Preventing Another Pandemic: How Changing the Legal Paradigm Governing Intensive Animal Agriculture Will Reduce the Risk of Future Zoonoses

The public health consequences tied to our relationships with animals are significant. The COVID-19 pandemic and previous instances of zoonotic disease emergence and re-emergence have demonstrated that human relationships with animals can have a profound impact on our health. In the US, the most prevalent human-animal relationship is the one we have with the animals that we eat. This relationship is defined and facilitated by intensive animal agriculture, a practice at high risk of causing zoonotic disease emergence. This Article explores the current regulatory regime governing intensive animal agriculture and argues that it is deficient in the context of zoonotic disease. It argues that this deficiency is a result of the legal anthropocentrism that manifests in practices inherent to intensive animal agriculture and demonstrates that such an approach is unable to adequately manage the risk of future zoonoses. This Article argues for a regulatory approach that acknowledges the interdependence of humans, animals, and the environment. It proposes Wild Law as the most appropriate framework to address the risk of zoonotic disease and concludes that intensive animal agriculture would not be permitted under a Wild Law approach due to its inherent inability to operate within the context of an interdependent human-animal-environment relationship.


I. INTRODUCTION
"Epidemics afflict societies through the specific vulnerabilities people have created by their relationship with the environment, other species, and each other. Microbes that ignite pandemics are those whose evolution has adapted them to fill the ecological niches that we have prepared." 1 The COVID-19 pandemic has, in the United States and globally, underlined the devastating impacts an infectious disease outbreak can have on society. The consequences have been far reaching, with 879,971 COVID-19 deaths and 74,222,140 total cases in the United States alone as of January 28, 2022. 2 The impacts of COVID-19 have not just been felt in relation to public health. Significant restrictions have been imposed in response to the outbreak, with governments issuing shelter in place and stay at home orders, mandating face masks and closing businesses. 3 COVID-19 and the lockdowns imposed in an attempt to curb its transmission have also had a significant emotional impact, with many in the United States reporting negative mental health impacts 4 -connected in part to the economic consequences of the pandemic, which have resulted in many Americans experiencing unemployment and poverty. 5 While the origin of SARS-CoV-2 (COVID-19) has been a point of contention and is still under investigation, 6 a leading theory is that the infection began in a non-human animal before passing-or "spilling over"-to human beings. 7 COVID-19 is therefore a zoonotic disease. The spill over theory aligns with the dire warnings that infectious diseases experts have been delivering for years. In 1988, for instance, Nobel prize recipient Joshua Lederberg warned that "[a]s one species, we have a common vulnerability… [t]he microbe that felled one child in a distant continent yesterday can reach yours today and seed a global pandemic tomorrow. Quammen wrote "[n]ow disease experts wonder about the 'next big one'-when will it come, what will it look like, from which reservoir host will it spill over, and how many people will it kill?" 9 Quammen aptly identified that "[t]he worst new diseases of the future, like those of the recent past, will be zoonotic." 10 Thus, despite the warnings, societies globally are grappling with the impacts of a global pandemic caused by a zoonotic disease, as predicted decades in advance.
Zoonotic diseases are innately connected to the relationships between humans and animals. The emergence or re-emergence of zoonotic diseases like COVID-19 are fundamentally driven by changes in the human-animal relationship and the associated increase in contact. 11 As Frank Snowden, emeritus professor in history and the history of medicine explains, "[e]pidemics afflict societies through the specific vulnerabilities people have created by their relationship with the environment, other species, and each other." 12 In the context of the US, there is no relationship between humans and animals more substantial or prevalent than the one we hold with the animals raised for human consumption. The United Nations (UN) has recognized the risk that this creates in terms of future zoonoses in a 2020 report entitled "Preventing the Next Pandemic." 13 In it, the UN identified an increasing demand for animal protein and the intensification of animal agriculture as key drivers of zoonotic disease. 14 The transition to intensive animal agriculture has likely been one of the most significant changes in the human-animal relationship since the transition from hunter-gatherer societies to large agricultural communities. 15 Intensive animal agriculture operations-the largest of which are known as concentrated animal feeding operations 9 David Quammen, Disease: The Next Big One, N.Y. TIMES (Oct. 14, 2013), https://www.nytimes.com/2013/10/15/opinion/disease-the-next-big-one.html [https://perma.cc/7W5D-XUUJ]. 10 Id. 11 U.N. ENV'T PROGRAMME & INT'L LIVESTOCK RSCH. INST., PREVENTING THE NEXT PANDEMIC: ZOONOTIC DISEASES AND HOW TO BREAK THE CHAIN OF TRANSMISSION 15-17 (2020) [hereinafter PREVENTING THE NEXT PANDEMIC]. 12 SNOWDEN, supra note 1, at ix. 13 See generally, PREVENTING THE NEXT PANDEMIC, supra note 11. 14 In total, the report identified seven driving factors behind the emergence of zoonotic diseases, including: 1) increasing human demand for animal protein; 2) unsustainable agricultural intensification; 3) increased use and exploitation of wildlife; 4) unsustainable utilization of natural resources accelerated by urbanization, land use change and extractive industries; 5) increased travel and transportation; 6) changes in food supply; and 7) climate change. PREVENTING THE NEXT PANDEMIC, supra note 11, at 15-17. 15  (CAFOs)-fulfill the current demand for substantial quantities of animal protein. They do so by replacing human labor with machinery, confining large numbers of animals indoors with minimal space, and providing the animals with specialized feed, designed to efficiently increase mass at low-cost, instead of allowing the animals to forage or graze. 16 Underpinned by productivity, efficiency, and profit, these operations are able to effectively meet the mass demand for animal food products in the United States at an economically low cost. However, as recognized by the UN, they also pose an unacceptably high risk in terms of zoonotic disease.
Considering this risk, this Article analyses the regulations governing intensive animal agriculture and asks whether they are sufficient to adequately minimize the risk of zoonotic disease emergence. Part I begins by explaining what a zoonotic disease is, what drives transmission, and the impact of human behavior on zoonotic disease emergence. Part II considers the context of the legal framework, the impact that animal welfare laws have on the zoonoses potential of intensive animal agriculture, the effectiveness of measures such as surveillance, depopulation and disposal, and regulation by the Environmental Protection Agency (EPA). It outlines the deficiencies in the current regulatory framework and concludes that current regulation is insufficient to address the risk that intensive animal agriculture poses in terms of future zoonotic disease outbreaks.
Informed by this discussion, Part III of this Article explores possible alternative legal frameworks for regulating intensive animal agriculture. Both One Health and Wild Law are considered as possible options, and the benefits and limitations of each are evaluated. This Article argues that Wild Law is the most appropriate framework to address the zoonotic disease risk as it recognizes the interdependence of human, animal, and environmental health and will produce the necessary paradigm shift. Nevertheless, Wild Law remains vague in terms of its practical operation and a wholesale application of a Wild Law paradigm to the regulation of animal agriculture is unlikely to be politically palatable. Given these considerations, we recommend in Part IV that the most obvious reform suggested by a Wild Law analysis be pursued. Intensive animal agriculture is inconsistent with a Wild Law approach, as it is unable to operate within a framework that demands equal consideration of humans, animals, and the environment. Therefore, to adequately minimize the zoonotic disease risk posed by animal agriculture, this Article recommends the immediate phasing out of intensive animal agriculture. As a Wild Law approach to the regulation of animal agriculture would require phasing out intensive operations, it would also discontinue factors inherent to their operation that pose an unacceptable risk in terms of zoonotic disease. This approach would address the risk of zoonotic disease outlined in this Article.

II. CONTEXT
A. What Are Zoonotic Diseases?
The COVID-19 pandemic has familiarized contemporary society with the threat of zoonotic diseases-that is, diseases that originate in non-human animals. Zoonotic diseases constitute approximately 75% of all newly emerging or re-emerging diseases that infect humans and, as has been demonstrated, pose a significant threat to public health. 17 The non-human animal that begins the process of zoonotic disease emergence is known as the reservoir host. The reservoir host will carry a pathogen, such as a virus, parasite or bacteria that can cause disease. The reservoir host will typically be largely unaffected, but the pathogen may jump to humans or to an intermediary animal before making a further jump to humans. This 'jump' is referred to as 'spillover', 18 and the consequences of a successful spillover to humans can be devastating. As Quammen outlines, a virus is "the most troublesome." 19 This is because viruses are "abundant, adaptable, not subject to antibiotics, and only sometimes deterred by antiviral drugs." 20 A successful spillover is one where the pathogen jumps and adapts to a human host, becomes established in a local human population and then spreads. In this instance, a zoonotic disease will have successfully emerged. Not all zoonotic diseases are successful. In fact, it is likely that even if spillover occurs, that disease will reach a dead-end and fail to become established in a human population. This may be because that pathogen fails to adapt to the immune response of its human host, or because it does not transmit effectively or efficiently between people. 21 If a zoonotic disease does successfully emerge it may become epidemic or pandemic. In the first instance, the disease will affect people in a given locality, and in the latter instance, the disease will spread across countries and continents.

B. Drivers of Emerging Zoonotic Infectious Diseases
Contact between humans and animals is fundamental to zoonotic disease emergence. 22 Increased contact provides pathogens with the opportunity to make the jump from animal to human, an opportunity seized by evolution. 23 The UN released a report identifying seven major drivers of zoonotic disease emergence-all of which were anthropogenic and a number of them related directly or indirectly to our relationship with the animals we consume. 24 Despite wet markets being identified as the likely source of COVID-19, increasing demand for animal protein and unsustainable agricultural intensification are the most relevant drivers of zoonotic disease in the United States. This is because live wildlife markets are significantly less common in the United States than intensive animal agriculture. The consumption of animal protein and the associated intensification of animal agriculture therefore present the greatest opportunity for pathogen spillover.
The United States is one of the largest meat consuming countries in the world, with the average American consuming around 58 pounds of beef, 53 pounds of pork, and 110 pounds of poultry in 2019. 25 Comparatively, in 1991, the average American consumed around 67 pounds of beef, 50 pounds of pork, and 80 pounds of poultry. 26 Despite the reduction in the consumption of beef since 1991, the large 21 See Ishan Kukreti, Bats Spread Viruses, so do Humans, 29 DOWN TO EARTH 38, 39 (2020). 22 Increased or full automation of intensive animal agricultural practices-to reduce contact between humans and animals-would further jeopardize animal welfare. Given developments in animal welfare science and particularly our improved understanding of animal sentience, this is highly undesirable. Further, certain factors that are currently inherent to intensive animal agriculture, such as transport of the animals from farm to abattoir, could not foreseeably be automated and thus the risk of zoonotic disease outbreaks would remain even if automation were to increase. 23 Quammen, supra note 19, at 59. 24 PREVENTING THE NEXT PANDEMIC, supra note 11, at 15-17. 25 OECD, Meat Consumption, OECD ILIBRARY, https://www.oecd-ilibrary.org/agriculture-andfood/meat-consumption/indicator/english_fa290fd0-en [https://perma.cc/5T35-EWN3] (last visited Nov. 2, 2021). 26 Id. increase in poultry consumption means that Americans are eating 24 pounds more animal protein per year than they were around thirty years ago. Further, Americans consume significantly more animal protein than people in many other countries. For instance, the average amount of animal protein consumed per person globally in 2019 was 14 pounds of beef, 24 pounds of pork, and 32 pounds of poultryaround 151 pounds less than the total in the United States. 27 Intensive animal agriculture, which is the second key driver of zoonotic disease identified by the UN, facilitates these high levels of meat consumption. Intensification of agriculture is evident in relation to all commonly farmed animals in the United States, with intensive operations supplying approximately 99% of all meat products. 28 Moreover, industrialization has increased significantly over the last 20 years. 29 Driven by increasing consumer demand for animal protein, intensified operations seek to increase the production of animal products using minimal space, labor, and expenditure. Industrialization of animal agriculture in the United States is best illustrated by CAFOs. The EPA defines CAFOs as operations that contain more than 1,000 'animal units' for a period of at least forty-five days. 30 An animal unit is the equivalent of 1,000 pounds of a live animal, and thus a CAFO is an operation that contains at least 1,000 cattle, 2,500 pigs, or 125,000 chickens raised for meat consumption. 31 The most recent data suggests that CAFOs supply around 50% of the total number of animals slaughtered for consumption, despite making up only 5% of animal agriculture operations in the US. 32 This Article uses the term 'intensive' to refer to CAFOs as well as intensified operations that do not meet the CAFO threshold.
As mentioned above, the farming operations that produce animals typically used for food, such as pigs, poultry, and beef cattle, have been massively scaled up. Pig and poultry farming have seen a rapid 27  transformation from small-scale operations to large, intensely concentrated systems. This is perhaps unsurprising given that the United States is the second-largest producer of pork 33 and the largest producer of poultry in the world. 34 In the case of pigs, the scaling-up of the industry is represented by the 70% decline in the number of pig farms in the United States since 1990, despite an increase in the total number of farmed pigs over the same period. 35 As Kelloway and Miller explain, this is "due primarily to a decline in small farms and a rise in large concentrated feeding operations." 36 A 2008 report by the Pew Commission on Industrial Farm Animal Production explains that "over the last 14 years, the average number of animals per swine operation has increased 2.8 times." 37 Hsu outlines that in 2012 approximately 96% of all pigs were reared on farms that held at least 1,000 pigs, compared to 7% of all pigs in 1969. 38 This substantial increase demonstrates the transition from largely extensive, small-scale farms to intensely concentrated pig farming operations-a transition that has made the United States one of the world's largest pork exporters. 39 An almost identical transition is evident in poultry farming. In 2020, over 9.25 billion broiler chickens-that is, chickens raised for meat consumption-were harvested in the US. 40 Intensive broiler operations are fundamental to this level of output. 41 The Second World War made the consumption of chicken more common, with national campaigns encouraging the population to consume more poultry and less beef, pork, and lamb to save those products "for the army and our allies." 42 The intensification of the poultry industry occurred relatively swiftly following the increase in consumption, with a 1956 report stating that "[g]rowers with a capacity of 1,500 to 10,000 birds fear that they cannot compete successfully with single enterprise growers who use mass production methods and have broiler capacities of 13,000 and perhaps eventually 50,000 or more." 43 Today, approximately 99% of the more than 9 billion broiler chickens produced in the United States are raised in intensive operations. 44 The trend towards intensification is also evident in cattle. Approximately 82% of all beef cattle in the United States are raised on intensive operations. 45 Cattle are typically moved to a feedlot for the final phase of production, 46 where they can be confined for a period of 90 to 300 days to fatten, or 'finish' them for slaughter. 47 Feedlots containing 1,000 or more heads of cattle supply around 80-85% of all fed cattle, and feedlots that contain at least 32,000 heads of cattle supply approximately 40% of fed cattle. 48 Thus, operations that meet the threshold of a CAFO supply around 85% of all fed cattle. As the U.S. Department of Agriculture (USDA) outlines, "[t]he industry continues to shift towards a small number of very large, specialized feedlots." 49 This trend in animal agricultural operations exacerbates the risk of zoonotic disease, as the industrialized conditions create a heightened opportunity for pathogens to spill over.
Intensive animal agriculture presents several key risks in relation to zoonotic disease emergence, all arising from factors inherent to the industrialized farming model. These include overcrowding, genetic uniformity, the use of antimicrobials, and the movement of waste and other materials into the external environment. Regarding overcrowding, high densities of animals are a defining element of intensive operations. Large populations are confined in small areas, resulting in increased contact between the animals. For instance, intensively 43  farmed pigs have about eight square feet of space each. 50 Large populations of animals with high levels of contact can increase the spread of pathogens between them, which may influence the way the disease evolves-potentially creating a disease that is more transmissible or virulent amongst human beings. 51 Large numbers of animals kept in industrial systems may have a further impact on zoonotic disease emergence due to associated welfare concerns. The high stocking densities inherent to intensive animal agriculture increase frustration within the animals, due to their inability to express natural behaviors. This frustration may manifest in acts of aggression towards other animals. For example, chickens may peck other birds, 52 and pigs may bite the tail of other pigs. 53 The animals are subject to painful interventions such as beak trimming or tail docking to manage these behaviors. 54 Procedures such as these are considered routine husbandry practices within intensive operations and are commonly performed on young animals without pain relief. 55 The procedures can cause chronic pain, physiological stress, and a lower level of overall welfare amongst the animals, 56 which may also contribute to increasing an animal's vulnerability to disease. 57 Genetic uniformity is also inherent to industrialized animal agriculture, particularly poultry and pig operations. For example, just two breeds of broiler chickens-the 'Cobb 500' and 'Ross 308'-account for most of the more than nine billion chickens produced in the US. 58 These chickens have been selectively bred to have large breasts, white feathers, and to grow quicker and more efficiently. 59 While selective breeding allows producers to meet consumer demand, the process results in decreased genetic diversity. 60 Low genetic diversity in animal populations can be problematic in terms of zoonotic disease emergence as it may result in decreased immune resistance to pathogens, making the animals more susceptible to disease. 61 Further, large populations of genetically homogenous animals may influence the transmission rate and virulence of pathogens. The Food and Agriculture Organization (FAO) explains the issue, stating that, "in monocultures involving mass rearing of genetically identical animals that are selected for high feed conversion, an emerging hyper-virulent pathogen will rapidly spread within a flock or herd." 62 Trevor Drew further explains that large populations of genetically uniform animals "may select highly pathogenic viral clades, leading to explosive outbreaks of novel disease." 63 Thus, the large groups of genetically similar animals that are fundamental to industrialized agriculture may operate to heighten the risk of zoonotic disease emergence, as well as the overall danger of the disease.
To manage animal health considering the welfare concerns detailed above, intensive operations commonly utilize antimicrobials. They are administered, often pre-emptively, for the treatment and prevention of diseases and to promote growth. 64 Antibiotic resistance-which occurs when a microorganism develops an ability to resist the effects of antibiotics-is recognized as a "major global public health threat." 65 The non-therapeutic use of antibiotics in animal agriculture is a key contributor to this threat, given around 80% of all antibiotics sold in the United States are used for animal agriculture. 66 59  The FDA implemented a ban on the use of medically important antibiotics as growth promoters in 2017, and the use of antibiotics for prevention and treatment of disease now requires veterinarian authorization. 67 Despite this, data released by the FDA in 2019 shows a 9% increase in the sale and distribution of medically important antibiotics in animal agriculture between 2017 and 2018. 68 Strains of bacteria in intensively farmed animals that develop a resistance to antibiotics threaten the efficacy of antibiotic use in humans. 69 Overuse and misuse of antibiotics in intensive animal agriculture contribute to the threat of zoonotic disease transmission by both increasing an animal's susceptibility to illness and reducing the available treatment options for bacterial diseases that are available to humans.
Finally, the emission of material such as litter, dander, and animal waste represents a potential gap in biosecurity and may facilitate the spread of pathogens into the environment. Ventilation systems are a necessary component of intensive operations; however, they may aid the transmission of pathogens to nearby animals through the discharge of pollutants into the external environment. 70 Large volumes of animal waste are also an unavoidable element of intensive animal agriculture, with pig CAFOs in North Carolina alone producing approximately 10 billion pounds of wet animal waste per year. 71 Pathogens in animal waste may come into contact with wild or domestic animals, and may also contaminate water, which increases the risk that a disease will spread. 72 Taken together, the various factors that are inherent to industrial animal agriculture, including high densities of genetically uniform animals, antibiotic use, and the potential for pathogen spread into the environment, significantly increase the risk of zoonotic disease emergence.

C. The Impact of Human Behavior on Zoonotic Disease Emergence
The threat of intensive animal agriculture has been evidenced by previous instances of zoonotic disease emergence. One such example is Nipah Virus, which first infected humans in 1997. 73 Nipah Virus made the jump from fruit bats to pigs on an intensive pig farm in Malaysia. 74 As Jones et al. outline, "[r]espiratory spread of infection between pigs was facilitated by high pig farm density and transport of pigs between farms to the main outbreak area in south Malaysia." 75 In this outbreak, the large number of susceptible pigs acted as an intermediary host before spillover to humans occurred. 76 A second example can be found in strains of highly pathogenic avian influenza, such as H5N1. This virus was first detected in humans in 1997, with domestic poultry acting as the intermediary host. 77 Intensive poultry farming was recognized, at least in part, as the root cause behind the emergence of H5N1. 78 The swine flu pandemic can also be attributed to intensive animal agriculture-specifically, to intensive pig farms in the US. 79 While the virus was first identified in humans in Mexico, virologists determined that the strain detected in Mexico was the same as the strain detected in intensive pig farms in North Carolina years earlier. 80 Further, while a link has never been established, the town at the center of the outbreak, La Gloria, was located next to one of Mexico's largest swine operations. 81 Finally, bovine spongiform encephalopathy, or 'mad cow disease', can also be linked to the way humans treat animals raised for consumption. Mad cow disease spread because cattle were commonly given feed containing parts of cattle that had been infected with the disease. This process of cannibalizing herbivorous cows was prompted by the substantial volume of cattle raised for human consumption. 82 This is because human beings only consume about 40% of the weight of each cow slaughtered for consumption, leaving billions of pounds of animal parts that must be dealt with. 83 These parts were rendered into meat-and-bone meal and fed to cows, which also increased productivity in intensive operations. 84 A variant of mad cow disease-Creutzfeldt-Jakob disease-was then passed to humans who consumed the infected cattle. These various instances of zoonotic disease emergence demonstrate that intensive animal agriculture poses a significant risk to public health.
The Pew Commission recognized this risk in 2008 and emphasized that "[t]he present system of producing food animals in the United States is not sustainable and presents an unacceptable level of risk to public health." 85 The production of 'food animals' in the United States has been largely unabated by this finding, with industrialization having increased since 2008. 86 Further, with the global population set to increase to 9.7 billion in 2050, 87 a significant increase in agricultural output will likely be required to meet the demand for animal products if meat consumption continues at current rates. 88 Given that agriculture already occupies approximately 50% of all habitable land, and farmed animals account for 77% of all farming land, 89 opportunity for agricultural expansion is somewhat limited. As a result, intensification of agriculture will likely increase, along with the risk of zoonotic disease emergence. As Jason R. Rohr et al. outline, this risk is exacerbated given that attributable to infectious diseases, where the risk of disease emergence might be greatest, and where disease surveillance and access to health care, particularly for those infections that accompany extreme poverty, are most limited. 90 Thus, if current consumption trends continue, intensive animal agriculture is set to increase despite being recognized as a key driver of zoonotic disease, and the threat of zoonotic disease emergence will likely increase in tandem.
The expanding world population and increasing demand for animal food products necessitates a prioritization of food production-an interest that may outweigh the risk of zoonotic disease emergence posed by intensive animal agriculture. However, intensive animal agriculture may not be the most efficient system to meet these demands. As identified by Cassidy et al., "[w]hile efficiencies of feed-to-edible food conversions have increased over time, the ratio of animal product calories to feed calories is, on average, still only about 10%. This suggests using human-edible crops to feed animals is an inefficient way to provide calories to humans." 91 Thus, rather than focusing on increasing intensive production, demand for food protein could instead be met with plant-based proteins. Shepon et al. explain that "[p]lant-based diets can also serve as a viable replacement for animal products, and confer larger mean environmental and food availability gains." 92 These systems would also significantly reduce the zoonotic disease risk.
The COVID-19 pandemic has given the world a preview into the impact of a successful zoonotic disease emergence, with devastating consequences for public health and global economies. However, as Michael Greger identifies, COVID-19 could be just a "dress rehearsal" for much greater zoonotic threats. 93 For instance, while the H5N1 virus mentioned above has not yet gained the ability to easily transmit between human beings, more than half of all human beings infected by the virus have died. 94  fatality rate of COVID-19 is around 1.2%. 95 The threat of the next zoonotic disease may therefore be much greater than the current crisis. The next section of this Article considers the adequacy of the regulations in place to reduce this threat.

The Anthropocentric Foundation
Intensive animal agriculture and the laws that regulate it are representative of broader notions of domination that underpin the humananimal relationship. Human dominion over animals and the wider environment is a fundamental tenet of all western legal systems. 96 These systems place human beings at the center of existence, with all remaining elements of the earth left to occupy the periphery-a hierarchy that can be described as anthropocentric. 97 This is because human beings are positioned as subjects, independent and separate from non-human objects. Laws operate primarily for the interests of human beings under an assumed hierarchy that considers non-humans to be inferior 'others.' 98 Accordingly, under western legal systems, the interests of animals are afforded only indirect consideration where doing so aligns with human interests. Robert Garner explains that "the level of protection afforded to an individual animal depends, not just-if at all-upon its needs and interests, but upon the institutional and legislative structure governing the particular use to which it is being put." 99 Where the use of an animal results in some degree of benefit to human beings, the laws regulating that use typically subordinate animal interests in favor of human benefit. This is illustrated by the regulation of intensive animal agriculture in the US, which permits industrial farming methods that maximize human benefit at the expense of animal welfare. A key component of the industrialized farming model is the large number of animals slaughtered each year. As mentioned above, over 9.25 billion broiler chickens were slaughtered in the United States in 2020. 100 There were also approximately 132 million pigs, 32.8 million cattle, 2.23 million lamb and sheep, and 456,400 calves slaughtered in 2020. 101 This means that there were over 9,417,486,400 animals slaughtered in 2020 in the US. This number does not include fish, whose deaths are measured in tons. 102 The sheer volume of animals slaughtered for human consumption each year is indicative of the way the law favors human benefit to the detriment of animal interests.
The legal anthropocentrism evident in the regulation of intensive animal agriculture permits the mass exploitation of non-humans to satisfy human interests. This extends to the industrial farming methods that facilitate mass exploitation. The efficient production of animal meat achieved by intensive animal agriculture is protected by the law and prioritized over animal welfare. For example, broiler chickens raised in intensive settings are kept in overcrowded sheds with around 20,000 to 30,000 other chickens, with less than one square foot of space per chicken. 103 As previously indicated, the large numbers of chickens and the level of confinement frustrates their natural behaviors, including their ability to socially organize and dust bathe. 104 In turn, this increases stress amongst the birds and causes aggressive behaviors such as feather pecking, which can result in harm to the chickens. 105 To counter this behavior, it is common practice in the industrial poultry industry for producers to partially amputate the tip of a chicken's beak without anesthesia, using a hotblade or infrared technology. 106 A chicken's beak contains pain receptors and this procedure can therefore cause them acute and chronic pain. 107 Further, to maximize productivity, efficiency, and profit, broiler chickens have been selectively bred to reach slaughter weight rapidly with less feed. Zuidhof et al. demonstrated that the growth rate of broiler chickens has increased by over 400% from 1957 to 2005, while feed requirements reduced by around 50%. 108 Such rapid growth can strain their heart, lungs, and legs, impacting their balance, ability to walk, and leading to respiratory problems and heart attacks. 109 Intense confinement, high stocking densities, painful surgical procedures, and selective breeding are elements inherent to industrial poultry farming and each element substantially increases productivity, efficiency, and profit. It is also clear that these farming methods negatively impact the welfare outcomes of each chicken. The subordination of the latter in favor of the former is representative of legal anthropocentrism in the regulation of intensive animal agriculture.
Pigs in intensive settings face similar conditions, both in terms of confinement and surgical procedures. Male piglets in the United States are commonly castrated without anesthesia or analgesia. 110 Castration is performed to avoid boar taint in male pigs, which is an odor and taste in pork that consumers find unpleasant. 111 The procedure is commonly performed with a surgical blade in the first few days of a piglet's life. 112 As pigs are sentient beings, 113 the procedure can cause acute pain. 114 "[H]igh-pitched squealing and pain-indicative behaviors, such as trembling and lying alone" can be observed. 115 Pigs in intensive operations also routinely have their tails cut with clippers without pain relief. 116 This industry practice is designed to prevent pigs from biting each other's tails, which can cause significant injury to the recipient pig and may lead to infection. 117 However, tail biting is largely a symptom of intensive conditions. Barren, overcrowded conditions increase tail-biting behavior, and tail docking is not required if welfare needs are met. 118 For instance, pigs have been found to be 50% less likely to engage in tail biting behavior if provided with straw. 119 Female pigs in the United States are also commonly confined in gestation and farrowing crates that are essentially the same size as the pig and prevent her from turning around. 120 The intense confinement has significant welfare impacts resulting from an extended lack of exercise and an inability to perform natural behaviors. 121 While gestation crates are illegal in some U.S. states, and despite an industry commitment to a phase-out by 2022, they were still regularly used on more than 75% of United States pig farms in 2018. 122 As is typical of industrial farming methods, surgical procedures and intense confinement are utilized to increase efficiency while maintaining the welfare of the animals at a minimum level that ensures they will be productive and generate profit. Legalized practices such as these are indicative of the way in which the law prioritizes human interests over an animal's interest in its welfare.
Intensive animal agriculture and the laws that permit it can be described as inherently anthropocentric. The animals are 'othered' in a manner that allows their sentience to be disregarded. In turn, this allows standard industry practices, such as intense confinement and painful surgical procedures, to be carried out with only indirect consideration of the animal's interests. It is beneficial to producers to consider the interests of an animal in the context of maintaining a level of welfare that delivers the desired food product. For instance, neglecting the nutritional needs of an animal would not be in the interests of producers, as it would impact productivity and potentially compromise the end product, and thus the available profit. In practice, this mechanizes the animals and serves to make their welfare valuable only as it relates to efficiency and productivity. While this anthropocentric approach benefits human interests in the first instance, the failure to recognize the interdependency between human health and animal health increases the risk of zoonotic disease emergence which may be detrimental to human interests overall.

Animals as Property
Legal anthropocentrism in relation to animals is both facilitated and further defined by the legal status of animals in the United States, which is one of property. 123 As property, animals are unable to hold rights and can generally be treated as humans see fit, subject to some legal restrictions. 124 The property status of animals is fundamental to the legal anthropocentrism that they are subject to, as it positions them as resources to be valued only insofar as they benefit humans. Likewise, the status of humans as legal persons is fundamental to the view that humans are separate from and superior to all other beings.
This strict legal separation is, however, becoming somewhat blurred. For example, all fifty American states have animal cruelty legislation that seeks to protect animals from harm which constitutes an implicit recognition of animal sentience that is not evident in relation to other forms of property. 125 A further example in some states is a departure from the traditional assessment of damages. Generally, if a companion animal dies or is injured due to the intentional or reckless actions of a person, only the market value of the animal is considered by the courts when estimating damages. 126 However, some state legislatures have addressed this by allowing for the recovery of damages for emotional distress or burial costs. 127 In Illinois, for instance, owners of companion animals may recover the market value of their pets, as well as "veterinary expenses incurred on behalf of the animal, any other expenses incurred by the owner in rectifying the effects of the cruelty, pain, and suffering of the animal, and emotional distress suffered by the owner." 128 While still confined within the traditional property framework, changes such as these represent the way incremental advancements are disentangling animals from traditional concepts of property.
Such advancements, however, are largely limited to companion animals. This is because farmed animals are typically subject to different legal protections than companion animals, which allows significant differences in their treatment. Thus, while companion animals have been awarded (limited) advancements that distance them slightly from their status as property, farmed animals remain positioned largely as resources-property to be used for the benefit of humans.
The following sections will discuss the way the law treats farmed animals, and how this impacts the risk of zoonotic disease emergence. e. Regulation of Intensive Animal Agriculture in the US A complex patchwork of various federal and state laws is in place to regulate intensive animal agriculture, which both directly and indirectly impacts the extent to which intensive animal agriculture poses a risk for zoonotic disease transmission. Relevant laws relate to animal welfare, surveillance, depopulation and disposal and environmental protection. We provide an overview of these laws below.

Federal and State Animal Welfare Laws
The primary federal law relating to animal welfare in the United States is the Animal Welfare Act (AWA). 129 However, farmed animals are (and have always been) explicitly excluded from the protections provided under the AWA. 130 Given that farmed animals account for approximately 98% of all animals with which humans interact in the United States, 131 this is a significant exclusion and places a heavy onus on state legislatures to ensure the welfare of farmed animals. The Preventing Animal Cruelty and Torture Act 2019 (PACT Act) at first glance appears relevant to this discussion, as it prohibits causing "serious bodily injury" to an animal. 132 Nevertheless, the PACT Act is directed towards the prevention and criminalization of acts of animal cruelty that underlie the creation of animal 'crush videos,' rather than acts of animal cruelty more generally and thus lacks relevance to the issue of zoonotic disease transmission.
Given the federal legislative void, 133 all fifty states have enacted wide-ranging animal welfare legislation. 134 In some states, provisions have been enacted specifically to protect farmed animals, or livestock. 135 The prohibitions and the extent to which they protect farmed animals vary between states. To convey the way most intensively farmed animals in the United States are regulated, we provide an overview of animal welfare laws relevant to farmed animals in the five states with the highest number of large CAFOs. As noted above, an animal feeding operation is one where animals are confined in a place that lacks crops or other vegetation and fed for at least forty-five days within a twelve-month timeframe. 136 A large CAFO is defined by reference to the number of animals it confines. For example, a facility that confines cattle (other than mature dairy cows or veal calves) is large if it holds 1,000 or more cows. 137 Pursuant to this approach, we look at the relevant legislation and cases in Iowa, Nebraska, Minnesota, North Carolina and California. 138 Iowa has by far the largest number of CAFOs in the US, with 3,896 CAFOs in operation. 139 Nebraska is the second largest state for CAFOs, with 1,743 CAFO facilities. 140 Following Nebraska, and in order of size are Minnesota (1,464 CAFOs), North Carolina (1,222 CAFOs) and California (1,083 CAFOs). 141

a. Iowa
Iowa's general animal welfare legislation is found in Chapter 717B of the Iowa Code. 142 However, livestock are expressly excluded from these protections. 143 Further, under 717B.3A, where a person acts pursuant to laws that allow the conduct, they are not guilty of animal torture even if the act would seemingly fulfil the definition of intentionally or knowingly inflicting on an animal severe and prolonged or repeated physical pain that causes the animal's serious injury or death. In operation, this provision would seem to exempt common animal husbandry practices. 144 In Iowa, separate protections for farmed animals are in Chapter 717 of the Iowa Code. 145 These protections are less than those provided for other animals under Chapter 717B. 146 Chapter 717 creates an offence of livestock abuse, which occurs where a "person intentionally injures or destroys livestock owned by another person," subject to specified exceptions. 147 Similarly, it creates an offence of neglecting farmed animals, which occurs where "[a] person … impounds or confines livestock" and fails to provide the farmed animals with care or sustenance, or "[i]njures or destroys livestock by any means which causes pain or suffering in a manner inconsistent with customary animal husbandry practices." 148 The legislation empowers a law enforcement officer to rescue neglected farmed animals in specified circumstances where a search warrant for that purpose has been obtained, where entry onto the premises is compliant with federal and state laws, or where a veterinarian has stated that the farmed animal is neglected. 149 It also requires that farmed animals be provided with sustenance pursuant to court order. 150 Also relevant to the treatment of farmed animals is Chapter 717A of the Iowa Code, entitled "Offenses Relating to Agricultural Production." 151 This Chapter criminalizes various actions in relation to agricultural production facilities. These offences include: destroying an animal facility's property or injuring or killing an animal confined at such a facility; exercising control over an animal facility or an animal confined at the facility with the purpose of divesting the facility of an animal or property; and entering an animal facility where the person knows it is not open to the public and has a specified intent. 152 It also creates an offence of agricultural production facility fraud, made out where a person attains access to an agricultural production facility by deception. 153 Similarly, agricultural production facility trespass is made out where a person uses deception to gain access to an agricultural production facility and has a specified intent. 154 The legislation also creates an offence of use of pathogens to threaten animals confined in an agricultural production facility. 155 While these offences are not aimed at ensuring animal welfare, their operation will impact the manner in which animals are kept in CAFOs, and thus the extent to which such organizations constitute a risk from the perspective of zoonotic disease transmission.

b. Nebraska
Like in Ohio, in Nebraska farmed animals are excluded from the protections set out in the state's anti-cruelty to animals legislation. 156 In 2010, the legislature in Nebraska enacted a specialized code for the welfare of farmed animals. The Livestock Animal Welfare Act 2010 criminalizes intentional, knowing or reckless abandonment, cruel neglect, or cruel mistreatment of farmed animals as well as "indecency with a livestock animal." 157 In this respect, livestock is defined as including cows, horses, pigs, sheep, goats, elk, deer, flightless birds, llamas and chickens. 158 Where law enforcement officers have reason to believe that a farmed animal offence is occurring, they are able to seek a warrant to inspect private property. 159 While these prohibitions are a positive step for the protection of farmed animals in Nebraska, they are significantly limited by the exclusion of "[c]ommonly accepted animal welfare practices" (which include "animal husbandry practices common to the livestock animal industry"), "[c]ommonly followed practices occurring in conjunction with the slaughter of animals," "commonly accepted animal training practices," and "[c]ommonly accepted practices occurring in conjunction with sanctioned rodeos, animal racing, and pulling contests." 160 Essentially, these exclusions mean that where a practice is common in industry, it is acceptable, even if it constitutes abandonment, neglect or mistreatment. For example, keeping cows in feedlots (large outdoor pens on a soil surface) would be deemed acceptable despite associated welfare issues including potential heat stress. In Minnesota, farmed animals are included within the scope of the general anti-cruelty legislation. Under the Prevention of Cruelty to Animals legislation, "animal" is defined as "every living creature except members of the human race." 162 The statute creates offences including: • torturing, treating cruelly, or neglecting animals that are unfit for labor; 163 • depriving any animal of necessary food, water or shelter; 164 • confining animals without providing exercise and change of air; 165 • feeding cows with food that produces "impure or unwholesome milk"; 166 • abandoning any animal; 167 • instigating or furthering cruelty to animals. 168 Minnesota's anti-cruelty legislation does not exclude farmed animals from these protections. However, the penalty for cruelty to an animal is significantly lower if the animal is not a pet or companion animal. 169 The legislation also contains several other prohibitions of relevance to farmed animals. These include a prohibition on docking horses, 170 poisoning animals, 171 injuring birds 172 and bestiality, 173 as well as provisions enabling care for animals that are not properly sheltered from the weather, fed or watered. 174 Of significance in the context of a discussion regarding zoonotic disease, § 343.28 makes it an offence for a person in charge of an animal that knows that the animal has, or has been exposed to, an infectious disease, to sell the animal or allow it to run at large or come into contact with another animal or another person without that person's informed consent. 175

d. North Carolina
Legal protections for farmed animals in North Carolina are in the general anti-cruelty legislation. Pursuant to the Consolidated Cruelty Laws, the word "animal" refers to "every living vertebrate in the classes of Amphibia, Reptilia, Aves, and Mammalia except human beings." 176 Nevertheless, while farmed animals clearly fall within this definition, the section expressly does not relate to "lawful activities conducted for purposes of… production of livestock, [or] poultry" or lawful activities conducted with the aim of supplying food for humans or animals. 177 Thus, the protections contained in the anti-cruelty legislation will not prohibit activities in relation to farmed animals that would otherwise fall within the boundaries of the law, even if they constitute cruelty. These provisions are somewhat bizarre as the law does not define what constitutes lawful activities, and thus it is "impossible to understand whether the statute exempts everything or nothing." 178 Nevertheless, the provisions seem to be directed at exempting common farm animal husbandry practices from cruelty prohibitions. 179 In terms of the substantive prohibitions, Article 47 of the legislation prohibits cruelty to animals, including intentionally injuring, depriving of necessary sustenance, torturing or mutilating an animal, causing or permitting an animal to experience unjustifiable pain, suffering or death, or abandoning an animal. 180 Article 49 provides protections for "livestock running at large," and prohibits the intentional driving of farmed animals from their range, or killing or injuring such farmed animals. 181 e. California The general laws criminalizing cruelty to animals in California are contained in California Penal Code § 597. In this legislation, the term "animal" is defined as "every dumb creature." 182 Clearly, therefore, the provisions extend to farmed animals. 183 The legislation criminalizes various acts in relation to animals, including maliciously and intentionally maiming, mutilating, torturing or wounding an animal; 184 maliciously and intentionally killing an animal; 185 depriving an animal of food, water or shelter; 186 or subjecting an animal to unnecessary suffering. 187 However, these protections do not "interfere with the right to kill all animals used for food."188 While there is not an explicit exemption for common farming practices in California, the prohibition against causing suffering only applies to that which is "unnecessary." 189 In practice, what constitutes "unnecessary" suffering is open to an interpretation that privileges human interests. 190 California also has in place specific laws to protect some farmed animals. Chapter 13.8 of the Californian Health and Safety Code sets out prohibitions on specific actions in relation to these animals. In this respect, the legislation defines a "covered animal" as "any calf raised for veal, breeding pig, or egg-laying hen who is kept on a farm." 191 It sets out prohibitions on: confining covered animals in a "cruel manner" and knowingly selling the meat of a covered animal that was confined in a cruel manner. 192

f. Conclusion Regarding Animal Welfare Protections for Intensively Farmed Animals
There is minimal protection or regulation in place at the federal level for intensively farmed animals. State anti-cruelty to animals statutes therefore provide the primary protections to farmed animals. Regulation of the animal agriculture industry by animal welfare statutes is problematic because these statutes are generally criminal in nature, which means that the prosecution of animal cruelty offences is subject to the higher legal burden of proof, being beyond reasonable 183 AWI, LEGAL PROTECTIONS, supra note 144, at 2. 184 CAL. PENAL CODE § 597(a) (West 2020). 185  doubt. 193 While there is significant variance between states, animal cruelty provisions typically operate to privilege companion animals above farmed animals because of the different ways in which humans use them. For instance, in Iowa, Nebraska, and North Carolina, anticruelty legislation explicitly excludes practices involving farmed animals that would be unlawful if perpetuated against companion animals. In Minnesota, inflicting cruelty upon an animal will likely result in a more severe penalty if that animal is a pet. Finally, in California, the prohibitions against killing an animal or causing them unnecessary suffering are explicitly prevented from impacting the slaughter of animals for food. Inconsistencies such as these demonstrate the way in which anti-cruelty legislation perpetuates unequal treatment of animals before the law depending on the human benefit to be gained from their use. 194 In the context of zoonotic disease, these inequalities in protection contribute to creating the conditions that are conducive to disease transmission.
Further, many of these statutes appear to be subject to influence from industry, in that 'commonly accepted industry practices' are often exempted and are ultimately determined by industry itself. 195 As discussed above, industry practices are exempted from animal welfare legislation in Iowa, Nebraska and North Carolina. Beyond the analysis above, similar provisions can also be found in statutes in thirty-four other U.S. states. 196 The ultimate consequence of these provisions is that the industry itself can determine what does and does not constitute cruelty to farmed animals. 197 If a farmer wishes to, for example, cut off pigs' tails without anesthesia, the farmer can do so if they are able to demonstrate that such a practice is common in industry. In other words, "[t]here is no legal limit to institutionalized cruel practices to farmed animals who live in states with customary farming exemptions." 198 By permitting what would be cruel practices in relation to other animals to be undertaken in relation to farmed animals, these provisions exacerbate the risk of zoonotic disease emergence in intensive animal farming settings.
Where anti-cruelty provisions do apply to farmed animals, enforcement of the laws is lacking. 199 For example, in Minnesota, where farmed animals are not exempt from the general welfare provisions, there are several instances involving one producer-Butterfield Foods-that have gone without prosecution. In February 2020, over 9,000 chickens were discovered frozen in trailers outside a Butterfield facility. The incident was not prosecuted due to "insufficient information and evidence to pursue criminal charges." 200 The Animal Welfare Institute details a similar instance in August 2020, in which over 9,000 birds died from heat exposure after being left in trailers outside the holding shed. 201 Butterfield Foods was also not prosecuted for this incident. 202 Thus, the lack of enforcement of minimum standards of welfare may remove any disincentive provided by animal welfare protections to treat farmed animals cruelly, which in turn may heighten the risk of zoonoses.

Federal and State Public Health Laws Regulating Intensive
Animal Agriculture Regulation of intensive animal agriculture in the context of zoonoses is primarily targeted at controlling disease rather than preventing emergence. At a federal level, for example, there are laws to protect consumers by ensuring the safe production of meat products. The Federal Meat Inspection Act 203 operates to prevent the sale of meat 199  products that are adulterated or misbranded. 204 To ensure meat offered for consumption is unadulterated, slaughterhouses and other animal processing plants must have federal inspectors present. 205 Animals that show signs of disease must be slaughtered separately and examined after slaughter. 206 The Food and Safety Inspection Service (FSIS) -an agency of the USDA -is responsible for these inspections. 207 FSIS regulations require non-ambulatory (or 'downed) animals to be separated from the other animals and inspected for disease after slaughter, as an inability to stand or walk is an indicator of disease. 208 The animals may, however, be electrically prodded or forced to walk to their slaughter through other means. 209 This applies to all animals except cattle, as they are the only animals that cannot be slaughtered if non-ambulatory at any point in the slaughter process. 210 Cattle must be removed from the slaughter process and promptly euthanized, whereas other species may be held for slaughter. The holding of non-ambulatory animals for slaughter may incentivize efforts to make the animals rise and walk, to allow for their slaughter and to minimize economic loss. 211 The regulation of the slaughter of downed animals is indicative of the conflict between animal welfare and human benefit. For example, downed animals clearly have an interest in avoiding prolonged suffering, which in the circumstances may best be achieved by immediate euthanasia. In contrast, euthanizing an animal causes a loss of profit and thus a reduction in human benefit. Federal laws allow for the slaughter of non-ambulatory animals (except cattle). However, downed animals pose an increased risk of disease-in part because their non-ambulatory state may be an indicator of disease, and because a downed animal has more contact with the ground and thus increased chance for contamination. 212 Allowing downed animals to enter the food supply therefore poses an increased risk to human health. Accordingly, while the slaughter of non-ambulatory animals may provide economic benefit to human beings in the first instance, it also poses an increased risk of future zoonoses. surveillance." 217 Accordingly, the framework aims to create a system for early identification, "to potentially prevent or limit the next zoonotic disease outbreak, or the next global pandemic." 218 Disease surveillance in states with a high animal agricultural output is also a primary element of zoonosis regulation in the United States. In Iowa, the Center for Acute Disease Epidemiology (CADE) collaborates with the CDC and engages in investigation and education activities. 219 CADE also consults with agencies at the county and local level to provide education and guidance on infectious diseases. 220 Nebraska's Animal and Plant Health Protection also engages in surveillance and inspection efforts to address the risk of zoonoses in agriculture. 221  local programs contributing to the surveillance of zoonoses in the United States. States hold the primary role as it relates to the detection and reporting of zoonotic diseases because the federal government does not have the power to mandate disease reporting. 226 Consequently, federal agencies rely largely on voluntary reporting of disease outbreaks. 227 As explained by Allen, this can hinder surveillance efforts and response time due to a lack of coordination amongst agencies. 228

b. Depopulation and Disposal
A further element of the United States' regulatory response to zoonotic disease is depopulation, which is the mass killing of animals to prevent the spread of disease. Depopulation occurs where a disease has been introduced to an animal population. 229 Federally, APHIS has delegated authority to take remedial actions such as holding, seizing, or destroying any animal that is or may be moved in interstate commerce, and may carry or may have been exposed to disease. 230 APHIS describes depopulation as "one of the most effective ways to stop disease spread and protect U.S. animal health as a whole" and, accordingly, it is an important component of the U.S. regulatory space. 231 There is a number of different methods for depopulation. The American Veterinary Medical Association (AMVA) provides guidelines for producers undertaking mass depopulation. The guidelines provide methods that are "acceptable" or "acceptable with conditions," as well as methods that are "unacceptable." 232 Unacceptable methods are those deemed inhumane or that pose an increased risk of disease spread. However, the guidelines acknowledge that "there will be lessthan-perfect situations" where unacceptable methods may be used. 233 There are also various methods of disposal once depopulation is complete, such as off-site incineration, on-site burial, below grade conventional burial, composting, and open burning. APHIS's Foreign Animal Disease Preparedness and Response Plan lists on-site burial as the least suitable method in relation to public health risk, biosecurity, and pathogen inactivation. 234 Despite these risks, on-site burial is still permitted as a method of disposal. 235 Producers depopulating and disposing of animals must also comply with state regulations, and states have broad discretion to control animal disease. 236 In Iowa, for instance, the Department of Agriculture and Land Stewardship has the power to "quarantine or destroy any animal exposed to or afflicted with an infectious or contagious disease." 237 In respect to disposal, on-site burial is considered an effective method in Iowa, however, the site must first be approved by the Iowa Department of Natural Resources. 238 On-site burial is accepted as an appropriate method in Nebraska, with the Nebraska Department of Environment and Energy stating that burial "is often the method of choice for catastrophic livestock losses." 239 A state permit is not required to undertake on-site burial in Nebraska. 240 In Minnesota, the Board of Animal Health, which is the primary body regulating disposal, notes that on-site burial "is usually not recommended for animals that have died from a disease" but may sometimes be "the only 233 Id. at 9. 234 U.S. DEP'T AGRIC. ET  option during disaster events." 241 Similarly, in California, on-site burial is considered the "least desirable and environmentally safe alternative" but remains a viable option. 242 In North Carolina, the State Veterinarian's Office-an agency of the North Carolina Department of Agriculture and Consumer Services (NCDA&CS)-holds regulatory authority in respect of disposal. 243 On-site burial remains a disposal option in North Carolina, however, sites are required to be pre-approved by the NCDA&CS. 244

c. Environmental Protection Agency
The EPA also has some authority regarding the zoonotic disease risk of intensive animal agriculture, due to the large amounts of animal waste produced. Animal waste from intensive operations can enter water bodies from various sources, including improper storage, overflow of waste lagoons following heavy rainfall, or over application of manure to land. 245 Animal waste discharges can have significant environmental effects and are a primary cause of ocean dead zones. 246 They also pose a significant risk in terms of zoonotic disease emergence as animal waste may contain pathogens that cause disease in humans. 247 The EPA is tasked with administering the Clean Water Act (CWA), which regulates the discharge of pollutants into waters of the United States. 248 The CWA created the National Pollutant Discharge Elimination System (NPDES), a federal permit system designed to regulate discharges into water from point sources. Amongst other conditions, the permit sets an effluent limit on discharge pollutants and restricts a point source from discharging in excess of that limit. 249 The NPDES program does not consider animal feeding operations (those operations not meeting the threshold of a CAFO) to be point sources, therefore excluding them from federal regulation under the CWA. 250 The CWA does, however, include CAFOs "from which pollutants are or may be discharged" in the definition of point source. 251 Therefore, in order to be considered a "point source," large and medium CAFOs (over 1,000 animal units and between 301 and 1,000 animal units respectively) must have the potential to discharge pollutants. Large CAFOs with pollutant potential are automatically regulated as point sources and must seek a NPDES permit for actual discharges, however, a medium CAFO must only obtain a NPDES permit if discharges occur through a man-made device, or if the confined animals come into direct contact with water. 252 The EPA can also designate small or medium size animal feeding operations as CAFOs and require them to obtain a NPDES permit if that operation is a significant contributor of pollutants to water. 253 Regulation of CAFOs under the CWA is further limited by a broad exemption for agricultural stormwater discharges. Stormwater runoff is excluded from the definition of "point source" and therefore any agricultural stormwater discharges from CAFOs are not subject to NPDES permit requirements. 254 Specifically, the EPA cannot require NPDES permits for runoff from land that manure has been applied to (known as the land application area), if that runoff is precipitation related and if the manure has been applied in accordance with nutrient management practices. 255 The scope of the agricultural stormwater exemption was essentially limited to those discharges; 256 however, as Anthony Schutz explains, "[a]bsent a direct addition of pollutants on a dry day, rainfall always has something to do with a discharge from land-application areas" 257 and thus the exemption is potentially far reaching. More recently, the exemption has been expanded by the District Court for the Northern District of West Virginia in Alt v. EPA 258 to include discharges outside the land application area. 259 The court in Alt v. EPA considered whether pollutants such as manure and dander that were expelled from exhaust fans in poultry barns and carried to water when it rained were included in the agricultural stormwater exemption. In this case, the court found that the discharges were eligible for the exemption, and were therefore not discharges as the pollutants would remain in the farmyard but-for the addition of rain. 260 As Emily Kenyon explains, "[b]y expanding the scope of the agricultural stormwater exemption, this decision allows CAFOs to evade permitting requirements and pollute our waterways." 261 This substantially limits the regulation of pathogens discharged from CAFOs into waters, which is a key risk in the context of zoonotic disease.

d. Deficiencies in the Current Regulatory Space
The U.S. approach to zoonotic disease regulation is reactionary and fails to address the root cause of emergence. This is clear considering the legal anthropocentrism that informs the regulation of intensive animal agriculture. Current federal and state regulation efforts prioritize short-term human interests over the welfare interests of non-The Tipping Point Source: Clean Water Act Regulation of Discharges to Surface Water via Groundwater, and Specific Implications For Nonpoint Source Agriculture, 23 DRAKE J. AGRIC. L. 439 (2018). 255 40 C.F.R. § 122.23(e) (2021). CAFOs subject to NPDES permits must implement a Nutrient Management Plan to be eligible for the storm water exemption. CAFOs that do not have NPDES permits do not require this plan, however, the application of manure to land must be done "in accordance with site-specific nutrient management practices." Id. human animals which-while satisfying economic motives-fails to adequately manage the zoonotic disease risk posed by intensive animal agriculture. Animal health is a primary consideration in the context of zoonoses, as animals with lower levels of overall welfare may be more susceptible to disease. Federal and state animal welfare laws are therefore a key aspect of the regulatory space and are also the aspect most aligned with addressing the root cause of zoonotic disease emergence. As has been outlined, federal regulation in this respect is minimal and state regulation is largely inadequate due to the broad exemptions for common farming practices and discriminatory levels of protection for farmed as opposed to other animals. In states such as California and Minnesota where anti-cruelty regulations do apply to farmed animals, the provisions operate in a manner that privileges intensive farming practices, and they lack meaningful enforcement. Inadequate enforcement fails to address instances of systemic cruelty within intensive farming operations and may in practice perpetuate conditions that increase the animals' susceptibility to disease.
The deficiencies in animal welfare regulation impact its ability address the root cause of zoonoses. As such, reactionary measures designed to control the emergence of zoonotic disease constitute a significant proportion of the U.S. regulatory response. While public health measures such as surveillance, depopulation, and restrictions on pollutant discharge are not aimed at prevention, they do form a vital part of limiting the impact of future zoonoses. However, as has been outlined, these measures are largely inadequate. In terms of surveillance, there is a recognized gap in the surveillance of human and animal diseases, and inadequate resources to rapidly detect and categorize emerging diseases at the federal level, which may significantly hinder response times. An adequate national response may be further hindered by the reliance on voluntary reporting from states to the CDC.
The process of depopulation and disposal is also flawed due to the continued use of disposal methods that are considered less desirable in the context of zoonotic disease. On-site burial remains an acceptable option in all of the states analyzed above, despite recognized disadvantages such as a risk to public health and biosecurity, and the potential survival of pathogens after burial. 262 In an outbreak, mass burial allows producers to cost-effectively dispose of animal carcasses at a speed closer to the depopulation rate, which reduces the number of infected animal carcasses awaiting disposal. 263 While this is a clear advantage, the need to utilize a disposal method that poses a public health risk due solely to the significant numbers of animals being depopulated demonstrates that CAFOs pose an inherent and unacceptable risk in the context of zoonotic disease.
Finally, the EPA's contribution to zoonotic disease regulation via the CWA is also insufficient. In terms of large CAFOs, the CWA only considers such operations to be point sources where they have discharge potential. As explained above, the agricultural stormwater exemption significantly limits this requirement. Large CAFOs that only have precipitation related discharges may therefore demonstrate no discharge potential and be able to operate without a NPDES permit and thus largely without federal regulation as to water pollution. The decision in Alt v. EPA 264 -while only binding the EPA in the Northern District of West Virginia-is also a worrying development in terms of zoonotic disease risk. The decision exempts discharges of manure and feathers from ventilation systems that are carried to U.S. waters by precipitation from permitting requirements, effectively eliminating federal oversight of such discharges. 265 In sum, the current regulatory regime fails to adequately address the zoonotic disease risk posed by intensive animal agriculture. Existing efforts are representative of legal anthropocentrism, in that they prioritize short-term human benefit over animal welfare. As a result, reactionary measures are favored over those designed to address the root cause of zoonoses, and such measures are themselves largely inadequate. Moreover, not only is current regulation insufficient in the context of zoonotic disease, government policy also actively encourages intensive farming practices through subsidies; government policies; and, in some jurisdictions, laws that favor the largest corporations. 266 Zoonotic diseases demonstrate that human health and animal health are interconnected. A regulatory regime that prioritizes short-term human health and human benefit fails to acknowledge human dependency on animal health, and therefore fails to adequately address the risk of zoonotic disease. This paper argues for a radical change to the current anthropocentric paradigm that underpins regulation of intensive animal agriculture. It calls for a focus on regulatory efforts that recognize the interconnectedness and interdependency of humans and animals. The following section analyzes the two dominant alternative paradigms and their potential impact on the zoonotic disease risk posed by intensive animal agriculture.

IV.
PREVENTION One Health is centered on the connection between humans, animals, and the environment they share. 267 It acknowledges that the nature of zoonotic disease requires collaboration between sectors and advocates for a holistic approach at the human-animal-environment interface. 268 There is no single definition for One Health; however, the CDC defines the approach as "collaborative, multisectoral, and transdisciplinary," stating that it works "at the local, regional, national, and global levels-with the goal of achieving optimal health outcomes recognizing the interconnection between people, plants, and their shared environment." 269 Clearly, at the heart of a One Health approach is cooperation between sectors focused on human health, animal health, and environmental health, with a goal of fully integrating research, disease surveillance and forecasting.
One Health was adopted by the American Veterinary Medical Association (AVMA) and the American Medical Association (AMA) in 2007. 270 Together, they formed the One Health Initiative task force that studied and delivered recommendations designed to facilitate integration of the One Health concept across multiple professions. The task force published a report in 2008 recognizing that "[o]ur increasing interdependence with animals and their products may well be the single most critical risk factor to our health and well-being with regard to infectious diseases." 271 The report made a series of recommendations, calling for collaboration between different sectors to complement the leadership role taken by the AMVA and the AMA. 272 In fulfilment of one such recommendation, the One Health Commission was founded in 2009 and continues today as a non-profit organization working towards "[a] world in which the interconnectedness of animals, environment, plants and people is deeply, and systemically recognized, valued and acted upon." 273 Outside of the United States, One Health has gained immense global support for its potential to alter the human-animal relationship and mitigate the risk of zoonotic disease outbreaks. For instance, the United Nations describes One Health as "the optimal method for preventing as well as responding to zoonotic disease outbreaks and pandemics." 274 The World Health Organization, The Food and Agriculture Organization, and the World Organization for Animal Health have worked in collaboration since endorsing the 'One World -One Health Framework' in 2018. 275 The organizations released their second tripartite strategic document in 2017 that declares a focus on the "strengthening and modernization of early warning and surveillance/monitoring systems" and "the foresight, preparedness and response to emerging, re-emerging and neglected infectious diseases," amongst other key areas. 276 Practically, the approach can be seen in efforts to address antibiotic resistance in the US-particularly in the National Action Plan for Combating Antibiotic-Resistant Bacteria (CARB). 277 As detailed above, antibiotic resistance poses a severe risk in the context of zoonoses in terms of increasing farmed animals' susceptibility to disease and simultaneously reducing the effectiveness of medically important antibiotics for human use. 278 The CARB plan, developed by the Federal Task Force on CARB, details a range of objectives to be achieved between the period of 2020-2025 to prolong the effectiveness of antibiotics. 279 The CARB plan has five goals, identical to those set in the first CARB plan which ran from 2015-2020. 280  The CARB plan also explicitly adopts a One Health approach and emphasizes that "[a]ntibiotic resistance is unquestionably a One Health Issue, impacting the health of humans, animals, plants, and the environment." 282 More than merely paying lip service to the One Health concept, the Task Force itself is comprised of representatives from various agencies focused on human, animal, and environmental health, including the Department of Health and Human Services, the USDA, the Department of Defense, the Department of the Interior, and the EPA (amongst others). 283 As Margaret Foster Riley identifies, the CARB plan also features a focus on antibiotic resistance in the environment-an element that has previously seen little attention. 284

Limitations
While presenting as a promising mechanism to guide the necessary changes at the human-animal-environment interface, One Health faces various challenges that have hindered its ability to have a significant, practical impact. Firstly, the concept is often defined differently by various organizations depending on their particular focus (be it human, animal, or environmental health). 285 There is generally a shared foundation to the differing definitions; however, the lack of a single definition or approach allows room for interpretations that favor a particular portion of the human-animal-environment interfacemost typically in favor of human health. 286 In part, this can be attributed to the difficulty in establishing a shared definition of health for humans, animals, and the environment. 287 This is especially pertinent given that human, animal, and environmental health may at times be in conflict. 288 For example, as discussed above, a primary element of the U.S. regulatory response to zoonotic disease is depopulation. In a disease outbreak, depopulated animals can include those infected with the disease, as well as those that had contact with diseased animals, and those in high-risk areas such as surrounding facilities. 289 Accordingly, animals not infected with a disease may be depopulated. This carries clear benefits in terms of protecting public health, especially given the impracticality of other disease containment methods for large populations of animals. 290 However, depopulation of animals in such circumstances carries little benefit for animal health. In conflict situations such as this, the ambiguity of One Health may facilitate an approach that does not equally value all elements of the human-animal-environment interface.
Secondly, political-economic factors hinder efforts to operationalize One Health at the structural level required. In a STEPS Working Paper, Galez et al. explore why implementation of One Health has been wanting despite receiving significant rhetorical support. 291 Through a series of interviews with stakeholders, all with an active professional involvement in One Health, Galez et al. found that funding flows and political interest were largely confined to a global "outbreak" narrative. 292 This narrative focuses on zoonotic disease at the transmission level, with implementation efforts directed towards disease surveillance and pharmaceutical solutions. 293 As one interviewee explained in reference to the avian influenza outbreak in the early 2000s, "[avian influenza] allowed us to focus on something that was a tangible threat and source significant amounts of money from contingency funds. Talking about generic threats at the human-animal interface-zoonoses-is less arresting and makes it harder to draw funds down." 294 In effect, efforts directed at addressing the drivers of zoonotic disease, such as intensive animal agriculture, are not incentivized and, as Galez et al. identify, face additional challenges in terms of "confronting powerful interests and entrenched political-economic relations." 295 This limitation is connected to the previously mentioned inequality between the different spheres of the One Health concept. If political impetus is directed largely at the point of transmission, One Health efforts may emphasize the human health sphere. The animal and environment spheres may therefore receive only secondary attention in service of human health as the primary beneficiary. Such an approach would likely impede the ability of One Health to bring about the paradigm shift necessary to address the risk of zoonotic disease.
In sum, the ambiguity of One Health, the "outbreak" focus, and the prioritization of human health likely renders the One Health approach inadequate in its current form to mitigate the zoonotic disease risk posed by intensive animal agriculture.

B. Wild Law
Like One Health, Wild Law, also known as Earth Jurisprudence, recognizes the interdependence of humans, animals, and the environment. However, Wild Law goes further by proposing an alternative legal framework that situates humans within the broader limits of the Earth. As touched on above, U.S. laws are inherently anthropocentric because they operate in favor of humans and treat all other beings as secondary. Wild Law proposes a framework that is designed to dismantle this legal anthropocentrism. Advocates for Wild Law describe the current legal system as human-centric, and human relationships with animals and the environment as separate, hierarchical, and subservient to human needs. 296 Cormac Cullinan, a pioneer of Wild Law, identifies the current system as one that "reserves all rights and privileges to use and enjoy Earth to humans and reduces all other aspects and creatures of the Earth status of objects for the use of humans." 297 It is this framework that produces concepts of dominion and structures an economic relationship between humans and the Earth. 298 The notion that Earth and its non-human inhabitants are resources to be exploited by humans has developed a worldview whereby humans are not considered part of the reciprocal relationship between Earth and its inhabitants. 299 In the context of zoonotic disease, this framework facilitates intensive animal agriculture, which operates irrespective of the limits of the Earth. 300 Wild Law challenges this legal anthropocentrism and points to the segregation of human and Earth as the cause behind the current ecological threats faced by humanity. 301 In the view of Wild Law, current threats cannot be addressed within the existing legal framework because the threats are themselves symptoms of that framework. As Cullinan explains, "our legal and political establishments perpetuate, protect, and legitimize the continued degradation of the Earth by design, not by accident." 302 Therefore, Wild Law calls for a radical alteration of current concepts of legality and governance. In this respect, in Wild Law, legality is seen as central to social change. 303 For example, Cullinan outlines that "[i]n order for any fundamental change in how a society perceives itself to be translated into any actual change in how it functions, it is necessary first to change that society's idea of law." 304 Wild Law is therefore predicated on the idea that the necessary societal changes cannot be realized "unless we simultaneously entirely reconceptualise the jurisprudence of the dominant culture." 305 In this respect, the alternative legal framework proposed by Wild Law recognizes human dependency on the Earth system and the reciprocal nature of this relationship. 306 A fundamental principle of Wild Law is that all members of the Earth community are rights holders. 307 This is a clear divergence from the existing property regime in the US, in which humans are positioned as subjects and all other elements of nature as objects. 308 Thomas Berry, who articulated the foundation of Wild Law, defined these rights in stating that "[e]very component of the Earth community, both living and non-living has three rights: the right to be, the right to a habitat or place to be, and the right to fulfil its role in the ever-renewing process of the Earth Community." 309 The rights held by each member of the Earth community are limited only by the rights of other members "to the extent necessary to maintain the integrity, balance and health of the communities within which it exists." 310 Berry explained that these rights "originate where existence originates." 311 That is, under Wild Law, laws are derived from the universe as opposed to human legal systems. 312 This means that human laws that do not align with the laws of the universe are invalid, as they operate outside of the limits of the Earth.
It is helpful at this point to define key terms employed in Wild Law. Firstly, "Earth community" refers to the land and all its inhabitants, capturing all organisms. As Peter Burdon explains, "[a]ll organisms are subjects-they have interiors and life worlds." 313 References to the "Earth" and the "universe" take their literal definitions. That is, the "Earth" is the planet humans share with the Earth community, and "universe" can be understood as the broader cosmos. 314 Considering laws as being derived from the universe means they are found and interpreted by humans, as opposed to being made. 315 This may be seen as reminiscent of natural law, 316 in which a universal higher law "is discoverable by humans through a process of reason." 317 While natural law is, in general, inherently anthropocentric given its primary concern with humans, 318 Burdon claims that "Earth Jurisprudence can correctly be described as a theory of natural law." 319 Wild Law also draws clear guidance from many indigenous perspectives that hold ecological integrity at the heart of governance. 320 Fundamentally, Wild Law is an eco-centric framework concerned with positioning humans within the context of the Earth. It involves an acknowledgement that laws are derived from the universe and thus human laws must be consistent with the limits of nature and be aligned with the health of Earth and its inhabitants.
Implementing Wild Law would require a fundamental and radical change to the current legal system. An example of how this change might look in the U.S. can be found in the Klamath River. The Native American Yurok Tribe has a deep connection with the Klamath River, which flows through Oregon and California. 321 The relationship between the Yurok Tribe and the Klamath River has existed since time immemorial. 322 The Yurok Tribe's culture, economies, and religion are connected to the Klamath River, and they rely on salmon from the river as a source of food. 323 As Beth Rose Middleton Manning and Kaitlin Reed explain, "[w]ithin Yurok epistemology, the natural world is composed of living beings; the river, the trees, and the salmon are intimately connected to Yurok culture-they are relatives." 324 The health of the river, and thus the health of the salmon, is of considerable importance to the Yurok Tribe. However, there have been several adverse impacts to the health of the river and the Yurok Tribe's way of life. In a 2011 report on the Yurok and the Klamath River for the Department of the Interior, Dr. Kathleen Sloan explains that many of these impacts result from "management decisions regarding commercial fisheries, the establishment and abolition of canneries, and the construction of a series of dams in the upper basin." 325 The impact of runoff from agricultural fertilizers and pesticides has also contributed to the ill health of the river. 326 In response to the Klamath River's declining health, the Yurok Tribal Council passed a resolution on May 9, 2019, declaring that the river has rights of personhood. 327 The resolution confirms that the Klamath River has the right "to exist, flourish, and naturally evolve; to have a clean and healthy environment free from pollutants; to have a stable climate free from human-caused climate change impacts; and to be free from contamination by genetically engineered organisms." 328 As Geneva Thompson explains, "[e]ven though the ordinance is newly developed, the principle has existed precontract, and the Yurok Tribe is simply codifying rights the Klamath River has always had." 329 This resolution allows cases to be adjudicated in Yurok Tribal Court on behalf of the Klamath River. 330 That is, cases can be bought against entities that violate the rights of the Klamath River through the infliction of ecological damage. 331 Tribal courts are reflective of the original sovereignty and inherent self-governing power of Native nations. Thompson outlines that, "[s]ince time immemorial, Native nations have had inherent authority to develop, exercise, and enforce civil and criminal regulatory and adjudicatory authority over the individuals throughout their territories." 332 The extent to which this authority applies to the conduct of non-members is limited; however, the decision in Montana v. United States confirmed that Native nations "may also retain inherent power to exercise civil authority over the conduct of non-Indians on fee lands within its reservation when that conduct threatens or has some direct effect on the political integrity, the economic security, or the health or welfare of the tribe." 333 Thus, the rights of the Klamath River operate within these jurisdictional limits. Establishing legal personhood for the river, in recognition of the reciprocal relationship between the Yurok Tribe and the Klamath River, is an example of the operationalization of Wild Law within the US. It represents an eco-centric conceptualization of the law and demonstrates that rights can be applied outside of their current anthropocentric understanding.
In terms of how Wild Law would be applied to intensive animal agriculture, any changes would be informed by the interdependent human-animal-Earth relationship. 334 Firstly, changes to the current system of animal food production would be necessary. Intensive animal agriculture does not operate for the good of the entire Earth system, and fails to acknowledge the interdependence of humans, animals, and the environment. This can be seen in the unacceptable risk of zoonotic disease described in the preceding sections. As explained above, under Wild Law, each member of the Earth community-including animals-has a right to be, a right to habitat, and a right to fulfil its role in the Earth community. 335 These rights are balanced against and limited only by the rights of other members of the Earth community. The exact rights applicable to each member are not defined, nor is the process for determining which rights prevail when balancing those held by each member of the Earth community. However, it appears clear given the impact of intensive animal agriculture on animals and the environment, and the associated impact of zoonotic disease emergence on humans, that intensive animal agriculture would be inconsistent with a Wild Law approach. Thus, as a starting point, changes to the current system of animal agriculture would be necessary.
The extent of the necessary changes can be understood through the principles of Wild Law articulated by Berry. In particular, the following passage provides guidance as to the impact of Wild Law on animal agriculture and the consumption of animals more generally: Planet earth is a single community bound together with interdependent relationships. No living being nourishes itself. Each component of the Earth community is immediately or mediately dependent on every other member of the community for the nourishment and assistance it needs for its own survival. This mutual nourishment, which includes the predator-prey relationship, is integral with the role that each component of the earth has within the comprehensive community of existence. 336 Human consumption of animals is not inherently inconsistent with Wild Law. Berry explicitly endorses a predator-prey relationship as part of Wild Law, which, presumably, applies to humans in the same manner as it applies to non-humans. As Heather McLeod-Kilmurray identifies, not all animal products are produced in exploitative ways, "[m]any societies-such as some indigenous peoples, hunter-gatherers, and fishing groups-have maintained balanced relationships with other species and ecosystems for generations as interdependent communities of life . . . ." 337 Given the guidance indigenous perspectives and lifeways have provided to Wild Law, it appears likely that Wild Law's treatment of animal consumption by humans would follow a similar vein. That is, intensive animal agriculture would be replaced by eco-centric animal consumption guided by the health of the entire Earth system. The rights of animals to be, to habitat, and to fulfil their role in the Earth community would not be limited more than required for humans to exercise their own rights. Similarly, the rights of humans would not be limited any more than is required for animals to exercise their rights. Thus, under Wild Law, animal consumption is permitted to the extent that it is necessary for humans to fulfil their right "to be"; however, consumption over and above the extent of this right would be in violation of the rights of animals. 338 Such a change would correct many of the aforementioned factors that contribute to 336 Id. 337 McLeod-Kilmurray, supra note 266, at 466. 338 Issues surrounding what constitutes "necessary" animal consumption, particularly in the context of culture, would need to be addressed; however, these issues sit outside the scope of this paper.
the zoonotic disease risk posed by intensive animal agriculture. Specifically, eco-centric modes of animal consumption-such as those practiced by indigenous peoples, would likely improve animal welfare, maintain genetic diversity, minimize the need for mass depopulation and disposal, and substantially reduce the discharges of animal waste into waters of the United States. Therefore, Wild Law would likely produce the necessary paradigm shift and provide the necessary framework to reduce the zoonotic disease risk posed by intensive animal agriculture.

Limitations
Wild Law promises to deliver the radical paradigm shift necessary to correct the human-animal-environment relationship. However, the substantive changes demanded by the approach will likely meet significant resistance. The recognition of the rights of nature and nonhuman animals would substantially alter current ways of life for most people. It would impact the ways in which some humans generate income, and their current relationships with the places they live-particularly in regional communities. For example, many people within rural communities view animal agriculture as integral to their security and as a source of generational stability. 339 Place attachmentwhich can be described as the bond between individuals and placeoften exists for farmers and their land. 340 A transition away from anthropocentric relations with animals and the environment may therefore be seen as a loss of stability and an affront to their relationship with their land. Many people also have complex social relationships intertwined with the food they eat and the entertainment they seek, 341 and thus the drastic alterations to human behavior would have far reaching consequences-not just economically, but emotionally. While this may potentially work against Wild Law as a viable alternative framework, fundamentally rebalancing the relationships between humans, animals, and the environment is necessary to address-amongst other global problems-the zoonotic disease risks posed by intensive animal agriculture.
The viability of Wild Law is further challenged by its practical implementation. The need to transition away from the anthropocentric hierarchy that positions humans as subjects and nature as a collection of legal objects underpins Wild Law, and the theory can therefore be understood as a critique of current property law systems. Wild Law proposes granting legal rights to nature in what would be an eco-centric reconceptualization of property in the United States. While, as discussed, this drastic reconceptualization is warranted, Wild Law is challenged by the same logistical vagueness that limits the One Health approach. While there are some instances of nature specific rights in the United States, 342 these are limited and are not as extensive as that envisioned under Wild Law. There is also insufficient detail surrounding the Wild Law alternative to current property systems, particularly in terms of how the rights held by members of the Earth community will be balanced against other members' rights. As was discussed in regard to One Health, a lack of a robust and detailed framework to address this balancing exercise may result in decisions that favor human interests. The limited practical implementation of Wild Law, combined with the need for further development of the scope and meaning of the rights of nature, means that the ability of the framework to respond to the zoonotic disease risk posed by intensive animal agriculture is essentially untested. This represents an obstacle in the implementation of Wild Law that would need to be overcome as the theory advances.
342 Some successful and some unsuccessful. Consider the Klamath river, detailed above, as well as the Lake Erie Bill of Rights (LEBOR), through which the residents of Toledo in Ohio recognized the rights of Lake Erie and its watershed "to exist, flourish, and naturally evolve." TOLEDO, OHIO, MUN. CODE ch. XVII, § 253 (2019). The Lake Erie Bill of Rights also allowed the residents of the city and the city itself to sue corporations and governments on behalf of the lake. The city of Toledo was immediately sued by an agricultural business, and in 2020, LEBOR was invalidated by the federal district court, ruling that "LEBOR is unconstitutionally vague and exceeds the power of municipal government in Ohio," although also noting that through LEBOR, residents pursued a "well-intentioned goal: the protection of Lake Erie." Eric Heisig, Federal Judge Strikes Down Toledo's Lake Erie Bill of Rights as Unconstitutional, Says Sweeping Law is Too Vague, CLEVELAND.COM (Feb. 28, 2020), https://www.cleveland.com/court-justice/2020/02/federaljudge-strikes-down-toledos-lake-erie-bill-of-rights-as-unconstitutional-says-sweeping-law-istoo-vague.html [https://perma.cc/J7CX-CCUM]. Consider also the "Bill of Rights for Sustainability" in Santa Monica, California. The 2013 Bill grants "[n]atural communities and ecosystems . . agriculture would require extensive consideration of who has rights and how those rights are balanced against each other, which is outside the scope of this Article. Nevertheless, this Article proposes that the basic concept of Wild Law, wherein the law recognizes and respects the interdependence of humans, animals, and the environment, be used to reform the laws relating to animal agriculture. In this respect, it is worthwhile noting that there have been some suggestions of a transition to eco-centric regulation in the United States in the recent past. 347

Regulation Informed by a Wild Law Approach
Full implementation of Wild Law would require drastic legal reform, which is unlikely to be politically palatable or desirable. Accordingly, reform should proceed progressively, with the most pressing matters at the forefront. As mentioned, Wild Law requires further development, particularly in relation to how the rights of each member of the Earth system would be balanced against the conflicting interests of other members. However, it does provide a vehicle for analyzing and seeking alternatives to current problems, such as intensive animal agriculture. Utilizing the key concepts of Wild Law-primarily by recognizing the interdependence of humans, animals, and the environment-may allow humans to develop better laws and systems of governance that move away from current anthropocentric modes.
Against this background, this Article suggests that Wild Law be used to inform the regulation of animal agriculture. Because of its pandemic potential, intensive animal agriculture is a pressing concern and should be the first focus for reform. A Wild Law approach would require regulation of animal agriculture that is not anthropocentric. That is, agricultural practices that only benefit human beings in the short-term, to the detriment of animals and the environment, would not be permitted. Wild Law would also require governance of animal agriculture to be guided by the interdependence of humans, animals, and the environment. Thus, regulation informed by Wild Law would need to take a holistic approach-recognizing human health, environmental concerns, and animal welfare as predominant goals.
This Article does not recommend-in the first instance-awarding substantive rights to animals or the environment to give effect to this change. Rather, Wild Law should be used as a legal tool to guide the regulatory changes. For instance, in practice, this could require the nature. As Helena Howe identifies, "[w]hile we can take the lesson offered from indigenous communities we will need actively to forge this connection. Developing the sense of 'oneness' with nature and of belonging to a community of beings needed to support a Wild Law of property will take time and require practical strategic endeavour." 349 Directing efforts at forging a predominant eco-centric perspective would facilitate the progressive implementation of a Wild Law approach and may also reduce the need for legal reform to demand radical changes of human behavior-that is, it may encourage radical changes to human behavior before such changes are imposed by law. Reforms that are informed by Wild Law concepts may be in opposition to current relationships that humans hold with the land. For instance, a Wild Law approach to the governance of animal agriculture may alter what people eat, what they wear, and how they generate income (among others). Devoting attention to building the relationship with nature that Wild Law is predicated on may reduce some resistance to the legal reform called for. It may also encourage and enable consumer action that decreases current reliance on intensive animal agriculture and therefore contribute to combating the risk of zoonotic disease. 350

V. CONCLUSION
The COVID-19 pandemic has demonstrated the devastating impact that zoonoses can have on public health and national economies. Zoonotic disease emergence is connected to the merging of the humananimal interface. In the US, this is best represented by the intensification of animal agriculture, which is recognized by the UN as a key driver of zoonoses. Intensified operations have responded to the mass demand for animal protein in the United States-a demand that could not be met with small-scale agriculture alone. However, several inherent features of these operations pose an unacceptably high risk in the context of zoonotic disease. These include low levels of animal welfare, genetic uniformity, excessive use of antibiotics, reliance on mass depopulation and on disposal methods that are least recommended in terms of pathogen inactivation, and the discharge of animal waste and other related pollutants into U.S. waters. As such,