The Non-Financial Ledger

A permit is a promise. It’s a contract between a corporation and the people whose environment it operates in. Scattered Acres, Inc. was granted a permit to run its massive animal feeding operation with the explicit understanding it would prevent its industrial-scale waste from contaminating public water. That promise was broken.

The EPA’s findings detail a fundamental failure. On June 23, 2022, and again on September 27, 2022, inspectors witnessed a system designed to fail. A compost pile, described in the compliance order as holding manure, bedding, and “mortalities”—the industry term for dead animals—was left exposed. Stormwater pooled around it, mixed with the decomposing organic matter, and drained away. It flowed into an “unnamed tributary of Little Cocalico Creek,” beginning a journey into the Cocalico Creek, then the Conestoga River, and finally the Susquehanna River.

This isn’t just an accounting error or a paperwork violation. This is a physical act of pollution. The cost isn’t measured in dollars but in the degradation of a shared natural resource. It’s paid by the ecosystems choked with nutrient runoff and by every person downstream who trusts that the water is safe.

Legal Receipts

Corporate responses to regulatory action are often wrapped in legal jargon. Scattered Acres, Inc. took a common route: the non-denial denial. While agreeing to the EPA’s jurisdiction, the company sidestepped any admission of guilt for the environmental damage.

This maneuver allows the company to accept the consequences without accepting the blame. The facts, however, were observed directly by federal inspectors. They saw the failure with their own eyes.

Societal Impact Mapping

Environmental Degradation

The path of pollution is clear. What starts in a single compost pile at Scattered Acres Farm does not stay there. The runoff introduces excess pollutants like nitrogen and phosphorus into the water. These pollutants fuel algal blooms that starve the water of oxygen, creating dead zones where fish and other aquatic life cannot survive. This damage cascades from the smallest tributary all the way down to the Susquehanna River, a major artery of the regional watershed.

Public Health

Waste from manure and decomposing animals carries more than just nutrients. It can be a vector for harmful bacteria and pathogens. When a facility operating under a Clean Water Act permit fails to contain its waste, it externalizes its risk onto the public. Communities downstream may rely on these water sources for recreation, agriculture, and even drinking water. The failure of one company becomes a potential threat to the health of many.

The Cost of Non-Compliance

The EPA order does not specify a monetary penalty. Instead, it mandates action. The “cost” for Scattered Acres is being forced to do what it should have already done. This isn’t a punishment; it’s a demand for basic compliance. The real cost was paid by the environment during the time the company was in violation.

What Now? A Watchlist for the People

The EPA’s order forces Scattered Acres, Inc. to build a “Roofed Composter” within two years of the agreement. This is a start, but accountability requires constant vigilance. The system only works when we are watching.

• Corporate Role to Watch: The order is signed by Harrison Hartman, Operator. As the person legally binding the company, he is responsible for ensuring compliance.
• Regulatory Bodies: The U.S. Environmental Protection Agency (EPA) Region 3 and the Pennsylvania Department of Environmental Protection (PADEP) are the primary agencies responsible for enforcement. Their actions, or lack thereof, determine if these orders have teeth.
• Your Role: This is not an isolated incident. Industrial agriculture is a massive source of pollution nationwide. Support local watershed protection groups. Attend township meetings. Demand that regulators like the EPA and PADEP hold every polluter to the letter of the law. Grassroots organizing is the most effective check on corporate power.