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Policymakers Should Not Rely on Manure Biogas to Curb Greenhouse Gases, Says New Report

Tuesday, August 16, 2022


Climate mitigation efforts must consider both environmental justice impacts and total emissions before relying on manure biogas to reduce livestock agriculture impact

The Center for Agriculture and Food Systems (CAFS) at Vermont Law and Graduate School released a new report today entitled " Rethinking Manure Biogas: Policy Considerations to Promote Equity and Protect the Climate and Environment ," which examines the use of manure anaerobic digesters to mitigate greenhouse gas emissions from animal agriculture operations.

On August 12, 2022, Congress passed the Inflation Reduction Act , which approved new and expanded tax credits for biogas, adding it to the list of eligible renewable energy sources such as solar and wind power. The bill is now waiting President Biden's signature, who is expected to sign the bill into law today.

However, climate change mitigation plans that rely on manure biogas-which transitions animal manure, often from concentrated feeding operations (CAFOs), into fuel-often ignore the larger environmental, social, and financial contexts in which biogas operates, says the CAFS report.

Written by Ruthie Lazenby, Staff Attorney at the Environmental Justice Clinic at Vermont Law and Graduate School, "Rethinking Manure Biogas" dives deep into the existing structure incentivizing manure biogas operations, their direct environmental justice impacts, as well as alternative methods of capturing livestock emissions and recommendations for policymakers.

The report focuses specifically on the equity implications of manure biogas, aligning with two Executive Orders by President Biden, " Tackling the Climate Crisis at Home and Abroad " and " Advancing Racial Equity and Support for Underserved Communities Through the Federal Government ."

"Environmental justice communities around the country have spent decades fighting for stronger protections from the air, water, and health harms imposed by factory farms," said report author Ruthie Lazenby. "The recent surge in enthusiasm for manure biogas among policymakers threatens to lock in the very systems that these communities have been fighting, under the guise of clean energy. There is nothing forward-thinking about rewarding industrial operations for capturing the GHG emissions they voluntarily produce-an intervention that can only be considered mitigation because of the ongoing failure of state and federal lawmakers to regulate GHG emissions and other pollution from factory farms as they do virtually every other industry."

Animal agriculture is responsible for approximately 20 percent of global greenhouse gas (GHG) emissions, and 57 percent of emissions directly related to the food industry. As the climate continues to change, animal agriculture is a field in which emissions mitigation must be implemented quickly and effectively.

While capturing emissions from livestock manure using anaerobic digesters that convert the waste product into biogas has emerged as a win-win for the livestock industry and the natural gas industry, adoption of these systems omits a variety of issues that must be addressed before committing to manure biogas at the expense of more comprehensive strategies.

Relying on manure biogas systems to mitigate livestock GHG emissions ignores both the extensive emissions created by the livestock industry outside of manure storage and the environmental justice impacts of locking in existing systems of industrial animal agriculture by investing in expensive, durable infrastructure that requires the ongoing production of manure to remain financially viable.

"It's imperative that policymakers address the GHG emissions created from agriculture, but we've seen that biogas is not a one-size-fits-all solution," said Laurie Beyranevand, Director of the Center for Agriculture and Food Systems. "Incentivizing the capture of manure biogas perpetuates a system of agriculture that policymakers need to support farmers in moving away from. It results in numerous environmental externalities that have been shouldered for far too long by environmental justice communities. Any legislation addressing climate change that considers further support and subsidies for manure biogas must realize its impact, not just its promise."

The report concludes with several recommendations for policymakers considering the adoption of manure biogas systems for GHG mitigation that would allow them to not only take advantage of the technology's benefits but address the various environmental and social harms that factory farms impose on local communities. These recommendations include:

  • Properly accounting for the full climate impacts of manure biogas and ensuring that emissions life cycle analyses consider the full range of emissions

  • Considering the full impact of policies supporting manure biogas on environment, public health, and quality of life

  • Evaluating USDA's manure biogas programs to ensure that they do not have a disproportionate impact on the basis of race, national origin, or other protected class

To view the report and full list of recommendations for policymakers, visit This publication was made possible with support from the United States Department of Agriculture National Agricultural Library , Agricultural Research Service.


About VLGS Center for Agriculture and Food Systems: Vermont Law and Graduate School's Center for Agriculture and Food Systems (CAFS) uses law and policy to build a more sustainable and just food system. In partnership with local, regional, national, and international partners, CAFS addresses food system challenges related to food justice, food security, farmland access, farmworkers' rights, animal welfare, worker protections, the environment, and public health, among others. CAFS works closely with its partners to provide legal services that respond to their needs and develop resources that empower the communities they serve. Through CAFS' Food and Agriculture Clinic and Research Assistant program, students work directly on projects alongside partners nationwide, engaging in innovative work that spans the food system. Visit to learn more.