"[CAFO pigs] produce more than 19,000,000 tons of manure per year and most of it is stored in lagoons for large uncovered containment pits;" an insufficient way to dispose of manure (Nierenberg). Because the manure is not sufficiently removed, in the event of strong storms, lagoons and retention pits overflow and open (Nierenberg). The manure spreads over large areas and contaminates rivers and groundwater (Nierenberg). Manure in rivers and other bodies of water causes mass fish kills and requires millions of dollars in cleanup costs (Nierenberg). Factory farms are harmful to the environment even though they can help improve