organization and provided a list of recommendations and required action for the state to meet. Unauthorized state case study: Massachusetts In unauthorized states, the EPA has the authority for issuing NPDES permits. In these states, such as Massachusetts, CAFOs communicate and file required documentation through an EPA regional office. In Massachusetts, the EPA issues a general permit for the entire state. The state's Department of Agricultural Resources (MDAR) has an agreement with the EPA for the implementation of CAFO rules. MDAR's major responsibility is educational. The agency assists operators in determining if their facility qualifies as a CAFO. Specifically they do onsite evaluations of facilities, provide advice on best practices, and provide information and technical assistance. If a state has additional state specific rules for water quality standards, the state government maintains the authority for permitting. For instance, New Mexico, also unauthorized, requires CAFOs and AFOs to obtain a Groundwater Permit if the facilities discharge waste in a manner that might affect local groundwater. The EPA is not involved in the issuing of this state permit. Massachusetts, however, does not have additional state permit requirements. Zoning ordinances State planning laws and local zoning ordinances represent the main policy tools for regulating land use. Many states have passed legislation that specifically exempt CAFOs (and other agricultural entities) from zoning regulations. The promulgation of so-called "right to farm" statutes have provided, in some instances, a shield from liability for CAFOs (and other potential nuisances in agricultural). More specifically, the right-to-farm statutes seek to "limit the circumstances under which agricultural operations can be deemed nuisances." The history of these agricultural exemptions dates back to the 1950s. Right-to-farm statutes expanded in the 1970s when state legislatures became increasingly sensitive to the loss of rural farmland to urban expansion. The statutes were enacted at a time when CAFOs and "modern confinement operations did not factor into legislator's perceptions of the beneficiaries of [the] generosity" of such statutes. Forty-three (43) states now have some sort of statutory protection for farmers from nuisance. Some of these states (such as Iowa, Oklahoma, Wyoming, Tennessee, and Kansas) also provide specific protection to animal feeding operations (AFOs) and CAFOs. Right-to-farm statutes vary in form. Some states, for instance, require agricultural operation be located "within an acknowledged and approved agricultural district" in order to receive protection; other states do not. Opponents of CAFOs have challenged right-to-farm statutes in court, and the