COWS Act Offers 100% Federal Payout for Farmers to Switch Manure Management, Prioritizing Small Farms and Climate Goals

The aptly named Converting Our Waste Sustainably Act of 2025 (or COWS Act) is a major push to change how livestock operations manage manure across the country. Essentially, this bill takes a page from California’s successful playbook—the Alternative Manure Management Program (AMMP)—and formalizes a massive federal incentive to get farmers to stop using traditional, methane-heavy liquid manure lagoons and switch to more sustainable methods like composting and solid storage. The bill amends the Food Security Act of 1985 to define these new practices and, critically, offers to cover up to 100 percent of all associated costs for implementation, including planning, equipment, and even labor, with at least half the payment provided upfront.

The Methane Problem and the Compost Solution

If you’ve ever driven past a large dairy or hog operation, you've likely smelled the traditional approach: storing manure in large, open liquid lagoons. While cheap, this process is a major source of methane and nitrous oxide—powerful greenhouse gases. This bill changes the game by adding "composting practice" and "alternative manure management practices" as official, federally supported conservation measures (Sec. 3). These practices include everything from compost-bedded pack barns to solid separation and forced evaporation. The goal is clear: reduce baseline methane emissions and increase carbon sequestration, which means better air quality and healthier soil.

For the farmer, this is a huge financial relief. Converting a manure system is expensive, often costing hundreds of thousands of dollars. By offering 100% cost coverage and 50% advance payment (Sec. 4), the government is taking the financial risk out of the transition. Think of it as a complete federal subsidy for a major infrastructure upgrade, which is a massive incentive for producers who are already operating on thin margins.

Prioritizing the Little Guys (and the Big Climate Win)

While the environmental benefits are the main driver, the bill also has a strong focus on equity. The Secretary is directed to prioritize applications that maximize carbon sequestration and greenhouse gas reduction, but they must also ensure geographical and scale diversity (Sec. 5). Crucially, the bill mandates that the majority of these new alternative manure management contracts should go to small and mid-sized dairy and livestock operations, including beginning farmers and ranchers and those from socially disadvantaged groups.

This is a smart move to ensure that the economic benefits of this environmental transition aren't just captured by the largest corporate farms. If you're a small, multi-generational dairy farmer, this program provides the capital and technical assistance (Sec. 6) needed to modernize your operation and meet new environmental standards without bankrupting your business. The contracts are limited to a 3-year term (Sec. 4), keeping the focus on implementation and immediate results.

The Fine Print: Waivers and Vague Authority

While the program is designed to support the smaller producer, there’s a catch in the payment structure that bears watching. The Secretary is given the authority to waive standard payment limitations for these specific 3-year contracts (Sec. 7). This means that while the focus is on small farms, the door is open for the government to issue massive, uncapped payments to a larger operation if the Secretary determines that a waiver is “required to meet the project’s objectives.” This provision could lead to a scenario where a handful of very large projects absorb a disproportionate amount of the federal funds, even if the spirit of the law favors the small farmer.

Furthermore, the bill grants the Secretary significant latitude in defining what counts as an “appropriate” practice (Sec. 3) and in determining the factors used to estimate carbon sequestration (Sec. 6). While some flexibility is needed, this broad administrative discretion means the real-world success of the COWS Act will heavily depend on how the Secretary writes the final rules and standards over the next year. For the average taxpayer, this bill represents a significant new federal expenditure designed to tackle climate change through agriculture, but the return on investment will hinge on robust, transparent implementation guidelines.