State Climate Programs Measure the Wrong Methane Metric

In 2024, California reported 284 billion BTUs of renewable natural gas injected into the state pipeline system. Oregon reported 12.4 billion. Washington reported 8.7 billion. Each state published these numbers in annual progress reports as evidence that their methane programs were working.

None of those reports mentioned how much methane was actually destroyed. The distinction matters more than most policymakers realize. A dairy digester that captures 90% of its methane but loses 8% to slip during upgrading and pipeline injection has a net destruction rate of about 83%. An enclosed flare on the same farm destroys 99.5% of captured methane. The atmospheric outcomes are not close, but only the first project shows up in a state production report.

How We Got Here

The measurement gap traces back to the early 2010s, when states began writing renewable portfolio standards that included biogas. The architects of those standards borrowed frameworks from renewable electricity, where production volume is a reasonable proxy for environmental benefit. A megawatt-hour of wind power displaces roughly a megawatt-hour of fossil generation, give or take transmission losses.

Biogas does not work that way. Producing a unit of renewable natural gas requires capturing methane, cleaning it to pipeline quality, compressing it, and injecting it into infrastructure that may be miles from the source. Each step introduces potential losses. The environmental value of the original methane capture can be partially or fully offset by the processing chain.

But states wrote their standards around production. California's SB 1440 tracks RNG procurement volumes. Oregon's mandate measures therms of renewable gas delivered. Washington's program counts pipeline injection. In every case, the metric that determines compliance is volume produced, not methane eliminated from the atmosphere.

The Metric Shapes the Market

When states measure production, they create incentives that favor production over destruction. This is not theoretical. It plays out in project selection every year.

A 5,000-head dairy in the Central Valley generates roughly 800,000 cubic feet of raw biogas per day. An RNG developer can install an upgrading system, build a pipeline interconnect, and inject 400,000 to 500,000 cubic feet of pipeline-quality gas daily. That project generates compliance credits, qualifies for LCFS pathways, and shows up in state progress reports.

A 400-head dairy in Tillamook County generates 60,000 cubic feet per day. Too little gas to justify the $8 to $12 million investment in upgrading and interconnection. No developer will build the project. No production shows up in state reports. The methane vents to the atmosphere, where it traps 80 times more heat than CO2 over a 20-year horizon.

An enclosed flare at the Tillamook farm would cost $200,000 to $400,000 and destroy 99% of that methane. But no state compliance framework gives credit for destruction alone. The farm does not produce gas, so the farm does not count.

What the Numbers Actually Show

EPA estimates there are roughly 8,200 candidate sites for biogas recovery in the United States. Of those, the American Biogas Council reports about 340 active RNG projects as of late 2025. These projects represent the largest, most economically favorable sites, the ones where production economics work.

That leaves approximately 7,860 sites where biogas could be captured but is not being converted to pipeline gas. Many of these sites are too small, too remote, or too far from pipeline infrastructure. Under current state metrics, they are invisible.

If states measured methane destroyed rather than gas produced, the picture would change. A small enclosed flare destroying 50 tons of methane per year at a 300-cow dairy would register in state climate accounting. Multiply that across thousands of sites and the cumulative impact dwarfs what the current RNG project pipeline can deliver.

The math is straightforward. The 340 active RNG projects collectively destroy an estimated 2.5 to 3 million tons of CO2 equivalent per year, after accounting for slip losses and energy inputs. If the 7,860 remaining candidate sites each installed a basic enclosed flare, even at smaller average scale, the additional destruction would exceed 10 million tons of CO2 equivalent annually. The smaller, cheaper interventions deliver three to four times the climate impact of the current approach.

The States That Are Starting to Notice

Vermont's 2025 methane reduction study, commissioned by the Agency of Natural Resources, was one of the first state documents to distinguish between methane captured for gas production and methane destroyed on-site. The study found that on-site destruction technologies could address 70% of the state's agricultural methane at less than one-third the cost per ton of RNG production.

Minnesota's Pollution Control Agency published a technical memo in late 2025 noting that its renewable gas standard did not account for methane slip during gas upgrading. The memo recommended adding a net destruction efficiency factor to the state's credit calculation, which would reduce the effective credit value of RNG projects with high slip rates.

Neither state has changed its compliance framework yet. But the fact that state agencies are documenting the gap suggests the production-only measurement regime is losing its monopoly on the policy conversation.

Wisconsin's Department of Agriculture, Trade and Consumer Protection has taken a different approach entirely. Rather than modifying its RNG framework, the department has begun exploring a standalone methane destruction incentive for dairy operations under 1,000 head. The program would award per-ton credits for verified destruction regardless of whether the methane enters a pipeline. If implemented, it would be the first state program to decouple methane credits from gas production.

What Better Measurement Would Look Like

A state methane program that measured destruction rather than production would have three features.

First, it would credit any verified methane destruction, whether the methane becomes pipeline gas, generates electricity on-site, or is simply combusted in a flare. The atmospheric outcome is the same: methane that would have reached the atmosphere is converted to CO2, reducing its warming impact by a factor of 80 over 20 years.

Second, it would apply a net efficiency adjustment. An RNG project with 8% methane slip during upgrading would receive credit for 92% of captured methane, not 100%. A flare with 99.5% destruction efficiency would be credited accordingly. This adjustment would direct investment toward the highest-destruction-rate technologies.

Third, it would scale credits to site size. A flat credit per ton of CO2e avoided would naturally favor low-cost destruction at small sites, exactly the interventions that current production-based frameworks exclude.

These are not radical proposals. They are standard measurement principles applied to a problem that has been measured badly from the start. When you track the wrong number, you fund the wrong projects. When you fund the wrong projects, you leave methane in the atmosphere that could have been destroyed for a fraction of the cost.