As a longtime member of the California Air Resources Board, we have prioritized environmental justice and public health, working together to combat climate change. However, we believe that state policy should consider the consequences for communities least able to bear the associated costs.
This concern applies to CARB’s recently adopted amendment to streamline the Low Carbon Fuel Standard, or LCFS, which we oppose. The fuel standards program, established in 2011, aims to reduce greenhouse gas emissions from transportation by limiting the carbon intensity of fuels. The current program mandates a 20% reduction in the carbon intensity of fuel by 2030. The proposed amendment makes this a 30% reduction by 2030 and 90% by 2045.
But faster implementation risks increasing gasoline prices — a significant burden on low-income communities already struggling with costs. This issue has attracted attention from the media, legislators and the public. Beyond financial problems, LCFS had another, less publicized consequence: the dramatic transformation of California’s dairy industry.
Over the past decade, many dairy companies have shifted priorities driven by LCFS incentives, with troubling public health consequences.
California’s dairy industry has historically focused on milk production, but today, many dairy companies are producing renewable natural gas by capturing methane from manure. LCFS is pushing this trend through California’s carbon credit system, which aims to reduce greenhouse gas emissions. In this program, entities acquire and sell credits to reduce emissions, and farmers profit by converting methane into renewable natural gas. However, the system rewards greater manure production, as more methane yields more credits and profits. This creates perverse incentives, prioritizing pollution-heavy practices over sustainable, low-impact solutions.
Capturing methane, a greenhouse gas more than 80 times more potent than carbon dioxide in the short term, is essential to combating climate change. However, the way to achieve the reduction is important. The new amendment unwittingly incentivizes the growth of mega-dairies that are now disproportionately concentrated in the Central Valley, where land is cheaper than other parts of the country – an area already experiencing environmental and health challenges.
As mega-dairies expand, their impact on local communities worsens. According to the comments of the Leadership Adviser for Justice and Accountability, a climate, health and equality organization working in the Central Valley, the facility increases air pollution, groundwater depletion and nitrate contamination, which does not affect low-income Latino communities.
The promise of renewable natural gas as a “bridge fuel” is fundamentally flawed. Instead of transitioning to a sustainable decarbonization, LCFS is now supporting the expansion of large-scale dairies to maximize methane production. Dairies are rewarded not for reducing methane emissions but for taking what they generate, perpetuating pollution-heavy practices. More waste generates more profit.
While methane capture contributes to California’s greenhouse gas reduction goals, the collateral damage is undeniable. Mega-dairies are one of the biggest emitters of ammonia, contributing to fine particle pollution that causes respiratory disease and premature death. The Central Valley, already burdened with some of the worst air quality in the country, cannot afford the additional harm. In addition, nitrate runoff from manure continues to contaminate drinking water, disproportionately affecting disadvantaged communities that depend on domestic wells.
Tightening the LCFS mandate will only accelerate the expansion of mega-dairies.
CARB has undermined efforts to regulate livestock methane emissions. While we successfully pushed the regulation to begin in 2028, last-minute changes allowed mega-dairies to continue to profit from “methane avoidance” credits based on faulty assumptions, encouraging the consolidation of polluting animal and liquid fertilizer systems. Sustainable alternatives, such as dry handling or pasture-based systems, which produce fewer pollutants, remain unsupported. For this reason, we were on the losing side of the 12-2 vote by the Board on the LCFS amendment.
Methane is an immediate climate threat, and failure to address it would be catastrophic. However, ignoring the long-term environmental and social costs of factory-farm gas development prioritizes short-term climate benefits over community health and equity. Our climate solutions must not come at the expense of environmental justice.
The LCFS program could be improved by limiting the size and number of dairy operations eligible for methane incentives. Without these limits, we run the risk of destroying an industry where the environmental harm outweighs the climate benefit.
Additionally, CARB should prioritize sustainable methane reduction alternatives, including practices that reduce pollution at the source rather than perpetuate harmful systems. Setting these limits will create a fairer and more effective framework for addressing emissions while protecting vulnerable communities.
Fighting climate change is not just about milk. It’s about choosing a path that doesn’t cause more harm to vulnerable communities. For air, water, and public health, we need to ensure that solutions work for everyone, not just those who profit from pollution.
Dean Florez, a member of the California Air Resources Board, is a former California Senate majority leader. Diane Takvorian, a member of the California Air Resources Board, is the founder and former executive director of the Environmental Health Coalition. in San Diego/Tijuana.
