Concentrated Animal Feeding Operations (CAFOs) are point sources of pollution and require Clean Water Act permits. The 2003 regulations allow Large CAFOs to propose alternative performance standards (APS) that offer equivalent or better environmental performance than the baseline technology. Principal obstacles to APS success include the complexities of demonstrating superior performance, cost uncertainties for obtaining approval, CAFO risks of participation, intra-organizational barriers of permitting agencies, and potential lawsuits brought by environmental groups. Despite obstacles, APS offers potential for technology innovations and reduced environmental compliance costs.