This report was last updated in November 2020. It may no longer be accurate, both with respect to the evidence it presents and our assessment of the evidence. We may revise this report in the future, depending on our research capacity and research priorities. Questions and comments are welcome.

Summary

Waste sites (such as landfills and agricultural waste storage) produce biogas from the decomposition of organic materials, including the powerful greenhouse gas methane. With the right infrastructure and systems, companies and municipalities can capture this methane and either destroy it or convert it into energy. Biogas capture projects cause a clear reduction in greenhouse gas (GHG) emission, but it is unclear whether waste biogas carbon offsets actually cause the projects to be implemented. While we have not yet found any biogas-related carbon offsets to recommend, we do believe that there are likely circumstances where these offsets do cause real emissions reductions. Better biogas offsets are in places where methane capture is not mandated by regulation (either current or future), and in sites where the electricity generated by biogas is not enough to make the project profitable.

Overall, we believe that there are likely good biogas offsets that are additional, but thus far we have been unable to find any that meet our criteria. As not all offsets are offered online, it is possible that these high-quality offsets are being directly sold to corporate buyers or are only transacted through brokers. Giving Green will continue searching for biogas projects we can recommend with confidence.

Waste biogas capture as a carbon offset

Landfills and agricultural waste sites produce biogas from the decomposition of organic materials. Biogas is composed of primarily methane and carbon dioxide (CO2), along with a small amount of other organic compounds. Both methane and CO2 are greenhouse gases that trap heat in the atmosphere. Methane is 28-36 times better at trapping heat in the atmosphere than CO2 over a 100 year period, making it a particularly potent GHG [1]. Of all methane produced in the United States, landfills are the third-largest source with approximately 14% of overall emissions [2]. Reducing methane emissions is a key priority in combating climate change.

Waste sites emit methane through an anaerobic process. Large amounts of organic material (e.g. food, wood) are deposited into landfills, and agricultural waste sites contain production byproducts (such as plant husks or animal excrement). Bacteria decompose these materials and produce a mixture of gases, which is then emitted into our atmosphere and contributes to global warming.

Biogas normally escapes from waste sites into the atmosphere soon after it is produced. However, if the right infrastructure and systems are put in place at waste sites, companies and municipalities can capture the methane and either destroy it or convert it into energy. Gas extraction wells and piping systems can be set up at waste sites and used to move biogas from the production site to treatment locations. At the treatment locations, biogas is either flared (burned to convert methane into a less harmful gas) [3] or converted into energy like electricity or car fuel.

To encourage biogas flaring or capture, the US Government regulates large emitters of GHG through the Clean Air Act and through reporting requirements to the Environmental Protection Agency (EPA). Regulations require landfill emissions to be measured and publicly documented. Large emitters are required to either capture and destroy or convert their landfill gas into a reusable resource [4]. However, biogas emissions from agricultural operations and smaller landfills are more lightly regulated, if at all.

Carbon offsets fund the construction and upkeep of biogas capture and treatment infrastructure. In the absence of regulation or profitable circumstances, biogas capture and treatment is unlikely to occur.

Causality

Overall, if projects are executed correctly, then waste biogas capture is highly likely to cause reductions in atmospheric greenhouse gas emissions.

Project-level additionality

In the absence of regulation or profitable circumstances, biogas capture and treatment is unlikely to happen. As such, carbon offsets can be catalytic for these projects in cases in which they are additional.

The cost of biogas projects depends on the size, location, and configuration of the site. There are significant capital outlays at the start of a project, as the physical infrastructure is designed and created. After the initial expenditure, there are routine costs to upkeep equipment and oversee operations. For projects that are not profitable and exempt from government regulation (e.g. too small), carbon offsets can provide a financial incentive to capture and use the biogas.

The EPA estimates that a privately owned and operated project with a 3 megawatt turbine and no previously installed capture system costs approximately $8.5 million to install and will lose approximately $3.5 million over a 15-year lifetime [5]. While the above cost does not factor in tax credits or exemptions or the ability to use the electricity produced for on-site operations, the cost of biogas capture and treatment systems are often prohibitive for companies and municipalities [6].

Marginal additionality

The marginal additionality of waste biogas carbon offset projects varies based on where the project is in the project lifecycle. Before construction, while trying to achieve sufficient financing for the project to go ahead, carbon offsets are likely to be marginally additional (as long as the target goal is eventually reached). After construction, however, the marginal additionality of waste biogas capture projects is relatively low as the binding financial outlay is for the construction of the initial system. In some cases carbon offsets might continue to fund operational expenses, which would satisfy marginal additionality; we have not yet found any projects in this space that make a compelling claim to use carbon offsets in that way.

Permanence

Some waste biogas projects destroy emissions; these have high permanence. Once the emissions are captured and destroyed, they are not at risk of leaking back into the atmosphere. We do not think that the capture of these emissions is likely to increase emissions elsewhere.

For projects that use captured emissions to produce energy, we see the permanence as lower. These projects often use the gases to create energy through a process that eventually emits them, meaning that they are not permanently removed from the atmosphere. In these projects, the benefit is more “clean” energy created by gases that would otherwise have just leaked into the atmosphere without any additional benefit.

Co-benefits

With projects that use waste biogas to create electricity or other energy, the co-benefits are more energy produced for the surrounding regions. We view this co-benefit as fairly weak as most of the surrounding where these projects are happening have other sources of energy.

Assessment of waste biogas capture projects

Carbon offsets for biogas are most “impactful” when they meet the best-in-class standards for carbon offsets - additional, not overestimated, permanent, not claimed by another entity, and not associated with significant social or environmental harms - along with meeting the following conditions [7]:

• Project is not required by regulation to implement biogas capture and treatment

• Project is not profitable from the sale of renewable resources from biogas treatment

• Project is capital constrained and will not happen without carbon offsets

• Carbon offsets go directly to purchasing biogas project infrastructure or maintenance, as opposed to non-essential inputs

When reviewing projects for this report, we found that it was difficult to get enough information to determine whether projects met the above conditions. Simply being certified by one of the major certifying agencies did not give us confidence that the project was indeed additional. We expect that some biogas projects will meet these conditions, and some will not. This appears to be confirmed by what others have concluded [8][9].

For example, the GHG Management Institute and Stockholm Environment Institute say that the usefulness of landfill gas projects and associated carbon offsets depends on the project. They state: “Varies by location. Projects are likely additional in most parts of the developing world. In developed countries, including the United States, some projects are pursued to avoid triggering regulatory requirements, and projects that generate energy can be economical without carbon revenue.” The report also describes how there is uncertainty in baseline levels of methane output with these projects, which further adds to the difficulty of quantifying their impact [10][11].

We therefore focused the remainder of our research on waste biogas projects in developing countries and projects involving small landfills in the US.

Developing countries: Unfortunately, we found few offsets in developing countries available for sale online. The UN offers two such projects, capturing biogas from agricultural waste in India and Thailand. However, after further consideration, we didn’t feel comfortable recommending either.

The Ratchaburi Farms Biogas Project in Thailand is a biogas capture system that generates energy for use on a large pig farm. The first issue with additionality is that the system may be profitable, and as a large company it’s plausible that the farm could and would have made the investment without the carbon credits. But more worrisome is that the project is quite old. It started operating in 2008, and in its original application for offset certification, it requested credits for 10 years. The project was a partnership with the Government of Denmark, who committed to buying some of the credits as part of their commitment under the Kyoto accord. So as far as we can tell, the current offsets for sale were generated before 2018 but were not part of the purchase agreement with Denmark. Given this, it is quite hard to believe that expectation of voluntary offsets purchases 10 years in the future actually contribute to additionality.

The Mabagas Power Plant in India is somewhat more promising. It generates energy by procuring animal waste from nearby farmers and feeding this waste into its digesters. Without this plant, this waste would degrade and release biogas into the air. There are no regulations requiring the construction of the plant. However, a couple of worries have prevented us from recommending these offsets. First, the project seems plausibly profitable. Although the IRR documents submitted as part of the offset certification procedure claim that selling carbon credits is necessary to achieve viability, these numbers are hard to verify. Next, there is a question of who precisely is on the receiving end of these offsets. Mabagas was launched as a joint venture between two companies that mainly deal in (petroleum-based) oil and gas: the state-owned Indian Oil Company, and the German company Marquard & Bahls. As revenue from offsets will ultimately flow to these companies or their subsidiaries, it is unlikely that this capital will fuel more green projects. Overall, we cannot recommend these offsets given the information available at this time.

US-based projects: Although large emitters are required to install methane capture systems, small landfills are not covered by these regulations, and carbon credits may certainly spur them to build capture systems. However, regulations are constantly changing [12], and plants may install landfill gas capture systems in anticipation of coming under regulatory authority (due to expansion or changing regulations).

We explored US landfill gas offset options and, at least given the data available, felt unable to confidently recommend any of them. For instance, this landfill in Massachusetts seems to be a project that was very much spurred by carbon credits, with credits originally issued for ten years. However, the offsets available for purchase now are for the second issuance of offsets, while the actual infrastructure seems to only have been modestly updated. It is unclear what additionality these new offsets are providing. The Hilltop Landfill in Virginia was a small landfill that installed methane capture financed with carbon credits. But the landfill closed in 2013, and it seems like the investment has already been refunded from previous carbon credit sales [13]. So further sales are likely not additional. Other options we explored are larger landfills that seem likely to fall under methane capture regulations as they grow or as new regulations are put into place.

Overall, we believe that there are likely good biogas offsets that are additional, but currently, we have been unable to find any that meet our criteria. As not all offsets are offered online, it is possible that these high-quality offsets are being directly sold to corporate buyers or are only transacted through brokers. Giving Green will continue searching for biogas projects we can recommend with confidence.

[1] https://www.sepa.org.uk/media/28988/guidance-on-landfill-gas-flaring.pdf

[2] https://www.epa.gov/lmop/frequent-questions-about-landfill-gas

[3] https://www.epa.gov/lmop/basic-information-about-landfill-gas

[4] https://www.epa.gov/lmop/basic-information-about-landfill-gas#methane

[5] https://www.eesi.org/papers/view/fact-sheet-landfill-methane

[6] Direct-use projects (i.e. where the energy created is used to power upkeep of the landfill) cost less and have a slightly higher ROI, but are less common because they require their facilities to be nearby.

[7] http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf

[8] http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf

[9] https://www.drawdown.org/solutions/buildings-and-cities/landfill-methane

[10] http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf

[11] https://www.drawdown.org/solutions/buildings-and-cities/landfill-methane

[12] http://biomassmagazine.com/articles/16424/epa-proposes-federal-plan-under-2016-landfill-gas-regulations

[13] https://www.ecosystemmarketplace.com/articles/offsetting-local-inside-landfill-gas-project/

References

https://www.epa.gov/lmop/basic-information-about-landfill-gas

https://www.epa.gov/sites/production/files/2017-04/documents/lmop_2017_special_session_cowan.pd

https://www.r-e-a.net/work/biowaste-recycling/

https://wasteadvantagemag.com/business-case-carbon-offsets-waste-diversion-waste-digestion-composting/

https://sustainability.wm.com/downloads/WM_CDP_Climate_Change_Response.pdf

https://earthworks.org/issues/flaring_and_venting/

https://en.wikipedia.org/wiki/Landfill_gas_utilization

https://www.eesi.org/papers/view/fact-sheet-landfill-methane

https://www.terrapass.com/project/flathead-county-landfill-gas-to-energy

http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf

http://www.offsetguide.org/wp-content/uploads/2019/11/11.15.19.pdf

https://www.sepa.org.uk/media/28988/guidance-on-landfill-gas-flaring.pdf

http://www.aqmd.gov/docs/default-source/permitting/toxics-emission-factors-from-combustion-process-.pdf?sfvrsn=0

https://www.eesi.org/papers/view/fact-sheet-landfill-methane

https://www.co2offsetresearch.org/consumer/Methane.html

https://americancarbonregistry.org/carbon-accounting/standards-methodologies/landfill-gas-destruction-and-beneficial-use-projects

https://americancarbonregistry.org/carbon-accounting/standards-methodologies/landfill-gas-destruction-and-beneficial-use-projects/landfill-gas-destruction-and-beneficial-use-methodology-v1-0-march-2017.pdf