The California Air Resources Board (CARB) has conducted yet another in a series of academic analyses verifying the climate benefits of dairy digesters and the minimal impacts to neighboring communities. Yet environmental justice (EJ) advocates remain steadfastly opposed to incentivizing farmers to invest in the technology.
While the venue changed last week, many of the arguments remained the same. CARB hosted a workshop in Fresno to present findings from a comprehensive database tracking dairy sizes as the state invested in grants and carbon credits through the Low Carbon Fuel Standard to scale up digester adoption.
Those incentives spurred the development of a new energy industry, as farmers began piping captured methane into the natural gas grid. It also contributed to the expansion of anti-digester community advocacy groups, which have for years refuted scientific findings from CARB and sister agencies as well as U.S. EPA, industry studies and research from air quality experts at the University of California, Davis. The Legislature has also rejected two attempts in the last two sessions to move beyond the voluntary approach to instead enact regulations on methane emissions.
The new California Dairy and Livestock Database (CADD) confirmed many of the previous findings. The state has been losing 5% of its dairies on average every year, with about 1,000 shuttering over the last 20 years, and it is on track to lose 700 more by 2030. The remaining dairies have grown larger over the past decade, aligning with a national trend of industry consolidation, and the overall herd size has continued to shrink as operations grow more efficient.
Refuting long-held EJ claims, CADD demonstrated that no connection exists between the widespread adoption of digesters and the industry’s growth rates. CARB’s board members had directed staff to develop the database in response to the EJ concerns and to hold the industry accountable for its emissions.
Ryan Jacobsen, Fresno County Farm Bureau“Agricultural systems that produce food we rely on can also be pollution sources that impact our air and water,” said CARB Chair Liane Randolph. “These challenges include addressing methane emissions, but as we have heard very clearly from community members, there are many other issues that as a state we need to address, such as air quality impacts and criteria pollutants.”
Karen Ross, secretary of the California Department of Food and Agriculture, stressed that her staff take EJ concerns into account and revise the digester program to address issues as needed.
“I hope we can all agree we've made advancements. But there's so much more for us to be doing,” said Ross. “We also want to make sure we're not growing in demand and sacrificing the environment or our neighbors and community.”
To dairy farmers and agricultural representatives testifying at the hearing, the data bolstered their argument that the administration should “stay the course” and maintain digester investments rather than taking the regulatory pathway.
“In my opinion, the discussion here should not be how to remove these programs, but how we can expand the investment California is making in reducing greenhouse gasses,” said Andrew Genasci, executive director of the San Joaquin Farm Bureau.
Ryan Jacobsen, CEO of the Fresno County Farm Bureau, described the state programs tackling manure methane as “the very definition of a highly successful public-private partnership.”
Sam Wade, who directs public policy at the Coalition for Renewable Natural Gas, welcomed CADD as “an impressive new public transparency tool.” He said it raises the importance of monitoring emissions leakage — such as creating more pollution by shifting the industry to states with minimal environmental regulations. CARB’s analysis noted that while California’s dairy herd size declined 0.7% from 2012 to 2022, seven other dairy producing states grew their populations over that time.
CADD affirmed many of the points that Dairy Cares Executive Director Michael Boccadoro has been lobbying to policymakers for several years. The industry is “well on our way” to reducing livestock methane emissions 40% by 2030, as prescribed in legislation the state enacted in 2016.
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“It's frankly working better than many of us envisioned when we were working and negotiating Senate Bill 1383 — without a doubt,” said Boccadoro.
Adding to the success, the industry is shifting focus from “the back end of the cows” to the enteric methane belched into the atmosphere through the digestive process. Several cooperatives, he explained, have received USDA funding to procure feed additives and will begin incorporating them into cow diets “very soon, within the next six months.”
Yet Boccadoro pointed to the migration of cows to other states to suggest that “some leakage” is inevitable.
“We can't keep up with a 1.3% attrition rate and continue to produce the same amount of milk we're producing today,” he said.
A noticeable change in the dialogue from previous debates was that dozens of industry advocates chimed in to defend digesters and farmers against the EJ accusations, roughly matching the number of environmental activists in the hearing.
Staff responded to several of the comments, occasionally refuting EJ assertions about the data. Yet those advocates maintained the same critiques against dairies.
“We have significant concerns with the accuracy of the underlying data in the data set,” said Phoebe Seaton, executive director of the Fresno-based Leadership Counsel for Justice & Accountability.
Seaton, a lawyer by training, argued the CARB scientists were “juicing the numbers” to make it appear herds at dairies without digesters were growing at the same rate as those with the technology.
“I really have to state the absurdity of CARB’s position that monetizing methane capture without a regulatory backstop has no perverse incentive effects,” added Tyler Lobdell, an attorney at Food & Water Watch, a nonprofit based in Washington, D.C. “CARB’s failure to regulate — paired with a myopic focus on lucrative incentives — is turning the dairy industry into a methane production industry.”
Some EJ advocates pivoted to water quality impacts from dairy manure. That led farm advocates to point out that state and regional water boards have strict regulations to minimize nitrate leeching into groundwater systems and are considering more stringent rules.
CARB also addressed criticism over ammonia emissions from dairies. The respiratory irritant forms ammonium nitrate, which makes up 30% of the San Joaquin Valley’s fine particulate pollution known as PM 2.5. Nitrogen oxides (NOx) from vehicles contribute to the ammonium nitrate formation. Yet CARB’s air quality modeling indicated that reducing NOx, not ammonia, is the most effective pathway to reducing ammonium nitrate. Federal air quality attainment standards attempt to tackle the mobile source problem, and CARB’s ban on diesel engines promises to eventually eliminate most of the NOx pollution.
Despite the negative response from the EJ community, Boccadoro was optimistic the CADD data could help to change the narrative.
“Hopefully, as we move forward, we can all accept the fact that we aren't dealing with faceless corporations. We're dealing with real farming families here in California,” he said. “We often hear the dairy digester program is not delivering methane reductions. It's unbelievable to hear some folks say that. There's no question the dairy digester program is delivering massive amounts of methane reduction.”
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