The Upgrader Is Not the Climate Device

California's dairy and swine manure biomethane calculator separates the job into parts: manure to biogas, avoided emissions, and biogas to RNG. That quiet spreadsheet detail matters. The methane cut happens at the manure system. The fuel product happens later. Source: https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2024/lcfs2024/instr.manual_tier1_ci_calc_%20dairy%26swine_manure_biomethane.pdf

Renewable natural gas can be useful. It can turn waste gas into a valuable fuel. It can help a large project earn revenue. But the upgrader is not the climate device. It is the fuel device. If policy forgets that distinction, farms end up waiting for a gas business before they are paid for the methane they can stop today.

Two Jobs, One Policy Shortcut

The first job is local and physical. Manure decomposes without oxygen, biogas forms, and methane has to be collected and controlled. EPA says liquid manure management systems lead to anaerobic conditions and increased methane production. It also lists methane capture from manure as a way to reduce agricultural emissions. Sources: https://www.epa.gov/agstar/practices-reduce-methane-emissions-livestock-manure-management and https://www.epa.gov/ghgemissions/agriculture-sector-emissions

The second job is industrial and commercial. Biogas has to be cleaned, upgraded, compressed, metered, injected, booked, sold, and reported as a fuel. The California Public Utilities Commission defines biomethane, also called RNG, as biogas that is captured and purified to a quality suitable for injection into an investor owned utility gas pipeline. Source: https://www.cpuc.ca.gov/industries-and-topics/natural-gas/renewable-gas

Those are both legitimate jobs. They are not the same job. One prevents methane from reaching the air. The other turns a gas stream into a pipeline product. A fair policy should pay for the first job wherever it is verified, and let the second job earn extra value where it makes sense.

Fuel Credits Reward the Long Route

The federal Renewable Fuel Standard was built around renewable fuel volumes. EPA says the program requires a certain volume of renewable fuel to replace or reduce fossil fuel in transportation fuel, heating oil, or jet fuel. RINs represent renewable fuel produced and used for transportation purposes in the United States. Source: https://www.epa.gov/renewable-fuel-standard/overview-renewable-fuel-standard-program

EPA's approved pathway table includes renewable compressed natural gas and renewable liquefied natural gas from biogas at agricultural digesters, landfills, wastewater treatment digesters, and other sources. Source: https://www.epa.gov/renewable-fuel-standard/approved-pathways-renewable-fuel

California's LCFS also works through fuel pathways. EPA's AgSTAR FAQ explains that transportation fuels need a carbon intensity score to participate, and that biogas from dairy and hog manure upgraded and used as vehicle fuel can receive very low carbon intensity treatment. Source: https://www.epa.gov/agstar/frequent-questions-about-livestock-biogas-projects

That fuel pathway can be valuable. The problem is what happens when it becomes the main door. A farm that can destroy methane today may still have to wait for an upgrader, an interconnection, a credit application, and a buyer before the climate value becomes bankable. The longer route may be worth it at some sites, but it should have to prove that extra complexity buys more climate benefit than a direct destruction project at the same farm.

The Scale Signal Is Already There

EPA reports 400 manure based anaerobic digestion systems operating on U.S. livestock farms as of June 2024, plus another 73 under construction or modification to upgrade biogas to RNG. AgSTAR also estimates that biogas recovery is technically feasible for more than 8,000 large dairy and hog operations. Source: https://www.epa.gov/agstar/agstar-data-and-trends

That does not mean every one of those farms should become an RNG producer. It means the technical opportunity is much wider than the fuel project pipeline. The bigger the policy stack gets, the more it favors farms that can host expensive systems, accept complex contracts, or join regional projects. The farms outside that lane still have manure methane.

The question is not whether RNG is good or bad. The question is whether RNG should be the gatekeeper. When a policy pays only after gas becomes a certified fuel, it can miss cheaper, faster methane destruction that does not need a pipeline product.

Pay for the Cut First

A better order is simple. Pay first for verified methane destruction. Pay more if a project also creates useful energy without adding unreasonable cost or delay. That lets RNG compete honestly while giving cap and flare a fair seat at the table.

This approach would be cleaner for consumers too. Ratepayers and taxpayers should know what they are buying. If they are paying for a fuel, call it a fuel. If they are paying for a methane cut, show the meter, the destruction record, the uptime, and the cost per ton. Do not hide the climate result inside a fuel label.

Farmers should not have to solve pipeline economics before they are allowed to solve methane. The atmosphere does not wait for an interconnection agreement. The manure system is emitting or it is controlled. The methane is destroyed or it is not.

RNG should remain an option for the farms where the whole project pencils. But the upgrader should not be treated as proof of climate value by itself. The climate device is the system that keeps methane out of the air. Policy should start there.