. Castanheira is the director for Molecular and Microbiology at JMI Laboratories, a private company that monitors drug resistance microbes in
people
hospitals and medical settings. They and others are finding this new type of resistance now simply because they’re looking for it, she said. Castanheira explains that
initially started digging for this new type of drug resistance —a gene called mcr-1—out of concern that it
makes bacteria resistant to the antibiotic colistin, which is a relatively toxic drug used only when nearly all others have failed against a multi-drug
resistant infection. Bacteria have shown up with colistin resistance before —in fact, many times in the US and elsewhere around the
world. But in those cases, the genes were embedded in the bacteria’s chromosomes and generally passed down through generations. The mcr-1 resistance gene, on the other
If colistin-resistant bacteria shared

hand, seems to always sit on a plasmid, a small loop of DNA that bacteria can readily pass around to neighbors.
their mcr-1 plasmid with others that are already resistant to lots of antibiotics, they could create a long-
feared invincible germ—a “pan-resistant” bacteria. "Doesn't scare me" So far that doesn’t seem to be happening, though,
Castanheira said. In more than a decade of skulking around , mcr-1 has made its way into bacteria in animals, people, and soil all over the
world. Yet, all of the mcr-1 carrying microbes examined have been susceptible to at least one antibiotic—
and often several.

AT Disease – Burnout
Resiliency, intervening actors, burnout

Adalja, 16 - infectious-disease physician at the University of Pittsburgh (Amesh, "Why Hasn't
Disease Wiped out the Human Race?," The Atlantic, 6-17-2016,
https://www.theatlantic.com/health/archive/2016/06/infectious-diseases-extinction/487514/)
In Michael Crichton’s The Andromeda Strain, the canonical book in the disease-outbreak genre, an alien microbe threatens the
human race with extinction, and humanity’s best minds are marshaled to combat the enemy organism. Fortunately, outside
of
fiction, there’s no reason to expect alien pathogens to wage war on the human race any time
soon, and my analysis suggests that any real-life domestic microbe reaching an extinction level
of threat probably is just as unlikely.
When humans began to focus their minds on the problems posed by infectious disease, human life ceased being nasty, brutish, and
short.
Any apocalyptic pathogen would need to possess a very special combination of two attributes. First, it
would have to be so unfamiliar that no existing therapy or vaccine could be applied to it . Second, it
would need to have a high and surreptitious transmissibility before symptoms occur. The first is
essential because any microbe from a known class of pathogens would, by definition, have family members that
could serve as models for containment and countermeasures. The second would allow the
hypothetical disease to spread without being detected by even the most astute clinicians.
The three infectious diseases most likely to be considered extinction-level threats in the world
today—influenza, HIV, and Ebola—don’t meet these two requirements. Influenza, for instance, despite
its well-established ability to kill on a large scale, its contagiousness, and its unrivaled ability to shift and drift away from our
vaccines, is still what I would call a “known
unknown.” While there are many mysteries about how new flu strains emerge,
from at least the time of Hippocrates, humans have been attuned to its risk . And in the modern era, a full-fledged
industry of influenza preparedness exists, with effective vaccine strategies and antiviral
therapies.
HIV, which has killed 39 million people over several decades, is similarly limited due to several factors. Most
importantly, HIV’s dependency on blood and body fluid for transmission (similar to Ebola) requires
intimate human-to-human contact, which limits contagion. Highly potent antiviral therapy allows
most people to live normally with the disease , and a substantial group of the population has
genetic mutations that render them impervious to infection in the first place. Lastly, simple prevention
strategies such as needle exchange for injection drug users and barrier contraceptives—when
available—can curtail transmission risk .
Ebola, for many of the same reasons as HIV as well as several others, also falls short of the mark. This is especially due to
the fact that it spreads almost exclusively through people with easily recognizable symptoms, plus the
taming of its once unfathomable 90 percent mortality rate by simple supportive care.
Beyond those three, every other known disease falls short of what seems required to wipe out
humans—which is, of course, why we’re still here. And it’s not that diseases are ineffective. On the contrary, diseases’
failure to knock us out is a testament to just how resilient humans are. Part of our evolutionary
heritage is our immune system, one of the most complex on the planet, even without the benefit of vaccines or
the helping hand of antimicrobial drugs. This system, when viewed at a species level, can adapt to almost any enemy
imaginable. Coupled to genetic variations amongst humans —which open up the possibility for a
range of advantages, from imperviousness to infection to a tendency for mild symptoms—this adaptability ensures
that almost any infectious disease onslaught will leave a large proportion of the population
alive to rebuild, in contrast to the fictional Hollywood versions.
While the immune system’s role can never be understated, an even more powerful protector is the faculty of consciousness.
Humans are not the most prolific, quickly evolving, or strongest organisms on the planet, but as Aristotle identified, humans
are
the rational animals—and it is this fundamental distinguishing characteristic that allows humans
to form abstractions, think in principles, and plan long-range. These capacities, in turn, allow humans to
modify, alter, and improve themselves and their environments . Consciousness equips us, at an
individual and a species level, to make nature safe for the species through such technological marvels as antibiotics,
antivirals, vaccines, and sanitation. When humans began to focus their minds on the problems posed by infectious
disease, human life ceased being nasty, brutish, and short. In many ways, human consciousness became infectious diseases’
worthiest adversary.
Burnout and variation check

York 14 (Ian, head of the Influenza Molecular Virology and Vaccines team in the Immunology
and Pathogenesis Branch of the Influenza Division at the CDC, PhD in Molecular Virology and
Immunology from McMaster University, M.Sc. in Veterinary Microbiology and Immunology from
the University of Guelph, former Assistant Prof of Microbiology & Molecular Genetics at
Michigan State, “Why Don't Diseases Completely Wipe Out Species?” 6/4/2014,
http://www.quora.com/Why-dont-diseases-completely-wipe-out-species)
But mostly diseases don't drive species extinct. There are several reasons for that. For one, the most
dangerous diseases are those that spread from one individual to another. If the disease is highly
lethal, then the population drops, and it becomes less likely that individuals will contact each
other during the infectious phase. Highly contagious diseases tend to burn themselves out that way.¶ Probably the
main reason is variation. Within the host and the pathogen population there will be a wide range of variants. Some hosts may
be naturally resistant. Some pathogens will be less virulent. And either alone or in combination, you end up
with infected individuals who survive.¶ We see this in HIV, for example. There is a small fraction of humans who are naturally resistant
or altogether immune to HIV, either because of their CCR5 allele or their MHC Class I type. And there are a handful of people who were infected with
defective versions of HIV that didn't progress to disease. ¶ We can see indications of this sort of thing happening in the past, because our genomes
contain many instances of pathogen resistance genes that have spread through the whole population.
Those all started off as rare mutations that conferred a strong selection advantage to the carriers, meaning that the
specific infectious diseases were serious threats to the species.
Deadzones Advantage
Cant Solve – Free Riders
The plan cant solve – the number of farms makes it impossible to monitor and
causes free riders
Ribaudo et al. 2008 –
Marc Ribaudo, Fred Kuchler, and Lisa Mancino November 01, 2008 “Market Failures: When the
Invisible Hand Gets Shaky” Feature: Agricultural Research and Productivity
https://www.ers.usda.gov/amber-waves/2008/november/market-failures-when-the-invisible-
hand-gets-shaky/
Agriculture is the source of a variety of pollutants—like nutrients, pesticides, sediment, and greenhouse gases—and is routinely
identified as the major source of impaired waters in much of the country. If markets allocate resources to their highest and best use,
is pollution from agriculture simply an undesirable but unavoidable outcome of doing business? Or is pollution a sign that markets
are not operating as expected and resources are not being allocated efficiently? As long as farmers can discharge
agricultural chemicals into waterways without being charged for the costs their actions impose on other
water users, the prices of the food they produce (and the chemicals they use) will not reflect full societal costs. And if prices
are not accurate indicators of costs, markets cannot allocate resources efficiently . Market prices
encourage farmers to produce more crops and more water pollution than if pollution’s costs
were reflected in those prices. This source of market failure is known as a negative externality. One solution is for
water users who are harmed by pollution to negotiate water quality with farmers. But doing so
would be costly and complicated. Take the case of hypoxia in the Gulf of Mexico, a “dead zone” caused by excessive
nitrogen coming down the Mississippi River. Simply identifying the numerous farmers in the Mississippi
Basin who contribute nitrogen to the Mississippi River would be an enormous task. The large
numbers of fishermen, water recreationists, and households affected by excess nitrogen in
rivers and streams would make the costs of negotiating an efficient outcome even more
onerous. It is not just the numbers of people involved that make negotiation impractical . Water
quality is a public good; individuals may enjoy the benefits without paying the cost (see box, “Why Public
Goods Defy Markets”). If one person pays farmers to reduce pollution, it is nearly impossible to
exclude other downstream water users from benefiting as well . As long as water users believe
that someone else is going to pay to reduce pollution, they have no incentive to pay for it
themselves, or even to reveal that they benefit from the improvement . If every water user
follows the same logic, water pollution persists.
AT Dead zones
No dead zones impact and alt causes.
Duarte, et al, 15—University of Western Australia's Oceans Institute and School of Plant Biology,
Department of Global Change Research at the Instituto Mediterráneo de Estudios Avanzados
(Carlos, with Robinson W. Fulweiler, Department of Earth and Environment and the Department
of Biology at Boston University, Catherine E. Lovelock and John M. Pandolfi both School of
Biological Sciences at the University of Queensland, Paulina Martinetto, Laboratorio de Ecología
at the Instituto de Investigaciones Marinas y Costeras, Megan I. Saunders, Global Change
Institute and the Marine Spatial Ecology Lab at the University of Queensland, Stefan Gelcich,
Laboratorio Internacional en Cambio Global (Lincglobal) and with the Centro de Conservacion
Marina, in the Departamento de Ecologia, Facultad de Ciencias Biologicas, at the Pontificia
Universidad Catolica de Chile, Scott Nixon, Graduate School of Oceanography at the University
of Rhode Island, “Reconsidering Ocean Calamities,” BioScience (February 2015) 65 (2): 130-139,
dml)
It is tempting to assume that all harmful algal blooms (HABs) are caused only by human activities,
such as changes to the delivery of both the quantity and the ratio of nutrients available to marine systems (Nixon 1995). In
particular, excess nitrogen and phosphorus in reference to silica favors the growth and proliferation of nonsiliceous
phytoplankton, most often flagellates (Van Dolah 2000). Reduced nutrient inputs have , therefore, proven
successful in reducing HABs in some cases (Okaichi 1997, Bodeanu and Ruta 1998). However, the connections
between anthropogenic eutrophication and HAB proliferation is more uncertain in some cases
(Anderson et al. 2012), such as HAB occurrence in association with upwelling nutrient supplies (Anderson et al.
2008) or nutrient limitation rather than excess (Smayda 2008). Overall, a complex picture remains, with
clear cases of some HAB's being driven solely by human activities; some being driven by larger-
scale forcings; and those that, at this point, cannot be cleanly associated with one cause or another.
AT Dead zones – timeframe
Its not reverse causal – it would take years for the plan to effect deadzones in
the Gulf
Chen 2019 - science and environment reporter at St. Louis Public Radio
Eli Chen 10/25/2019 “Reducing Runoff To Protect The Gulf”
https://www.sciencefriday.com/segments/sos-reducing-runoff-to-protect-the-gulf/
Research suggests it could be many years before efforts by farmers and state governments
would make much of a difference in the Gulf of Mexico, said Steven Herrington, director of
science and impact measures at the Nature Conservancy’s Missouri chapter. “Let’s say we
reduced all of our nitrogen into our soil to zero,” Herrington said. “We still have a legacy of
nitrogen in our soils from decades and decades of agriculture that would still be moving down
through these systems.”
They cant solve the advantage for hundreds of years

Eller 2019 – covers agriculture, the environment and energy for the Register
Donnelle Eller July 17 2019 “Iowa could need hundreds, potentially thousands of years to reach
nutrient goals under current approach” Des Moines Register
https://www.desmoinesregister.com/story/money/agriculture/2019/07/17/iowa-water-quality-
years-nutrient-reduction-goals-gulf-mexico-dead-zone-environment-council-
nitrogen/1746256001/
It could take Iowa hundreds, potentially thousands of years to reach its goal to cut by 45% the
nutrients that contribute to the Gulf of Mexico dead zone, according to a new report. The Iowa
Environmental Council said Tuesday the state needs to reassess its approach to cutting nitrogen
and phosphorus levels that leave the state and contribute to the Gulf dead zone, an area the size of Massachusetts this
summer that's unable to support marine life. "The rate of implementation we have now does not reach the
nutrient reduction goals in any kind of timely fashion ," said Ingrid Gronstal Anderson, the council's water
program director. "We're talking hundreds to thousands of years at the current rate to get to the goals of the nutrient reduction
strategy," she said. "We need to look at doing things differently to scale things up." The state adopted the Iowa Nutrient Reduction
Strategy in 2013 to cut the nitrogen and phosphorus levels from places such as wastewater treatment plants, factories and farms.
Agriculture has come under intense scrutiny for its role in adding to the dead zone, since its participation in meeting nutrient
reduction goals is voluntary. Mike Naig, Iowa's agriculture secretary, said the council's assessment is unfair, since the state's
adoption rate is likely to increase. State lawmakers agreed last year to pump $282 million into water quality improvements over 12
years. The money available for conservation practices such as building wetlands and bioreactors to filter and clean water will
increase annually. "We're just beginning to see the impact of those dollars," Naig said. "We're really focused on ramping up." Naig
said the state also is aggressively seeking federal money to support water quality projects. For example, the state received nearly
$1.2 million this month from the U.S. Environmental Protection Agency to help build six wetlands. Last year, the state reported that
public and private investment in "nutrient reduction-related" practices reached $512 million, the Environmental Council said. But
most of the money was payments to farmers for participating in Conservation Reserve Program and other federal initiatives. Only
about $17 million was spent on "Nutrient Reduction Strategy-focused" initiatives such as building wetlands and bioreactors, and
planting cover crops, the group said. Even with increasing funding, it's a small amount compared to the
cost to address nutrient pollution, the Environmental Council said. The state strategy estimates it could cost up to $1.2
billion annually to meet its goals. Under the state's current rate of adoption, the Environmental Council says it will take:
93 years to reach the state's goal to adopt 12.6 million acres of cover crops, seeded each fall to
help hold nitrogen and phosphorus in the soil . Cover crop acres have increased from about 15,000 acres in 2011 to
760,000 in 2017. 913 years to treat 7.7 million acres with wetlands that help filter nitrates from water. So
far, 104,000 acres are being treated. 31,103 years to treat 6 million acres with bioreactors, a structure that
intercepts water leaving a field and runs it through wood chips or other materials , where
microorganisms break down nitrates.
No Biodiversity !
No environmental extinction, and intervening actors solve.
Kareiva & Carranza 18, * Director of the Institute of the Environment and Sustainability
at UCLA, Pritzker Distinguished Professor in Environment & Sustainability and Chair,
Doctorate, in the Environmental Science and Engineering program; **PhD Student at
University of California, Riverside. (Peter, Valerie, “Existential risk due to ecosystem
collapse: Nature strikes back”, Futures, 102, pg. 39-50, doi: 10.1016/j.futures.2018.01.001)
While there are data that relate local reductions in species richness to altered ecosystem
function, these results do not point to substantial existential risks. The data are small-
scale experiments in which plant productivity, or nutrient retention is reduced as species
number declines locally (Vellend, 2017), or are local observations of increased variability in
fisheries yield when stock diversity is lost (Schindler et al., 2010). Those are not existential
risks. To make the link even more tenuous, there is little evidence that biodiversity is
even declining at local scales (Vellend et al 2017; Vellend et al., 2013). Total planetary
biodiversity may be in decline, but local and regional biodiversity is often staying the same
because species from elsewhere replace local losses, albeit homogenizing the world in the
process. Although the majority of conservation scientists are likely to flinch at this
conclusion, there is growing skepticism regarding the strength of evidence linking trends in
biodiversity loss to an existential risk for humans (Maier, 2012; Vellend, 2014). Obviously if
all biodiversity disappeared civilization would end—but no one is forecasting the loss of all
species. It seems plausible that the loss of 90% of the world’s species could also be
apocalyptic, but not one is predicting that degree of biodiversity loss either. Tragic, but
plausible is the possibility our planet suffering a loss of as many as half of its species. If
global biodiversity were halved, but at the same time locally the number of species stayed
relatively stable, what would be the mechanism for an end-of-civilization or even end of
human prosperity scenario? Extinctions and biodiversity loss are ethical and spiritual
losses, but perhaps not an existential risk.
What about the remaining eight planetary boundaries? Stratospheric ozone depletion is one
—but thanks to the Montreal Protocol ozone depletion is being reversed (Hand, 2016).
Disruptions of the nitrogen cycle and of the phosphorous cycle have also been proposed as
representing potential planetary boundaries (one boundary for nitrogen and one boundary
for phosphorous). There are compelling data linking excesses in these nutrients to
environmental damage. For example, over-application of fertilizer in Midwestern USA has
led to dead zones in the Gulf of Mexico. Similarly, excessive nitrogen has polluted
groundwater in California to such an extent that it is unsuitable for drinking and some
rural communities are forced to drink bottled water. However, these impacts are local. At
the same time that there is too much N loading in the US, there is a need for more N in
Africa as a way of increasing agricultural yields (Mueller et al., 2012). While the disruption
of nitrogen and phosphorous cycles clearly perturb local ecosystems, end-of-the-world
scenarios seem a bit far-fetched.
Another hypothesized planetary boundary entails the conversion of natural habitats to
agricultural land. The mechanism by which too much agricultural land could cause a crisis is
unclear—unless it is because land conversion causes so much biodiversity loss that is
species extinctions that are the proximate cause of an eco-catastrophe. Excessive chemical
pollution and excessive atmospheric aerosol loading have each been suggested as
planetary boundaries as well. In the case of these pollution boundaries, there are well-
documented mechanisms by which surpassing some concentration of a pollutant inflicts
severe human health hazards. There is abundant evidence linking chemical and aerosol
pollution to higher mortality and lower reproductive success in humans, which in turn
could cause a major die-off. It is perhaps appropriate then that when Hollywood envisions
an unlivable world, it often invokes a story of humans poisoning themselves. That said, it is
doubtful that we will poison ourselves towards extinction. Data show that as nations
develop and increase their wealth, they tend to clean up their air and water and reduce
environmental pollution (Flö rke et al., 2013; Hao & Wang, 2005). In addition, as
economies become more circular (see Mathews & Tan, 2016), environmental damage due
to waste products is likely to decline. The key point is that the pollutants associated with
the planetary boundaries are so widely recognized, and the consequences of local toxic
events are so immediate, that it is reasonable to expect national governments to act
before we suffer a planetary ecocatastrophe.
No biodiversity impact – most losses have no impact on humans, and we can

easily adapt.
Blomqvist ’18 (Linus; is Director of Conservation and Food & Agriculture at Breakthrough;
November 6th; “Does wildlife loss threaten civilization?”;
https://thebreakthrough.org/issues/conservation/does-wildlife-loss-threaten-civilization;
In the widest sense of the word — nature as everything except humans — this is hard to
disagree with. But framing the loss of wild species as a threat to human civilization and
material well-being is a questionable proposition. The declines in animal populations
documented in the Living Planet Report are tragic and painful news for nature and wildlife
enthusiasts like myself. Yet it is not clear that the loss of species and populations, even at
the scale we’ve seen in the last few decades, really endangers human material well-
being. Overall well-being and quality of life certainly are affected, no doubt — less non-
human life makes for a world that is less beautiful and exciting — but the same may not be
true for material well-being.
Of course, there are ecosystem services like carbon sequestration and flood control that
provide clear benefits to society, and this can sometimes justify protecting ecosystems as a
whole. But as for the role of species diversity and abundance in enabling these services,
the evidence is mixed. In some cases, such as with carbon sequestration, a greater
diversity of plants can be a boon. But non-native, generalist species can often support an
ecosystem service just as well as native species. Simplification of ecosystems can
sometimes enhance service provision; this is the essence of agriculture. And for ecosystem
services like flood protection and water quality, there is no clear relationship with
biodiversity. A tree canopy and some undergrowth will do just fine in many cases. Even in
cases where biodiversity enhances ecosystem function, like primary productivity, it might
not improve the service, if there is no human demand for it.
It’s hard not to observe, for instance, that while populations of wild species have been
thoroughly depleted in places like Europe, whose landscapes have been deeply
transformed for millennia, Europeans are, overall, healthy, well-fed, and enjoy high living
standards. Meanwhile, the world’s poorest and most vulnerable populations are often
found in tropical regions rich in biodiversity, such as the Congo Basin. Furthermore, we all
seem to be doing just fine without the megafauna that went extinct even before the
emergence of agriculture, at least in part due to human pressures.
Some have suggested that this presents an “environmentalist’s paradox”: why has human
well-being increased even as wildlife and natural ecosystems have declined? I’m not sure,
however, that it’s much of a paradox. Humans through the ages have altered their
environment to better serve their needs — and that has often meant converting natural
habitats to cropland or favoring some species over others. For example, while there were
also more sinister motives behind the near eradication of American bison, one simple driver
was the fact that cattle were easier to raise and provided more food and higher profits.
I’m acutely aware of the fact that the stories we tell can influence the public’s support for
conservation, and I am as dedicated as any other conservationist to finding narratives that
can persuade people to care for wildlife. It is entirely understandable that many
conservationists have embraced the argument that species should be preserved because
they provide “life support” to people and societies. But I have a hard time arguing in good
faith that further wildlife losses per se would prove catastrophic to the material basis
of societies. And I worry that pushing the argument too far — that our lives depend on
wildlife — could eventually backfire if it is later perceived as crying wolf. This could
jeopardize the public’s trust in conservation scientists and practitioners. To avoid that, we
need to reconcile ourselves to the thought that many wild animals, while priceless in the
aesthetic and spiritual sense, might be dispensable in the material sense.
Solvency
No Solvency – EPA Ineffective
The plan cant solve – regulatory hurdles, state backlash, and legal challenges
take out the aff
McConnell 2017 – J.D. Candidate, University of California, Berkeley, School of Law
K.A. McConnell “Limits of American Farm Bureau Federation v. EPA and the Clean Water Act’s
TMDL Provision in the Mississippi River Basin” Ecology Law Quarterly Vol. 44:469
Three seemingly insurmountable roadblocks exist when attempting to transfer the Chesapeake
Bay model to the Mississippi River Basin. First, the EPA has made clear its reluctance in taking on
water quality issues in the Mississippi River Basin, given the daunting management challenges it
presents. Second, even if the EPA wanted to take on the challenge of creating a watershed-wide
TMDL for the Mississippi River Basin, the EPA would likely face political backlash from the
conservative, agricultural states lining the river. Such opposition would only add to the EPA’s
administrative burden by limiting the agency’s access to local knowledge regarding the sources
of pollution and their relative economic significance. Lastly, even if the EPA were able to
promulgate a prescriptive, watershed-wide TMDL for the Mississippi River Basin in the face of
vehement opposition, a court would be unlikely to uphold the validity of such a TMDL based on
the Third Circuit’s opinion in American Farm Bureau if any affected state challenged its
implementation.
No Solvency – Cant Enforce
The plan cant solve – nutrient baselines lack coordination, aren’t enforced at
the state level, and lack the necessary tools to force farmers to change
behaviors
Many regarded the TMDL provision as a positive “first step” toward controlling nonpoint source pollution.43 With little evidence of
its effectiveness,44 however, significant skepticism exists as to whether the TMDL program is at all
useful in trying to address America’s nonpoint source pollution problem.45 At their heart, TMDLs are merely
“informational tools,” with limited ability to spur state action.46 Even if the features of the 2000 TMDL rule
had survived, TMDLs would remain a flawed planning mechanism to address nonpoint source
pollution. The TMDL statute does little to ensure states produce coordinated plans capable of
improving and protecting water quality throughout the entirety of shared, interstate bodies of water.
The EPA’s 1991 TMDL Guidance envisioned a “watershed planning” program, but such an approach is not reflected in either the
statute or the EPA’s regulations.47 Under the TMDL provision and its current regulations, no
role exists for the federal
government to coordinate states’ TMDLs to ensure upstream states’ nonpoint source
pollution does not burden downstream states’ efforts to meet their water quality standards. The
system is fragmented, with each state submitting its own TMDLs in isolation from the plans of
surrounding states sharing the same body of water.48 Without direct authority to regulate nonpoint source pollution, the EPA’s only
recourse to protect downstream states is to ensure upstream NPDES permits are strict enough to meet downstream water quality
standards.49 For example, if an upstream state’s pollution is causing a violation of a downstream state’s water quality standards,
EPA has the authority to deny point source polluters permits to discharge until downstream water quality standards are met.
Therefore, the TMDL program—designed to address nonpoint source pollution—is inherently flawed, as it
leaves the federal government no way to hold a state’s nonpoint source polluters accountable
for their respective contribution to an interstate water’s water quality violations.50 The program relies on the states to
hold their nonpoint source polluters accountable , which they have little political incentive to
do.51 Potential consequences for inadequate state action include (1) the EPA promulgating its own TMDLs for the state, (2)
withholding nonpoint source management plan funding if states do not attempt to implement the EPA’s TMDLs, and (3) federally-
initiated restrictions on guiltless point source polluters.52 None of these “penalties”
punish nonpoint source
polluters. Thus, a problematic regulatory gap exists in the CWA where the federal government is
unable to regulate nonpoint source pollution in upstream states, even when it leads to water
quality violations in downstream states.53 This gap shifts the burden of reducing pollution from
nonpoint source to point source polluters, leaving nonpoint source polluters, like the
agricultural industry, largely unaccountable even though they contribute a significant portion of today’s water
pollution.54 Furthermore, such a gap leaves activities that negatively affect interstate commerce
essentially unregulated and impedes the EPA’s ability to carry out the CWA’s mandate to restore
and maintain the integrity of the nation’s waters.
EPA cant coordinate national standards

Due to the constraints of the CWA’s cooperative federalism framework, nonpoint source
pollution continues to plague waterways across the country, in violation of the statute’s goal to
restore and maintain the integrity of the nation’s waters. The goal of the CWA is gravely
compromised by the dependence upon state and local governments to regulate nonpoint
source pollution, whose generally poor record of controlling pollution triggered the need for
federal legislation in the first place. While the CWA’s TMDL provision was considered a positive
first step toward facilitating the implementation plans necessary to reduce nonpoint source
pollution in impaired waters, the provision has largely failed in this respect. Part of the reason
for the failure of TMDLs is the lack of statutory authority for the EPA to coordinate TMDLs in
interstate bodies of water that are capable of holding upstream nonpoint source polluters
accountable for their effects downstream.214 The Chesapeake Bay TMDL stands as a shining
example of what is possible when cooperative federalism works as intended. With the
permission of the Bay jurisdictions to set a watershed-wide TMDL in the first instance, the EPA
capitalized on decades of coordinating efforts from state and local jurisdictions, Congress, and
the executive branch, and was able to transform the concept of a TMDL into a meaningful,
interstate water quality standard attainment plan. By leaving much of the pollution allocating to
the states in their interim WIPs, and by effectively leveraging proxy actions to ensure states are
held accountable for their share of the Bay’s pollution, the Bay jurisdictions were able to bridge
the regulatory gap in the CWA’s TMDL provision to address nonpoint source pollution in a
treasured interstate body of water. Yet, despite the success of the Chesapeake Bay TMDL, the
CWA’s regulatory gap still exists, and the American Farm Bureau decision does little to remedy
that. The regulatory gap persists, as it always has, when states do not cooperate. Through an
examination of the applicability of the Chesapeake Bay model in the Mississippi River Basin
context, it is clear that the politics of a watershed will dictate whether a federal TMDL can be
established. What made the Chesapeake Bay TMDL possible was the Bay jurisdictions’
willingness to partner with the EPA to reduce pollution that directly affected them. Because
such an incentive is currently lacking among most states within the Mississippi River Basin,
cooperation and a federal TMDL are unlikely to occur. Until Basin state leadership feels the
threat of regulation, it will not appreciate the benefits of cooperation, and the nutrient problem
in the Mississippi River Basin will go unaddressed.
No Solvency – EPA lacks resources
EPA lacks the resources to determine the standards necessary for permits
The EPA has explained it has no interest in crafting a watershed-wide TMDL that the Mississippi
River Basin states have not asked for and are not prepared to develop.154 Without active
interest and cooperation from the states, a watershed-wide TMDL is virtually impossible. The
Mississippi River Basin is the nation’s largest watershed, extending over thirty-one states.155
Coordinating such a massive TMDL, even without state and industry pushback, would be a huge
administrative burden for the EPA.156 While the bulk of the Chesapeake Bay watershed is
housed within a single EPA region,157 the Mississippi River Basin spans six different EPA regions,
further complicating the agency’s ability to coordinate such a colossal undertaking.158 Recent
litigation concerning water quality in the Mississippi River highlights both the EPA’s
unwillingness to play a major role in improving water quality in the Basin and the court’s
hesitancy to force such a burden upon the agency.159 In Gulf Restoration Network v. Jackson,
environmental advocacy groups challenged the EPA’s denial of their petition requesting the
promulgation of federal numeric water quality standards for nitrogen and phosphorous.160 In
response, the agency voiced its preference to pursue a more “effective and sustainable”
approach to water quality in the Mississippi River by “work[ing] cooperatively” with state
agencies.161 The EPA noted the request to promulgate federal numeric nutrient criteria for
thirty-one states at once is “unprecedented and complex,” “highly resource and time intensive,”
and ultimately impractical.162 Before requiring the EPA to make a necessity determination in
response to the plaintiffs’ petition, the district court stressed that the CWA is a “states-in-the-
first-instance regulatory scheme.”163 On appeal, the Fifth Circuit remanded the case to the
district court to determine whether the EPA appropriately declined to make a necessity
determination.164 The EPA’s necessity determination is subject to the Administrative Procedure
Act’s “highly deferential” arbitrary and capricious standard of review, and, therefore, “the
agency’s burden is slight.”165 So long as the EPA provides “some reasonable explanation as to
why it cannot or will not exercise its discretion,” and so long as this explanation is grounded in
the statute, the EPA has considerable discretion in choosing how to best carry out the CWA’s
mandate.166 While the Gulf Restoration Network litigation deals with setting water quality
standards for nutrient pollution, rather than TMDLs, the EPA’s concerns about administrative
burden remain valid. Given that setting nutrient criteria is a necessary precursor to setting a
watershed-wide TMDL for nutrient pollution, the management challenge only becomes more
daunting as the EPA’s responsibilities grow. The variability of ecosystem responses to nutrient
pollution makes nutrient criteria much more difficult to develop than other types of water
quality standards.167 Setting nutrient criteria for 31 states that effectively tracks the effects of
nutrient pollution as it travels the 2300-mile stretch of the Mississippi River and its various
tributaries would be a resource intensive, highly technical scientific undertaking for the EPA.168
Completing the rulemaking process adds another significant burden to the EPA’s plate, given the
complexity of the technical issues and the large number of stakeholder comments to which the
EPA must respond.169 Once established, the EPA would then have to figure out the sediment,
phosphorous, and nitrogen pollution contributions of each point source and nonpoint source
sector in all thirty-one states, set load allocations that attempt to account for the pollution
sources’ relative importance to the local economy, and coordinate the allocations in a manner
that ensures upstream states’ nonpoint source pollution is not unfairly impacting downstream
states’ water quality goals.
No Solvency – States would oppose
Lack of political will means states along the Mississippi River wont enforce
Even if the EPA were willing to create a watershed-wide TMDL for the Mississippi River Basin,
the agency would still likely face backlash from the Basin states for doing so. Unfortunately,
uncooperativeness is the norm under the CWA’s framework of cooperative federalism .180
States’ blind adherence to their political boundaries and lack of meaningful incentive for
enforcement has always made solutions to interstate water pollution difficult .181 The failure of the
Basin states to promulgate numeric nutrient criteria is indicative of the level of interest the
states have in addressing nutrient pollution in the Gulf.182 While states in the Chesapeake Bay were also slow to
adopt numeric nutrient criteria, key differences between the watersheds suggest such sluggishness will be much more difficult to
overcome in the Mississippi River Basin context. Unlike the Chesapeake Bay, which lies mostly within Maryland and Virginia, the
nutrient pollution that runs through the Mississippi River pools in a dead zone in the northern Gulf of Mexico.183 In the Chesapeake
Bay context, the Bay jurisdictions either lined the polluted Bay or sat in very close proximity to it, seeing for themselves the nutrient-
induced algal blooms and feeling the economic effects of water pollution on their tourism and fishing industries.184 In
the
Mississippi River Basin context, however, the Gulf dead zone is both physically and economically
removed from its largest polluters.185 This physical distance between polluter and the polluted in
the Mississippi River Basin context likely contributes to the lack of political will among states to
address nonpoint source nutrient pollution. This is a classic case of unchecked interstate externalities and is therefore a
perfect candidate for federal regulation.186 At the same time, due to the CWA’s regulatory gap, the EPA has
limited authority to coordinate TMDLs in the interstate context that are capable of holding
upstream nonpoint source polluters accountable for their effects downstream.187 Colburn’s Chesapeake Bay model
for intergovernmental administration relies on the EPA’s ability to spur states to contribute their local knowledge to help the federal
government solve an interstate pollution problem.188 The initial voluntary cooperation by the principal Bay jurisdictions was vital to
the Chesapeake Bay model’s success.189 Without the voluntarily signed Chesapeake 2000 Agreement and its
commitments, the Chesapeake Bay TMDL likely would not have been possible. The commitments in the
Chesapeake 2000 Agreement—combined with Congress’s establishment of the Chesapeake Bay Program—gave EPA some leverage
to help spur state cooperation in the WIP drafting process.190
States along the Mississippi would oppose the aff – no incentive for
enforcement
Unfortunately, securing initial voluntary commitments from key Basin states is unlikely. The
conservative leadership in the Basin states likely views regulating nonpoint source polluters as a
major political risk, with little-to-no discernable payoff for its constituents.191 Most of the Basin
states’ economies rely heavily on the agricultural industry.192 A TMDL of the magnitude that
would be required to address the Gulf dead zone would likely result in significant costs to both
taxpayers and the agricultural industry throughout the Mississippi River Basin.193 Because most
states’ agricultural runoff flows downstream to the Gulf, the citizens of upstream states have
little, if any, incentive to invite the compliance costs associated with a TMDL. Therefore, the only
states with an economic incentive to reduce nutrient pollution along the Mississippi River Basin
are the states sitting on the Mississippi River Delta who derive significant income from the
fishing and seafood industries.194 The National Oceanic and Atmospheric Administration
estimates the Gulf dead zone currently costs the U.S. seafood and tourism industries $82 million
a year.195 Yet, historically, even these states have done little to combat environmental harms
threatening their marine operations. This is likely because many of the states in the Mississippi
River Basin have depressed economies, and pollution-heavy industries, namely oil and farming,
make up a disproportionate share of their economies.196 For example, Mississippi has the
lowest gross domestic product (GDP) per capita of any state in the nation, and its economy is
inextricably linked to its farming operations.197 Louisiana’s per capita GDP is higher, due in
large part to the state’s petrochemical industry;198 even still, the unemployment rate is much
higher in Louisiana than in other states across the nation.199 State officials charged with
protecting the environment in these states have a long history of allowing the growth of
industry at the cost of environmental contamination.200 If even the downstream states most
affected by nutrient pollution are politically and economically opposed to a federally
orchestrated TMDL, the EPA is unlikely to find any states in the Mississippi River Basin willing
to cooperate.201 Without some modicum of cooperation from the Basin states, the EPA would
struggle to obtain the necessary information required to develop a coordinated, watershedwide
TMDL. Even if the EPA did, there would still be the issue of enforcement, as the EPA does not
have the authority to force states to develop detailed implementation plans for its TMDL.
No Solvency – Monitoring
EPA doesn’t have the information needed to solve—non-compliance from
states makes solvency impossible.
Foley 2016 - PhD, The Pennsylvania State University, Agricultural and Extension Education MS,
Virginia Polytechnic Institute and State University, Dairy Science - Reproductive Physiology BS,
Cornell University, Animal Science AAS, SUNY College of Agriculture and Technology Agricultural
Science / Animal Science-Assistant professor
Caitlin Foley, 16 “REGULATING FEEDLOTS: APPROACHES TO CONTAINING CONCENTRATED

ANIMAL FEEDING OPERATIONS” accessed online 11/25/16 http://aldf.org/wp-
content/uploads/ALC/2016/Regulating_Feedlots_Approaches_to_Containing_Concentrated_Ani
mal%20Feeding_Operations.pdf
Despite the powers granted to the agency, the

EPA has generally failed to successfully police CAFOs that come
under the CWA’s purview because
of several insufficiencies in the Act itself and the agencies inability to
bridge them. The EPA may issue civil or criminal enforcement actions for violations , and has done so
against large and medium CAFO operators in increasing frequency in the past several years, including eight criminal actions brought
from 2009-2012.38 The agency even included the reduction of “animal waste pollution from livestock
and poultry operations that impair our nation’s waters, threaten drinking water sources, and
adversely impact communities” in both its FY 2011-2013 and FY 2014-2016 national enforcement
initiatives, signaling a renewed focus on the problem.39 Yet in a 2013 EPA enforcement report
on noncompliance among nonmajor permitted facilities regulated under the CWA, the EPA Assistant
Administrator, Cynthia Giles, noted the central concern of the report was that “noncompliance
rates are too high and enforcement is too infrequent in the NPDES program.”40 The EPA has limited
resources for detecting violators among its nearly one million NPDES permittees,41 making enforcement
unlikely and litigation costly.42 This is seen on the ground, where of the 4,741 classified CAFOs currently regulated under
the CWA, 283 have a current violation, and only 1,593 have been inspected in the last five years.43 The EPA’s lack of
independent resources to police the program results in an unpredictable and uneven flow of
enforcement and information, with the agency relying on states, citizens, and advocacy
groups to support it. Another hurdle in the CWA’s enforcement structure is that the vast majority of CAFOs
applying for permits are not regulated by the EPA, but by the states . Under the CWA’s model of cooperative
federalism, wherein responsibility for the Act’s mandates is divided between the federal agency and
the states, state permitting programs contribute additional identification, monitoring, and
enforcement power. As of 2003, only 5 states did not receive delegated authority from the EPA to regulate point source
polluters.44 In all others, states were granted authority to oversee the permitting program, including
setting standards for effluent limitations that are at least as restrictive as federal regulations .45
States can issue permits that regulate beyond the powers of the EPA, including the imposition of permitting on CAFOs that have
never discharged into qualified waters.46 Though this should bolster the amount of information available
to the EPA, state detection, enforcement, and monitoring are inconsistent and erratic . For
instance, though the EPA requires states to submit the percentage of permittees reviewed for CWA
compliance every year, in 2013 states reviewed only 81% of permittees .47 In fact, of the problems the
EPA identified in their public database of CWA permittees and violations, the EPA notes the state’s failure to submit
penalty data, single-event violations (such as an unpermitted discharge by a CAFO), and
locational data for non-major facilities.48 States are unable or unwilling to effectively gather the
required information on CAFO polluters (among other CWA violators), and arguably have an incentive
not to. State governments charged with authority to implement the CWA permitting scheme have an incentive to
impose fewer restrictions on their CAFO operators , granting them a competitive advantage over
states with more restrictions (and hence, more imposed costs).49 The EPA itself identified the possibility of state-by-
state enforcement generating an unfair market. Lack of state enforcement results from sympathy toward
CAFO operators, personnel shortages in finding dischargers, and agency apathy .50 Present in these
challenges is the theme of information. Information “is a critical component of the administration of an
environmental law for all farms, and one that is in short supply.”51 The agency’s inability to find
discharging CAFOs that do not apply for permits, even when supplemented by state permitting programs and
citizen suits, has limited any effectiveness the agency can hope to have under the CWA. Absent r ules
that require non-discharging CAFOs to apply for permits or a more effective federal-state information-sharing
scheme, the EPA has no means to gather information on the existence of CAFOs or the
operations’ risk to pollute. Overall, information has been the EPA’s historical Achilles heel . A GAO
report on the EPA’s information collection of CAFOs resulted in a dismissal of the reliability of
the information they could obtain, and a negative review of the agency’s ability to collect
simple locational data on existing operations.52 The EPA’s inaccurate statistics on the actual number
of CAFOs existing means any attempt to enforce against potential polluters will be largely
underperformed due to their low estimates of CAFOs and the furtive existence of operations who have never applied for a
permit. 53 No federal agency consistently collects information on CAFOs, forcing the GAO study in question to rely on USDA figures
compiled on large animal farms to approximate the surge of CAFOs over the last 30 years. Using this information, the study found
that from
1982 to 2002, CAFOs increased by 230 percent, yet despite this the EPA “does not
have the information it needs to regulate these [unpermitted] CAFOs .”
The aff cant solve – lack of monitoring and the ability to accurately identify
sources of runoff makes the plan unenforceable
D.C.
bay/
Economically competitive farmers operate profit-seeking businesses, and they consider input and output prices and other costs and
incentives as well as their resource base when making decisions about what mix of crops to grow and how to grow them.
Traditionally, policies to reduce pollution from agriculture have relied almost exclusively on voluntary approaches, including
education, technical assistance, and financial assistance. Voluntary decisions to adopt conservation measures that protect water
quality, however, generally depend on private benefits outweighing private costs. Policymakers can consider a range of policy
instruments to influence farmer management decisions. These range from purely voluntary to regulatory and make use of various
incentive and targeting mechanisms. No matter which approach is taken, achieving water quality goals at least cost to both farmers
and to taxpayers is important, especially given limited conservation budgets. Cost-effective
control of nonpoint-
source pollution must take into account the heterogeneity of agriculture by tailoring environmental
performance goals for different farms and regions to minimize abatement costs over the landscape (also known as allocative
efficiency). A large body of research has found that particular types of farms —because of their resource
characteristics, farming practices, and/or geographic location— tend to contribute a disproportionate share of
pollutants. A cost-effective policy induces operators who can most easily reduce pollution (often on the most highly polluting
operations) to adopt appropriate conservation measures. However, assigning responsibility for nonpoint-
source pollution is difficult. Runoff does not emanate from a single point, but leaves each field
through multiple pathways, often unseen, so accurate monitoring is prohibitively expensive. The
amount and nature of runoff from a field depend not only on factors that can be managed, such as
the technology employed and the use of variable inputs, but also on factors such as rainfall that are difficult to
predict. Uncertainty about who is responsible and the degree of responsibility creates problems
for efficient nonpoint-source policy design . Requiring farmers who are contributing little to the
problem to adopt best management practices may reduce program cost-effectiveness . Similarly, not
reaching those farmers who can provide the greatest reductions at the lowest cost also limits
cost-effectiveness. The difficulty in identifying which producers are producing the most
pollution is an often cited reason why voluntary actions are the tools of choice in existing
nonpoint-source programs.
Politics
Plan Popular
Opposing corporate Ag is popular with the public
Goehl 2019 – staff writer
George Goehl September 4 2019 “The secret to Democrats winning the midwest: fight big
agriculture” https://www.theguardian.com/commentisfree/2019/sep/04/democrats-2020-
midwest-elections-farming
Taking a stand on factory farms is the right thing to do. It’s also good politics. Unless, of course,
your path to the Oval Office is dependent on contributions from corporate agriculture. “Factory
farms profit at the expense of rural communities, displacing family farmers, bypassing main
street businesses, and polluting the air and groundwater,” Bobby King told me. King works with
the Land Stewardship Action Fund, a Minnesota-based farm and rural organization. “Rural
people experience this directly. Candidates that have the courage to stand up to corporate
agriculture will connect with and inspire rural people as they head into the ballot box.” Factory
farms are far from popular. In exit polling from the midterm elections, 73% of Iowa voters said
the governor and legislature should require limits to manure pollution runoff into Iowa’s
waterways. It’s not surprising. Iowa is home to 3 million people, and 26 million hogs, which
create the waste equivalent of 65 million people. That waste, full of dangerous nitrate, makes its
way into Iowa’s waterways. 750 waterways in Iowa are currently affected. It’s why the City of
Des Moines is operating the largest nitrate removal system in the entire world. “Enough is
enough,” Cherie Mortice, of Iowa CCI Action Fund, told me. “We’ve got 10,000 factory farms in
Iowa. That’s too many corporate hogs and way too much corporate hog manure.”
Plan Bipartisan
Local Water Protection Act proves the plan would be bipartisan
Mast 2019 –
Brian Mast April 9 2019 “Mast Bill To Help Prevent Toxic Agricultural Runoff, Other Water
Pollutants Passes House of Representatives” ic-agricultural-runoff-other-water-pollutants-
passes-house-of-representatives
WASHINGTON, D.C. – U.S. Representatives Brian Mast (FL-18) and Angie Craig (MN-02)’s Local Water Protection Act today passed
the House of Representatives. The
bipartisan effort to reduce harmful water pollution increases grant
funding for state and local governments to decrease water pollutants , including addressing toxic
agricultural runoff, septic to sewer conversions, legacy pollutants, impacts from dams, effects of channelization of waterbodies and
other forms of pollution. “Florida has felt the social and economic consequences of environmental disaster firsthand. The water
issues stemming from Lake Okeechobee exemplify why it's absolutely critical that we work together to strengthen conservation
programs, promote public health, defend our environment and protect our waterways,” Rep. Mast said. “ This
bipartisan bill
will increase federal support to address pollution from agricultural runoff, assist with septic to
sewer conversions and prevent other forms of pollutants. It goes to show how working together
we can make a real difference for our waterways.” Specifically, the bill will reauthorize the EPA’s successful
Section 319 Grant Program, which addresses nonpoint source pollution through state-run nonpoint pollution management programs
and related technical assistance. The bill increases the funding level from the $70 million specifically authorized in 1991 to $200
million in Fiscal Years 2020 through 2024. Under Section 319, states, territories and tribes receive grant money that supports a wide
variety of activities including technical assistance, financial assistance, education, training, technology transfer, demonstration
projects and monitoring to assess the success of specific nonpoint source implementation projects. “Local communities are the
experts on the most innovative and effective ways to address pollution caused by snowmelt and storm runoff in their water
sources,” Rep. Craig said. “I’m honored to have passed my first bipartisan bill out of the House today to support local government
efforts to keep our water clean and safe for generations to come.” The Section 319 Grant Program has funded hundreds of programs
in Florida alone since its creation in 1987, including McCarty Ranch in St. Lucie County, Willoughby Creek in Martin County and the C-
43 Reservoir in Hendry County. A full list can be found here.
Plan Unpopular
Plan causes massive backlash
Geiling 2016 - Reporter at ThinkProgress
Natasha Geiling, 1/14/2016.. “A Controversial EPA Rule Is Pitting Small Farmers Against Big
Agribusiness,” ThinkProgress, https://thinkprogress.org/a-controversial-epa-rule-is-pitting-small-
farmers-against-big-agribusiness-650061605b8b#.ajste9xpz.
In May, when the EPA released its final version of the Clean Water Rule — meant to clarify which waters
are under the jurisdiction of the Clean Water Act — the agency cheered the broad reach of the rule , arguing
that it would protect the drinking water of some 117 million Americans, or roughly a third of the population. But
when Sen. Joni Ernst (R-IA) introduced a resolution to kill the EPA’s Clean Water Rule back in November,
she seemed especially concerned with the rule’s impact on a single group in particular: farmers and ranchers, who
comprise just two percent of the population. “I spent the weekend going back through letters my fellow Iowans
have sent me on this issue,” Ernst said on the floor of the Senate. “And so many of them are frustrated with the lack
of common sense coming out of Washington. They are taking this issue personally because their
livelihood depends on it.” On Wednesday, the House voted 252–166 to pass Ernst’s resolution. It now goes to
President Obama for approval, though the White House has long insisted that it will veto any attempt to overturn the
rule. As a representative of a state with the third-highest number of farms and second-highest
total farm sales in the country, it makes sense that Ernst would want to look out for the
interests of farmers when it comes to policy. But Ernst isn’t the only politician singling out
farmers as particularly hurt by the rule — legislators on both sides of the aisle have trotted out
farmers as the group that would be most burdened if the rule is allowed to go forward . The
American Farm Bureau — the country’s largest farm lobby — has also vehemently opposed the rule,
launching a campaign to block it long before the finalized version hit the federal register . Once
the final rule was announced, the Farm Bureau launched another campaign, titled “Ditch the
Rule,” meant to drum up public opposition to the rule . In his final speech given at the American Farm
Bureau Annual Convention earlier this week, outgoing president Bob Stallman called the Clean Water Rule
“one of the worst examples of overregulation,” and promised that the Farm Bureau would
continue to fight the rule both in the courts and in the halls of Congress.
Farm Bureau Opposes
The American Farm Bureau opposes the plan
Doering 2016 – staff writer
Christopher Doering “AFBF: Federal regulations are the biggest threat to farmers”
https://www.desmoinesregister.com/story/money/agriculture/2016/01/10/federal-regulations-
biggest-threat-farmers/78131422/
Efforts by the federal government to regulate agriculture is one of the biggest challenges facing
farmers and ranchers, the head of the country's largest farm group said last week as he worked
to rally producers to defend their land. Bob Stallman, outgoing president of the American Farm
Bureau Federation, used his final speech before an estimated 5,000 people at the group's annual
convention to tell members that while generations of farmers have survived difficult markets
and weather, “bad government should not be the straw that breaks us.” The Texas rice and
cattle farmer criticized an Environmental Protection Agency's plan to clean up the Chesapeake
Bay in the eastern U.S., warning that unless it is struck down, it would set a dangerous
precedent for the government to regulate pollution flowing into the Mississippi River and other
waterways. The Farm Bureau, which has sued, recently asked the Supreme Court to hear its
case. “EPA is starting with the Chesapeake Bay watershed, but unless the Supreme Court steps
in, this latest EPA power grab will soon be coming to watersheds all across the country,”
Stallman said. “If we’re going to let the government dictate where we can and cannot farm …
then this is not the Land of Liberty.” Stallman also addressed a regulation from the EPA and the
Army Corps of Engineers to curb pollution in small waterways and wetlands that he said could
infringe on farmers and ranchers and saddle them with higher costs — concerns that have been
downplayed by the White House.
Farm Bureau Lobby Powerful
The American Farm Bureau will oppose the plan
Shearn 2012 – freelance journalist
Ian Shearn July 16 2012 “Whose Side Is the American Farm Bureau On?”
https://www.thenation.com/article/archive/whose-side-american-farm-bureau/
Although illustrative, Christen’s case is not unusual. From California to New York, the Farm Bureau leads the charge for
industrial-scale food production. It opposes the labeling of genetically engineered food, animal welfare reform and
environmental regulation. In Washington, its well-funded team of lobbyists and lawyers seeks to
undermine the federal Clean Water Act and the Clean Air Act, opposing pesticide restrictions and increased
scrutiny of greenhouse gas emissions and pollution from CAFOs, like the “farm” up the road from Christen. The Farm
Bureau has sued the EPA, which is trying to limit farm runoff from polluting the Chesapeake Bay.
At the same time, the Bureau pushes hard to expand international trade and lobbies for the stream of government subsidies that
disproportionately benefit the nation’s biggest commodity farm operations and, indirectly, the agribusinesses at the heart of this
system. In Washington, the 2012 Farm Bill has predictably been a top priority for the Farm Bureau lobby team. They have surprised
players from both sides of the debate by conceding cuts in traditional subsidies in exchange for a large expansion of subsidized crop
insurance that protects against disasters and falling prices at an estimated cost to taxpayers of $9 billion a year. The tactical,
philosophical shift garnered praise even from Farm Bureau adversaries. Nonetheless, it should be noted that crop insurance is a
small, but significant piece of Farm Bureau insurance companies’ portfolio. In 2011, they collected over $300 million in crop
insurance premiums. In rural areas, the
Farm Bureau grooms compliant political candidates, mostly Republicans; it wields
the power to dictate outcomes of legislative elections and appointments to powerful state
agriculture committees. Then it influences which farm-related bills become law. Along the way, it has
become a close second to Monsanto in lobby expenditures for agriculture-related issues,
spending nearly $6 million in 2011 —all in the name of “farmers.” American Farm Bureau Federation president Bob
Stallman was succinct, almost militant in his opening address last year at the group’s annual meeting: “We will not stand idly by
while opponents of today’s American agriculture…try to drag us down…try to bury us in bureaucratic red tape and costly regulation
—and try to destroy the most productive and efficient agricultural system in the world,” he said.
States CP
1NC
The counterplan solves
Heathcote 2013 – Water Program Director, Iowa Environmental Council
Susan Heathcote “Curbing Agricultural Runoff Pollution: Lessons from the Clean Water Act”,
Getting Into Soil & Water https://www.iaenvironment.org/webres/File/News
%20%26%20Resources/Fact%20Sheets/Curbing_Ag_Pollution_Runoff.pdf
Following the CWA model, establishing clean water standards for nitrogen and phosphorus is
the first step to solving this pollution problem. Iowa currently lacks numeric standards limiting
nitrogen or phosphorus. Iowa’s current standards include only narrative limits that apply to
nitrogen and phosphorus that say water should be free of “aesthetically objectionable” or
“acutely toxic” conditions. Unfortunately, by the time these conditions are present, signifiant
pollution has already occurred. Setting numeric pollution limits provides clear goals to prevent
pollution of Iowa’s rivers and lakes. Matching solutions to the problem In addition to setting
goals, a key reason for the success of the Clean Water Act has been its two-tiered approach to
pollution control by cities and industries: • Common-sense, basic limits everyone follows:
Technology-based limits for all industries and municipalities determine a basic level of required
treatment that is both technically and economically achievable. These limits utilize treatment
technologies that are proven to effectively remove pollutants, and they allow the facility to
choose from several different options. • Additional action when and where it is needed: If
technology-based limits are insufficient to achieve clean water goals, additional treatment is
required to meet water quality based pollution limits. Again, the facility is allowed to choose
between different treatment technologies to achieve these limits. The Clean Water Act does not
regulate agricultural non-point sources of pollution. However, it is possible to consider state
pollution control requirements for these sources modeled after the CWA’s successful two-
tiered strategy: Common-sense basic conservation: Implementation of stewardship plans for all
farmland would help protect soil and water resources. Like technology based limits for point
sources, performance goals for these plans could be based on eff ective, affordable conservation
practices, but also would allow each farmer to choose any of several practices that meet the
plan’s goals and the farmer’s needs. Additional action when and where needed: Where the farm
stewardship plan is insufficient to meet water quality goals, farmers could partner with their
neighbors- -and with cities and industries that are also contributing to the problem--to
implement targeted practices in their watershed to meet water quality goals. Equal
accountability for all Under the Clean Water Act, clear goals for cities and industry and a
measurable cleanup plan insures accountability for point source pollution and has resulted in
significant water quality improvements. With new research on the effectiveness of conservation
practices included in the Nutrient Reduction Strategy, the ability of conservation professionals
to provide farmers science- based solutions that support both agricultural productivity and clean
water has improved dramatically. The Clean Water Act model suggests combining these
solutions with meaningful accountability will achieve results for Iowa’s clean water goals.
States Solve Better
Only the counterplan solves – the Clean Water Act bars federal intervention on
nonpoint-source pollution
pubid=45209
Section 305(b) of the CWA requires States to report to Congress every 2 years which waters are meeting water quality standards and
which are not meeting the standards. When technology-based controls are inadequate for waters to meet State water quality
standards, Section 303(d) of the CWA requires States to submit to the U.S. EPA a list of impaired waters and the cause of the
impairment. Once listed as impaired, a TMDL may be required, along with a plan to mitigate the impairment and meet the applicable
water quality standard. Developing a TMDL involves calculating the maximum amount of a pollutant
that a water body can receive and still meet water quality standards, and allocating pollutant
loads to the various sources. The TMDL for the watershed is the sum of individual wasteload
allocations for point sources, load allocations for nonpoint sources and natural sources (i.e., runoff
from undisturbed forests and other natural areas), and a margin of safety. Waste load allocations for point sources are met
through the NPDES permit, which is regulatory in nature. Load allocations for nonpoint sources can be met
through regulatory or voluntary approaches developed by the States . Since the Clean Water Act
specifically bars the use of Federal regulations to reduce nonpoint-source pollution,
regulations would have to originate at the State level.
Agriculture is outside of the jurisdiction of the CWA – it’s a nonpoint source

pubid=45209
Agriculture is the largest contributor of nutrients and sediment to the Bay. Crop production
and animal operations contributed about 38 percent of total nitrogen loads, 45 percent of total
phosphorus loads, and 60 percent of total sediment loads in 2007 (National Academy of
Sciences, 2011). The Clean Water Act is the main Federal law for addressing water pollution.
However, nonpoint sources such as crop production are exempt from the permitting
requirements of the Act. The burden of pollution reduction is on point sources, which are
regulated by the National Point Discharge Elimination System (NPDES). U.S. EPA estimates that
only 49 percent of nitrogen, 35 percent of phosphorus, and 4 percent of sediment loads
entering the Bay are subject to Federal regulation (U.S. EPA, 2010a). The remainder must be
addressed through non-regulatory provisions of the Clean Water Act, voluntary conservation
programs administered by USDA, and State policies.
Incentives / Voluntary CP
1NC
Performance based incentives solve
NRDC ‘9 (National Resource Defense Council, May 2009, “Reducing Pollution in Domestic
and International Uncapped Sectors: The Role of Offsets and Complementary Polices”,
https://www.nrdc.org/sites/default/files/uncapped.pdf)
Congress should use a portion of allowance auction revenues to fund performance based incentives that will
achieve additional abatement in uncapped sectors. These incentives can be targeted, for example,
at foresters to promote sequestration-enhancing forest management, at small landfills to help capture methane emissions and increase
capture efficiency, and at farmers to encourage fertilization practices that reduce nitrous oxide
emissions. To maximize abatement per dollar spent, incentive payments can be set at the project developer’s marginal cost of
abatement rather than the marginal cost reflected in the overall offsets market. Unlike abatement claimed in the form of
a tradable offset credit, abatement purchased through incentives is not tied to a corresponding
increase in emissions from a capped entity, and therefore a lower verification standard is acceptable. To receive
payment, participants would have to show they are taking actions above and beyond business as
usual, but would not need to demonstrate this additionality on a ton-per-ton basis. As a result, transaction costs could be
significantly reduced making lower incentive payments attractive to and lucrative for their recipients. In addition, regular
upward revision of the baseline for qualifying for these incentives would ensure consistent
improvements in practices. Initially, approximately 15 percent of total U.S. GHG emissions are
likely to be outside the cap. Of that 15 percent. just less than half are from the agricultural sector, while the rest are from
fossil CO2 or industrial sources too small to be capped. Assuming the United States does not expand the scope
of coverage for the cap (or require more than 80 percent reductions from upped emitters), the United States must
have complementary policies in place that deliver at least 0.32 GtCO2e of uncapped sector
abatement by 2020-beyond any abatement from domestic offsets-to meet our overall target. According to the EPA, in
2020, incentives of $15 to 20 per ton of Co2e abatement could drive sufficient investment in the necessary number of tons at an
approximate cost of $4.8 to 6.4 billion, representing roughly 3 to 4 percent of allowance auction revenues" Over
time, these
incentives could be phased out if the emissions threshold for capped entities is gradually reduced
to capture smaller sources in all sectors and baselines for good practices in agriculture and forestry are
revised upward. Once the EPA has ensured the necessary economy-wide reductions through capping,
setting mandates, and establishing performance based incentives targeted at domestic uncapped sectors, it
can then define eligibility standards for both domestic and international offsets as a cost-containment strategy. Investing
in our recovery by jumpstarting abatement in the domestic agricultural sector. Making immediate investments in the
domestic agricultural sector should be part of a “cap-and-recover” policy package . Allowance
auction revenues could be pulled forward so that performance-based incentive dollars could be
pumped into the economy during 2009 to 2013, preceding the launch of a US. carbon market. The initiative would
target high-cost, high-quality, and easy-to-measure abatement opportunities , such as methane capture in
livestock manure lagoons, thereby encouraging capital investment in equipment such as anaerobic digesters. Incentives would
also encourage enhanced soil carbon sequestration and reduced nitrous oxide emissions through
more efficient fertilizer application on farms . Such an investment would help develop key
infrastructure for uncapped sector involvement in cap-and-trade , including regulatory capacity, and build
confidence in the viability of a federal incentive program for the agricultural sector .
Performance Based Policies Solve
Performance based solutions are most effective – its key to flexible adoption
from farmers at a lower cost than status quo regulatory frameworks
D.C.
bay/
Performance-based policies are a relatively new addition to the conservation toolbox. Basing
payments on environmental performance, measured through monitoring or estimated with
models, can benefit farmers who can provide the greatest pollution abatement for the least
cost. The USDA Conservation Stewardship Program bases some of its payments on performance.
Water quality trading programs that allow regulated sources of pollution to purchase offsets
from unregulated sources are also performance-based (see “Agriculture and Water Quality
Trading: Exploring the Possibilities” in Amber Waves, 2009). Most of the States in the watershed
have developed trading programs, but most successful trades involve point-sources whose
pollution discharges can be monitored. Field-scale process models can provide the ability to
implement performance-based policies where actual monitoring is impractical (which is the case
for nonpoint-source pollution). How well a model-based performance approach works in
practice has not yet been demonstrated, as the accuracy and public acceptance of such models
remain open to question. The practice-based approach for pollution abatement is much more
familiar to farmers. Adoption of water quality-enhancing conservation measures is encouraged
under current conservation programs, including USDA’s Environmental Quality Incentives
Program (EQIP), by providing financial and technical assistance. The same practices could be
required through regulation, as has been done in some States. The major difference between
the two approaches, from the farm operator’s perspective, is that performance-based policies
let farmers decide how pollution will be reduced, while practice-based policies limit farmers’
management choices by encouraging or mandating adoption of a specific set of practices. In our
analysis, we had available three representative management systems that farmers could adopt
to address the Bay’s water quality concerns: cover crops, nutrient management, and water
erosion controls. We found the following: Hypothetical performance-based policies could
achieve pollutant reduction goals at a much lower cost than practice-based policies, ignoring
information, regulatory, and other transactions costs. Our most efficient practice-based policy
was more than six times more costly than the performance-based policy. If properly
operationalized, such policies tap into farmers’ understanding of their operations and enable
them to combine inputs most effectively in order to achieve an environmental goal. By selecting
the fields and practices that offer the most bang-for-the-buck, this performance-based approach
could hypothetically lower costs to reach water quality targets by requiring far fewer acres to be
treated. Performance approaches can be through financial incentives (a subsidy for pollution
reduced or a tax on pollution delivered) or in the form of a regulatory restriction on the amount
of pollutants delivered. The problem with implementing such policies is that measuring and
assigning responsibility for nonpoint-source pollutants is still inherently difficult and costly,
although modeling tools are being developed and applied in pilot water quality trading
programs. No policy is economically efficient if the value of the resulting benefits is outweighed
by information and transactions costs needed to implement it. Modeling tools have the
potential of reducing the information and transactions costs, relative to costly ongoing
monitoring of nonpoint sources of pollution that has hampered wider adoption of performance-
based policies to date. On the other hand, modeling approaches provide measures of expected
performance, rather than actual performance, and thus are less accurate. Choosing among
alternative policy instruments will necessarily entail making tradeoffs between potential
efficiency gains, information and other costs necessary to implement a policy, and the level of
accuracy required. A targeting scheme that includes factors related to water quality improved
cost-effectiveness. Targeting on the NRCS measure of treatment need (fields inherently at risk to
pollutant loss without adequate conservation treatments) and other factors related to water
quality risk improved cost-effectiveness relative to an E3 approach. We found that concentrating
on cropland with high treatment need or in close proximity to water would provide the lowest
cost option for meeting water quality goals under a practice-based approach.
Performance-based approaches are key – enables widespread adoption at a

fraction of the cost
D.C.
bay/
State programs for meeting the TMDL water quality goals are moving ahead. Public programs are providing (mostly)
voluntary incentives to adopt particular practices. The cost-effectiveness of these traditional practice-based policies
for reducing pollution to the Chesapeake Bay can be potentially improved through targeting. But the greatest
opportunities may lie with performance-based approaches if they can be implemented in a
way that accurately and inexpensively measures and attributes pollution reductions among
nonpoint sources of nutrient pollution . Given the considerable cost savings that a performance-
based approach would potentially provide, making use of available modeling tools and developing
better ones to quantify environmental performance could provide significant payoffs . While the cost
of developing, testing, and verifying model-based performance measures and gaining their acceptance among regulators, program
participants, and the public has slowed their implementation, the research reported here provides a rough estimate of the potential
benefit of doing so. Finding ways to reduce the modeling and transaction costs implicit in performance-based policy approaches
could be a fruitful area for research.
Solvency
Only voluntary action solves – it enables flexible solutions that fit specific needs
of the farmers
Speaking at a session of the Iowa Farm Bureau annual meeting in Des Moines this week, Iowa Secretary of Agriculture Bill Northey
told farmers that regulators
from the U.S. Environmental Protection Agency and other government agencies
are certain to seek mandatory actions on farms if landowners don't show they can reduce the
amount of runoff pollution making its way into Iowa streams and rivers. Nitrate and phosphorus are ending up in the Gulf
of Mexico, the home of the largest commercial fishing and shrimping industry in the United States, and government regulators are
poised to force farmers in states like Iowa to change how they farm the land if farmers don't take action voluntarily to reduce the
runoff. Northey, a farmer himself as well as the top government agriculture official in Iowa, said, "If we don't address these issues
ourselves, we should expect regulation." Northey noted that he and Iowa Gov. Terry Branstad and Iowa Department of Natural
Resources chief Chuck Gipp introduced the Iowa Nutrient Reduction Strategy at a press conference on November 19 at the state
capitol in Des Moines. That report lays out the voluntary options for farmers to take on their farms to reduce the pollution. " As
farmers we want to be part of the solution by finding out how we can do a better job," said Northey.
"We each need to find out what works best. I think using one or two of the best management practices for each farm will meet the
goal that has been set for our state, which is to reduce nitrogen and phosphorus runoff by 45%." The
varying geology and
topography of the land, even in a state as big as Iowa, makes the kind of mandatory actions EPA has
discussed for the Chesapeake Bay a bad idea to try to put to work in the Heartland of America,
said Northey. "I believe now is the time for us as farmers to find the farming practices that work. This Iowa Nutrient Reduction
Strategy is a voluntary plan and it is based on science. It will not work if we don't voluntarily put these
practices on the land."
Voluntary Actions are key – establishes flexible solutions and avoids regulation
Farmers are encouraged to participate in public comment period by going online The in-depth discussion forum on the 2012
Nutrient Management Strategy drew capacity crowds at the IFBF meeting. In addition to Northey and Lemke being part of the
discussion panel, Iowa State University ag engineering professor Matt Helmers, a scientist who studies agricultural drainage and
related issues, led the discussion and answered many questions from farmers. Helmers explained that the water quality plan
provides several scenarios for conservation measures that would impact nutrient run-off in Iowa and farther down the Gulf. Northey
concluded by emphasizing that a
science-based voluntary approach to conservation works best with all
farmers. "I do believe now is the time for us as farmers to find these practices that will work in their
own operation and use them, to figure out how we each can do a better job," said Northey. "Again, let me emphasize that
this is a voluntary, science-based plan, but it does not work if we don't put these practices to
work on our farms. We want to tell the story that we are making progress. This strategy is a
better alternative than a one size fits all regulation that limits choices." Iowa farmers are encouraged to
familiarize themselves with the water quality plan and participate in the online public comment period by going to the nutrient
reduction strategy website. The 45-day comment period ends January 4, 2013. You can read the report on the website and also
leave your comments there.
AT Farmers Don’t Have Access
Existing programs provide sufficient guidance towards better farming practices
Fisher et al. 2016 – PhD, Winrock International - Winrock International is a nonprofit
organization whose mission is to increase economic opportunity, sustain natural resources, and
protect the environment
Kristin A. Fisher, Jonathan R. Winsten, Ph.D., Winrock International, Elisabeth Spratt, Winrock
International, Ryan Anderson, Delta Institute, Ryan Smith, Delta Institute “Pay-For-Performance
Conservation: A How-To Guide” Winrock International https://www.winrock.org/wp-
content/uploads/2016/02/PfP-How-To-Guide-Final.pdf
Water quality impairments resulting, in part, from agricultural nutrient runoff have remained
stubbornly difficult to solve in the United States. In U.S. freshwaters alone, the cost of
eutrophication is estimated to total at least $2.2 billion annually.1 Fortunately, farmers can cost
effectively implement land management changes which minimize soil erosion and nutrient
losses from their fields. These agricultural changes, which do not disrupt commodity production
in our agricultural lands, are often more cost-effective than urban based approaches to mitigate
pollution. Several government programs already exist to support farmers implementing
improved practices. Historically these are ‘pay-for-practice’ programs, in which standardized
financial payments are provided for a set of standardized management practices, regardless of
the local field conditions. When these programs were initiated, the existing data and technology
prevented cost-effective estimation of the nutrient reductions resulting from a specific change in
practice for a given location. In this guidance document, we present an alternative “pay-for-
performance” (PfP) conservation approach that capitalizes on scientific and technological
advances to deliver cost-effective and quantifiable estimates of nutrient reductions. Under the
PfP program, field and farm specific information is combined with nutrient and economic
modeling to find the most technically and cost-effective ways to reduce nonpoint source
pollution. Payments to farmers are then based on the quantified estimate of nutrient
reductions. The combination of a challenging problem, the freedom to creatively collaborate on
a solution to that problem, and a data-driven framework for making decisions and providing
incentive payments is powerful motivation for farmer involvement in solving a water quality
problem. We intend for this guidance document to serve as a handbook to agricultural and
conservation organizations as well as publicly-owned treatment works (POTWs) and
municipalities who are interested in planning and implementing a flexible solution to agricultural
nonpoint source pollution. This guide strives to not only describe the steps of implementing a
new program, but also to provide examples of challenges and successes from our experience
administering these programs in Iowa, Vermont, Ontario, and in the Great Lakes region
including Wisconsin, Michigan, and Ohio. PfP conservation creates an exciting new framework
for engaging farmers and other stakeholders, providing customized information about farming
operations and solutions for how to best tackle “hot spots” or “problem areas” on specific farm
fields. PfP has the potential to empower farmers to play an active, cost effective, and significant
role in meeting conservation and water quality goals.
MISC
Alternative Mechanisms
EPA
Plan: The United States federal government should amend section 319 of the
Clean Water Act to include a requirement that states submit programs for
implementing best management practices on waters that have been impaired
by nonpoint source pollution.
The aff solves – it forces states to establish environmental conservation
strategies to mitigate agricultural runoff while providing them the flexibility to
choose strategies that best fit their needs
Andreen 2016 – University of Alabama - School of Law
William L. Andreen “No Virtue Like Necessity: Dealing with Nonpoint Source Pollution and
Environmental Flows in the Face of Climate Change” 34 Va. Envtl. L.J. 255 (2016).
When section 319 was enacted in 1987, a number of members of Congress appeared skeptical about whether a voluntary approach
to controlling nonpoint source pollution could work.2 69 They were prescient. Twenty-nine years later, it is clear that the "trial run,"
as Senator Stafford put it,27 “has failed to clean up the vast majority of our nonpoint source-impaired waters. At the current pace, it
will be 700 years before even the current nonpoint source impaired waters are restored to health. 71 The
time is ripe for a
new approach, an approach that would include regulatory controls for those nonpoint sources that
contribute to the impairment of water quality . The 1990 Coastal Zone Act Reauthorization
Amendments ("CZARA")2 72 offer some valuable insights on how such a regulatory program could
be developed. CZARA requires each state with an approved management plan under the Coastal Zone Management
Act ("CZMA")7 3 to develop a Coastal Nonpoint Pollution Control Program and submit it to EPA and the
National Oceanic and Atmospheric Administration ("NOAA") for approval. 74 These coastal nonpoint source control programs
must provide for the implementation of management measures that conform to guidance developed by EPA and NOAA.175 That
guidance sets forth a number of technology-based options for controlling nonpoint source
pollution and gives state officials flexibility in choosing among them ."6 If a state fails to submit an
approvable program, it is subject to the loss of a portion of its CZMA grant. 277 The CZMA requires that state CZARA programs
contain "enforceable policies and mechanisms" to implement nonpoint source management measures. 2718 While "enforceable
policy" is statutorily defined to mean "legally binding" laws and regulations, 279 EPA and NOAA approve voluntary or incentive-
based programs in order to provide the states with more flexibility.2 1 8 So far, all of the states participating in the CZMA program
have submitted nonpoint source programs, and all have received either full or conditional approval. 81 The federal agencies have
had little choice. A cut in funding would hurt water quality, and, in any case, federal funding of the program has been dwindling. 82
As the administrative implementation of CZARA demonstrates, the forces aligned against the broad regulation of nonpoint source
pollution remain strong. In order to be more politically expedient, a better
approach under a revised section 319 of
the CWA would be to target mandatory best management practices ("BMPs") towards nonpoint
source impaired waters. Political opposition to such an approach would still be powerful, but, as Professor Jonathan Cannon
has written, perhaps "less vehement" than resistance to more "generally applicable requirements. 283 Moreover, by focusing more
intently upon the restoration of nonpoint source impaired waters, Congress could perhaps garner support for the program from
local communities. Rather than a diffuse and opaque program applied on a national scale, the BMPs
would be applied to specific bodies of water. Such a localized approach could stir the passions of all of those citizens
and groups that would love to see their favorite stream or lake restored to health. Under a revised section 319, states
would be required to establish enforceable BMPs for those nonpoint sources contributing to
water quality impairment. These BMPs could be drawn from a menu of technology-based
options set forth by EPA in order to give the states some flexibility in selecting the practices that
are most appropriate for their state. However, EPA should not be confronted with a Hobson's choice in the event a
state fails to submit a plan containing adequate, enforceable controls. The reduction or elimination of funding for nonpoint source
programming are neither reasonable nor pragmatic responses to the problem. Instead, EPA
should have the authority to
disapprove an inadequate state plan and, if a satisfactory revision is not forthcoming, to
promulgate a federal plan in its stead . Increased and more stable federal funding is also necessary
to provide small-scale farmers and other appropriate grant recipients with the wherewithal to
comply with these new requirements. Further, the new requirements would have to be implemented over a period of years in
order to give the newly regulated entities the time and, where appropriate, access to the funding necessary to come into
compliance. A monitoring program should also be established to help ensure that the BMPs and the
related financial investments are meeting their intended goals . If not, a revised plan should be submitted and
implemented-a process in keeping with an adaptive approach to such complex problems. Prying more funding out of Congress
will not be an easy task, but additional funding is absolutely necessary to help defuse opposition from the
nonpoint source community and enlist at least grudging support from the pragmatists in that community. The problem,
moreover, is already severe--more than 40,000 waters are currently impaired primarily by nonpoint sources284-and the situation
will only deteriorate as more intense rainfall events associated with climate change produce more polluted runoff and more
wildfires caused by higher temperatures and dryer conditions produce more erosion. Although
EPA funding of the
section 319 should certainly be increased, some additional financial support could possibly come
from collaboration with other government bodies . Improved targeting of the funding given to the U.S.
Department of Agriculture ("USDA") for its various conservation programs could do much to reduce nonpoint source impairment. In
short, Congress could make expenditures to support the implementation of these BMPs a
priority,285 as well as requiring more cooperation between USDA, EPA, and the respective state agencies with respect to grant
decisions, monitoring and reporting. This could be coupled with a broader USDA program to assist farmers in adapting to climate
change. As Robert Adler has recounted, climate change will affect almost all agricultural producers."6 Some will face increased
drought and water scarcity." 7 Others will confront losses from increased flooding and heightened levels of erosion."' Higher
temperatures will adversely affect crop yields as well as the viability of livestock production at least in some regions." 9 And more
heavily polluted waters from more intense precipitation can negatively impact economic productivity in many ways. Agriculture,
especially irrigated agriculture, is not immune to these adverse effects.29 Perhaps a new initiative aimed at helping American
agriculture adjust to climate change (for example, by utilizing more efficient forms of irrigation,291 shifting to less-water intensive
crops, utilizing low-till or no-till cropping to retain moisture, and improving the efficiency of fertilizer and pesticide usage to reduce
water pollution)292 could be combined with a more rigorous approach to addressing nonpoint source problems. Of course, the
enactment of any such grand bargain would depend upon a successful navigation of the jealously guarded silos of committee
jurisdiction that exist on Capitol Hill. 93 The
new approach to section 319 should be coupled with revisions
to the TMDL provisions in the CWA, requiring that load allocations developed for specific
nonpoint sources be implemented and enforced under the new section 319 regulatory program.
The new section 319 regulatory program should not end the efforts of our states to mitigate
nonpoint source pollution on non-impaired waters. 94 Those programs help prevent additional degradation of our nation's
waters, and they promote some progress towards the CWA's goal of eliminating the discharge of pollutants to the nation's
waters.295 Therefore, the
scope of an amended section 319 should include a requirement that the
states submit programs providing for either regulatory or voluntary programs for implementing
BMPs on waters that have not been impaired by nonpoint source pollution . Ideally, these BMPs
would be drawn from EPA's list of technology-based options, supplemented with education,
training, technical and financial assistance, and demonstration projects. These programs should
also be subject to EPA review, and if approved, eligible for continued section 319 funding. While a
large share of federal funding should be aimed at the restoration of impaired waters, the states
have long depended upon federal funding of their overall section 319 programs and that funding
should continue, albeit in an enhanced form.
Water Quality Trading
Water Quality Trading Solves Runoff
pubid=45209
The previous section demonstrated the benefits of a performance-based approach that provides
incentives for farmers of fields that can provide the most abatement at least cost to adopt
appropriate management systems. One such policy is point/nonpoint water quality trading.
State Watershed Implementation Plans for meeting the Bay TMDL all include the development
of point/nonpoint water quality trading programs. TMDL wasteload allocations for point sources
such as Publicly Owned Treatment Works (POTWs) may require costly upgrades to meet their
new emission limits. To help reduce the costs of meeting these limits, the U.S. EPA is
encouraging the development of water quality trading programs that allow regulated sources
such as POTWs to meet their permit requirements by purchasing offsets or credits from
unregulated nonpoint sources such as agriculture. In 2006, U.S. EPA and USDA signed a Water
Quality Credit Trading Agreement stating that pointnonpoint trading will complement existing
subsidies for water quality improvement from agriculture (U.S. Department of Agriculture,
2006). How Trading Works Water quality trading is a type of emissions trading. Trading can in
theory allow firms with different pollution abatement costs to allocate pollution abatement
among themselves in the most efficient way. In a cap-and-trade program, trading is organized
around the creation of a good called an emission allowance, which allows the holder to
discharge one unit of pollutant. Regulated dischargers— point sources that discharge directly to
water through a pipe or other conveyance—can legally discharge only as much as their holding
of allowances. Emissions in excess of the allowances result in a fine or other penalties. The total
number of emission allowances allocated to regulated dischargers in a watershed is set by the
State regulatory agency, based on the proportional contribution of the regulated pollutant to
the total emissions limit for a watershed (a Total Maximum Daily Load, or TMDL, is often the
basis for a water quality trading program). Emission allowances are initially allocated to firms by
the regulatory agency, usually in proportion to current emissions. Assuming that the number of
allowances granted to a firm is less than its baseline emissions, all firms face a choice. Firms with
discharge levels greater than their initial holdings of allowances will have to either purchase
more allowances or reduce emissions. Firms with marginal costs of pollution control greater
than the price of an allowance will purchase allowances in the market. Firms with marginal
control costs less than the price of an allowance will reduce emissions and sell their excess
allowances in the market. In equilibrium, the water quality goal is met (total emissions are no
more than the number of emission allowances in the market), those firms that can reduce
emissions at the lowest cost provide most of the pollution control, and marginal control costs
for all emissions are equal (thereby meeting the efficiency goal). The promise of emissions
trading, along with the real-world success of air emissions trading, has led U.S. EPA to encourage
States to consider agriculture as a source of offsets in water quality trading programs, and a
number of States are either implementing or considering water quality trading programs that
allow point/nonpoint source trading. Allowing agriculture to supply credits in a market created
by capping emissions from regulated point sources would (1) reduce the cost of meeting water
quality goals by allocating abatement more efficiently among sources (the economic rationale
for trading); and (2) provide a strong economic incentive for unregulated nonpoint sources to
play a larger role in improving water quality (U.S. EPA, 2008). This is an important goal for water
quality trading in the Chesapeake Bay watershed. Regulators designing point/nonpoint trading
markets must contend with uncertainty about sources and levels of emissions, the effectiveness
of best management practices, the water quality impacts of emissions from different sources,
and farmer willingness to participate in a market driven by regulation (on point sources) (Hoag
and Hughes-Popp, 1997; King, 2005; King and Kuch, 2003; Woodward and Kaiser, 2002; Ribaudo
and Gottlieb, 2011; Horan and Shortle, 2011; Shortle 2013). The failure of current trading
programs to perform as hoped can largely be attributed to failures of market design and
program rules to adequately address these issues, and to the high transaction costs due to the
necessity of incorporating uncertainties into market design. The Role of Trading Baselines In a
point/nonpoint trading program, pollutant reductions that would have occurred as a result of
technology upgrades by regulated point sources are replaced by equivalent, long-term
reductions from unregulated nonpoint sources that would not have occurred in the absence of
the trading market. In order for water quality to be protected, the nonpoint-source reduction in
pollutants must be identical in quality to the forgone point-source reduction and must not have
occurred without the incentive provided by the market (the credit is “additional”). This is the
role of the baseline. A baseline is a prediction of the amount of pollutant emissions from an
activity resulting from the expected future behavior of actors absent any policy intervention
(trading program), holding all other factors constant (Marshall and Weinberg, 2012; U.S. EPA,
2007). Fields not meeting the baseline criteria cannot produce credits for sale in a market until
the baseline criteria are achieved. If a full credit is issued for an activity that would have
occurred anyway, then it is non-additional and total pollutant loadings will be greater than if the
credit had been additional (Marshall and Weinberg, 2012). In the Chesapeake Bay watershed,
Pennsylvania, Maryland, and Virginia have all established baselines that do not reflect current
practices, but that require a certain level of stewardship be attained before credits can be sold.
These are consistent with U.S. EPA guidance on baselines. U.S. EPA’s trading policy states that
where a TMDL is in place, the Load Allocation or other appropriate baseline should serve as the
threshold for nonpoint sources to generate credits (U.S. EPA, 2007). In a sense, the baseline
becomes a representation of the TMDL Load Allocation implemented at the field scale, akin to
the Waste Load Allocation for point sources being incorporated into the individual NPDES
permits. Establishing a stewardship-based baseline essentially requires a farm to contribute to
the TMDL’s Load Allocation before being able to sell credits. The ability to sell credits is expected
to be a sufficient incentive for farmers to provide this extra abatement. Farmers already meeting
the baseline, who could be considered good stewards for previously adopting conservation
practices, would be able to enter the trading program without first contributing to Load
Allocation. Farmers who are not using best management systems (from a resource conservation
standpoint) would likely have to adopt some conservation measures to meet baseline
requirements. The more stringent the baseline (i.e., the smaller the pollutant losses allowed),
the greater the percentage of cropland needing improved management before being able to
produce and sell credits. However, setting a baseline that is more stringent than current
practices could come at a cost to point sources trying to reduce their own permit compliance
costs. Such a baseline could significantly restrict credit supply by discouraging producers who
can supply credits at a relatively low cost but are not meeting the baseline from voluntarily
entering a market. A farmer would only be willing to create and sell credits if the expected credit
price is high enough to generate the revenue necessary to cover the cost of meeting the
baseline plus the cost of any measures taken to produce additional abatement. If the price is
sufficient for the farmer to enter the market, the amount of abatement equal to baseline is
credited toward Load Allocation, while the remainder goes to the market. In aggregate, the
sector’s credit supply curve shifts to the left, reflecting the higher cost of supplying credits.
Higher credit costs will reduce the amount of credits purchased by point sources. The amount of
the shift depends on the share of cropland not currently meeting baseline requirements and the
amount of abatement farmers must achieve before being eligible to trade. In aggregate, the
shift in the sector supply curve increases the market price of credits, reducing the number of
nonpoint-source credits purchased by point sources. There are also consequences from the
standpoint of reducing nonpoint-source pollution. If meeting an eligibility baseline discourages
those farms that can provide the most abatement at the least cost from participating in a
trading program, the overall efficiency of the policy for meeting TMDL goals could be reduced.
As demonstrated earlier, traditional design-based policies that might be used to achieve a
stewardship baseline consistent with the TMDL are much less efficient than performancebased
policies, such as trading. Stephenson et al. (2010) found that when the eligibility baseline is
more stringent than current practices, agricultural credit costs for nitrogen can surpass marginal
abatement costs for point sources because the baseline has claimed the lowest-cost pollutant
reductions. Ghosh et al. (2011) found that Pennsylvania’s baseline requirements significantly
increased the cost of entering a trading program, making it unlikely that nonpoint sources that
could reduce nutrient losses for the lowest unit costs would enter the market. Wisconsin has
expressed concern that U.S. EPA’s approach to defining baselines could obstruct agricultural
sources’ participation in trading programs and possibly impede water quality improvements
(Kramer, 2003). The concern is that fewer nonpoint-source credits would be purchased by point
sources, and that total abatement costs for regulated sources would be higher than they would
be otherwise. None of these studies examined the effect of baseline choice on total nonpoint-
source abatement.
TMDLs
TMDLs Solve
Total maximum daily loads solve
Blankenship 2020 - editor-at-large of the Bay Journal
Karl Blankenship Jan 14, 2020 “Can the EPA enforce the Chesapeake Bay’s ‘pollution diet’?”
https://www.bayjournal.com/news/policy/can-the-epa-enforce-the-chesapeake-bay-s-
pollution-diet/article_97b4488e-3b9c-11ea-aee3-131df627f5d6.html
A TMDL sets the maximum amount of a pollutant that the waterbody can receive and still meet
those standards. The Bay TMDL maximum “loads” are established for the pollutants nitrogen,
phosphorus and sediment. The TMDL, often called the Bay’s “pollution diet,” allocates those
loads among the states and major rivers that drain into the Bay. It also establishes specific limits
for entities with a discharge permit. But, in a strict sense, it is not the TMDL that enforces those
numbers for individual dischargers. The permits do that job — but they must be consistent with
the TMDL. “TMDLs are not self-implementable,” said Mike Haire, who helped manage the U.S.
Environmental Protection Agency’s TMDL program for years, and now teaches environmental
science at Towson University. “But,” he added, “the bottom line is you can’t write permits that
aren’t consistent with the TMDLs.” And if water quality standards are not being met after those
permit limits are in place — possibly because unregulated sources of runoff are not meeting
their goals — the limits “might have to become more stringent than the requirements in the
TMDL,” Haire said.
Water Quality Trading
The CWA’s TMDL mechanism links point sources and nonpoint sources for water bodies where
the water quality is impaired.234 Each TMDL thus creates incentives for point sources to
encourage their state legislatures and water quality agencies to more actively and effectively
address nonpoint source pollution and to work with nonpoint sources to reduce their
contributions to water quality impairments.235 In addition, the TMDL process has forced many
states to acknowledge that for many water bodies, water quality impairments arise either
exclusively or primarily through nonpoint source pollution.236 This recognition provides another
incentive for states to strengthen their nonpoint source management programs.237 The TMDL
requirement has also provided incentives for more creative water quality improvement
mechanisms.238 For example, in watersheds with TMDLs for nutrients or sediments, the EPA
allows water quality trading among all sources.239 The potential advantages of water quality
trading for agricultural nonpoint sources is becoming widely recognized, and the U.S.
Department of Agriculture has recently decided to promote it to farmers.240 In addition,
nutrient trading is being pursued in the Chesapeake Bay region— primarily in Virginia and
Pennsylvania—to encourage nonpoint sources to reduce nutrient pollution.241 Integrated
watershed water management approaches, like those adopted by the state of Texas, are also
emerging.242
States Water Trading Solvency
tag
pubid=45209
Prior to the TMDL, the Bay States relied heavily on traditional USDA conservation programs,
which use financial incentives to encourage farmers to voluntarily adopt management measures
consistent with the goals laid out by the various Chesapeake Bay agreements. These
conservation programs include the Environmental Quality Incentives Program (EQIP), the
Conservation Reserve Program (CRP), and the Conservation Reserve Enhancement Program
(CREP). Watershed Implementation Plans (WIPs), developed by the Bay Watershed States
outlining their strategies for meeting the TMDL, show a continued reliance on Federal and State
financial assistance for practices such as cover crops on cropland. However, exclusive reliance
on such policies has not been effective in improving water quality (Shortle et al., 2012). Despite
years of conservation expenditures, nearly 90 percent of cropland in the Bay watershed is in
need of additional nutrient or sediment management measures (USDA, NRCS, 2011). High
expected costs and farmer resistance have hindered the use of practices necessary to reduce
agricultural runoff (Bosch et al., 1992; Osmond et al., 2012). All of the Bay States have
developed or are developing water quality trading programs. Trading programs provide
regulatory flexibility for point sources, allowing them to purchase abatement from other
sources, including nonpoint sources, that exceed a compliance baseline. Ideally, trading reduces
the cost of meeting TMDL goals and increases abatement by nonpoint sources. Each State has
its own set of rules for establishing eligibility (baselines) and calculating credits or offsets.
Program design plays a critical role in the attractiveness of trading to potential program
participants and their ability to meet their TMDL goals.
TMDL – Federalism Link
If a future court were to face vehement opposition from a state actor directly affected by an
equally prescriptive, interstate TMDL, that court would be unlikely to adopt the Third Circuit’s
expansive interpretation of “total” or ignore claims rooted in rhetoric of agency overreach. If a
state filed suit against a federal, watershed-wide TMDL, the Chesapeake Bay model would likely
look more unconstitutionally coercive than collaborative.143 Given the limits of the CWA’s
cooperative federalism framework, the politics surrounding such a TMDL are likely to heavily
influence the court’s decision; nothing in the American Farm Bureau decision prevents future
courts from striking down federal TMDLs in uncooperative watersheds. Using the Mississippi
River Basin as an example, Part IV highlights the shortcomings of the Chesapeake Bay model and
the TMDL provision more broadly in addressing nonpoint source pollution in interstate bodies of
water.

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UTNIF_Agricultural Runoff

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

That causes super bugs

Requiring NPDES permits establishes performance based standards that solves

The largest one is in the Gulf of Mexico

Biodiversity loss causes extinction – makes life unsustainable

Federal intervention is key to eliminate manure lagoons

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

Status quo permitting makes agricultural permitting optional – reversing this

Uniform requirements flatten out the financial cost of adhering to

Livestock Air Pollution

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

Mutating diseases lead to extinction

That risks extinction

(Michael Greger, Bird Flu: A Virus of Our Own Hatching, http://birdflubook.com/a.php?id=111)

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

CAFOs decimate rural economies – causes labor migration

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

Agriculture is the primary cause of nonpoint pollution in the US

Agriculture is the largest contributor

Agricultural runoff is one of the primary sources of pollutants in water quality

Agricultural runoff is the largest contributor to water pollutants – that causes

July 5, 20135:17 PM ET https://www.npr.org/sections/thesalt/2013/07/09/199095108/Whats-

CAFOs are a primary source of nitrogen pollution

CAFOs cause nitrogen runoff from overapplication to croplands

40-45% reduction in N2O could solve the gulf’s dead zone

Fertilizer efficiency alone solves for 2/3 of gulf’s dead zone

Commercial fishing industry is key to the economy

Coastal economies drive the US economy

Reducing nitrogen benefits coastal and Midwest economies

Key to coastal economies

The affirmative solves – permitting closes regulatory loopholes

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

By Changing Prices, Incentive-Based Policies May Unintentionally Enhance the Profitability of an

(Michelle Johnson-Weider “From Factory Farming to a Sustainable Food System: A Legislative

ABR won’t cause extinction

ABR is slow and gradual --- reject their alarmism

If colistin-resistant bacteria shared

and often several.

Resiliency, intervening actors, burnout

Burnout and variation check

They cant solve the advantage for hundreds of years

No biodiversity impact – most losses have no impact on humans, and we can

EPA cant coordinate national standards

Caitlin Foley, 16 “REGULATING FEEDLOTS: APPROACHES TO CONTAINING CONCENTRATED

Despite the powers granted to the agency, the

Agriculture is outside of the jurisdiction of the CWA – it’s a nonpoint source

Performance-based approaches are key – enables widespread adoption at a

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