With respect 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 must apply for a National Pollutant Discharge Elimination System permit. Further regulation concerned the submission of information by CAFOs, but the measures were not effective because the EPA indicated that it could obtain the necessary information from existing government agencies (CAFO regulations). Additional metrics were developed in relation to the Chesapeake Bay watershed. In 2009, President Obama called the bay a "national treasure" and thus launched efforts to increase cleanup measures and restore the watershed (Stubbs, 18). The EPA has recognized industrial agriculture as a major contributor to the bay's pollution, with agriculture covering approximately 25 percent of the bay's land area. the Bay watershed. Livestock waste and poorly managed administration of chemicals and nutrients are considered the main pollutants. In response to the polluted Chesapeake Bay watershed, the EPA established Total Maximum Daily Loads – TMDLs. Essentially, a TMDL is a pollution report that lists how much pollution a waterway can receive without violating standards. In addition, states are required