The 17,500 Sites Left Behind

There are approximately 17,500 methane sources in the United States that have no capture plan, no project timeline, and no pathway to methane destruction under current policy. These are not theoretical sites. They are real facilities: dairies, swine operations, wastewater treatment plants, and legacy landfills, all of which vent methane to the atmosphere every day.

The Scale Problem

RNG project economics require minimum throughput to justify the capital. A biogas upgrading system, pipeline interconnect, and gas quality monitoring infrastructure costs $8-25M regardless of whether you are processing 500 or 5,000 scfm of raw biogas.

This creates a hard floor. Sites producing less than roughly 1,000 scfm of raw biogas will never see an RNG project. That eliminates the vast majority of U.S. dairy operations (average herd size: 300 head), nearly all swine operations outside of the top 100, and most municipal wastewater plants serving populations under 50,000.

The industry calls these sites "sub-scale." The atmosphere does not recognize that distinction.

Geographic Distribution

The sites left behind are not concentrated in one region. They are distributed across every state with significant agricultural activity. Wisconsin alone has over 1,200 dairy operations that produce meaningful methane but will never qualify for RNG. Iowa has 3,400+ swine operations in the same position.

Rural locations compound the problem. Pipeline interconnection costs, often the single largest line item in an RNG project budget, increase dramatically with distance. A site 15 miles from the nearest pipeline injection point faces $3-5M in interconnect costs before a single molecule of gas is processed.

The Timeline Problem

Even for sites that could theoretically support an RNG project, the development timeline is measured in years. Permitting, interconnect agreements, utility negotiations, and construction typically span 24-36 months from project inception to first gas flow.

Methane does not wait. Every day these sites remain uncovered, methane vents to the atmosphere at 80x the warming potential of CO2 over a 20-year horizon. An enclosed flare can be operational in 4-8 weeks. The policy framework provides no mechanism to bridge this gap.