Related to water, large concentrated animal feeding operations – CAFOs – are defined as point sources of pollutants and therefore fall under federal regulation (Stubbs, 16). In 2011, the U.S. Court of Appeals upheld EPA regulations stating that CAFOs that discharge waste into waterways are required to apply for National Pollutant Discharge Elimination System permits. Additional regulations addressed the submission of information by CAFOs, but the action was insufficient as the EPA reported that it could obtain the necessary information from existing government agencies (CAFO regulations). Additional parameters were developed in relation to the Chesapeake Bay watershed. In 2009, President Obama labeled the Bay a “national treasure” and then led efforts to strengthen cleanup efforts and restore the watershed (Stubbs, 18). The EPA has recognized industrial agriculture as a major contributor to pollution of the Bay as agriculture covers approximately 25% of the land. watershed of the Bay. Livestock waste and mismanagement of chemicals and nutrients are considered major pollutants. In response to the polluted Chesapeake Bay watershed, the EPA established Total Maximum Daily Loads – TMDLs. Essentially, a TMDL is a pollution budget that lists the amount of pollution a waterway can receive without violating standards. Furthermore, states are needed