Document Details

Confined Animal Facility Permitting and Reporting Under the Porter-Cologne Water Quality Control Act: An Analysis of Regional Board Activities

Zoe Robertson, Evan Lehmann, Amanda Zerbe, I. Avery Bick, Deborah A. Sivas | February 2nd, 2026


This white paper analyzes reports containing (1) data from 2023 for the five regions with the largest numbers of CAFs in California; and (2) data from 2024 from the region with the most CAFs in the state. We identify six central problems with the self-reporting regime:

CAFs frequently underreport wastewater production, or fail to report it at all. CAFs frequently underreport manure production. CAFs do not disclose, or inadequately document, where waste goes. Most CAFs fail to report how much waste they apply to their crops. (Those that do typically report significant overapplication.) CAFs frequently fail to account for all nutrients in the waste they produce. Regional Boards do not adequately enforce reporting requirements.

Keywords

agriculture, groundwater contamination, nutrients