I'm sorry, but that article makes me so mad. they are still talking about factory-farming, except that the chickens are on the floor. But they are probably in a filthy environment -- with 35,000 chickens, they are breathing "fecal dust" which is basically dried poop that becomes airborne. It is a totally unhealthy enviroment that is sure to cause the hen deaths they refer to. Just having "access to the outdoor" in reality in factory farming may just mean there's a small door on one side of a huge warehouse type building with a small run outside. I'd like to know if all 35,000 chickens can be "outside" at the same time! The premise of the article is ridiculous and the doubts it tries to raise are also ridiculous given that it's still factory farming.
To me, "free-range" implies LOTS of space for each chicken, outside all day long, digging in the dirt, eating green grass, etc.