The Converting Our Waste Sustainably (COWS) Act of 2025 amends the Food Security Act of 1985 to formally add “composting practice” to the conservation definitions and to expand the Alternative Manure Management Program (AMMP). The bill lists concrete alternative practices (pasture‑based systems, compost‑bedded pack barns, solid separation plus drying/composting and related methods), authorizes payments covering planning, materials, equipment, installation, labor, maintenance and training, and requires at least 50% of those payments to be advanced for materials, equipment, or technical assistance.
Beyond authorizing stronger cost‑share, the bill directs USDA to publish methods for estimating carbon sequestration and greenhouse‑gas reductions, to revise or create conservation practice standards (including an on‑farm composting standard within one year), and to prioritize grants and contracts that maximize carbon sequestration, greenhouse‑gas reductions, and overall environmental and public‑health benefits while favoring geographic and scale diversity and serving small and mid‑sized producers.
At a Glance
What It Does
The bill amends multiple sections of the Food Security Act to (1) define 'composting practice' and broaden eligible 'alternative manure management practices'; (2) authorize cost‑share up to 100% of covered costs and require at least 50% advanced payments for materials/equipment and technical assistance; and (3) require USDA to publish GHG/carbon estimation factors and to develop or revise conservation practice standards.
Who It Affects
Dairy and livestock operations (with explicit preference for small and mid‑sized producers), USDA/NRCS and their technical assistance networks, compost facility developers and manure‑management technology vendors, and communities near livestock operations who may see changes in air quality and local nutrient recycling.
Why It Matters
This shifts federal conservation spending toward methane mitigation and on‑farm nutrient recycling rather than anaerobic lagoon biogas in many cases, creates new measurement and standards work for USDA, and enables shared/clustered composting projects — all of which will reshape where capital and technical assistance flow in the livestock sector.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The bill reworks definitions in the Food Security Act to bring composting explicitly into conservation policy and to expand what counts as alternative manure management. That expansion is substantive: it lists pasture‑based systems (including managed rotational grazing), compost‑bedded pack barns and other dry systems, and solid removal plus a menu of post‑separation treatments (solar drying, composting, vermiculture, forced evaporation, etc.).
By embedding composting into the statute, the bill makes on‑farm compost production a first‑class conservation activity rather than an incidental practice.
On the money side, USDA may cover up to 100% of costs tied to an approved alternative manure management practice — planning, design, materials, equipment, installation, labor, management, maintenance and training are all enumerated. The Secretary must provide at least half of the total contract payments up front for purchases or contracting of materials and equipment and for any technical assistance, and contracts cannot exceed three years.
Those two choices — large upfront advances and short contract terms — will determine how projects are structured and financed on the ground.The bill rewrites prioritization rules: applications must be ranked to maximize carbon sequestration, greenhouse‑gas reductions, and broader environmental and public‑health benefits (including water quality). It also requires USDA to design criteria to ensure geographic and scale diversity, explicitly promotes small and mid‑sized operations (including beginning, limited‑resource, and socially disadvantaged farmers), and allows joint applications for shared composting facilities with allocated payments to participating producers.To make outcomes verifiable, USDA must publish factors for estimating carbon sequestration and GHG reductions for each eligible practice, identify producers using anaerobic lagoons who could replace or complement those systems, and review and, if necessary, revise conservation practice standards.
The agency must also enter cooperative agreements with third‑party technical assistance providers. Finally, the bill gives USDA limited authority to waive certain payment limits for these contracts and to impose separate payment ceilings when appropriate, and it directs the agency to create an on‑farm composting practice standard within one year.
The Five Things You Need to Know
The bill inserts a statutory definition of 'composting practice' that covers compost produced from farm‑generated organic waste or waste brought from the nearby community, and conditions on‑farm compost use on compliance with applicable law.
It defines 'alternative manure management practices' to include pasture‑based systems, compost‑bedded pack barns, solid separation and scrape/vacuum systems coupled with drying or composting, vermiculture, forced evaporation, and related measures.
USDA may pay up to 100% of eligible costs for an alternative manure management contract and must provide at least 50% of total payments in advance for materials, equipment, or technical assistance.
Contracts for alternative manure management are limited to 3 years; the Secretary must rank applications to maximize carbon sequestration, greenhouse‑gas reductions, and water quality/public‑health benefits while ensuring geographic and scale diversity and prioritizing small and mid‑sized operations.
USDA must publish the factors used to estimate carbon sequestration and GHG reductions for each practice, revise or develop conservation practice standards (including an on‑farm composting standard within one year), and can enter cooperative agreements with third‑party technical assistance providers.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Designates the bill as the 'Converting Our Waste Sustainably Act of 2025' (COWS Act). This is a formal label with no regulatory effect, but the short title signals the bill's framing around waste conversion and sustainability for stakeholders and agency dockets.
Sense of Congress regarding AMMP
States congressional findings that California's Alternative Manure Management Program (AMMP) has 195 projects and claims a 1.6 million metric‑ton GHG reduction, and frames those practices as models for national adoption. While non‑binding, this language makes Congress' policy intent explicit and can shape USDA prioritization and reporting.
New statutory definitions: 'composting practice' and expanded AMMP
Amends Food Security Act definitions to add 'composting practice' and to expand the scope of 'alternative manure management practices.' The composting definition ties the practice to farm‑generated waste or feedstock brought from nearby communities and conditions on‑farm use on compliance with applicable law — an important caveat for permitting and nutrient‑management rules. The expanded AMMP list names specific technologies and treatment chains (e.g., solid separation + composting or solar drying), which narrows agency discretion and signals which projects Congress expects to fund.
Payment authority and new AMMP subsection
Modifies program administration to allow payments that cover up to 100% of enumerated costs (planning, design, materials, installation, labor, management, maintenance, training). It inserts a new AMMP subsection authorizing at least 50% of total payments in advance for purchases or technical assistance and limits contracts to three years. Practically, the advance addresses capital and cash‑flow barriers on smaller operations, while the 3‑year cap will influence project financing and amortization of equipment or shared infrastructure.
Application prioritization and cluster projects
Rewrites prioritization criteria so USDA must rank AMMP offers by projected carbon sequestration, GHG reductions, and overall environmental and public‑health benefits (including water quality). It requires the agency to assure geographic and scale diversity, explicitly support small and mid‑sized operations (and beginning, limited‑resource, and socially disadvantaged producers), and to establish procedures for joint 'cluster' applications for shared composting facilities with payment allocation rules. This creates new program design tasks—scoring metrics, rules for joint ownership, and monitoring obligations.
Secretary duties: measurement, standards, and technical assistance
Directs the Secretary to (1) determine and publish the factors used to estimate carbon sequestration and GHG reductions for each AMMP practice; (2) identify eligible producers—specifically those operating anaerobic lagoons or similar liquid anaerobic storage who can transition; (3) provide payments, technical assistance and training; (4) review and revise conservation practice standards or develop new standards where needed; and (5) enter cooperative agreements with third‑party technical assistance providers. These provisions shift substantial technical and methodological work to USDA and its partners, creating immediate demand for measurement protocols and standard updates.
Payment‑limit waiver authority and separate limitations
Amends payment‑limitation language to allow the Secretary to waive certain statutory payment caps (such as those in section 1001D(b) or earlier AMMP limits) for particular alternative manure management payments where necessary to meet project objectives, and to impose a separate payment limitation for the contract subject to the waiver. This offers flexibility for large or higher‑cost projects but raises questions about consistency, oversight, and how 'necessary to fulfill objectives' will be judged.
Technical assistance and on‑farm composting standard
Adds a requirement that USDA review existing practice standards for composting and soil carbon amendment and develop a new conservation practice standard for on‑farm compost production within one year. This is an implementation deadline that will force near‑term regulatory drafting, and it creates an avenue to reconcile nutrient‑management, air‑quality, and biosolids rules with program incentives.
This bill is one of many.
Codify tracks hundreds of bills on Agriculture across all five countries.
Explore Agriculture in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Small and mid‑sized dairy and livestock operations — the bill explicitly prioritizes these producers, increases cost‑share up to 100%, and requires majority awards to serves these scales where practicable, lowering financial and technical barriers to converting away from wet lagoon systems.
- Producers willing to adopt on‑farm composting or dry manure systems — eligible costs include planning, equipment, training and maintenance, and at least 50% of payment must be advanced to cover upfront capital needs.
- Manure‑management equipment manufacturers and compost facility developers — expanded eligible practices and encouragement of cluster/shared facilities expand market opportunities for separation equipment, drying systems, composting infrastructure and related services.
- Third‑party technical assistance providers and conservation planners — the statute funds technical assistance, requires USDA to enter cooperative agreements, and creates demand for measurement and implementation expertise.
- Nearby communities and farmers using recycled manure products — the statute frames compost as a recycled soil amendment, which can increase local access to organic fertilizer and can improve local air quality if methane is reduced.
Who Bears the Cost
- Large operations primarily using anaerobic lagoons that cannot be fully covered by cost‑share — while the bill targets transitions, retrofitting or decommissioning lagoons can be capital‑intensive and may exceed program payments or the practicality of a 3‑year contract term.
- USDA/NRCS and implementing partners — the agency will need to develop GHG and sequestration estimation protocols, revise/create practice standards under a one‑year deadline, and build capacity to manage cluster contracts and advanced payments.
- Local permitting authorities and municipalities — increased on‑farm composting and shared facilities can trigger zoning, air quality, and waste handling permitting questions, potentially shifting workload and costs to local regulators.
- Taxpayers/public budgets — the authorization to pay up to 100% of costs and to waive payment limits for some contracts expands potential program outlays and concentrates fiscal risk in federal appropriations and budget execution.
- Operations that lack capacity to manage contracts or technical reporting — producers who cannot meet monitoring, reporting, or co‑management expectations may face administrative burdens or fail to receive full benefits, effectively bearing compliance costs.
Key Issues
The Core Tension
The bill seeks to accelerate transitions away from methane‑intensive lagoon systems by using generous federal cost‑share and prioritization to achieve climate and local environmental gains, but it faces a classic trade‑off: incentivize rapid change with broad payments and you risk funding solutions that shift pollution pathways, overwhelm local permitting and technical capacity, or fail to deliver measured climate benefits; tighten measurement, standards, and oversight and you slow rollout and raise barriers for the very small and mid‑sized producers the bill aims to help.
Implementation depends on measurement and standards work that the bill pushes to USDA. Publishing factors to estimate carbon sequestration and GHG reductions is necessary for ranking and accountability, but developing defensible, practice‑level factors is methodologically complex and resource‑intensive.
Different practices have context‑dependent outcomes: a practice that reduces methane on one operation may not deliver the same net GHG benefit elsewhere when lifecycle feedstock movements, energy inputs for drying, or nitrous oxide tradeoffs are considered.
On‑farm composting and shared compost facilities create local permitting and air‑quality issues (odors, ammonia, particulate emissions) and nutrient‑management tradeoffs (compost application rates affecting nitrate leaching). The statutory condition that on‑farm compost use comply with federal, state, and local law will not remove practical permitting barriers or siting resistance.
The program's directive to favor small and mid‑sized operations and to enable cluster contracts is equitable in intent but operationally tricky: defining 'small' and 'mid‑sized', allocating payments within a joint contract, and monitoring shared facilities require new agency rules and dispute‑resolution processes. Finally, the 3‑year contract cap and requirement for at least 50% advanced payments create tension: the advance helps cash flow, but three years may be short relative to infrastructure lifespans and the time needed to verify sustained emission reductions.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.