California’s Top Methane Emitter is a Vast Cattle Feedlot. For Now, Federal and State Greenhouse Gas Regulators Are Giving It a Pass.
Forty miles north of the U.S.-Mexico border in Southern California’s Imperial Valley, the Brandt Company cattle ranch is the largest single point source of methane emissions in the state, releasing more of that greenhouse gas than any oil or gas well, refinery or landfill.
The 643-acre feedlot is home to 139,000 beef cattle, according to the most recent figures reported by state regulators. With their belching and manure, the animals produce an estimated 9,167 metric tons of methane annually, according to an Inside Climate News analysis. The calculations build on the work of the nonprofit coalition Climate TRACE, which is developing a farm-by-farm inventory of methane emissions from cattle with the aid of public records, satellite imagery and artificial intelligence.
In essence, the ranch’s emissions of methane, a greenhouse gas 81 times more potent than carbon dioxide over a 20-year period, equal the annual greenhouse gas emissions of 165,000 automobiles. Only Southern California Gas Company and Pacific Gas and Electric Company, the state’s largest two natural gas utilities—with leaks across tens of thousands of miles of underground pipeline networks—release more methane, the primary component of natural gas.
But you won’t find the Brandt ranch, or any other single livestock operation or dairy, in state or federal greenhouse gas emissions databases.
The Environmental Protection Agency’s Greenhouse Gas Reporting Program, which was established in 2007 to provide a detailed accounting of emissions, site by site, from “all sectors of the U.S. economy,” exempts agriculture. A state reporting program that began in California in 2008 gives farmers a similar pass.
Methane’s potency as a greenhouse gas, combined with its short lifetime, means that curbing emissions of the gas is the single best way to combat climate change in the near term, according to the United Nations Intergovernmental Panel on Climate Change, or IPCC.
Nationwide, cows collectively emitted more than twice as much methane from their belching and manure in 2020 as all of the country’s oil and gas wells, including those active and abandoned, onshore and offshore, according to an Inside Climate News assessment of the EPA’s 2022 Inventory of U.S. Greenhouse Gas Emissions.
The shortage of government information about emissions from individual dairies and livestock operations presents a paradox. From one year to the next, California is increasingly threatened by the droughts, wildfires and floods associated with climate change. It is lauded—and sometimes resented—for its pathbreaking environmental policies on auto emissions and renewable energy. Yet it keeps little official data on the largest emitters of what is arguably the most consequential greenhouse gas.
The state has ambitious climate policies for agriculture, including a target for reducing methane emissions from the dairy and livestock sector by 40 percent within the next decade. Starting next year, it will also have the authority to regulate methane emissions from individual farms.
But without the site-by-site numbers from dairies and feedlots, that authority could be meaningless.
“We treat this area of regulation with kid gloves compared to all the other primary polluting industries,” said Ben Allen, a California state senator representing parts of Los Angeles.
David Clegern, a spokesperson for the California Air Resources Board, said methane emissions from individual dairies and livestock operations are not included in its greenhouse gas reporting program “mostly because methods available to quantify the emissions from these facilities are not sufficiently accurate.”
A recent study by the state agency’s own scientists, however, suggests that existing methods are surprisingly accurate.
The EPA gave similar reasons for excluding methane emissions from cows when it launched its greenhouse gas reporting program in 2009, noting that “the methodologies are uncertain, variable and burdensome for reporters.”
For decades, environmental advocacy organizations have submitted public records requests and filed lawsuits against the EPA in a quest for that data but have been frustrated in compiling even basic information on the location and size of large industrial farms in most states.
Now, with the help of satellite imagery and artificial intelligence, Climate TRACE is filling the void with detailed information on the locations and emissions of the biggest feedlots and dairies in California and Texas, two national powerhouses in milk and meat production.
“We should be able to know where these facilities are,” said Sam Schiller, who led the agriculture work for Climate TRACE and is chief executive of Carbon Yield, a company that helps farmers access revenue streams that reward them for reducing their greenhouse gas emissions. “You can’t manage what you don’t measure.”
A Clue in Wastewater Permits
Schiller and his colleagues first focused on California and Texas, where state wastewater permits document the number and type of cows allowed at each dairy or livestock operation. Then they applied estimates developed by the IPCC for the volume of methane released by individual dairy or beef cows to calculate each facility’s annual methane emissions.
The group is now training artificial intelligence to identify cattle production facilities worldwide based on satellite images. They have also built models that relate cattle numbers from wastewater permits to satellite images showing each facility. Once trained, the AI system and modeling effort should be able to estimate the number of cows from satellite images of cattle-feeding operations in places that lack reliable permitting data, Schiller said.
“Our work with Climate TRACE really is about building better data systems that monitor the progress, or lack of progress, in agriculture and really help put into the public domain the kind of tools that you need to monitor emissions from agriculture,” Schiller said.
Inside Climate News generated an interactive map of methane emissions from dairies and cattle feedlots across California by drawing on updated state wastewater permits that were not available to Climate TRACE at the time of its assessment last year. The new assessment also factors in efforts made by individual California dairies to reduce methane emissions from cow manure that were not part of Climate TRACE’s initial analysis.
So far, 231 dairies and heifer ranches in California have either installed state-subsidized biogas digesters, which capture methane from lagoons where cow manure is channeled, or have adopted “alternative manure management practices.’’ Inside Climate News was able to match 217 of these projects to the sites involved and reduced its estimates of their methane emissions accordingly.
Methane from manure can account for nearly half of the methane produced at dairies. It typically accounts for only a small fraction of the methane produced at feedlots, though, because of differences in how the manure is managed.
Rob Jackson, an earth system science professor at Stanford University who is not affiliated with Climate TRACE, said that farm-by-farm data is crucial for reducing emissions.
“It gives us power to track pollution,” Jackson said. “We want to be able to have a lookup table for every large greenhouse gas emitting source in the world. Where is it? Who owes it? How much are they emitting? And how much have they cut emissions?”
Daniel Lee Miller, a professor at Duke Law School focusing on agriculture and the environment, agreed.
“If the regulators are not going to do their job in producing an accurate count of these facilities and making an accurate assessment of their contributions to climate change, then I’m delighted that others are stepping in to fill that gap,” he said.
The March of Industrial Farms
The information on dairies and feedlots unearthed by Climate TRACE helps to fill a gap in data that has persisted for decades as federal and state regulators failed to accurately assess the environmental impact of the livestock industry. Even as the data went unreported, the sprawling industrial livestock operations known as Concentrated Animal Feeding Operations, or CAFOs, were multiplying across the country, churning out vast amounts of manure along with meat and milk.
“EPA doesn’t know where those CAFOs are and has not put the resources in to inspect and identify those CAFOs and hold them accountable,” said Emily Miller, an attorney with Food & Water Watch, a nonprofit watchdog group that has repeatedly pressed the agency through lawsuits and petitions to strengthen its regulatory oversight. “If we did have more information on where CAFOs were in the country and how they operate and how many animals they have, it would certainly be easier to calculate their methane emissions.”
In addition to methane emissions, the manure produced by closely confined animals on large, industrial farms contributes to nutrient pollution through runoff to creeks, rivers and lakes, which is why federal and state wastewater regulations exist.
A 2008 report by the U.S. Government Accountability Office, a nonpartisan congressional agency, concluded that the EPA could not fulfill its obligation to monitor CAFO pollution until it obtained accurate “facility-specific” information about CAFOs and their locations.
The EPA acknowledged that it had no accurate national inventory of CAFOs and said it would work with states to introduce a national data system that provided an accurate tally.
Currently, only one-third of the country’s 21,000 largest CAFOs have wastewater permits.
The EPA followed up by proposing regulations that would require all CAFOs to obtain wastewater permits, but the industry challenged the rules in court and won. Ultimately, the environmental groups and the agency agreed to a settlement with the livestock industry, requiring the EPA to propose yet another rule. This one, issued in 2011, would have required CAFOs to submit basic information about their operations and facilities to the agency.
But the following year the agency withdrew the rule, saying it could obtain the information it needed from states and other sources without it—something it had previously deemed impossible—and that it would work with states to do so.
Environmental groups filed Freedom of Information Act requests to the EPA in 2012 to see whether the agency was following through. However, a lawsuit filed by the American Farm Bureau Federation and the National Pork Producers Council subsequently blocked the agency’s release of public records.
In 2021, Food & Water Watch sued EPA, seeking stronger effluent limitation guidelines for CAFOs. In response, the agency announced earlier this year that it would undertake a detailed study of CAFO water pollution to determine whether and how to strengthen the guidelines.
This week, under a settlement deadline in a separate Food & Water Watch-led lawsuit, the agency denied a Food & Water Watch-led 2017 petition seeking to expand and improve water pollution permitting. Instead, the agency said it would only form a federal advisory committee to study CAFO pollution beginning in 2024.
The advisory committee will consider inadequate permitting, among other issues raised in the petition, and the EPA says it will complement the detailed study.
“If There’s a Will …”
Environmental experts argue that if state and federal regulators were willing, they could provide emissions data similar to what Climate TRACE is now generating for individual dairies and feedlots.
“They could of course take these measurements if they wanted to,” said Daniel Lee Miller, the Duke Law School professor. “To say that we just really can’t estimate at the facility level with any kind of certainty—that doesn’t hold any water for me.”
The California Air Resources Board and the EPA currently report estimates of methane emissions from cows at the state and national level with a simple and surprisingly accurate method. The agencies tally the number of cows in the state or country and then multiply the number of cows by one of several “emissions factors,” the average methane emissions from a cow over the course of the year.
The IPCC, which developed the emissions factors in 2006, assigns different figures depending on criteria including whether the cow is a dairy cow or a beef cow, the feed it ingests and the climate conditions where it lives.
While the agencies use the emissions factors to estimate the total methane emissions from cows for the state of California and for the nation, both said the data yielded from this approach is too crude to estimate emissions from individual dairies or feedlots.
However, a team of California Air Resources Board researchers reported last year after a three-year study that the emissions factor approach was “able to estimate real-world CH4 [methane] emissions” at individual dairies and “adequately” predicted methane concentrations in the air surrounding the dairies.
The team used both ground-level and airborne sensors to monitor methane emissions from 107 California dairies, “making this study the most comprehensive mobile research study focused on CH4 emissions from California dairies to date,” the authors reported in April 2022 in the journal Atmospheric Environment.
Clegern, the spokesperson for the California Air Resources Board, or CARB, said the study on its own would be an insufficient basis for changing the agency’s policy of not reporting emissions from individual dairies.
“We will continue to do research to enable better quantification of emissions using the latest science, but no single research project is considered sufficient to change a program,” he said.
While CARB does not publish methane emissions from dairies and ranches, the California Department of Food and Agriculture provides detailed information on how much individual dairies have reduced their methane emissions through the use of biogas digesters or alternative manure management programs.
The digesters capture methane from the liquid manure lagoons that can then be sold through the state’s Low Carbon Fuel Standard program. The alternative methods involve dry storage, a practice that avoids nearly all methane formation, and composting.
“Finding a New Profit Center”
Despite the environmental stakes in methane reporting and capture, the tune changes when money is involved, Miller of Duke Law School suggests. “If it’s about regulation, then everyone seems to have no idea,” he said of measuring methane emissions from individual dairies. “If it’s about finding a new profit center from this waste, then suddenly everyone has a lot of really specific ideas about how much methane is being produced that could potentially be captured.”
The California Department of Food and Agriculture uses methods developed by CARB to estimate emissions reductions from biogas digesters and alternative manure management at individual dairies.
Asked how CARB manages to measure reductions in methane emissions at individual dairies but not their emissions totals, Clegern said that it was tied to the application process for state funding.
Dairies that apply for state funding for the alternative manure management program “have to submit information about their unique dairy conditions that then gets used to calculate estimated GHGs [greenhouse gases]” as a condition of their application, he said.
Pressed on why CARB does not simply require all dairies to provide information about their unique conditions so that the agency could calculate total methane emissions from manure for all dairies, Clegern said that CARB’s emissions tallying process was not designed for that purpose.
The methods used are “for a specific purpose, that is, to take individual grant applications (and the specific dairy data included in their voluntarily submitted grant applications) and calculate future/projected emission reductions for those individual grant applications, which can then be used to compare estimated future reductions against other grant applications,” he said in an email.
“Data coming into the CDFA [California Department of Food and Agriculture] program does not cover the approx. 1,200 dairies in California,” Clegern wrote.
Jackson, the Stanford earth science system professor, suggested that the Climate TRACE data on individual dairies and cattle farms provides an emissions estimate that other researchers can follow up on with actual on-site measurements to refine the data.
For Schiller of Carbon Yield, the Climate TRACE effort helps establish a baseline to pave the way for emissions reductions going forward. “I would think that there is a really good argument, particularly for larger facilities, to be able to start to set performance standards,” Schiller said. “But there’s just nothing on the books right now.”
California law requires the dairy and livestock sector to reduce greenhouse gas emissions by 40 percent from their 2013 levels by 2030. The sector is roughly halfway toward meeting its goal, according to a 2022 CARB report.
The report estimates that as much as $3.9 billion in additional investment in dairy biogas digesters may be needed to meet the mandate.
Allen, the state senator, said he worried that financial incentives for generating biogas could result in an increase in the number of dairy cows and large dairies, posing the risk of greater air and water pollution in nearby communities.
CARB will have the authority to regulate methane emissions from dairies and feedlots as of Jan. 1, 2024, but it is unclear if or when the agency will begin to exercise it. “At this point, the rule-making has not begun,” Clegern said.
For Brandt, a Dry Manure Strategy
The Brandt family cattle company got its start in Southern California in 1945. Its feedlot along the Alamo River exploded in size in the 1970s, from 1,200 head to 90,000, under the direction of William Brandt, who remains the current owner.
Brandt declined multiple requests for comment for this article.
But in 2019, the company commissioned an extensive greenhouse gas emissions analysis, a mandatory assessment as it sought approval from county and state regulators to increase the size of its feedlot by 107 acres to accommodate an additional 30,000 cows.
The resulting report noted that “no single project could generate enough GHG emissions to change the global climate temperature noticeably.” But it added that “the combination of GHG emissions from past, present and future projects could contribute substantially to global climate change.”
The report concluded that the proposed expansion, which was subsequently approved, would add 1,325 metric tons of methane to the atmosphere each year, the vast majority of it from “enteric” emissions, or cow burps. That methane output has the same near-term climate impact as the annual greenhouse gas emissions of nearly 25,000 automobiles.
The Brandt Company does not use digesters to capture methane from manure. Unlike most large dairies, which store manure in methane-producing lagoons, the feedyard keeps the manure dry. This prevents all but a small amount of methane from forming and allows the Brandt family to compost the manure for use as fertilizer on its crops.
Reducing methane emissions from cow burps is far more difficult. The report noted several potential strategies supported by the state of California for trying to reduce enteric emissions from cows, like finding ways for the animals to grow larger or more quickly, breeding them for lower methane production or changing their diet. The project assessment said that such measures were still in the development phase, however.
Four years later, little seems to have changed.
“Our cattle producers in California want to be a part of the solution, but we can’t get ahead of the science and we can’t get ahead of the markets,” said Kirk Wilbur, the vice president of government affairs for the California Cattlemen’s Association, an industry organization.
Feed additives such as seaweed and other synthetic compounds that inhibit methane production could significantly reduce methane emissions from cow burps, but the additives have not been approved for use in cows by the U.S. Food and Drug Administration.
Pressed on whether the beef and dairy industry should be required to report methane emissions at each site, as other industries do, Wilbur dismissed the idea, saying that the state’s cumulative tallying was sufficient.
“Frankly, I haven’t given it a lot of thought,” Wibur said. “I think we can use those aggregated inventories to meaningfully reduce the scale of our emissions within each of these industries.”
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