PORK INDUSTRY RESEARCH SERIES | RESEARCH BRIEF
What State Records Show About Hog-Farm Enforcement That EPA’s Database Doesn’t
EPA’s enforcement database lists 13 Iowa hog farms. Iowa’s own field-office records show 4,120 Iowa hog operations that have received at least one notice of violation or letter of non-compliance. This follow-up counts what six states’ enforcement records show, state by state.
Prepared for publication by Farm Animal Transparency | October 2026
| At a glance |
| The follow-up. Our October 8 brief, The Hog Farms EPA’s Database Doesn’t Show, counted hog operations. This one counts enforcement: how many operations on each state’s list have a state notice of violation (NOV) or similar action on record. |
| Six states. Iowa, North Carolina, Indiana, Missouri, Nebraska and Michigan. Across them, 4,989 hog operations have at least one state enforcement action on record. Minnesota is pending a records request. |
| The federal view. EPA’s Enforcement and Compliance History Online (ECHO) database lists 175 hog-farming facilities in total across the five of these states we searched. Outside Michigan, the operations with state enforcement on record outnumber ECHO’s entire hog-farm list in every state. |
| What it is not. A farm near a processing plant is not necessarily one of its suppliers. This context sits beside the FAT Score and never changes it. |
1. Why count enforcement
Our first brief showed that EPA’s ECHO database misses most hog farms. A large animal feeding operation needs a federal Clean Water Act discharge permit, called an NPDES permit (National Pollutant Discharge Elimination System), only if it discharges to surface water. Most hog farms are permitted under state no-discharge programs instead, and those permits generally do not appear in ECHO.
Enforcement follows the same pattern. When a state agency cites a hog farm under a state permit, the action goes into the state’s files, not EPA’s. So we went to each state’s own enforcement records, matched them to the state’s list of hog operations, and counted operations with at least one action on record. We count operations, not violations. One farm with ten notices counts once.
2. The count, state by state
“Last 5 years” means an action dated on or after the same date in 2021 as the day each state’s records were retrieved (October 24 to 26, 2026). The ECHO column repeats the counts from our October 8 brief: EPA’s facility search for the hog-farming industry code (NAICS 112210) across all EPA programs. It counts facilities EPA tracks, not enforcement, so it is a rough guide to how many hog farms ECHO could show enforcement for in each state.
| State | Hog operations on the state list | With at least one state enforcement action, ever | …in the last 5 years | Hog-farming facilities in EPA ECHO (Oct. 8, 2026) | Hold a federal NPDES permit (state data) |
|---|---|---|---|---|---|
| Iowa | 8,816 | 4,120 (46.7%) | 1,577 (17.9%) | 13 | 37 |
| North Carolina | 1,987 | 331 (16.7%) | 179 (9.0%) | 10 | 1 |
| Indiana | 1,274 | 105 (8.2%) | 6 (0.5%) | 1 | 400 |
| Missouri | 254 | at least 179 (70.5%) | at least 106 (41.7%) | 41 | 22 |
| Nebraska | 2,914 | at least 158 (5.4%) | at least 31 (1.1%) | Not searched in the October 8 brief | Unknown (no field in state data) |
| Michigan | 110 | 96 (87.3%) | 77 (70.0%) | 110 | 110 |
| Minnesota | 5,543 | Pending: Minnesota Pollution Control Agency records request filed October 24, 2026 | 0 | 605 | |
Do not rank states by these percentages. Each state lists different operations (Iowa lists facilities of 300 or more animal units; Missouri lists only its largest, federally defined CAFOs, or concentrated animal feeding operations), files different kinds of actions, and keeps records for different spans of years. A high share can mean closer oversight as easily as worse farms. The comparison that holds in every state is the one with ECHO.
3. What each state’s number means
Iowa
Source: Iowa Department of Natural Resources (DNR) Field Office Compliance database. Counted: notices of violation and letters of non-compliance under the animal feeding operation program or for a manure spill, since about 2009. 8,784 of the 8,816 operations matched a database record.
- Most notices are paperwork. In a 1,887-facility sample, 79% of these enforcement actions came from reviews of manure management plans or desk reviews, not from inspections. Statewide, 2,651 of the 4,120 operations had only paperwork-review notices.
- Field findings. 1,469 operations had at least one notice from an inspection, complaint, spill or other field action.
- Spills. 143 operations have a manure spill linked to them in DNR’s spill records.
- Not included. Enforcement handled by DNR’s central office is not in this database. The facility list itself was last updated April 5, 2024.
North Carolina
Source: documents filed by the NC Department of Environmental Quality (DEQ), Division of Water Resources, under each permit’s facility number. Counted: notices of violation (by document type or an NOV case number).
- Only since about 2018. Older files were scanned in bulk and are not itemized, so they cannot be counted. The “ever” column is really “since about 2018.”
- Penalties. 58 operations have a civil penalty assessment on file.
- Lesser notices. Another 577 operations have a notice of deficiency, a lower-level warning, but no notice of violation. They are not in the table count.
Indiana
Source: Indiana Department of Environmental Management (IDEM) Virtual File Cabinet, Confined Feeding program. Counted: formal enforcement documents (notices of violation, violation letters, proposed and final agreed orders, commissioner’s orders, enforcement referrals). Correspondence and close-out letters are not counted.
- Thin after 2021. Only 6 of the 105 operations have a formal action dated in the last five years. That may reflect fewer actions or a change in how IDEM files them; the records alone do not say which.
- Orders. 83 operations have an agreed order or commissioner’s order.
- Scanned records are sparse before 2009.
Missouri
Source: Missouri Department of Natural Resources (MoDNR) public search of letters of warning and notices of violation, records from 2009. Counted: letters of warning, notices of violation (including referrals) and enforcement action requests.
- “At least.” The search has no permit number, so we matched records by facility name and county. Some records will not match, so every Missouri figure is a minimum. MoDNR also says the search holds most, but not all, of these letters.
- Notices of violation. 49 operations have a notice of violation, as opposed to a letter of warning.
- Largest farms only. The state list covers only the 254 Class I CAFO permits, so the high share reflects big operations.
Nebraska
Source: Nebraska Department of Water, Energy, and Environment public document index, plus its legal-program records. Counted: notices of violation, letters of noncompliance, enforcement requests and legal pleadings (orders, consent decrees, complaints, petitions).
- “At least.” Documents are imaged from about 2011, and many facilities have none, so these are minimums.
- Legal actions. 66 operations have a legal action (a pleading or legal-program enforcement record).
- Our October 8 brief did not search ECHO for Nebraska, so we give no ECHO figure here.
Michigan: the state where the two records agree
Every Michigan swine CAFO holds an NPDES permit, so the Michigan Department of Environment, Great Lakes, and Energy (EGLE) records its own actions in EPA’s national permit data. That makes Michigan the one state where ECHO tells the full story: 108 of the 110 permits appear in ECHO’s data, and 96 have a notice of violation, letter of violation or warning letter, or administrative consent order. 50 have a notice of violation and 9 a consent order. Michigan shows what ECHO can do when farms hold federal permits. In the other five states, most do not.
Minnesota: pending
Minnesota lists 5,543 active swine operations, and ECHO’s hog-farming search returned none. The Minnesota Pollution Control Agency (MPCA) publishes enforcement actions one facility at a time, but its site blocks bulk retrieval. FAT emailed MPCA on October 24, 2026, requesting a bulk extract under the Minnesota Government Data Practices Act. We will add Minnesota when it arrives.
4. A worked example: Tyson, Storm Lake, Iowa
A pork label names the processing plant by its USDA establishment number, not the farm. Here is what the FAT App’s nearby-farms card shows for the Tyson Fresh Meats slaughter plant in Storm Lake, Iowa (USDA establishment M244):
| Hog operations in state records within 50 miles | 2,062, all in Iowa |
| Hold a federal NPDES permit | 7 |
| Matched to an Iowa DNR field-office record | 2,057 |
| At least one notice of violation or letter of non-compliance, ever | 1,006 |
| …in the last 5 years | 350 |
| At least one from an inspection, complaint, spill or other field action | 348 |
| Manure spill linked in DNR records | 23 |
Read that as context about the plant’s neighborhood, not its supply chain. Farms near a plant are not necessarily its suppliers. Hogs can travel long distances to slaughter, and no state FAT reviewed publishes which company owns the hogs on a contract farm. These counts tell a shopper what state regulators have recorded around the plant. They do not say any of these farms sold hogs to it.
5. How this fits the FAT App
Since October 26, 2026, the FAT App’s pork scan card shows these counts for every plant with state hog-operation records within 50 miles. This context never changes the FAT Score. The score counts what the label and the company disclose; nearby enforcement is shown beside it for information only.
FAT publishes counts only. We do not publish farm names, owner names, farm locations or permit numbers, in the App or here. The state records are public, but our purpose is plant-level context, not a farm-by-farm list.
Other work points the same way. In September 2026 Sentient Media published a map of Iowa enforcement records covering all livestock species, with farms named. FAT’s recount of their published file finds 4,097 of 8,948 swine sites (45.8%) with at least one NOV, letter of non-compliance or administrative order. FAT’s count, from the same Iowa DNR database, is 4,120 of 8,816 (46.7%). The two differ in scope (Iowa only and all species, versus six states and hogs only, tied to the plant on the package) but agree on the scale.
Method and limits
- Operations are each state’s list as used in our October 8 brief: Iowa DNR’s animal feeding operation database (300+ animal units, updated April 5, 2024); NC DEQ active swine permits, one per permit number; IDEM confined feeding approvals with pigs; MoDNR effective Class I swine permits; Nebraska livestock waste control facilities with an active swine program record; Michigan EGLE swine CAFO permits (2024 layer).
- Enforcement records were joined to operations on each agency’s own facility identifier, except Missouri (facility name and county). Counts are operations with at least one qualifying action, not the number of actions.
- An NOV is a formal finding that a rule or permit condition was not met. It is not proof of pollution; many are for late or incomplete paperwork.
- Record start dates differ: Iowa about 2009, North Carolina about 2018 (itemized), Indiana sparse before 2009, Missouri 2009, Nebraska about 2011, Michigan 2008.
- ECHO figures are facility counts for NAICS 112210 from our October 8 search. Facilities coded otherwise, or not coded, are not counted. We did not search ECHO for Nebraska.
- Percentages are shares of each state’s list and are not comparable across states.
- Statewide totals were recomputed from the same build that produced the App’s data file, and that rebuild matched the published file exactly. The 79% paperwork share is from a 1,887-facility Iowa sample taken October 22, 2026.
Companion brief: The Hog Farms EPA’s Database Doesn’t Show.
Sources
- U.S. EPA, Enforcement and Compliance History Online (ECHO), facility search, NAICS 112210, queried October 8, 2026, as reported in FAT, The Hog Farms EPA’s Database Doesn’t Show.
- Iowa DNR, Field Office Compliance database, retrieved October 24, 2026; Iowa DNR spill incidents layer.
- Iowa DNR, Animal Feeding Operations database (April 5, 2024).
- NC DEQ Division of Water Resources, document records (Laserfiche WebLink), retrieved October 24, 2026.
- NC DEQ, Animal Feeding Operation Permits layer.
- IDEM, Virtual File Cabinet, retrieved October 25, 2026; IDEM, Confined Feeding Operations.
- MoDNR, Letters of Warning and Notices of Violation search, retrieved October 25, 2026.
- MoDNR, NPDES Animal Feeding Operations.
- Nebraska DWEE, public document index, retrieved October 26, 2026; Nebraska livestock waste control facility locations.
- U.S. EPA, ECHO ICIS-NPDES data downloads (Michigan EGLE actions), data as of October 25, 2026.
- Michigan EGLE, Concentrated Animal Feeding Operations.
- Minnesota Pollution Control Agency, Feedlots in Minnesota.