Much of what the agricultural industry calls biogas or “renewable natural gas” (RNG) is just greenwashed factory farm gas.¹See FWW. “The Big Oil and Big Ag Ponzi Scheme: Factory Farm Gas.” January 2024. Factory farm gas is the mixture of gases produced from the breakdown of organic materials in an anaerobic digester.²Environmental and Energy Study Institute. “Biogas: Converting waste to energy.” October 2017 at 1; EPA. “Basic information about anaerobic digestion (AD).” Available at https://www.epa.gov/anaerobic-digestion/basic-information-about-anaerobic-digestion-ad#HowADworks. Updated August 31, 2022. Waste (like manure or poultry litter) goes into the oxygen-free digester, and even more waste and gas (mostly methane and carbon dioxide) come out.³Ibid. This gas can be used on-site to produce electricity or heat,⁴International Energy Agency. “An introduction to biogas and biomethane.” Available at https://www.iea.org/reports/outlook-for-biogas-and-biomethane-prospects-for-organic-growth/an-introduction-to-biogas-and-biomethane. Accessed April 2023. or it can be “upgraded” to biomethane by removing hydrogen sulfide, carbon dioxide, and moisture.⁵California Environmental Protection Agency (CalEPA). “Central Valley Dairy and Co-digester PEIR — Notice of Preparation/Initial Study.” ESA/209481. March 2010 at 6. Biomethane is used primarily for vehicle fuel and has a higher methane content than raw factory farm gas.⁶DOE. Alternative Fuels Data Center. “Renewable Natural Gas Production.” Available at https://afdc.energy.gov/fuels/natural_gas_renewable.html. Accessed February 2023.

As an end-use, burning factory farm gas produces the same pollutants as any fossil fuel source of energy.⁷Gittelson, Phoebe et al. “The false promise of biogas: Why biogas is an environmental justice issue.” Environmental Justice. Vol. 15, No. 6. 2022 at 355. On top of this, the transport of the gas and materials to and from digesters still requires massive amounts of toxic diesel fuel.⁸CalEPA (2010) at 6. The manure does not disappear either — it comes out of the digester as digestate, a solid and liquid sludge.⁹EPA. “How does anaerobic digestion work?” Available at https://www.epa.gov/anaerobic-digestion/basic-information-about-anaerobic-digestion-ad. Accessed November 2023. This liquid effluent is typically reapplied to land while still retaining nitrogen and phosphorus,¹⁰Vermont Department of Environmental Conservation (DEC). Agency of Natural Resources. “Anaerobic Digesters.” Available at https://dec.vermont.gov/air-quality/permits/source-categories/anaerobic-digesters. Accessed January 2023 and on file with FWW. and it may in fact increase the leaching of nutrients into the soil or water compared to a fossil fuel alternative.¹¹Hijazi, Omar et al. “Review of life cycle assessment for biogas production in Europe.” Renewable and Sustainable Energy Review. Vol. 54. 2016 at 1299.