An independent look at methane policy

The RNG Industry Is
Leaving 17,500 Methane
Sources Behind

Renewable Natural Gas was supposed to solve agricultural methane. Instead, it built a subsidy-dependent industry that only works at scale -- and left thousands of sites venting to the atmosphere with no plan and no timeline.

See the numbers Read the argument

By the numbers

The Numbers They Don't Talk About

17,500

Methane sources with no capture plan

Dairy, swine, wastewater, and landfill sites currently venting methane with zero infrastructure to stop it.

45 MMT

CO2e per year venting to atmosphere

The annual emissions from uncovered methane sources in the U.S. alone. Equivalent to 10 million cars on the road.

$8-25M

Minimum capital for an RNG project

The floor cost to build an RNG facility. Most methane sources will never see this kind of investment.

5-15%

Methane slip in RNG systems

Processing and transport losses that the industry calls acceptable. Enclosed flares destroy 98%+ on-site.

90%+

Of sites will never qualify for RNG

Too small, too remote, or too low-volume. The industry calls them sub-scale. The atmosphere calls them a crisis.

“The goal is destruction,
not monetization.”

The argument

Four Failures of the RNG Model

The Subsidy Trap

RNG only works when you stack LCFS + RINs + 45Z. Remove any one leg and the economics collapse. That is not infrastructure. That is arbitrage. When your entire business model depends on the intersection of three volatile policy instruments, you have not built a solution. You have built a bet.

The Sites Left Behind

A 1,000-head dairy has real methane. It will never get an RNG project. Neither will 90% of swine operations or small municipal wastewater plants. The industry calls these sites sub-scale. We call them abandoned. The technology to destroy their methane exists today. It costs a fraction of an RNG build. But there is no credit, no incentive, no policy pathway to deploy it.

The Destruction Gap

RNG claims 85-95% capture. But methane slip -- the 5-15% lost through processing and transport -- means the atmosphere still gets hit. Enclosed flares destroy 98%+ on-site, with no transport risk and no processing loss. The math is not ambiguous. When you factor in methane's 80x warming potential over 20 years, that slip is not a rounding error. It is the whole story.

The Policy Failure

Flare-only projects get zero incentives under LCFS. Zero RINs. Limited 45Q access. The policy framework rewards complexity over outcomes, monetization over destruction. A site that converts methane to pipeline gas and sells credits is celebrated. A site that simply destroys 98% of its methane on day one gets nothing. The incentive structure has inverted the priority.

The RNG Industry IsLeaving 17,500 MethaneSources Behind