The Proof Is in the Pluming
Factory Farm Biogas Has no Place in the Low Carbon Fuel Standard
New research from Food & Water Watch (FWW) reveals the fatal flaws in California's Low Carbon Fuel Standard (LCFS), a pollution trading program that is incentivizing factory farm expansion in California and beyond. LCFS currently allows participants to sell credits for factory farm biogas, produced from manure and other farm waste in anaerobic digesters. This is on the flawed assumption that factory farm gas eliminates the dairy industry’s greenhouse gas footprint and then some.
Satellite and airborne imaging tell a different story. FWW overlayed methane plume data, collected from NASA and Arizona State University and compiled by Carbon Mapper , with locations of digesters whose factory farm gas earns companies lucrative credits in the LCFS program. What we found is alarming and shows that factory farm gas is no carbon negative fuel. Instead, the lavish credits given to factory farm gas in the LCFS only incentivize more factory farm expansion and more methane production — including more enteric fermentation (cow burps) not at all captured by digesters. These findings should serve as a wakeup call to California regulators as they propose amending the LCFS.
At least 16 dairy operations participating in the LCFS released massive methane plumes into the atmosphere after their digesters were installed.
All but one are located in California. The remaining operation is owned by Threemile Canyon Farms in Boardman, Oregon. These factory farms reportedly house between 5,200 and 39,000 cows each.
California's 15 LCFS digesters with reported methane plumes.
We identified 59 post-installation plumes from these dairy operations recorded between March 2017 and July 2023. Emissions rates (reported for all but 10) range from 44 to 1,729 kilograms of methane per hour (kg CH4/hr).
At these rates, the digesters could be called methane "super-emitters" by Carbon Mapper's definition.
Just a single hour of pluming at these rates releases the carbon dioxide (C02) equivalent of driving a passenger car 1.1 million miles. That's the same as driving around the equator 45 times.
Satellite view of Hilarides Dairy (blue dot) in Tulare County, California with its nine recorded methane plumes (red bursts).
At least twelve of the 16 digesters with recorded plumes were subsidized with public funding, amounting to nearly $27 million from 2017 to 2019.
Anaerobic digesters are prohibitively expensive to install and operate on all but the largest factory farms. Even so, they often depend on public funding, and still experience high failure rates. California Biogas LLC (CalBio) is one of the biggest names in the industry and its projects have devoured more state digester funding than any other entity — over $110 million since 2015.
CalBio earns credits by upgrading and piping gas from 11 of the 16 digesters with post-installation plumes that we identified. Just an hour of pluming at their reported rates releases the C02 equivalent of burning over 30 thousand gallons of gasoline — or driving around the equator 28 times.
Cluster of digester projects associated with CalBio. Blue dots are factory farms; red bursts are methane plumes.
Methane plumes reported in Carbon Mapper come from sporadic monitoring, suggesting that they are just the tip of the iceberg; significantly more methane is likely being released from manure lagoons on these and other operations with anaerobic digesters. Clearly, digesters do not make dairy and other factory farms carbon negative. They do not wipe out emissions from manure handling and do absolutely nothing to mitigate enteric fermentation, which makes up one-quarter of the U.S. livestock industry's methane emissions (compared to manure management's 9 percent).
Instead, by putting a lucrative price on factory farm gas credits, California is incentivizing the expansion of mega-dairies and other factory farms — which will bring more manure waste, more methane emissions, and more misery for local residents who shoulder the pollution burdens. This thwarts California's efforts to fight climate change and address environmental injustice, all while squandering hundreds of millions of public dollars.
California must stop offering credits for factory farm gas in the Low Carbon Fuel Standard, and ban new and expanding factory farms.
Methodology
Food & Water Watch mapped digester projects that participate in California’s Low Carbon Fuel Standard (LCFS) pathways, using data disclosed by the California Air Resources Board . The data were pulled on 4-19-2022 and 11-17-2023. We located digester addresses from the project application packages and used GoogleMaps to geocode them. We then mapped them in ArcGIS Pro.
We overlaid the digester layer with data on livestock methane plumes pulled on 11-17-23 from Carbon Mapper . Carbon Mapper is a collaboration that uses airborne and satellite imaging from NASA and Arizona State University’s Global Airborne Observatory to detect carbon dioxide and methane plumes from point sources. The airborne and satellite imaging generally detects methane plumes with emission rates of at least 10 kilograms per hour (kg CH4/hr) and 250 kg CH4/hr, respectively.
Carbon Mapper identifies the plume sources and their respective industries, and as such, we limited our search to livestock plumes. According to Carbon Mapper, the majority of livestock plumes in the database come from anaerobic lagoons. It does not include plumes originating from enteric fermentation and other non-point sources.
Using ArcGIS’s satellite imagery as our base map, we looked for methane plumes located over dairy operations whose digesters feed into LCFS pathways. Plumes located outside of the operation’s visible boundaries were not included. We also excluded any plumes that occurred before or during the month the digester was installed, as indicated in each LCFS project’s application package.
Plume data may include emissions rates, but do not include the duration or cumulative emissions. As such, we applied the emissions rates to estimate the total emissions occurring over one hour for all plumes with reported rates. We calculated the carbon dioxide equivalency (CO2e) of these emissions using the Environmental Protection Agency’s Greenhouse Gas Equivalencies Calculator .