Ari - Jan & Feb

2020.xlsx
ACKNOWLEDGEMENTS
Written and researched by Tom Pelton, Mariah Lamm
and Abel Russ of the Environmental Integrity Project.
Additional analysis by KCI Technologies, Inc.

THE ENVIRONMENTAL INTEGRITY PROJECT

The Environmental Integrity Project
(http://www.environmentalintegrity.org) is a nonpartisan,
nonprofit organization established in March of 2002 by
former EPA enforcement attorneys to advocate for effective
enforcement of environmental laws. EIP has three goals: 1)
to provide objective analyses of how the failure to enforce or
implement environmental laws increases pollution and
affects public health; 2) to hold federal and state agencies, as
well as individual corporations, accountable for failing to
enforce or comply with environmental laws; and
3) to help local communities obtain the protection of
environmental laws.

CONTACTS:

For questions about this report, please contact:

Tom Pelton, Environmental Integrity Project, (202) 888-

2703 or tpelton@environmentalintegrity.org

PHOTO CREDIT S: COVER PHOTO AND O THER PICTURES

ON PAGES 4,11,13,16 AND 18-25 BY TOM PELTON.
PICTURE OF INTERIOR OF POULTRY HOUSE ON PAGE 1
BY SHUTTERSTOCK. PHOTEO OF CHICKENS ON PAGE 12
FROM JLASTRAS / WIKIMEDIA COMMONS. AERIAL PHOTO
OF POULTRY HOUSES ON PAGE 17 FROM ASSATEAGUE
COASTKEEPER.

2
Poultry Pollution in the Chesapeake Region
Executive Summary

W
hen many people think about the contributions of the poultry industry to
water pollution in the Chesapeake Bay, they consider only manure runoff.
Farmers working for Perdue and other companies raise more than a billion
chickens a year for the meat industry in the region – including 600 million on the
Delmarva Peninsula, 182 million in Virginia’s Shenandoah Valley, and 164 million
in Pennsylvania.1 Contract farmers also sell about 18 million turkeys for slaughter
(mostly in Virginia) and keep about 25 million hens at a time for the egg industry
(mostly in Pennsylvania).2 All of these birds produce about 5.7 billion pounds of
manure annually,3 which is often over applied to farm fields that are already
saturated with nutrients. This leads to runoff of nitrogen and phosphorus into
waterways, stimulating excessive growth of algae and low-oxygen “dead zones” that
can kill fish and crabs. The Bay region states have developed strategies to reduce this
pollution, including by requiring farmers to follow manure-management plans and
phosphorus limits in some areas, and by encouraging the planting of strips of trees
and vegetation along streams to act as filters.

However, the poultry industry also pollutes the Chesapeake Bay through a second
pathway that is not even monitored, let alone controlled. Industrial-scale chicken
houses – windowless, airplane hangar-like metal structures often twice the length of a
football field -- have large exhaust fans that blow ammonia from the poultry waste
out into the community. These air emissions, combined with ammonia rising from
chicken manure spread on farm fields, fall back down onto land and water in the Bay
watershed. The emissions contribute significantly to nitrogen pollution in the
nation’s largest estuary, because
ammonia breaks down into
nitrogen in the environment.4
Ammonia can also harm the health
of neighbors downwind, triggering
coughing, asthma attacks, watery
eyes, and the irritation and
inflammation of throats and nasal
passages.5 A 2018 study by Johns
Hopkins researchers found that
people who live near poultry houses
in Pennsylvania are 66 percent
Industrial scale poultry operations in the Chesapeake Bay region are
more likely to be diagnosed with releasing ammonia air pollution that contributes about 12 million
pneumonia.6 pounds of nitrogen water pollution into the estuary every year.

This report by the Environmental Integrity Project (EIP) examines data from the
federal and state Chesapeake Bay Program,7 emissions estimates from the most
recent scientific studies, and numbers from the U.S. Department of Agriculture’s
most recent farm census. EIP used the Bay Program’s computer modeling of

1
pollution entering the estuary to evaluate the total nitrogen load from the poultry
industry, including both the runoff of manure spread on fields as fertilizer, and
ammonia that rises from chicken houses and litter before falling back down in the
Chesapeake Bay watershed. EIP adjusted the Bay Program numbers – which are
based on EPA estimates – by using a review of more recent scientific studies of
ammonia emissions from poultry barns than EPA used to provide more realistic
estimates of total emissions and nitrogen pollution in the Bay. In our definition of
“poultry” we include not only chickens raised for meat (called “broilers,”) but also
chickens used for eggs (“layers”), turkeys, and other poultry. By “Bay” pollution
load, we mean pollution entering the tidal waters of the Chesapeake Bay, often
described as the “delivered load.” (For a detailed discussion of methodology and
sources, see Appendix A.)

The impact of ammonia on the Chesapeake Bay is significant. This report concludes
that ammonia emissions from poultry operations contribute about 12 million pounds
of nitrogen pollution to the Bay every year.8 To put those 12 million pounds into
context, they exceed the total nitrogen pollution from all the sewage and industrial
wastewater plants in Maryland (which released 10 million pounds of nitrogen in
2018) or Pennsylvania (9 million pounds) and almost as much as Virginia (12.6
million pounds from sewage and wastewater).9 The poultry ammonia total does not
include runoff from manure spread on farm fields, which adds another 12 million
pounds of nitrogen to the estuary every year. Altogether, if the ammonia and runoff
are combined, the poultry industry adds a total of 24 million pounds of nitrogen to
the Chesapeake Bay ever year. That is more nitrogen than from all of the urban and
suburban stormwater runoff in Virginia and Maryland combined (which was 20
million pounds in 2018). It is also 17 times more nitrogen pollution than in all the
overflows from the combined sewage and stormwater systems in the Chesapeake Bay
watershed, including those in Washington, D.C., and Harrisburg, Pennsylvania.10

Table 1: Nitrogen Pollution Entering Bay from Poultry Industry (lbs in 2018)

Nitrogen Nitrogen from

from ammonia Nitrogen runoff Total nitrogen
ammonia emissions from poultry from poultry
State emissions (adjusted) manure entering the Bay
DE 508,015 752,114 1,483,306 2,235,420
MD 2,802,139 3,324,251 2,066,499 5,390,750
NY 77,478 81,433 59,185 140,618
PA 4,017,257 4,258,587 5,757,462 10,016,049
VA 2,139,000 2,473,710 2,322,844 4,796,554
WV 702,972 742,929 709,977 1,452,906
Grand Total 10,246,861 11,633,024 12,399,273 24,032,297
Note: Results are expressed as annual pounds of nitrogen entering the tidal waters of the Chesapeake Bay in 2018. Numbers are from the
11

Chesapeake Bay Program Bay Model, with the “adjusted” correcting for the likely underestimate in ammonia in the program’s watershed
model (see Appendix A). We apportioned the ammonia falling directly onto the Bay between the portions of the estuary in Maryland and
Virginia.12

2
For a version of this chart with a separate line item for ammonia falling directly onto the
Bay, see Table 6 on page 15. Our adjusted ammonia totals (the total amount of nitrogen
entering the Bay from ammonia emissions) are about 14 percent, or 1.4 million pounds,
higher than the totals implied by the Bay Program’s watershed model. This is in part
because the model relies on ammonia emissions estimates from EPA’s 2011 National
Emissions Inventory, which is in turn based on outdated ammonia emissions studies,
including, for example, studies of European broiler operations from the 1980s and 1990s.

3
Based on more recent research, ammonia emissions from modern American broiler barns
can be significantly higher because U.S. chicken companies grow larger birds, work in
different climates, and follow different farming practices. We documented this problem in a
2018 report, and derived a set of emissions factors for ammonia from broiler barns. 13 In this
report, EIP incorporated these more up-to-date emissions factors for broilers, and we also
used updated emissions factors for layers and turkeys. Finally, we made use of more recent
inventory and production data from the U.S. Department of Agriculture to account for
recent growth in the industry.
Our estimate of 24 million pounds of nitrogen per year may still be too low, because the Bay
Program model may underestimate the rate at which airborne ammonia deposits onto land
and water. A recent study published by researchers from North Carolina State University
suggested that ammonia deposition on Maryland’s Eastern Shore may be two to three times
higher than previously assumed. For a full discussion of that report, see Appendix B.
Of course, poultry is only one part of the agricultural sector across the Chesapeake Bay
watershed. All farms add a total of more than 119 million pounds of nitrogen pollution to
the estuary on an annual basis, according to EPA figures.14 That total agricultural share of
pollution is more than three times the combined total from all the municipal sewage plants
and industrial wastewater treatment plants in the watershed, and represents about 45
percent of the total nitrogen pollution entering the Bay from all sources, according to EPA.15
Reducing that agricultural
pollution has been a
challenge in part because
the federal Clean Water
Act requires enforceable
permits with numeric
pollution limits for
sewage plants and other
facilities with pipes that
dump directly into
waterways, but not for
farm fields or agricultural
air pollution. Federal and
state permitting
requirements for poultry
houses and other animal The exhaust fans on industrial-scale poultry houses blow ammonia, particles of
feeding operations include fecal matter, bacteria and other pathogens into the surrounding community.
some rules on the storage Neighbors sometimes complain of asthma attacks, pneumonia, and other
illnesses.
and management of
manure, to discourage
runoff into nearby streams. But, so far, no permits require the monitoring or control of

4
ammonia or other air emissions. That leaves a major source of pollution, as well as a threat
to public health, unchecked and largely unknown.
This report recommends the following policy steps to address the problem:
1) EPA should update the ammonia emission estimates it uses to simulate nitrogen
loads to the Bay to reflect the most recent available science.
2) All large new animal feeding operations should be required to install air pollution
monitors and report their emissions on an annual basis to state environmental
agencies and the EPA.
3) EPA should establish safety thresholds for ammonia that apply to the fenceline areas
between poultry operations and neighboring residents, to help protect local
communities from excessive levels of ammonia.
4) States and the EPA should require poultry houses to install effective air pollution
control systems, including filters to capture particulate matter being blown by poultry
house exhaust fans out into the community.
5) Poultry companies should pay for the planting of more trees and forested areas
around chicken houses, to protect neighbors and to help catch and reduce ammonia
emissions.
6) Because the Chesapeake Bay region states are already struggling with the
overproduction of manure, lawmakers should impose limits on the approval of new
permits for large animal feeding operations, especially in areas that produce more
manure than crops can use.
The big picture is that air emissions from factory farms cause both environmental harm and
public health threats for families who live nearby. For this reason, more air pollution
monitoring and controls are needed. This report provides a discussion of the most recent
science and agricultural census data on chicken farms and other broiler operations across
the Chesapeake region.
We then illustrate the real-life impact of poultry air pollution with profiles and photos of
families living downwind from industrial scale poultry houses in Maryland, Pennsylvania,
and Virginia.

5
Table of Contents
Nitrogen Pollution from Poultry ...................................................................................................................7
History and Scale of the Chesapeake Broiler Industry ......................................................................... 10
Broiler Weight................................................................................................................................................ 12
Varying Estimates of Ammonia Emissions ................................................................................................ 13
Impact of Higher Rates of Ammonia Emissions ...................................................................................... 14
EPA’s Delay in Updating Ammonia Numbers ......................................................................................... 16
Efforts to Require Air Monitoring and Pollution Limits ........................................................................ 16
The Health Impact of Factory Farms......................................................................................................... 18
Local Profile: Maryland ................................................................................................................................. 19
Local Profile: Pennsylvania ........................................................................................................................... 22
Local Profile: Virginia .................................................................................................................................... 25
Conclusion ...................................................................................................................................................... 28
Appendix A: Methodology ........................................................................................................................... 30
Appendix B: Discussion of Recent North Carolina State University Research on Ammonia
Emissions on Maryland’s Eastern Shore.................................................................................................... 37
Appendix C: Maps of Nitrogen Pollution Entering Bay from Poultry Ammonia............................. 40

6
Nitrogen Pollution from Poultry
Ammonia is a chemical compound of nitrogen and hydrogen with a pungent smell that is
produced, among other places, in the guts of animals as a byproduct of food digestion. In
the environment, ammonia breaks down into its component parts, liberating the nitrogen,
which acts as a nutrient to feed algae blooms and low-oxygen “dead zones” in the Bay.

The Environmental Integrity Project estimated the total nitrogen load from poultry
operations in the Chesapeake Bay watershed for the year 2018. That was the most recent
year for which complete data were available from the Chesapeake Bay Program’s computer
modeling of pollution flowing into the estuary.16 We extracted from these total estimates the
amount of nitrogen delivered into the Bay from the land application of poultry litter, and
added to this the ammonia air emissions that rise from poultry houses and manure before
falling back down onto the land and water.17 By limiting our numbers to just the nitrogen
entering the tidal waters of the Bay, we focused on the ecological impact of the nitrogen on the
estuary itself and not on the freshwater streams and rivers that are its tributaries. The
methods we used are described in detail in Appendix A.

Nitrogen pollution from poultry tends to be concentrated in certain hot spots. The counties
with the highest per-acre nitrogen load are in three areas: The lower Susquehanna River in
Pennsylvania, the Delmarva Peninsula, and Virginia’s Shenandoah Valley.

Table 2: Top 10 Counties for Most Poultry Nitrogen Pollution Entering the Bay
(pounds in 2018)

County Nitrogen from Runoff of nitrogen Total nitrogen

ammonia air from manure pollution entering
emissions entering Bay from poultry
the Bay

Lancaster, PA 955,417 2,358,676 3,314,092

Sussex, DE 446,005 1,372,170 1,818,175
Rockingham, VA 287,659 751,730 1,039,389
Lebanon, PA 212,599 536,327 748,926
Caroline, MD 211,069 455,774 666,843
Snyder, PA 177,152 446,623 623,774
Dauphin, PA 313,296 278,561 591,857
Dorchester, MD 283,788 275,791 559,579
Somerset, MD 187,562 351,516 539,079
Wicomico, MD 285,806 219,121 504,927
Numbers above reflect nitrogen load in pounds entering the Chesapeake Bay’s tidal waters in 2018, based on Chesapeake
Bay Program numbers. See Appendix A for methods.

7
The pollution hot spots are roughly the same when the counties are ranked on a per acre
basis, as opposed to a total nitrogen load basis. The map below shows a breakdown per acre
in Bay region counties.

County Breakdown of Nitrogen Pollution Entering Bay, 2018

This map shows the total nitrogen load from the poultry industry per acre entering the Chesapeake Bay from poultry from
each county, with the darker blue colors representing higher concentrations of pollution. For additional maps showing
ammonia-related nitrogen pollution from poultry, see Appendix C.

8
Of course, there are different types of poultry farms in the Chesapeake Bay watershed –
including those that raise chickens for meat (“broilers”), egg-laying chickens, turkeys,
ducks, and other birds. As mentioned earlier in this report, the industry produces more
than a billion broilers in the region every year, and sells about 18 million turkeys for
slaughter (mostly in Virginia’s Shenandoah Valley). Farmers keep about 25 million hens
at a time for the egg industry (the majority in Pennsylvania). All these varieties of birds
produce different amounts of manure, ammonia and nitrogen pollution. Below is a chart
showing the different amounts of nitrogen entering the Bay from each type of poultry:

Table 3: Nitrogen Pollution Entering Bay from Types of Poultry in 2018 (lbs)

Nitrogen from Nitrogen from Total nitrogen entering

Type of Poultry
ammonia runoff Bay

Broilers 8,026,122 8,147,014 16,173,136

Layers 1,755,809 2,749,433 4,505,242
Turkeys 1,407,782 1,016,293 2,424,074
Other Poultry 443,311 486,533 929,844
Grand Total 11,633,024 12,399,273 24,032,297
Note: Numbers only include poultry within the Chesapeake Bay watershed. “Other poultry” includes pullets, ducks, and all
other forms of poultry. Based on Chesapeake Bay Program numbers. See Appendix A for methods.

Across the Chesapeake Bay watershed, about two thirds of the poultry industry’s nitrogen
pollution comes from broilers, which is also a rapidly growing sector in some areas, such as
in south central Pennsylvania the Shenandoah Valley in Virginia.

9
History and Scale of the Chesapeake Broiler Industry
The modern poultry industry has its origins back in the 1920s on the Eastern Shore of
Maryland. After World War I, Arthur Perdue invented the factory-style poultry production
methods – with giant metal buildings packed with thousands of animals – that have now
spread around the world and to other livestock industries, including the raising of hogs and
turkeys.18

A key to the industry’s growth was that the meat company – in industry parlance, the
“integrator” – owns the chickens and makes most of the profits from processing and selling
the birds, while requiring contract farmers to borrow large sums of money to build and
maintain chicken houses
according to terms dictated
by the company. The
contract farmers assume all
the responsibility for
disposing of the waste.19
Over the decades, this
factory-style farming
spread to Virginia’s
Shenandoah Valley, central
Pennsylvania, and
elsewhere.
In total, farmers in the U.S.
grew about nine billion
broiler chickens in 2018,
with Georgia, Alabama,
and Arkansas now the
biggest producers.20
Maryland and Virginia
rank numbers 10 and 11,
and Pennsylvania ranks 14.
The scale of both the
poultry houses and the
chickens themselves –
fattened by specialized
diets and antibiotics – have
continued to grow larger
over the last century since
Perdue’s innovations.
The most recent numbers from the U.S. Department of Agriculture farm census, which is
conducted every five years, suggest that the overall broiler industry grew by about six
percent in the Chesapeake Bay states between 2007 and 2017, with 1,012,953,727 broilers

10
sold in Bay watershed counties at the beginning of that decade, and 1,073,683,072 at the
end.21 (And it is worth noting that the agricultural census figures are just estimates, and the
real numbers may be different).
The growth of the industry was not even across the region, however, with some areas
experiencing spikes in chicken house construction and other areas declines. As an example
of areas with uneven growth, Maryland as a whole experienced a four percent increase in
broilers produced between 2007 and 2017. However, Dorchester County (on the southern
part of the Eastern Shore) witnessed a 35 percent drop in broiler production, while Caroline
County (on the mid Shore) experienced an 18 percent increase over this decade, according
to the U.S.D.A. estimates. Of all the Bay region states, Pennsylvania experienced the largest
growth, with a 19 percent rise in the number of broilers produced in counties that drain into
the Chesapeake Bay from 2007 to 2017. York and Lebanon counties in Pennsylvania had
the highest growth rates, with the number of chickens grown in York County rising 87
percent, to 4.9 million, in 2017, and Lebanon experiencing a 73 percent growth, to 27
million broilers. The overall growth in Virginia was only four percent. However, in
Virginia’s Shenandoah Valley, farms grew 15 percent more broilers in 2017 than in 2007,
with Augusta County producing 45 percent more birds and Rockingham 38 percent more.
Below is a chart illustrating the different increases:
Table 4: Broiler Chickens Raised, and Manure Produced, in Chesapeake States

State Broilers Produced in Broilers in Change Manure in Manure in Change

2007 2017 2007 (lbs) 2017
MD 295,911,411 306,955,125 4% 336,431,474 422,351,664 15%
DE 246,098,878 262,807,807 7% 366,846,867 433,938,433 18%
PA 137,353,085 163,582,244 19% 182,685,961 210,069,927 15%
VA 244,809,617 255,620,381 4% 280,702,674 339,990,000 21%
WV 88,772,940 84,703,496 -5% 83,473,689 75,757,729 -9%
NY 7,796 14,019 80% 9,583 18,325 91%
TOTAL 1,012,953,727 1,073,683,072 6% 1,280,150,248 1,281,476,896 16%
Note: Figures are from USDA Agricultural Census estimates on broilers (meat chickens) for counties in Chesapeake Bay watershed.
Manure figures are from EPA per bird estimates, and reflect different average weights over time in different states.

As shown in the manure numbers above, the amount of waste produced by the broiler
industry in each state did not change at the same rate as the number of birds grown – or at
the same rate as other states. This is because, in general, the broilers have been getting
heavier, and heavier chickens produce more manure (and more ammonia). However, farms
differ from place to place, and so the changes in average bird weights vary.

11
Broiler Weight
Poultry companies over last half century have used selective breeding techniques,
specialized diets, antibiotics, and dietary supplements to engineer birds that grow faster and
larger and therefore have more meat.22
Nationally, the average market weight for a broiler chicken in 2018 was 6.26 pounds. That
was an increase of 12 percent from 5.58 pounds a decade earlier, and two and a half times
the average weight of a chicken (only 2.5 pounds) back in 1925.23 In the Chesapeake Bay
region, the trend has been similar, with increasingly large birds. The average weight of a
broiler in bay states was 5.76 pounds in 2018 – compared to 5.28 pounds in 2009.
For this report, EIP examined broiler production data from U.S. Department of Agriculture
to determine the average weight of broilers over the last decade in Delaware, Maryland,
Pennsylvania, Virginia, and West Virginia.24 No data were available for New York, so we
assumed that New York broilers weighed as much as the average broiler from the other five
states.

Average Weight of Broiler Chickens Nationally

6.20

6.00

5.80

5.60

5.40

5.20

5.00
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Chart above shows increasing weight of an average chicken raised for meat (“broiler” chickens) from 2008 to 2018, according to data from
the U.S. Department of Agriculture.

It should be noted that broiler weight varies significantly from state to state over time. The
average broiler weight in Delaware, for example, has been rapidly growing and is now
roughly double the average West Virginia broiler, where the weight has been relatively
constant. The table below shows average broiler weight in each Bay state from 2008 through
2018.

12
Table 5: Average Weight of Broilers, By State (In Pounds)

Average Bay Broiler

Year Delaware Maryland Pennsylvania Virginia West Virginia Weight
2008 6.50 5.40 5.80 5.00 4.10 5.36
2009 6.90 4.80 5.70 5.00 4.00 5.28
2010 6.94 4.77 5.62 5.16 3.95 5.29
2011 7.00 5.30 5.60 5.30 4.00 5.44
2012 7.10 5.30 5.60 5.40 4.00 5.48
2013 7.10 5.30 5.60 5.40 4.00 5.48
2014 7.10 5.40 5.50 5.50 3.90 5.48
2015 7.20 5.70 5.60 5.60 3.80 5.58
2016 7.30 6.10 5.60 5.70 3.90 5.72
2017 7.20 6.00 5.60 5.80 3.90 5.70
2018 7.30 6.00 5.70 6.00 3.80 5.76

The above chart shows the varying weights of chickens raised for meat in the different Chesapeake region states, from 2008 to
2018, according to U.S. Department of Agriculture data. The final column shows the average weight per broiler chicken in
the whole Bay watershed.

Heavier birds produce more manure. To determine manure production, EIP applied a
weight-based manure production estimate that EPA used in creating its most recent
computer modeling of pollution inputs into the Chesapeake Bay.25

We conclude that the one billion broilers grown in the region produced about 1.5 billion
pounds of manure in 2017, which was a 16 percent rise over 2007, although the number of
birds grown only increased by about six percent over this time period. More manure means
more waste that needs to be managed, and also more ammonia rising into the atmosphere.
Both can lead to more pollution in the Chesapeake Bay.

Varying Estimates of Ammonia Emissions

EPA’s current estimates of how much ammonia is produced per broiler chicken are
outdated and should be replaced by findings from more recent and relevant scientific
studies.26 The agency is in the process of reviewing new data, but has been undergoing this
review process for more than a decade. As of 2018, the Chesapeake Bay Program – which is
led in part by EPA – was still using old emissions estimates from EPA’s 2011 National
Emissions Inventory (NEI) in its computer modeling of pollution entering the estuary.27 The
estimates in the 2011 NEI were based on European studies of pollution from its chicken
industry.28 Specifically, EPA relied on Dutch studies from 1988 to 1998 that examined
emissions in the Netherlands, England, and Germany.29

Using these old studies, EPA estimated that emissions from chicken houses could be
expressed as 0.22 pounds of ammonia per broiler per year.30 However, these European
studies are not representative of U.S. poultry operations because European farms generally
grow lighter birds, Europe is generally cooler than the U.S., and farming practices are

13
different on each continent. For example, European farmers tend to replace the litter in their
chicken houses after each flock, while American broiler operations repeatedly reuse litter.
All of these factors cause American broiler emission rates to be significantly greater than
European rates.

A growing body of science, published in peer-reviewed journals over the last 16 years and
reviewed by the Environmental Integrity Project, shows that North American broiler barns
can produce twice as much ammonia as European barns, with a mean emissions rate of 0.43
pounds of ammonia per broiler per
year.31 For example, researchers
working with EPA between 2007 and
2009 performed studies at four
broiler houses in Kentucky and
California that concluded that
emissions from chickens were
significantly higher than those in
Northern Europe.32 In 2005 and
2006, researchers examined four
Arkansas chicken houses and also
found higher average ammonia
emissions than those EPA has been
assuming,33 as did scientists New scientific research suggests that air pollution from chicken
houses, like this one in York County, Pennsylvania, contribute about
examining farms in Texas,34 1.4 million pounds more nitrogen pollution into the Chesapeake Bay
Maryland,35 Pennsylvania,36 and every year than EPA has estimated.
Mississippi between 2003 and 2014.
37

Impact of Higher Rates of Ammonia Emissions

In order to account for the changes in ammonia emissions estimates and the most recent
science, as well as changes in the poultry industry (including the rapidly increasing size of
broilers), EIP made a series of adjustments to our calculations of the nitrogen load from
poultry. These adjustments are described in detail in Appendix A. In short, we increased the
nitrogen load to the Bay attributable at the state level38 to the “dry deposition” of ammonia
– that is, ammonia that deposits as a gas on water and land. We adjusted only the “dry
deposition” because the Bay Program’s computer modeling of “wet deposition” – meaning
the ammonia falling to earth in wet precipitation – is mainly based on direct measurements
of ammonia in rainfall, so it is not affected by EPA’s assumptions about ammonia
emissions.
Our adjusted results are presented below. The bottom line is that EIP estimates that about
one million more pounds of nitrogen are entering the Chesapeake Bay each year from
poultry-related ammonia than the Bay Program currently assumes. Regardless of whether
one uses the raw or the adjusted ammonia estimates, ammonia emissions are responsible for

14
roughly half of the total nitrogen entering the Bay from both the poultry industry’s air
emissions and runoff pollution.

Table 6: Nitrogen Pollution from Chesapeake Region Poultry Industry in 2018

(pounds).

Nitrogen from Total poultry-

Nitrogen from Nitrogen from runoff of Total poultry- related
ammonia ammonia poultry related nitrogen
State emissions (adjusted) manure nitrogen (adjusted)
DE 508,015 752,114 1,483,306 1,991,322 2,235,420
MD 1,801,341 2,188,068 2,066,499 3,867,840 4,254,567
NY 77,478 81,433 59,185 136,663 140,618
PA 4,017,257 4,258,587 5,757,462 9,774,719 10,016,049
VA 1,205,677 1,414,130 2,322,844 3,528,521 3,736,974
WV 702,972 742,929 709,977 1,412,948 1,452,906
Ammonia
falling directly 1,934,121 2,195,763 1,934,121 2,195,763
onto the Bay39

Grand Total 10,246,861 11,633,024 12,399,273 22,646,133 24,032,296

Note: Results are expressed as delivered pounds of nitrogen entering the tidal waters of the Chesapeake Bay, adjusted to account for the
likely underestimate in ammonia emissions in the Chesapeake Bay Program’s watershed model. See Appendix A for methods.

However, the above numbers may still be lower than reality, because more ammonia may
be falling back down onto the land and water than is reflected in this estimate. The evidence
for this can be found in a recent study published by researchers from North Carolina State
University, which suggests that ammonia deposition may be two to three times higher than
previously assumed. Specifically, that study estimates that poultry production on
Maryland’s Eastern Shore results in the annual deposition of about 23 million pounds of
ammonia just on land.40 That could mean 3.8 million pounds of nitrogen from the ammonia
entering the Bay every year, just from Maryland’s Eastern Shore.41 By contrast, the Bay
Program’s estimates suggest that only about 2 million pounds of nitrogen enter the Bay
annually from the ammonia landing in Maryland.42
EPA has, in some contexts, acknowledged the evolving state of the science. For example, in
2017 EPA issued guidance for estimating and reporting ammonia emissions that
recommended emissions factors of between 0.41 and 0.75 pounds of ammonia per broiler
per year.43 However, EPA has not incorporated this guidance into its official calculations for
how much pollution is flowing into the Chesapeake and other waterways.

15
EPA’s Delay in Updating Ammonia Numbers
Back in 2004, EPA announced
that it would be conducting a
“groundbreaking” study of air
emissions from factory farms.44
That $15 million project was to be
funded by livestock industry
groups—the National Pork Board,
National Milk Producers
Federation, United Egg Producers,
and National Chicken Council—as
part of a compliance agreement
with EPA.45 Farms that
participated in the study would
receive immunity from air
A EPA study of ammonia emissions from poultry operations
pollution and hazardous waste has been stalled for almost a decade.
enforcement actions by the EPA.
Livestock operators contributed from $200 to $100,000 each depending on the size and
number of the factory farms they wanted to receive immunity from EPA for possible
violations. Using this funding, EPA’s National Air Emissions Monitoring Study monitored
24 sites at animal feeding operations in nine states over two years to measure releases of
ammonia, particulate matter, hydrogen sulfide, and volatile organic compounds.46

The project stalled in 2013 after the EPA Science Advisory Board rejected the proposed
methodology for the study.47 Since then, the effort by EPA to monitor or regulate air
pollution from factory farms has slowed down, with no final emissions estimates as of 2020.
EPA may produce its own official updated ammonia estimates from this research, but it has
not yet. “EPA is currently analyzing the data,” the agency’s website said in March 2020.48
The agency plans to release its updated draft models for ammonia, hydrogen sulfide, and
particulate matter emissions from poultry farms in November 2020.49 After that, EPA says it
will conduct a “stakeholder review period” and then finalize all emission estimating
methodologies at a date “to be determined.”

Efforts to Require Air Monitoring and Pollution Limits

None of the Chesapeake region states or EPA require poultry houses to install monitoring
or air pollution control devices, and so scientific data on the amount of pollution escaping
from poultry operations is limited. One local exception to the lack of pollution control
devices is in south-central Pennsylvania, where the Codorus Township Board of Supervisors
passed a local health ordinance on August 6, 2015, in reaction to a proposal by an egg
company, the Hillandale Corp., to build four additional huge chicken houses to hold two
million birds.50 The ordinance requires any future industrial-scale animal feeding operations
to install air pollution control filters and ultraviolet lights on their exhaust fans, to catch

16
particulate pollution and kill pathogens. (For more on this example in Pennsylvania, see
page 22).

In 2017, 2018, and 2019, Maryland lawmakers introduced a bill called the “Community
Healthy Air Act” that
would have required the
Maryland Department of
the Environment to conduct
air monitoring at factory
farms and assess the health
risks to nearby residents.51
The legislation was
supported by public health
professionals,
environmentalists, many
local residents, as well as
the National Association for
the Advancement of
Colored People on
Maryland’s Eastern Shore.
Neither the EPA nor the states require any monitoring or air pollution control
“In Wicomico County, one equipment on animal feeding operations, even though they produce large
of the top broiler producing amounts of ammonia and other pollutants.
counties in Maryland, the
rate of emergency room visits due to asthma among adults is double the rate of the state
overall,” wrote more than two dozen doctors and nurses in a 2019 letter of support for the
bill that was signed by, among others, Assistant Professor Keeve Nachman of the Johns
Hopkins Bloomberg School of Public Health.52

Opposed to the air monitoring proposal were the Maryland Farm Bureau, the poultry
industry, Maryland Chamber of Commerce, and some Eastern Shore lawmakers. Stephan
Levitsky, a vice president at Perdue Farms, testified: “We believe this bill is not needed at
this time, based on currently available air sampling and emission studies and pending
information from planned ambient air sampling.”53 Levitsky was referring to an upcoming
joint study known as the “Lower Eastern Shore Ambient Air Quality Monitoring Project”
by the Keith Campbell Foundation for the Environment, the Maryland Department of the
Environment, and the Delmarva Poultry Institute, a trade organization.54

In 2020, Maryland legislators debated a pair of bills that would have banned the Maryland
Department of the Environment from approving any more new permits or expansions for
poultry operations that produce more than 300,000 birds per year.55 One argument for the
proposed pause in new approvals was that the state still lacks adequate data on the amount
of air pollution from animal feeding operations. “Emissions from these factory farms are
linked with negative health consequences,” said State Del. Vaughn Stewart of Montgomery
County, a sponsor of the bill.56Another argument offered by advocates of the bill is that
poultry operations in Maryland produce hundreds of millions of pounds more manure than

17
can be spread on local farm fields, many of which are already saturated with nutrients.57
Strongly opposed to the ban on new permits were the Maryland Farm Bureau and the
poultry industry. Holly Porter, executive director of the Delmarva Poultry Institute, a trade
group, testified about the industry’s impact on local business: “The bill … would devastate
the Delmarva economy that is fueled by the $3.5 billion value and more than 20,000 jobs
directly tied to this community.”58

The Health Impact of Factory Farms

Beyond just ammonia, poultry houses – which often house as many as 45,000 chickens at a
time – can also release microscopic particles of manure and other pollutants, which can
trigger asthma attacks. The buildings also emit hydrogen sulfide (which can cause nausea,
watering eyes, and coughing), as well as pathogens, endotoxins, and other potential health
hazards, according to studies by scientists at Johns Hopkins School of Public Health and
other universities.59 Researchers have found that the airborne contaminants can pose a
health risk to nearby residents.60 The intense odors from large animal feeding operations
can also disrupt people’s quality of
life.61
One 2018 study by Johns Hopkins
researchers that examined poultry
factory farms in Pennsylvania
found that people living nearby and
exposed to emissions were 66
percent more likely to be diagnosed
with community-acquired
pneumonia.62 A 2015 review of
available medical literature found
consistent associations between
living near factory farms and a
variety of health-related problems,
including asthma attacks, lung
Trucks loaded with chickens rumble down once-quiet rural roads in disease, fevers, stress, and
Somerset County, Maryland, to move birds from warehouse-sized infections with methicillin-resistant
buildings to slaughterhouses. Staphylococcus aureus (MRSA).63
A 2017 study found that living near
animal feeding operations was associated with higher rates of people who required asthma
medications and hospitalizations.64 And a 2018 study linked poultry operations to infectious
diahhrea and campylobacteriosis in people who live nearby.65
Beyond medical impacts to nearby residents, air pollution and water contamination from
industrial-scale poultry operations can also degrade property values of nearby homeowners,
increase truck traffic on once-quiet rural roads, and cause harm in other ways.
To illustrate these health and quality of life problems, EIP profiled three residents living
near animal feeding operations in Pennsylvania, Maryland, and Virginia.

18
LOCAL PROFILE: MARYLAND

When a City of Industry Sprouts in the Field Next Door

Princess Anne, Md. – A quarter
century ago, Sam Berley and his wife
Patricia bought a white clapboard
house with a porch on 10 acres of
land on Maryland’s Eastern Shore,
surrounded by nothing but fields and
forests. They had two kids, a boy and
a girl. And for years, they enjoyed the
rural serenity, with Sam working as a
special education teacher in the
Somerset County public schools.
Then, in 2015, everything changed.
This aerial photo shows Sam Berley’s home at bottom right and
The family farmer next door sold the
the six new poultry houses built in 2015 by an adjacent property
owner. property to a real estate investor. In
place of the corn fields a Frisbee
throw away from the Berleys’ porch, the new owner built six chicken houses holding a total
of 270,000 birds.
Now, instead of looking out on a field of golden grain, every morning Berley gazes from his
porch over a waste pond to windowless metal buildings, grain silos, gravel roads, trucks
heaped with chicken cages, and heavy equipment.
The landlord – who lives and works
elsewhere as a real estate agent – is
rarely around, Berley said. But the
roaring of the exhaust fans is
incessant, day and night, as they
blow dust and pollutants onto
Berley’s property and into his lungs.
“The ammonia smell from urine and
feces is so strong, and so offensive,
it’s hard to breathe sometimes,” said
Berley, who suffers from asthma.
“There are other chicken houses
down the road that are even closer
than these. When I drive by, half the Air monitoring at Sam Berley’s home found levels of ammonia from the
time I have to hold my breath until adjacent chicken houses much greater than background levels. “It’s hard
to breathe sometimes,” said Berley, who suffers from asthma.
I’ve passed. The odor is just
overwhelming.”

19
Air monitoring by the Environmental Integrity Project near Berley’s home from September
2016 through August 2017 found ammonia levels that averaged more than 20 times higher
than background levels measured at Blackwater National Wildlife Refuge.
In addition, soon after the poultry houses opened next door, Berley’s drinking well water
became contaminated, requiring the family to use bottled water for drinking and cooking.
As result of all the odors, contamination, truck traffic, and other problems, Berley estimates
that his home has dropped in value by perhaps 70 percent, from $100,000 to perhaps
$30,000, making the property difficult to sell.
“So you’ve got environmental costs, with the air and water being polluted. But you also
have the economic costs, such as the falling property values,” Berley said.
Table 7: Hot Spots for Broiler Industry Growth in Maryland

Location Chickens Chickens Change Manure in Manure in Change

Produced in in 2017 2007 (lbs) 2017
2007
Caroline
County 50,524,965 59,634,292 18% 62,585,811 82,053,175 32%
Worcester
County 57,937,906 63,739,795 10% 71,745,365 87,702,098 22%
Wicomico
County 53,098,623 57,869,664 9% 65,752,810 79,625,153 21%
Somerset
County 58,143,551 62,226,553 7% 72,000,019 85,619,969 19%
The above chart shows Maryland counties with the highest percentage growth in chickens raised for the meat industry from
2007 to 2017, according to U.S. Department of Agriculture data. Manure is in pounds.

When Berley moved in 25 years ago, there were eight chicken houses on his street,
including a small one on the family farm next door. Now there are more than 40. The new
houses are also much larger – each holding about 45,000 chickens, instead of about 30,000.
According to estimates from the U.S. Department of Agriculture’s census of farms, the
number of chickens sold for meat in Somerset County rose from 58 million in 2007 to 62
million in 2017, a seven percent increase. But because the broilers keep getting heavier, the
amount of waste that Somerset’s broilers produced rose from 72 million pounds in 2007 to
86 million pounds in 2017.
“Somerset County is the poorest county in the state of Maryland,” Berley said. “And these
huge operations and the companies that oversee them target the poorer counties because it’s
easier to move more chicken houses in. There’s less opposition, because they say, ‘Hey,
think of the tax dollars that are going to go into your county.’ Tax dollars are well and good,
but the other costs – the environmental and social costs – are just too high.”

20
For more than a year, Berley worked with another local resident, Lisa Inzerillo, to try to
convince the county to approve better public health protections for people who live next to
CAFOs. Together, they advocated for a
requirement that new chicken houses
install air pollution control filters on their
fans. That effort failed, as did their
suggestion for a temporary moratorium
on approvals for large new CAFOs.
However, the county did approve a
slighter larger setback requirement (50
additional feet) between future chicken
houses and nearby homes.
“The poultry industry just went nuts
because they did not want any air
pollution control filters,” Inzerillo Sam Berley, a special education teacher, loves his home and his
recalled. “It’s like the poultry industry vintage 1948 Chevy. But he estimates that his property overall has
bought the whole Eastern Shore and they dropped about 70 percent in value because of the poultry houses
feel like they can do whatever they want built next door.
with it.”

21
LOCAL PROFILE: PENNSYLVANIA

Fighting Factory Farms with a Public Health Law

Spring Grove, Pa. – For years, Brian
Kaltreider, a construction contractor,
worked on a pet project for his family.
He moved and rebuilt an 1864 log house
so that it offered all the modern
conveniences in the scenic wooded hills
of York County.
With his own hands, he laid 150 tons of
stone for the foundation. He carved
wooden pegs to secure the rough-cut
beams. He crafted a covered porch,
where he and his wife and kids could
relax in rocking chairs.
“This cabin has been my only real
dream in life,” said the 50-year-old
builder, as he played with his beagle,
Yuengling, beside a pile of firewood
beneath his porch.
Then, a few years ago, the dream turned
into a nightmare. An industrial chicken
operation with 1.3 million birds started
dumping tons of manure into the fields
behind the cabin.
“The flies would be all over you, all the
time, even when you went to the Instead of surrendering his home because of pollution from
bathroom,” Kaltreider said. “We had a a factory farm, Brian Kaltreider fought back and passed a
neighbor across the street with two local public health law that has discouraged future
young kids who just moved out, that’s construction of CAFOs in his township.
how bad the flies were. They just
couldn’t take it anymore.”
Kaltreider and his family nearly moved out, too, when they heard that the owner of the egg
facility – the Hillandale Gettysburg LP corporation – was proposing to build four additional
industrial-scale buildings and add two million more chickens.
The expansion was part of a trend. The number of chickens in York County has grown by
87 percent over the last decade, rising from 2.6 million broilers a year in 2007 to 4.9 million
annually in 2017, according to estimates from the U.S. Department of Agriculture. That
near doubling was among the highest rates for any county in the Chesapeake Bay
watershed, and it meant that the amount of chicken manure spread in local farm fields
nearly doubled to 6.3 million pounds a year.

22
Table 8: Hot Spots for Broiler Industry Growth in Pennsylvania

Location Chickens Chickens Change Manure in Manure in Change

Produced in 2017 2007 2017
in 2007
York County 2,633,566 4,924,806 87% 3,502,765 6,324,364 81%
Lebanon 15,626,022 26,962,357 73% 20,783,333 34,624,665 67%
County
Snyder County 13,283,321 17,712,428 33% 17,667,432 23,217,639 31%
Union County 7,719,646 10,415,342 35% 13,267,487 13,375,230 30%
This table shows the PA counties with highest percentage growth in chickens raised for the meat industry from 2007 to 2017,
according to U.S. Department of Agriculture estimates.

At the time, Kaltreider was serving as a supervisor on the Codorus Township Board. But he
resigned his position so he could work as an advocate against the massive Hillandale
project. Over a period of several months, Kaltreider rallied his neighbors and formed a
group called Friends of York County Family Farms. They fought the expansion of the
poultry operaration, including by sampling local streams to document the harm the manure
was causing to local water quality.
“It was amazing. We had some of the biggest turnouts at the township level, ever, for the
meetings on the project,” Kaltreider said. “We even had to hold one meeting outside, with
people standing outside in the rain, because there were so many people interested.”
Table 9: Hot Spots for Egg Industry Growth in Pennsylvania

Location Layer Layer Manure in Manure in Change in

Inventory Inventory 2007 2017 Manure
in 2007 in 2017 Generation
Northumberland
131,286 847,956 33,924,177 219,111,024 546%
County
Lancaster County 7,086,263 13,914,918 1,831,083,627 3,595,601,592 96%
Snyder County 300,957 569,521 77,767,003 147,163,685 89%
Franklin County 1,173,886 1,728,944 303,331,027 446,757,487 47%
This chart shows the PA counties with the most growth in chickens raised for the egg industry (“layer” chickens) from 2007
to 2017, according to U.S. Department of Agriculture estimates.

Among the local residents Kaltreider recruited to help was Maria Payan, a consultant with a
nonprofit organization called the Socially Responsible Agriculture Project. She also lived
beside a broiler chicken factory farm in York County and had been fighting to protect her
family’s health.

Payan said she was acutely aware of the large volumes of ammonia that poured out of
chicken houses. Four huge poultry barns, holding a total of about 100,000 birds, opened up
across the street from her home.

“My son would get off the bus and just throw up because it was just that odorous outside at
times,” said Payan. “I was running him to the doctor’s office for tightness of the chest,

23
rashes all the time. I mean, it was not normal. I called 911 one time at night, because we
were actually dizzy in our own house because of all the ammonia.”
She and Brian Kaltreider and his neighbors were helped in their battle against the factory
farms by attorneys at Food & Water Watch, a national, nonprofit advocacy group. In the
end, Kaltreider’s coalition won their fight against the Hillandale egg farm expansion project.
On August 6, 2015, the Codorus Township Board of Supervisors voted to deny a set of
plans for the Hillandale project. The board also approved a local health ordinance that
requires any future poultry houses to install air pollution control filters and ultraviolet lights
on their exhaust fans to catch particulate pollution and kill pathogens. The law prohibits any
new large animal feeding
operations that would be within
two miles of any other existing
factory farms and requires
$10,000 permitting fees for large
new facilities.
Scott Edwards, Director of the
Food and Water Justice Program
at Food & Water Watch, said that
the Codorus Township health
ordinance had the effect of not
only stopping the Hillandale
project (at least temporarily) but
also discouraging any new CAFO
applications from coming to the Brian Kaltreider points to the Hillandale Farm egg production facility
township. in York County that had been proposing to expand with four more
buildings and two million more chickens.
“The density requirement
essentially stopped the expansion of the CAFO industry in the township,” said Edwards. “I
think ordinances like this one would absolutely be helpful across the Chesapeake Bay
watershed and elsewhere. It’s an absurdity of the industry that state environmental agencies
don’t even know what pollutants are coming out of these facilities, let alone require any
pollution controls for them.”

24
LOCAL PROFILE: VIRGINIA

Fleeing from the March of Industrial Agriculture

Pungoteague, Va. – At night behind
Carlene Zach’s farm house, when
the spotlight on her dog run blazes
into the darkness, it looks like it’s
snowing, with a cloud of fluffy
particles drifting down onto the
grass.

This blizzard falls even in July. The

particles are not snow flakes, but
feathers and specks of manure.
They’ve been blown into her back
yard from an industrial-scale poultry
operation that opened next door
about two years ago. The 24 chicken
Carlene Zach and her husband Peter are trying to sell their 1901 farm
houses hold a total of a million birds. house on Virginia’s Eastern Shore to escape the ammonia air pollution
Their industrial exhaust fans roar 24 from a poultry farm next door. But nobody wants to buy the house.
hours a day, creating a foul wind of
dust and bacteria.

“In the summertime, when the winds come this way, you can’t even be outside,” Carlene
Zach said, standing in front of her farmhouse, with its wrap-around porch, robin’s egg blue
shutters, and doormat proclaiming “home sweet home.” “You can’t even play in the yard.”

Before the poultry farm opened two years ago here in Accomack County, Carlene Zach, a
60-year-old retired postmaster, and her husband Peter Zach, 62, a lineman for an electric
company, were in good health. But then the ammonia and fecal dust from the chicken
houses started drifting through their
windows, and the cloying odor triggered
incessant coughing, sneezing, and sore
throats.

“You constantly suffer from upper

respiratory infections,” she said. “You
suffer through the headaches, the stuffy
nose, the days when you don’t even want
to go out and enjoy your property.
We’ve lost the use of the property that we
pay taxes on. We can’t even sit on the
back deck for a barbecue because of the
Exhaust fans on 600-foot-long chicken houses blow feathers, smell. It’s obnoxious, and you can never
dust and particles of manure into Carlene Zach’s yard. get away from it.”

25
Peter Zach’s chronic headaches from sinus infections – which he had never suffered from
before – drove him to undergo surgery to open up his inflamed nasal passages. That surgery
helped him only temporarily, before the infections returned.

The couple decided they had no

choice but to move to escape from
the air pollution. Unfortunately, no
one wanted to buy a house with
giant sheds holding a million
animals only 600 feet away. The
Zachs dropped their price $50,000,
but still found no buyers.

“It’s a beautiful house, but we just

have to get out of here for health
reasons – even if that means just
leaving the house empty,
unfortunately,” said Carlene Zach.
“You got to do what you got to do A Texas-based company bought the land next to the Zach family and
to survive. We are moving to built 24 poultry houses that can hold a million birds at a time.
Tennessee, to a farm we found in
the mountains.”

Although family-owned poultry farms have been a part of the fabric of Accomack County
for decades, the scale and number of the factory farms have exploded in recent years. In
2014, the county had 254 chicken houses on 51 farms.66 But then that number was projected
to nearly doubled, with 480 houses on 83 farms by 2020, and at least 19 more permitted but
not yet built, according to a report by the Accomack County Planning and Zoning
Department.67 While the old
generation of houses were 200 feet
long, the new facilities are
sometimes three times that size.

The chickens are trucked a few miles

down the road to Tyson and Perdue
slaughterhouses in Accomack
County, which employ 3,040 people.
“The local economy benefits from
the poultry industry with
employment and payroll in the
following areas: poultry growers and
farm workers, truck drivers, grain
elevators, and grain farmers,”
Carlene Zach loves her four horses and selected her home so she could according to an Accomack County
ride. But she can’t even be outside anymore when the wind blows the
wrong way, because of all the ammonia from the poultry industry.
Planning Department report in 2019.

26
But the industry also has downsides, with increased water and air pollution, truck traffic,
and burdensome loans for contract farmers who must follow strict industry dictates to raise
the chickens.

Carlene and Peter Zach’s decision to move marks a sad end to the couple’s love affair with
Virginia’s Eastern Shore.

Carlene had moved from Florida and purchased the 1901-era home on Pungoteague Road
two decades ago. She worked as the postmaster in the nearby town of Melfa (population:
408) and loved riding horses on the weekends. She selected her home because of its 4.75
acres of land for her horses and barn.

It was riding that she met her future husband, Peter. They soon married and moved in
together into her farm house, which they remodeled together, adding an elegant library.
With their four horses and five dogs, the couple savored the outdoors, galloping through the
nearby meadows fringed by loblolly pine trees.

Then, a little more than two years ago, Carlene heard a rumor from a neighbor. The corn
and soybean farmer next door had sold his land to a Texas-based corporation that planned
to build 24 large chicken houses
on contract for Tyson foods.

Carlene gathered the signatures of

35 neighbors on a petition
opposing the project, and together
they marched into a meeting of
the Accomack County Board of
Supervisors. They announced
their strong objections. “We were
told, ‘It’s a done deal. There’s
nothing we can do,’” Carlene
recalled.

As soon as the poultry houses

opened about two years ago, the
waves of air pollution were Carlene Zach remembers riding her horses in a field now dominated by 24
windowless industrial buildings that are raising broiler chickens on
unbearable. In addition to clouds contract for Tyson Foods.
of feathers, dust, and ammonia,
the facility produces tons of manure, which is spread on nearby fields and runs off to
contaminate a stream beside the Zachs’ home and eventually the Chesapeake Bay.

“It’s creating havoc,” Carlene Zach said of the expanding poultry industry. “The county
board wasn’t really ready for the situation. They didn’t understand that outside investors are
coming in, and that Tyson is one of the largest meat producers in the world. They are now
putting in more and more of these industrial facilities and they’ve got way more manure
now than you’ve got land to spread it on. So it just runs off everywhere, and the ammonia is
just too much for us to bear.”

27
Down the road from her house, she climbed atop a sandy hill overlooking what used to be a
wind-swept field surrounded by pine forests. She recalled riding on her horse through the
field on a beautiful day, a few years ago.

Then she lifted her hand to cover her mouth. A wave of nauseating gas floated up the hill
from the 24 windowless buildings with exhaust fans.

“This used to be the most beautiful place on Earth to live,” she said. “I mean, the Eastern
Shore out here is one of the few places left that isn’t developed. And to sacrifice all this
beauty for this type of industry – it’s like a rape of this beautiful land.”

Conclusion
The poultry industry in the Chesapeake Bay watershed is growing – especially in the
hotspots of south central Pennsylania, the Shenandoah Valley, and parts of the Eastern
Shore – and the poultry waste problem is expanding even faster. Because meat companies
are engineering birds to become ever heavier, broilers in this region produced 16 percent
more manure in 2017 than in 2007. This means more ammonia and more runoff. In total,
5.7 billion pounds of poultry waste is spread on farm fields every year contributing to runoff
pollution and low-oxygen “dead zones” in the nation’s largest estuary.

The Bay region states are only just beginning to get a handle on the problem of the over-
application of manure to soil that is already saturated with nutrients. It’s an issue that
sparked heated debate in the spring of 2020 over Maryland legislation, for example, that
would have temporarily banned permits for any new large poultry houses.

But beyond this, EPA and the Bay states continue to struggle with even accurately
quantifying the ammonia air emissions problem. Federal and state regulators remain far
from implementing a strategy for controlling and reducing this source of pollution. The
Environmental Integrity Project’s analysis of the most recent science suggests that EPA has
been underestimating the amount of nitrogen entering the Bay from broiler air pollution by
at least a million pounds annually. Overall, the runoff and ammonia pollution from poultry
operations are sending about 24 million pounds of nitrogen into the Chesapeake Bay each
year. To put that number into context, 24 million pounds of nitrogen is more than the
pollution from all the urban stormwater runoff in Maryland and Virginia combined (which
was 20 million pounds in 2018).68 Or to put it another way, the 24 million pounds is twice as
much nitrogen as is released every year from all the sewage and wastewater plants in
Maryland.
This report recommends the following policy steps to address the problem:
1) EPA should update the ammonia emission estimates it uses to simulate nitrogen
loads to the Bay to reflect the most recent available science.

28
 2) All large new animal feeding operations should be required to install air pollution
monitors and report their emissions on an annual basis to state environmental
agencies and the EPA.
3) EPA should establish safety thresholds for ammonia that apply to the fenceline areas
between poultry operations and neighboring residents, to help protect local
communities from excessive levels of ammonia.
4) States and the EPA should require poultry houses to install effective air pollution
control systems, including filters to capture particulate matter being blown by poultry
house exhaust fans out into the community.
5) Poultry companies should pay for the planting of more trees and forested areas
around chicken houses, to protect neighbors and to help catch and reduce ammonia
emissions.
6) Because the Chesapeake Bay region states are already struggling with the
overproduction of manure, lawmakers should impose limits on the approval of new
permits for large animal feeding operations, especially in areas that produce more
manure than crops can use.

Although strategies for reducing pollution from the poultry industry have been hotly
debated in the Chesapeake region for years, an increased sense of urgency is needed with a
major Chesapeake Bay cleanup deadline approaching in 2025. The time for action is now:
First, through more monitoring and better estimates of pollution; and then, through tighter
controls, enforceable limits, and pragmatic steps toward healthier communities and a
restored Bay.

29
Appendix A: Methodology
1. County-level nitrogen load estimates
Our primary focus was on pollution loads in 2018, the most recent year for which complete
modeling results could be obtained. We evaluated data from four sources:

• The Chesapeake Bay Program’s Chesapeake Assessment Scenario Tool (CAST)69

provides detailed information for 2018 simulations, and simulations for earlier years,
using the Bay Program’s new “Phase 6” watershed model. This modeling tool
provides various inputs (e.g., land application of nitrogen and phosphorus in
manure, atmospheric deposition of nitrogen, point source wastewater pollution
loads, etc.) and outputs (e.g., pounds of nitrogen delivered to the Chesapeake Bay).
The CAST website appears limited to pollution coming from land and non-tidal
waterways, and does not provide estimates of nitrogen deposition directly to the
surface of tidal waters in the Bay watershed.
• The Bay Program’s Chesapeake Progress website70 provides separate estimates of
total nitrogen (and phosphorus and sediment loads). This website does include
estimates of nitrogen deposition to tidal waters.
• The Bay Program’s modeling makes use of ammonia emissions estimates from the
EPA National Emissions Inventory (NEI), so we also use these estimates to
characterize the extent to which ammonia emissions come from various forms of
livestock at the county level. For example, the 2011 NEI assumes that 41 percent of
the ammonia emissions in Lancaster County, PA came from poultry in 2011. We
therefore assumed that 41 percent of ammonia deposition in Lancaster County could
be attributed to poultry. We have been critical of the NEI in the past, and remain
critical – the NEI is often unreliable, omitting large sources of emissions71 and using
emissions factors that conflict with the best available science.72 Nevertheless, the NEI
estimates are baked into the Bay Program modeling, so we turned to these estimates
where necessary to interpret and analyze Bay Program modeling results. However,
we also adjusted our results at the state level to account for improvements in
ammonia emissions estimates since 2011. Our adjusted results are presented in Table
1 of this report, and our methods for making the adjustments are explained in section
2 below.
• Finally, we found that we needed expert assistance in extracting, interpreting and
analyzing data from the Bay program’s CAST website, so we commissioned a report
and database from KCI Technologies, Inc. (Attachment A).

To estimate how much ammonia air pollution from the broiler industry is entering the
Chesapeake Bay, KCI and EIP looked at “delivered load” to the Bay (meaning the amount
of pollution actually entering the estuary), described in the Bay Program model as the “edge
of tide” load (meaning the amount entering the Bay’s tidal waters.) The delivered load is
less than the amount of nitrogen deposited on land, and it accounts for things like nutrient
uptake by crops and other plants and nutrient dynamics in streams and rivers.

30
In order to calculate the delivered load associated with poultry, we started with the
delivered load for each county. KCI Technologies helped us extract, for each county, the
following components of delivered load:

• Direct load for pullets, turkeys, broilers, and layers. These are mostly made up of the
land application of poultry manure (70 percent of total), but also include loads from
pasture (12 percent of total) and from feeding spaces (18 percent of total).73
• Atmospheric deposition. This component of load is largely invisible in most
summaries of Chesapeake Bay nitrogen loads, because the nitrogen load is assigned
to the land use in place where the ammonia deposits. Ammonia depositing on
forested land, for example, is typically reported as “natural” or forest load.

In order to estimate how much of the atmospheric deposition came from poultry-related
ammonia, we had to make four simplifying assumptions.

• First, we assume that ammonia’s contribution to delivered nitrogen load is

proportional to its share of deposition. For example, the Bay Program estimates that
59 percent of the atmospheric nitrogen deposition in Sussex County is in the form of
ammonia. We made the assumption that 59 percent of the delivered nitrogen load
that the Bay Program assigns to atmospheric deposition originated as ammonia
deposition.
• Second, we assume that all of the ammonia depositing in a county was emitted in
that county for purposes of attributing ammonia deposition to various sources of
emissions. This is a simplifying assumption, but it is not unreasonable for two
reasons. First, most emitted ammonia deposits close to the source. For example, a
recent North Carolina State University study of Maryland’s Eastern Shore estimated
that 40 percent of ammonia emissions deposit within 2.5 km of the source.74 Second,
counties tend to be similar to neighboring counties. For example, poultry is the
source of 84 percent of the ammonia emissions in Sussex County, Delaware, and 92
percent of the ammonia emissions in neighboring Wicomico County, Maryland.
Assuming that 84 percent of the ammonia depositing in Sussex County comes from
poultry makes sense, even if some of the ammonia originated in neighboring
counties, because the poultry contribution to ammonia emissions in those counties is
similar.
• Third, we assume that poultry’s contribution to deposition in a given county is
proportional to its contribution to ammonia emissions from that county in the 2011
NEI:

𝐸𝑂𝑇 𝑝𝑜𝑢𝑙𝑡𝑟𝑦 𝑎𝑚𝑚𝑜𝑛𝑖𝑎 𝑙𝑜𝑎𝑑 =

𝐴𝑚𝑚𝑜𝑛𝑖𝑎 𝐷𝑒𝑝𝑜𝑠𝑖𝑡𝑖𝑜𝑛 𝑃𝑜𝑢𝑙𝑡𝑟𝑦 𝐴𝑚𝑚𝑜𝑛𝑖𝑎 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠

𝐸𝑂𝑇 𝐴𝑡𝑚𝐷𝑒𝑝𝑁 ∗ ∗
𝑇𝑜𝑡𝑎𝑙 𝐷𝑒𝑝𝑜𝑠𝑖𝑡𝑖𝑜𝑛 𝑇𝑜𝑡𝑎𝑙 𝐴𝑚𝑚𝑜𝑛𝑖𝑎 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠

Where “EOT AtmDepN” is the delivered nitrogen load attributable to atmospheric

deposition.

31
 For example, consider Somerset County, Maryland. The 2018 delivered nitrogen
load from atmospheric deposition in Somerset County was 353,015 pounds.
According to CAST, 55 percent of nitrogen deposition in Somerset County is in the
form of ammonia. According to the 2011 NEI, 96 percent of Somerset County
ammonia emissions come from poultry. We therefore assume that delivered nitrogen
load coming from poultry-related ammonia emissions amount to [353,015 pounds *
0.55 * 0.96], or 187,562 pounds.

Finally, in order to account for ammonia that deposits outside of county boundaries
(i.e., directly onto tidal water), we assumed that the fraction of atmospheric nitrogen
deposition to tidal water coming from poultry was equal to the share of atmospheric
nitrogen deposition to land and non-tidal water coming from poultry.75

Poultry numbers were taken from the 2007, 2012, and 2017 USDA census, where number
of broilers produced were specified for each state and county. USDA census data can be
found at online at this address. The Census of Agriculture is taken only once every five
years.

2. State-level adjustments

For 2018 model runs, the dry deposition of ammonia was simulated using 2011 National
Emissions Inventory estimates of ammonia emissions.76 Recognizing that these emissions
estimates are outdated, we attempted to adjust our estimates of delivered nitrogen load to
account for changes in the industry and in emissions factors since the 2011 NEI.
We began by reviewing the draft 2017 NEI to see whether we could calculate simple ratios
of emissions in 2017 to emissions in 2011. However, there are a number of problems with
the 2017 NEI. First, the only three poultry categories in the livestock data file are broiler
confinements, turkey confinements, and layer confinements with dry manure management
systems. There are no ammonia emissions estimates for manure storage or land application
for any poultry category, and no estimates for layer confinements with wet manure
management. These gaps make it impossible to construct an “apples to apples” comparison
of ammonia emissions from poultry for the two years. Second, there are some estimates in
the 2017 NEI that seem highly unlikely. For example, ammonia emissions from layer
confinements with dry manure systems in Pennsylvania declined by 50 percent between the
2011 and 2017 NEIs. Yet according to the USDA census of agriculture, the layer population
in Pennsylvania increased by 46 percent between 2007 and 2017. It seems virtually
impossible that ammonia emissions from layer confinements actually declined by 50
percent. Given the data gaps and likely errors in the 2017 NEI, we chose to ignore it.
Instead, we made state-level adjustments for three factors that have changed since 2011 –
industry growth, new science on ammonia emissions factors for layers and turkeys, and the
effect of increasing broiler weight on ammonia emissions from broilers.

a. Industry growth

32
First, we attempted to account for the fact that some parts of the industry in some states
have grown substantially. For example, between 2007 and 2017, the number of layers in
Pennsylvania increased by 46 percent.

b. Emissions factors for layers and turkeys

Second, we attempted to account for the fact that the emissions factors for layer and turkey
confinements may also be outdated and incorrect.
For layer confinements, the 2011 NEI used two different emissions factors, one for “dry
manure operations,” and one for “wet manure operations.” These equate to 1.1 and 0.3
grams of ammonia per bird, per day, respectively.77 More recently, a 2015 paper assembled
nine studies of layer emissions.78 These studies show a distinct difference between the
emissions rates from two types of layer operations – “high-rise/deep pit” facilities and
manure belt facilities. The deep pit facilities, where manure is only cleaned out once or
twice each year, have ammonia emissions on the order of 200 to 300 grams of ammonia per
animal unit (500 kg of weight) per day. Manure belt systems, on the other hand, have much
more regular manure removal, and therefore much lower ammonia emissions, on the order
of 15 to 30 grams per animal unit per day.
Since farm census data only report layers, without reference to manure management type,
we had to derive a single composite emissions factor. We began by converting the above-
cited estimates to units of grams per bird per day by assuming an average layer weight of
1.55 kg, and then averaging the emissions factors for each manure management type. We
then used a 2016 Chesapeake Bay Program inventory to sort the layer industry into different
manure management types. Specifically, we assumed that 61 percent of layer operations in
the Bay watershed use deep pit systems, and 5 percent use manure belt systems.79 For the
remaining 34 percent (which use other types of manure management), we assumed, in the
absence of better information, an average of the emissions rates for the first two categories.
Our composite ammonia emissions factor for Chesapeake Bay watershed layer
confinements is 0.75 grams of ammonia per bird per day.
For turkeys, The 2011 NEI used emission factor of 1.24 grams of ammonia per bird per
day.80 We reviewed two studies of ammonia emissions from turkey confinements in
Minnesota and Iowa published in 2008 and 2011,81 and derived a composite emissions
factor from these studies which ended up being very close to, but slightly higher than, the
NEI estimate: 1.31 grams per bird per day.
Folding these first two adjustments together, we calculated the emissions of ammonia from
layer and turkey confinements using inventory statistics from the USDA census of
agriculture for 2017 and our literature-based emissions factors.

c. Broiler weight and ammonia emissions

Third, we attempted to account for the fact that the broiler industry is growing bigger birds.
Between 2007 and 2017, the number of broilers in the Chesapeake Bay states’ inventory has
only grown by 2 percent. However, the production of broilers – in terms of the total weight of
broiler meat producted – has increased much more, because the average bird weight

33
continues to increase. Between 2007 and 2017, the total pounds of broilers produced and
sold has increased by 18 percent. Larger birds generate more manure, litter, and ammonia.
The only way to account for the growth in the industry when estimating ammonia
emissions is to use an emissions factor based on pounds produced, rather than inventory.
For each state, we calculated ammonia emissions by multiplying the broiler production in
2017 (in pounds of broilers produced) by an emissions factor that we derived in 2018: 14.2
grams of ammonia per kilogram of broiler (market weight).82 We then calculated the ratio of
ammonia emissions in 2017 (based on production) to ammonia emissions in the 2011 NEI.
The following table provides the state-level results.
Adjusted Estimates of Ammonia Emissions from Broiler Confinements (kg)

2011 NEI 2017 production- Ratio of 2017

based estimate estimate to 2011
NEI
DE 5,102,400 12,048,571 2.36
MD 6,509,282 11,852,764 1.82
NY 46,774 n.a.83 1.0184
PA 2,739,180 6,679,981 2.44
VA 4,352,475 10,362,956 2.38
WV 1,278,301 2,162,894 1.69

In order to estimate changes in the emissions of ammonia from broiler litter in storage or on
crop fields, we calculated the ratio of 2017 broiler production (in pounds) to 2007 broiler
production.
Given the small populations and numerous gaps in the farm census for other forms of
poultry such as ducks and geese, we chose not to adjust the NEI emissions estimates for
these birds. For all other sources of ammonia, including layer and turkey litter in storage or
land-applied, we calculated the ratio of the 2017 inventory to the 2007 inventory. The
following table summarizes the adjustments we made to each poultry source category.

Poultry ammonia emission source Adjustment

Broiler confinements (excluding New York) Ratio of 2017 production-based emissions

estimate to 2011 NEI estimate
Broiler ammonia from storage and land Ratio of 2017 production (pounds) to 2007
application (excluding New York) production (pounds)
Turkey and layer confinements Ratio of 2017 inventory-based emissions estimate
to 2011 NEI estimate
All other categories, including New York broiler Ratio of 2017 census inventory to 2011 census
ammonia inventory

In each case, we used the final adjustment ratio to adjust the portion of delivered nitrogen
load attributable to dry deposition of ammonia from each type of poultry in each state. For
example, the total delivered nitrogen load from Maryland in 2018 was 52.8 million pounds.
Of that total, 5.3 million pounds came from the atmospheric deposition of ammonia, and
2.8 million pounds came specifically from dry deposition of ammonia. Since 34 percent of

34
the ammonia emissions in Maryland come from poultry, we assumed that 34 percent of the
nitrogen load attributed to dry ammonia deposition – 937,000 pounds – came from poultry
operations. This 937,000 pound total is the value that we adjusted. In order to calculate an
overall adjustment ratio, we adjusted each poultry category as follows:

Adjusting Nitrogen Load from Dry Ammonia Deposition, Maryland Example

2011 NEI
2017 estimate
Category (ammonia 2017 estimate method Ratio
(ammonia kg)
kg)
2017 production (kg) * 14.2
Broiler confinements 6,509,282 grams of ammonia per kg of 11,852,764 1.82
broiler weight
Broiler litter storage 2011 estimate * (2017
6,502,773 7,517,057 1.16
and land application production/ 2007 production)
2017 inventory * 0.75 grams of
Layer confinements 1,033,622 817,196 0.79
ammonia/bird-d
Layer manure storage 2011 estimate * (2017
77,436 86,428 1.12
and land application inventory/ 2007 inventory)
2017 inventory * 1.31 grams of
Turkey confinements 101,005 26,238 0.26
ammonia/bird-d
Turkey manure
2011 estimate * (2017
storage and land 109,033 26,803 0.25
inventory/ 2007 inventory)
application
Other poultry 89,861 No change 89,861 1.00

Total 14,423,012 20,416,347 1.42

The overall ratio of 2017 ammonia emissions to 2011 ammonia emissions is 1.42, so we
multiplied the 937,000 pounds of delivered nitrogen attributable to dry deposition of poultry
ammonia by 1.42, yielding a new total of roughly 1.3 million pounds.

There are at least two critical areas of uncertainty associated with our adjustments that cut
in opposite directions. On one hand, we may be underestimating 2017 ammonia emissions
by relying on the 2017 farm census. Many counties do not report inventory data to protect
confidential information, so the census totals are often incomplete. We followed the 2011
NEI approach and tried to rely on state-level census data where possible, but this only
partially fills the gaps. Delaware, for example, only reports county-level data, and not for all
counties.

On the other hand, where we assume greater ammonia emissions from confinement barns,
one could argue that ‘downstream’ emissions from storage and land application should be
lower, because more of the nitrogen in the litter has volatilized in the barns. We were not
able to account for this possibility with the information at our disposal, and as a result we
may have overestimated total ammonia emissions to a certain degree.

3. Poultry statistics and manure production estimates

35
Broiler chicken production data for 2008-2018, measured by head and pounds, were taken
from USDA survey datasets, which are conducted annually.85 No survey data were
available for New York; for manure production purposes, we assumed that New York
broilers weighed the same as the average broiler from the other five states. For purposes of
adjusting delivered nitrogen load from New York, we used broiler inventory data in place of
broiler production data.

Manure generation was estimated using manure production factors from the Chesapeake
Bay Program’s Agriculture Workgroup.86 The following table outlines the factors and
formulas used:

Bird Type Manure Production Measurement Unit

Factor/Formula
Broiler 0.312971 X (Average Bird Lbs of Litter per Bird Produced
Chicken Market Weight) + 0.732730
Layer Chicken 69.35 Lbs of Manure per Bird in Inventory
Pullet Chicken 49.91 Lbs of Manure per Bird Produced
Turkey 58 Lbs of Manure per Bird Produced

36
Appendix B:

Discussion of Recent North Carolina State University Research on

Ammonia Emissions on Maryland’s Eastern Shore
A recent study from North Carolina State University estimated ammonia emissions from
poultry on Maryland’s Eastern Shore and subsequent ammonia deposition.87 The study
differed from Chesapeake Bay Program modeling and from our analysis in several ways.
First, as already noted, the study was limited in its geographic scope to poultry operations
on Maryland’s Eastern Shore. Second, the study included both broiler and layer operations,
while our analyses focused on either all poultry or just broilers.

The study’s assumptions about ammonia emissions were in line with EPA assumptions, but
both the authors of the study and EPA are likely underestimating emissions from broiler
confinement barns. This requires some explanation: Baker et al. estimate ammonia
emissions from confinements, storage, and the land application of poultry litter using an
emissions factor of 0.55 g NH3 per bird per day. This is for both broilers and layers, though
the authors note that 90 percent of the emissions from poultry in the region come from
broilers. The emissions factor used by Baker at al. is very close to the emissions factors used
by EPA’s National Emissions Inventory (NEI). For example, the 2011 NEI assumed that
ammonia emissions from broilers – including emissions from confinements, storage, and
land application – were 0.55 g NH3 per bird per day, the same as Baker et al.88 The NEI
(and, implicitly, Baker et al.) assume that half of this total – 0.27 g NH3 per bird per day –
comes from broiler confinements. Our recent literature review found that a more reasonable
emissions factor for broiler confinements would be roughly twice that – 0.54 g NH3 per bird
per day. In short, Baker et al. and the NEI appear to be undercounting ammonia emissions
from broiler barns by roughly half. The analysis presented in this report corrects for that
error.

Baker et al. used a different atmospheric fate and transport models than the Chesapeake Bay
Program. Specifically, Baker et al. simulate atmospheric fate and transport using a model
known as “AERMOD,” while EPA uses a combination of regression modeling (for wet
deposition) and a model known as “CMAQ” (for dry deposition).

More broadly, our analysis and the Baker study approach the issue from opposite directions.
We start with the Chesapeake Bay Program’s estimates of delivered nitrogen load,
specifically the delivered nitrogen load that can be attributed to the atmospheric deposition
of ammonia. We then allocate that load to various sources in the watershed, including
broiler chickens and other poultry. Baker et al., on the other hand, start by estimated how
much ammonia is being emitted by poultry litter, and then estimating where the emitted
ammonia might be landing. With respect to a specific location such as Maryland’s Eastern
Shore, our analysis asks “how much of the nitrogen coming from that area can be attributed
to poultry ammonia emissions?” Baker et al., on the other hand, ask “how much ammonia

37
is being emitted by poultry litter in that area, and how much lands in the modeling domain
(including areas outside of Maryland’s Eastern Shore)?”

Finally, Baker et al. did not estimate the delivered load of ammonia, or the amount of
nitrogen reaching the Chesapeake Bay.

The study had one critically important conclusion (among other important results). Baker et
al. estimate that that poultry production on Maryland’s eastern shore results in the annual
deposition of 11,684 tons of ammonia on land, almost exclusively on the eastern shore.89
The Bay Program, by contrast, estimates that only 4,466 tons of ammonia deposited on
Maryland’s eastern shore counties in 2018.90 If true, these results suggest that the nitrogen
load from ammonia might be much higher than the Bay Program assumes, particularly in
ammonia hotspots, but potentially overall as well. This applies not just to ammonia from
poultry, but also ammonia from dairy and swine operations.

38
Appendix C: Additional Maps

Map of Nitrogen Pollution Entering Bay from Poultry Ammonia

39
Map of Poultry Nitrogen Entering Bay as a Fraction of Total
Nitrogen from Each County

40
END NOTES
1
USDA Agricultural Census numbers for 2017, available at:
https://www.nass.usda.gov/Publications/AgCensus/2017/
2
Figures from 2017 Census of Agriculture, and only include counties within the Chesapeake Bay watershed.
Turkey figures are annual sales for slaughter. Laying chicken number is inventory (a one time figure) captured
by the 2017 Census of Agriculture.
3
Manure figure calculated by using USDA Agricultural Census data for 2017, and multiplying it by an
estimate of manure-per-pound of bird (for layers) and manure-per-pound-produced (for broilers, turkeys, and
pullets) used by the EPA Chesapeake Bay Program.
4
Ammonia is a chemical that is made up of nitrogen and hydrogen. In the environment, it breaks down into
its component parts, liberating the nitrogen.
5
U.S. Agency for Toxic Substances and Disease Registry, “Public Health Statement for Ammonia,” accessed
March 16. 2020. Link: https://www.atsdr.cdc.gov/phs/phs.asp?id=9&tid=2
6
Poulsen, Melissa; Pollak, Jonathana; Sills, Deborah; Casey, Joan; Nachman, Keeve; Cosgrove, Sara;
Stewart, Daltonc; Schwartz, Brian, “High-density poultry operations and community-acquired pneumonia in
Pennsylvania,” Environmental Epidemeology, June 2018. Link:
https://journals.lww.com/environepidem/FullText/2018/06000/High_density_poultry_operations_and.5.as
px
7
The Chesapeake Bay Program is a partnership, founded in 1983, that is led by the U.S. Environmental
Protection Agency, but also includes the national Oceanic and Atmospheric Administration, U.S. Geological
Survey, University of Maryland Center for Environmental Science and several other federal, state and
university partners.
8
Ammonia is a chemical that is made up of nitrogen and hydrogen. In the environment, it breaks down into its
component parts, liberating the nitrogen.
9
Chesapeake Bay Program, Chesapeake Assessment Scenario Tool (CAST) https://cast.chesapeakebay.net/,
(2018 edge of tide (EOT) nitrogen load for wastewater).
10
Ibid. The Chesapeake Bay tidal (“edge of tide”) load of nitrogen from combined sewage overflows totaled
1.4 million pounds in 2018.
11
Nitrogen entering the Chesapeake Bay from ammonia emissions is also known as the nitrogen “deposition,”
or the nitrogen that is deposited into the Bay watershed after falling from the atmosphere or being carried by
rain.
12
About 52 percent of the surface area of the Chesapeake Bay is in Maryland, and 48 percent is in Virginia.
Calculation of square miles of water in each state from 2012 U.S. Census Statistical Abstract of the United
States, page 223, Table 358. “Land and Water Area of States and Other Entities.” Link:
https://www.census.gov/prod/2011pubs/12statab/geo.pdf
13
EIP, Ammonia Emissions from Broiler Operations Higher than Previously Thought (Jan. 2018),
https://environmentalintegrity.org/reports/ammonia-emissions/ (hereinafter “EIP 2018”).
14
Chesapeake Bay Pogram, Chesapeake Progress, Modeled Nitrogen Loads to the Chesapeake Bay (1985-
2025), https://www.chesapeakeprogress.com/clean-water/watershed-implementation-plans

41
15
Ibid.
16
Ibid

We calculated and apportioned the atmospheric deposition of ammonia among various sources of ammonia
17

emissions, including poultry confinement barns, manure storage areas, and land application.

Ellen K. Silbergeld, Chickenizing Farms and Food: How Industrial Meat Production Endangers Workers,
18

Animals, and Consumers, Johns Hopkins University Press, 2016.

19
Ibid.
20
National Chicken Council, “Broiler Chicken Industry Key Facts 2019,” web page, accessed 2/17/2020.
Link: https://www.nationalchickencouncil.org/about-the-industry/statistics/broiler-chicken-industry-key-
facts/
21
U.S. Department of Agriculture farm census data from 2007 and 2017. Note: These numbers include
broilers raised in counties that are in all or part in the Chesapeake Bay watershed, including Sussex County,
Delaware, the eastern portion of which drains into the Atlantic Ocean.
22
Wei Zhai, Assistant Professor at Mississippi State University Extension Service, “Why the Rapid Growth
Rate in Today’s Chickens?” 2018. Link:
http://extension.msstate.edu/sites/default/files/publications/is1950.pdf
23
National Chicken Council web page, “About the Industry,” March 22, 2019. Link:
https://www.nationalchickencouncil.org/about-the-industry/statistics/u-s-broiler-performance/%20

United States Department of Agriculture National Agricultural Statistics Service, “Quick Stats,”accessed
24

April 10, 2020. Link: https://quickstats.nass.usda.gov/?source_desc=CENSUS

25
EIP used the weight-based manure production estimate described in the Chesapeake Bay Program’s
Recommendations to Estimate Poultry Nutrients for the Phase 6 Model. The equation is as follows:
Lbs of litter = 0.312971 X (broiler pounds) + 0.732730
The broiler pounds produced in a given state and year was derived from the USDA Survey. Chesapeake Bay
Program Agriculture Workgroup, Agricultural Modeling Subcommittee, Poultry Litter Subcommittee,
Recommendations to Estimate Poultry Nutrient Production in the Phase 6 Watershed Model (Mar. 2015)
26
EIP, Ammonia Emissions from Broiler Operations Higher than Previously Thought (Jan. 22, 2018),
https://environmentalintegrity.org/reports/ammonia-emissions/.
27
According to EPA staff, the 2018 watershed model runs used ammonia emissions estimates from the 2011
National Emissions Inventory (NEI). Future runs will start to incorporate more recent emissions estimates
from the 2017 NEI. Personal communication with Jesse Bash, staff scientist with EPA’s National Exposure
Research Laboratory (Oct. 24, 2019).
28
U.S. EPA, “National Emission Inventory, Ammonia Emissions from Animal Agricultural Operations
(revised draft report)” at 3-15, Table 3-8 (2004). Link:
https://www3.epa.gov/ttnchie1/ap42/ch09/related/nh3inventorydraft_jan2004.pdf
29
Ibid.

42
30
U.S. EPA, “National Emission Inventory, Ammonia Emissions from Animal Agricultural Operations”
(revised draft report), at 3-15, Table 3-8 (2004). Link:
https://www3.epa.gov/ttnchie1/ap42/ch09/related/nh3inventorydraft_jan2004.pdf
31
EIP, Ammonia Emissions from Broiler Operations Higher than Previously Thought (Jan. 22, 2018),
https://environmentalintegrity.org/reports/ammonia-emissions/.
32
U.S. EPA, “Development of Emissions Estimating Methodologies for Broiler Operations” (Draft), Feb.
2012. Link: https://www.epa.gov/afos-air/development-emissions-estimating-methodologies-broiler-
operations-draft-february-2012
33
P. Moore et al., “Ammonia Emissions Factors from Broiler Litter in Barns, in Storage, and after Land
Application,” Journal of Environmental Quality 1395 (2011). Link:
https://www.ncbi.nlm.nih.gov/pubmed/21869501
34
R.E. Lacey et al., “Particulate Matter and Ammonia Emission Factors for Tunnel-Ventilated Broiler
Production Houses in the Southern U.S.,” Transactions of the ASAE 1203 (2003).

R.L. Siefert et al., Characterization of Atmospheric Ammonia Emissions from a Commercial Chicken
35

House on the Delmarva Peninsula, 38 Environ. Sci. Technol. 2769 (2004).

E.F. Wheeler et al., Ammonia Emissions from Twelve U.S. Broiler Chicken Houses, 49 Transactions of the
36

ASABE 1495 (2006).

D.M. Miles et al., Ammonia and Nitrous Oxide Emissions from a Commercial Broiler House, 43 J Environ.
37

Quality 1119, 1123 (2014).

38
We derived adjusted load estimates at the state level, and not at the county level, because county-level data
are not consistently available in USDA resources.
39
“Atmospheric Deposition to Tidal Water (to be reduced to 15.2 million lbs/yr under Clean Air Act).”
Chesapeake Bay Program, Chesapeake Progress – 2018 Progress data,
https://www.chesapeakeprogress.com/files/Data_2018_Reducing_Pollution_040519_FINAL_%281%29.xlsx
40
J. Baker et al., Modeling and Measurements of ammonia from Poultry Operations: Their Emissions,
Transport, and Deposition in the Chesapeake Bay, 706 Sci. Total Environ. Article 135290 (March 2020,
available online Nov. 24, 2019), https://www.sciencedirect.com/science/article/pii/S0048969719352829
41
Chesapeake Bay Foundation press release, “New Study Estimates Ammonia Emissions from Poultry Farms
on Maryland’s Eastern Shore,” Dec. 5, 2019. Link: https://www.cbf.org/news-
media/newsroom/2019/maryland/new-study-estimates-ammonia-emissions-from-poultry-farms-on-
marylands-eastern-shore.html
42
See Appendix A and Attachment A for methods relating to ammonia deposition expressed as delivered
nitrogen load.

U.S. EPA, CERCLA and EPCRA Reporting Requirements for Air Releases of Hazardous Substances from
43

Animal Waste at Farms (Nov. 2017); U.S. EPA, Ammonia and Hydrogen Sulfide Emission Rates for Poultry
Operations (Nov. 2017).
44
Food and Environment Reporting Network, A breathtaking lack of oversight for air emissions from animal
farms, (Dec. 2019), https://thefern.org/2019/12/a-breathtaking-lack-of-oversight-for-air-emissions-from-
animal-farms/

43
45
EPA, Animal Feeding Operations Consent Agreement and Final Order (2005),
https://www.epa.gov/sites/production/files/2016-06/documents/afolagooneemreport2012draftappe.pdf
46
EPA web page, “National Air Emissions Monitoring Study,” reviewed in March, 2020. Link:
https://www.epa.gov/afos-air/national-air-emissions-monitoring-study

Amanda Peterka, “EPA study of CAFO emissions grinds on with no end in sight
47

Amanda Peterka, E&E reporter,” Greenwire, June, 2014. Link: https://www.eenews.net/stories/1060001938

48
EPA web page, “National Air Emissions Monitoring Study,” reviewed on February 12, 2020. Link:
https://www.epa.gov/afos-air/national-air-emissions-monitoring-study
49
Ibid.
50
The Evening Sun (Hanover, Pa.), “Codorus Township Denies Hillandale Farm Plans,” August 6, 2015.
Link: https://www.eveningsun.com/story/money/2015/08/06/codorus-township-denies-hillandale-farm-
plans/32359713/
51
Maryland Senate Bill 542 of 2019, fiscal and policy note, available at:
http://mgaleg.maryland.gov/2019RS/fnotes/bil_0002/sb0542.pdf

Carolyn Hricko, Keeve Nachman, et al. “Health Community Letter in Support of the Community Healthy
52

Air Act,” February, 2019. Available in the files of the Maryland General Assembly library.

Written testimony of Stephan Lavitsky, Vice President of Sustainability at Perdue Farms, against the
53

Community Healthy Air Act, February 2019. Available in the files of the Maryland General Assembly library.
54
Maryland Department of the Environment, Lower Eastern Shore Ambient Air Quality Monitoring Project,
https://mde.maryland.gov/programs/Air/AirQualityMonitoring/Pages/Lower-Eastern-Shore-Monitoring-
Project.aspx
55
Maryland House Bill 1312, sponsored by state Del. Vaughn Stewart of Montgomery County and colleagues;
and Senate Bill 0841, sponsored by state Sen. Clarence Lam of Howard and Baltimore Counties and
colleagues.
56
Public testimony of State Del. Vaughn Stewart, D-Montgomery County, on House Bill 1312, during
committee hearing on March 4, 2020.
57
Salisbury University Business, Economic and Community Outreach Network report for the Maryland
Department of Agriculture, “A Scenario Analysis of the Potential Costs of Implementing the Phosphorus
Management Tool on the Eastern Shore of Maryland,” 2014. https://mda.maryland.gov/Documents/pmt-
analysis.pdf
58
Public testimony of Holly Porter, Executive Director of Delmarva Poultry Institute, on during committee
hearing on March 4, 2020.
59
Spencer JL, Guan J. “Public Health Implications Related to Spread of Pathogens in Manure from Livestock
and Poultry Operations,” Public Health Microbiology. Vol. 268. Springer, 2004. Pages 505-515.
Graham, JP and colleagues, “The animal-human interface and infectious disease in industrial food animal
production,” Public Health Rep. 208. 282-299.
Graham, JP and colleagues, “Antibiotic resistant enterococci and staphylococci isolated from flies collected
near confined poultry feeding operations.” Science of the Total Environment. 2009. 407-8. 2701-2710.

44
Donham KJ and colleagues, “Community Health and Socioeconomic Issues Surrounding Concentrated
Animal Feeding Operations,” Environmental Health Perspectives, 2007, 317-320.
Kirychuck, SP and colleagues, “Total Dust and Endotoxin in Poultry Operations: Comparison Between Cage
and Floor Housing and Respiratory Effects in Workers,” Journal of Occupational Environmental Medicine,
2006. 47-48. 741-748.
60
Graham, JP, et al. “The Animal Human Interface and Infectious Disease in Industrial Food Animal
Production: Rethinking Biosecurity and Biocontainment,” Public Health Rep. 2008. 282-299.
Baykov B, Stoyanov M., “Microbial Air Pollution Caused by Intensive Broiler Chicken Breeding,” FEMS
Microbiology Ecology, 1999 29 (4). 389-392.

Donham, KJ and colleagues. “Community Health and Socioeconomic Issues Surrounding Concentrated
61

Animal Feeding Operations,” Environmental Health Perspectives, 2007, pages 317-320.

Wing, S, Wolf, S, “Intensive Livestock Operations, health, and Quality of Life among Eastern North Carolina
Residents,” Environmental Health Perspectives, 2000. 108 (3). 233-238.
62
See note 6.

Casey, J.A. and colleagues, “Industrial Food Animal Production and Community Health,” Current
63

Environmental Health Reports, 2015. https://www.ncbi.nlm.nih.gov/pubmed/26231503

64
Rasmussen S.G., Casey J.A., Bandeen-Roche K., Schwartz B.S., “Proximity to Industrial Food Animal
Production and Asthma Exacerbations in Pennsylvania, 2005-2012,” International Journal of Environ
Research and Public Health, March 31, 2017. Link: https://www.ncbi.nlm.nih.gov/pubmed/28362334
65
Poulsen M.N., Pollak J., Sills D.L., Casey J.A., Rasmussen S.G., Nachman K.E., Cosgrove S.E., Stewart
D., Schwartz B.S., “Residential proximity to high-density poultry operations associated with
campylobacteriosis and infectious diarrhea,” International Journal of Hygiene and Environmental Health,
March 2018. Link: https://www.ncbi.nlm.nih.gov/pubmed/29268955
66
Accomack County Planning Commission, “2020 Annual Poultry Report.”
67
Ibid. And County of Accomack Planning and Zoning Staff, “2019 Annual Poultry Report,” February 26,
2019. Link: https://www.co.accomack.va.us/home/showdocument?id=11067
68
CAST public reports, including both “regulated developed” and “non-regulated developed.”
69
https://cast.chesapeakebay.net/
70
https://www.chesapeakeprogress.com/clean-water/watershed-implementation-plans
71
For example, the ammonia emissions factors for broilers in the 2014 and draft 2017 NEIs only account for
emissions from broiler confinements, and not from manure storage or land application. In addition, the 2014
and 2017 NEIs appear to omit layers with wet manure management systems, and the 2014 NEI omitted
several other categories of livestock waste.
72
See, e.g., EIP 2018 at 6-7.
73
Based on data provided by KCI Technologies to EIP.
74
Jordan Baker et al., “Modeling and Measurements of ammonia from Poultry Operations: Their Emissions,
Transport, and Deposition in the Chesapeake Bay, 706 Sci. Total Environ. Article 135290 (March 2020,

45
available online Nov. 24, 2019).” Link:
https://www.sciencedirect.com/science/article/pii/S0048969719352829
75
This was calculated by dividing the delivered nitrogen load coming from the atmospheric deposition of
poultry ammonia emissions on land and non-tidal water (8.3 million pounds) by the delivered nitrogen load
coming from all atmospheric deposition on land and non-tidal water (71.5 million pounds).
76
According to EPA staff, the 2018 watershed model runs used ammonia emissions estimates from the 2011
National Emissions Inventory (NEI). Future runs will start to incorporate more recent emissions estimates
from the 2017 NEI. Personal communication with Jesse Bash, staff scientist with EPA’s National Exposure
Research Laboratory (Oct. 24, 2019).
77
U.S. EPA, 2011 National Emissions Inventory, version 2, Technical Support Document, Table 3-33 (Aug.
2015).
78
D. Wood et al., A summary of ammonia emission factors and quality criteria for commercial poultry
production in North America, 115 Atmospheric Environment 236 (Aug. 2015).
79
S. Hawkins et al., Animal Waste Management Systems, Recommendations from the BMP expert panel for
animal waste management systems in the phase 6 watershed model, CBP/TRS-315-16 (Dec. 2016).
80
U.S. EPA, 2011 National Emissions Inventory, version 2, Technical Support Document, Table 3-33 (Aug.
2015).
81
H. Li et al. Ammonia and PM Emissions from a Tom Turkey Barn in Iowa, American Society of
Agricultural and Biological Engineers Annual International Meeting 2008, ASABE 2008, 4724-4737 (2008); H.
Li et al. Air Emissions from Tom and Hen Turkey Houses in the U.S. Midwest, 54 Transactions of the ASABE
305-314 (2011).
82
EIP 2018, Table 7.
83
Production-based results for New York could not be calculated because New York broiler production
statistics are not available from the USDA.
84
For New York, we calculated the ratio of the state’s 2017 broiler inventory to its 2007 broiler inventory
85
U.S. Department of Agriculture, Quick Stats, https://quickstats.nass.usda.gov/. The Quick Stats website
provides access to both survey and census datasets.
86
Chesapeake Bay Program Agriculture Workgroup, Agricultural Modeling Subcommittee, Poultry Litter
Subcommittee, Recommendations to Estimate Poultry Nutrient Production in the Phase 6 Watershed Model
(Mar. 2015).
87
Jordan Baker et al., “Modeling and Measurements of ammonia from Poultry Operations: Their Emissions,
Transport, and Deposition in the Chesapeake Bay, 706 Sci. Total Environ. Article 135290 (March 2020,
available online Nov. 24, 2019).” Link:
https://www.sciencedirect.com/science/article/pii/S0048969719352829
88
Subsequent NEIs in 2014 and 2017 only estimated ammonia emissions from confinements, and not from
manure storage or land application. For broilers in Maryland, the 2017 confinement emissions factors is 0.26 g
NH3 per bird per day. This is almost identical to the emissions factor for confinements in the 2011 NEI (0.27
g/bird-d).

46
89
J. Baker et al., Modeling and Measurements of ammonia from Poultry Operations: Their Emissions,
Transport, and Deposition in the Chesapeake Bay, 706 Sci. Total Environ. Article 135290 (March 2020,
available online Nov. 24, 2019), https://www.sciencedirect.com/science/article/pii/S0048969719352829
90
Chesapeake Assessment Scenario Tool, Ammonia deposition report for 2018,
https://cast.chesapeakebay.net/.

47