The rapid spread of highly pathogenic avian flu (HPAI) H5N1 through our agriculture system presents a deep threat to our food supply and a growing risk that the virus will mutate to become the next dangerous human pandemic. Sadly, the U.S. federal government response has not only been insufficient, but has actually worked to encourage the dangerous corporate practices driving this risk. Longtime close ties between federal agricultural regulators and the industry they are supposed to regulate has resulted in taxpayers actually footing the bill for programs that profit the industrial animal sector while making a human H5N1 pandemic more likely.

As of February 27, 2025, there have been 70 confirmed cases of the virus in humans in the U.S., causing one human death. While the virus has not yet been documented to spread between humans, researchers found that the H5N1 variant in dairy herds required only one mutation to spread more easily in humans. Given that H5N1 mutates rapidly, like other forms of influenza, scientists and public health officials are particularly concerned to know that we are just one mutation away from a potentially deadly human pandemic. The World Health Organization reports that, since 2003, 48.6 percent of global H5N1 cases in humans have been fatal.

Farm Forward’s review of current policies and data reveal six essential flaws with USDA’s response to the pandemic at poultry farms:

• USDA compensation payments to poultry farms with infected birds increase pandemic risk.
• USDA compensates repeat offenders.
• Current audits of safety measures are meaningless.
• Huge loopholes in safety requirements allow many farms to take no measures at all.
• Information blackout from the new administration leaves public health officials in the dark.
• Vaccine requirements lag far behind many other countries.

Executive Summary

One of the most sophisticated greenwashing and corporate welfare schemes ever designed, “manure biogas,” is providing Big Ag cover to use public dollars to fund an expansion of factory farms in the Midwest. The first thing to know about “biogas” is that the term itself is misleading. “Biogas,” also sometimes called “renewable natural gas” or “RNG,” refers to the use of methane digesters (also known as anaerobic digesters) to capture gas emanating from the cesspools of waste that concentrate on factory farms. These digesters process some portion of the waste from factory-farmed animals into fuel while also producing a polluting byproduct called digestate. “Manure biogas” is more accurately described as factory farm gas, or FFG for short.

Industry has touted its use of FFG as a climate solution, but an investigation by Farm Forward released in parallel with this one documents that FFG functions as a net negative by incentivizing the expansion of factory farming and entrenching current factory farms and their worst practices. This Farm Forward report demonstrates how Big Ag is effectively bringing its waste problem to the Midwest by confusing legislators and the public with lofty talk of “biogas” or, as it is alternatively branded, “renewable natural gas” or “RNG.”

With industrial dairy at the helm, a coalition of utility and fossil fuel companies are making plans to entrench and expand factory farming’s most destructive practices: mass confinement of animals and manure cesspools. At the center of this plan is FFG, which industry plans to promote by a combination of deregulating digesters and manipulating clean fuel standards. Industry has already introduced legislation in Michigan to deregulate anaerobic digesters and their waste byproducts, and to establish a new “clean fuels standard,” a credit trading scheme for polluters.

Michiganders are increasingly waking up to the industry’s plans, and concerned citizens are resisting and opposing the growth of CAFOs in their states.1 However, industry misinformation has led to considerable confusion about FFG, even among policymakers and some environmentalists. This report demonstrates that FFG is a clear case of egregious greenwashing. FFG threatens a massive misappropriation of public funds to expand a polluting industry deeper into America’s heartland.

Executive Summary

“Manure Biogas” (also known as factory-farmed gas, or FFG) is rapidly expanding, and industry has structured it to produce a reverse Robin Hood effect: the increasing subsidies for FFG are supposed to incentivize green practices but instead fund greenwashing that promotes the growth and entrenchment of the largest factory farms at the expense of the surrounding communities, the climate, and public health.

“Biogas” is how Big Ag refers to the use of methane digesters—large sealed tanks with no oxygen—to capture gas emanating from the cesspools of waste that concentrate on factory farms. These costly and inefficient digesters process some portion of the waste from factory-farmed animals into fuel while also producing a polluting byproduct called digestate. “Biogas” is more accurately described as factory farm gas or FFG for short.

FFG functions to pump billions of dollars into propping up industrial animal production. In places where data is available like Wisconsin and Iowa, FFG growth has meant the growth of factory farms. In 2023, federal subsidies for biogas began rapidly expanding and exceeded $150 million. In one federal grant program alone, there was an over 2,600 percent year-over-year increase in federal grants for biogas. These public funds have attracted private investments that further exacerbate the problem.

Farm Forward’s analysis reveals that these subsidies flow almost exclusively to factory farm interests and disproportionately to the biggest, most destructive farms—rewarding the ones that do the most environmental damage. In addition to grants, low-interest loans, tax deductions, and other free monies from public coffers, the justification of FFG involves a blatant overvaluation of environmental credits. Despite these obvious problems being flagged by 15 members of the U.S. Senate and House,1 the federal government has doubled down on support for FFG.

Greenwashing gas from factory farms is not a climate solution. It’s climate gaslighting. The real solutions to the problems of factory farming are well known: reducing our overall dependence on animal products and raising the remaining animals on farms that combine the best of traditional and modern models to reduce the many public health and environmental costs of large-scale animal agriculture.

See our parallel report, “The ‘Biogas’ Plot: Fueling Factory Farms in the Midwest.”

Abstract

Industrial farmed animal production,”1” also known as factory farming, has been widely criticized as inhumane, ecologically unsustainable, and a contributor to a range of public health problems. These problems have largely been hidden from public view by refusing journalists and concerned citizens access to industrial farms. Given this systematic effort by agribusiness to render its practices invisible, undercover video investigations have become one of the few effective means for bringing the problems of industrialized agriculture into public view. Fearful of the public scrutiny created by such investigations, agribusiness has worked for decades to pass “ag-gag” legislation that limits normal free speech rights by preventing the production or use of photos and video taken on farms. These efforts have intensified since 2011. Ag-gag laws are arguably the most dangerous threat to fair public discussion of industrial agriculture, yet they have already been passed in a number of states. An immediate response is required to challenge this threat to free speech and the devastating blow it deals to those working to curb the abuses of factory farming.