United States. For instance, in 2002, the state of Florida passed an amendment to the state's constitution banning the confinement of pregnant pigs in gestation crates. As a source for comparison, the use of battery cages for egg-laying hens and battery cage breeding methods have been completely outlawed in the European Union since 2012. Whereas some people are concerned with animal welfare as an end in itself, others are concerned about animal welfare because of the effect of living conditions on consumer safety. Animals in CAFOs have lives that do not resemble those of animals found in the wild. Although CAFOs help secure a reliable supply of animal products, the quality of the goods produced is debated, with many arguing that the food produced is unnatural. For instance, confining animals into small areas requires the use of large quantities of antibiotics to prevent the spread of disease. There are debates over whether the use of antibiotics in meat production is harmful to humans. We have discussed that milk production is a metric of a cows health. Since 1960 average milk cow production has increased from to by 2008, as noted by Dale Bauman and Jude Capper in the Efficiency of Dairy Production and its Carbon Footprint. The article points to the fact that the carbon footprint resulting from the production of a gallon of milk in 2007 is 37% of what it was in 1944. This is largely due to the efficiencies found in larger farming operations and a further understanding of the health needs of farm animals. Regulation under the Clean Water Act Basic structure of CAFO regulations under the CWA The command-and-control permitting structure of the Clean Water Act (CWA) provides the basis for nearly all regulation of CAFOs in the United States. Generally speaking, the CWA prohibits the discharge of pollution to the "waters of the United States" from any "point source", unless the discharge is authorized by a National Pollutant Discharge Elimination System (NPDES) permit issued by the EPA (or a state delegated by the EPA). CAFOs are explicitly listed as a point source in the CWA. Unauthorized discharges made from CAFOs (and other point sources) violate the CWA, even if the discharges are "unplanned or accidental." CAFOs that do not apply for NPDES permits "operate at their own risk because any discharge from an unpermitted CAFO (other than agricultural stormwater) is a violation of the