In much of rural Wisconsin, manure is everywhere. It’s in the ground, the drinking water, and the air communities breathe. The state is home to more than 300 Concentrated Animal Feeding Operations (CAFOs) that produce billions of pounds of manure every year.

Kim Dupre, a clean water advocate who lived in St. Croix County, Wisconsin, for 20 years, has watched the state go from an idyllic agricultural haven to a barren region dominated by factory farms and their waste. Schools and local businesses have closed, and the state’s growing public health crisis has been linked to a lack of access to clean drinking water in rural areas. “It doesn’t feel like country living. You feel like you’re in an industrial park,” Dupre said.

Big Ag took hold of the Midwest decades ago. And some of these trends—shrinking populations, farm consolidation, and local business closures—are common in rural areas across the country. But some residents and activists say a recent, allegedly pro-environmental policy is making things worse: A climate program implemented some two thousand miles away is encouraging farms in Wisconsin to turn manure into fuel using anaerobic digesters. The pollution problem is growing.

The California Low-Carbon Fuel Standard (LCFS) is a climate program implemented in 2011 to incentivize the production of alternative fuels and reduce greenhouse gas emissions in the state. It’s a key part of California’s climate strategy, and has issued more than 22 billion dollars’ worth of credits for low-carbon fuels since 2013. One of the “low-carbon” fuels heavily incentivized by the LCFS is factory-farm biogas, a fuel source produced from methane released by manure and animal waste. Farmers are paid to install anaerobic digesters—giant machines that break down waste, capture methane, and turn it into natural gas used for electricity, heating, and fuel—and are awarded credits, which California transportation companies and fuel producers can buy to offset their carbon emissions. In 2024, the California Air Resources Board, the governing body of the LCFS, updated the program to accelerate the deployment of zero-emission infrastructure like digesters, which critics argue solidified factory farm biogas as one of the program’s most incentivized fuels. Nearly 200 manure digesters across 16 states are now funded by the LCFS, according to an analysis from Food and Water Watch. Outside California, Wisconsin, Texas, and New York have the most LCFS-funded digester projects.

Biogas and biodigester technology are supported by a broad coalition of agricultural groups, fossil fuel giants, utility companies, and politicians across bi-partisan lines. Supporters call it a game-changing technology that will cut methane emissions from the agriculture sector, while providing farmers a new source of income. Alongside the LCFS, a number of federal grants and state programs have been dedicated to building more digesters. With funding from former-President Joe Biden’s Inflation Reduction Act, the Rural Energy for America Program (REAP) program funneled over $150 million in subsidies to manure biogas projects in 2023 alone.

Critics view digesters—and the public funds being funneled into their construction—as a form of greenwashing, i.e. making something seem more environmentally friendly than it actually is. Digesters lead to larger herd sizes, they say, meaning not just more planet-warming methane overall, but also more air and water pollution in rural communities already burdened by the impacts of industrial agriculture. “It’s not that we’re anti-technology, but we don’t want to be a sacrifice zone either,” Dupre said.

To produce biogas and feed a digester, a massive quantity of manure needs to be produced on-farm, said Tyler Lobdell, a staff attorney at Food and Water Watch. “You only have biogas production when you have a factory farm in operation that has all sorts of problems that go far beyond methane emissions,” he added. The average number of cows confined on a factory farm dairy generating LCFS credits is 7,900 cows. For context, the national average dairy herd is 377 cows.

“LCFS is rewarding factory farms for polluting locally, for contaminating communities drinking water, for causing more air pollution in local communities, and ultimately for just being bigger climate polluters,” Lobdell said. When the LCFS began incentivizing methane capture in 2018, that began a “gold rush for manure,” that has led to the emergence of a whole new industry,” he said.

Mary Dougherty, a senior regional representative at the Socially Responsible Agriculture Project says digesters and the fiscal support they’re receiving from programs like the LCFS have drastically changed the purpose of American dairies. “We’ve reached a point where the manure is more valuable than the milk. The cows are not there to feed people, they’re there to feed the digester and generate carbon credits. That is not the American farmer—the story, the fable, the myth, and the beloved archetype of our country—it’s not that,” Dougherty said.

The mother-of-five has been fighting factory farming in Wisconsin since 2015, when she first heard of plans for an industrial hog farm to be built nearby her town of Bayfield. She ran a restaurant at the time, and knew little about factory farming.

“It felt like we were being invaded without any sort of consent on our part,” she said. It’s a common occurrence in rural communities: Companies come in preaching a new operation or technology, promising jobs and a revived economy. But the more Dougherty learned about industrial agriculture, the more she believed a CAFO would harm her community’s health and wellbeing. She threw herself into organizing, and with the help of her community and allies, the proposal was dropped. Dougherty has since spent her career helping other communities organize against CAFO expansions and digester implementation—which she, like other critics, fears will drive farm expansion and a worsening public health crisis. “Quality of life suffers when CAFOs expand,” Dougherty said.

Research suggests that dairies with digesters have increased their herd sizes by 3.7 percent annually, which is 24 times the growth of dairies without digesters. But in Kewaunee County, Wisconsin, which has five industrial dairies that receive LCFS credits, herd sizes grew on average 58 percent since they were installed. More cows means more manure, and more manure means increased risk of water contamination.

Across Wisconsin, where 25 percent of people get their drinking water from private wells, an estimated 80,000 wells contain unsafe levels of nitrate, the compound found in animal manure and commercial fertilizer. More than 90 percent of nitrate contamination comes from excess manure and fertilizer application from industrial agriculture, according to a recent report from the Alliance of Great Lakes. Surplus nitrate consumption has been linked to a number of health risks including thyroid cancer, premature birth, and blue baby syndrome.

It’s not just Wisconsin being impacted by California’s carbon market either. In Iowa, a dairy that leaked over 365,000 gallons of manure in three weeks in 2022 now receives LCFS credits. Residents in San Joaquin Valley, California, a predominantly Latino area dealing with water and air pollution from industrial agriculture, and a number of environmental organizations, are suing the California Air Resources Board for its failure to address the environmental justice impacts of the LCFS.

Digesters have been promoted as a form of climate policy. But in addition to the environmental justice concerns, it’s not clear that digesters reduce greenhouse gas emissions as much as they claim to, particularly if they’re driving an increase in cows overall: They do not address enteric fermentation (cow burps), which accounted for 27percent of U.S. methane emissions in 2022 alone, said Sarah D’Onofrio, a researcher who works with digester-impacted communities across the country. “That’s where most of the methane emissions from dairy are coming from, they just ignore that,” she said. D’Onofrio fears the LCFS and programs like it will only worsen consolidation among American farms. Several states, including Washington, Oregon, New Mexico, and Michigan have now implemented or are considering programs similar to the LCFS. “It’s encouraging already bad patterns of letting the big guys get even bigger and the small guys are getting left out. They can’t even benefit from these programs.” The California Air Resources Board did not respond to a request for comment.

To truly mitigate the environmental impacts of agriculture, Dupre, who herself owned a farm for two decades, said taxpayer dollars should be going to small-scale farmers who prioritize pasture-based grazing and perennial cover—more sustainable farming practices that improve animal welfare while enhancing soil health. “You get what you incentivize in this country,” she said. “If you get paid for your pollution, you don’t have any incentive to reduce or quit polluting, right?”