New Standards for Landfill Gas Energy Support Renewable Energy and Materials Management Goals

Best Practices for Landfill Methane Request for Proposals released

When Michigan passed Public Act 235 in 2023, the new clean energy law recognized landfill gas as a renewable energy source, allowing it to be included in the state’s portfolio standard and earn regulated credits and incentives.  As of June 2025, rate-regulated utilities that file with the Michigan Public Service Commission were projecting that they would obtain approximately 286,000 renewable energy credits per year, for the near future, from landfill gas generation (Ecology Center, 2025). 

However, the distinction was contingent on projects meeting best practice guidelines to be developed by Michigan’s Department of Environment, Great Lakes, and Energy:  “A landfill gas recovery and electricity generation facility located in a landfill whose operator employs best practices for methane gas collection and control and emissions monitoring, as determined by the Department of Environment, Great Lakes, and Energy (EGLE).”  

As an extension of its circular economy and food waste programming, Michigan Sustainable Business Forum has been supporting a coalition of environmental and business groups to encourage the timely development of those standards, currently led by the Ecology Center.  EGLE recently issued a Request for Proposal for a qualified contractor that would develop these guidelines.  It received six bids and should be announcing the project kick-off in the near future. 

According to the 2024 Economic Impact Potential and Characterization of Municipal Solid Waste in Michigan (MiSBF, 2024), approximately 81% of materials currently disposed of in the state’s landfills and its one remaining municipal waste to energy facility could be recycled.  With the state currently targeting a recycling rate of 45%, landfills are likely to remain a necessary and important asset to Michigan communities for the foreseeable future. 

The organic material in landfills produce methane, a greenhouse gas that is nearly 80 times more potent than carbon dioxide in the first 20 years after release.  In addition to its climate effects, methane is difficult to monitor, is highly volatile, and believed to cause long-term risks to human health and the environment.  Food waste and other organic material known to produce methane make up nearly 60% of Michigan’s waste stream.  The U.S. EPA has published studies suggesting that methane emissions from landfills are underreported.  

To prevent potentially dangerous accumulations of methane, landfills burn excess as flares.  LFG collection systems allow it to instead be captured and used as fuel.  There are 25 landfills in Michigan currently generating electricity from natural gas through reciprocating engine, cogeneration, or gas turbines, and another half-dozen providing natural gas directly to utilities. Landfill gas energy projects directly reduce 6.7 MMTCO2e in emissions per year while providing 148 MW of generating capacity (EPA LMOP, 2024). 

Guidelines can reduce methane emissions through improved practice

EGLE is calling for a contractor to develop best practices for a renewable energy system that utilizes LFG and how they should be implemented, monitored, and enforced. This implementation system would minimize the generation of landfill gas through improved materials management, responsibly manage and monitor landfill gas emissions where they occur, support Michigan’s climate goals by maximizing GHG reductions, and avoid creating incentives that could increase the landfilling of organics.  

The development process will include the following minimum deliverables:

• Literature and Policy Review
• Assessment of Existing Infrastructure and Practices
• Stakeholder Engagement (at least two meetings)
• Technical and Climate Impact Analysis
• Development of Best Practices
• Public Review and Finalization
• Implementation and Oversight Strategy

It is unknown whether the guidelines will be published and finalized in 2026, or whether the MPSC will approve new projects before that happens. 

The Ecology Center recommends that any policy adjustment or best practice definition should start with better gas collection, requiring automated wellhead tuning systems that monitor for gas leaks in real time. This would include stronger pollution controls, better landfill covers, modern methane monitoring systems, and greater public transparency.  

The landfill emissions coalition has provided the following best practice recommendations for consideration in the guidelines: 

1. Better Gas Collection: Requiring automated wellhead tuning systems that continuously monitor press and gas quality to reduce methane leaks in real time.
2. Stronger Pollution Controls: Ensuring all flares and treatment systems are enclosed and destroy 99% of methane. Require regular performance testing and monitoring of flow rates to track effectiveness.
3. Better Landfill Covers: Limit the size of active dumping areas and require timely cover installation to reduce emissions. Require methane-oxidizing biocovers for long-term unused areas.
4. Modern Methane Monitoring: Adopt satellite, drone, and continuous monitoring techniques to monitor the landfill and help guide repairs. These tools are cheaper, safer, and more effective than old-fashioned walking surveys that miss or ignore large areas.
5. Public Transparency: Require landfills to provide public, accessible reporting of all monitoring data and corrective actions so communities know what’s happening.

Upstream opportunities to reduce emissions through food loss and waste reduction

In landfills that have LFG collection systems, the EPA estimates that 34 metric tons of methane escapes gas collection for every 1,000 tons of food waste deposited Methane from food waste is released faster than systems can be deployed (MiSBF, 2024). 

As Michigan’s counties restructure their solid waste plans (originally focused on increasing landfill capacity) into materials management plans (focused on waste diversion from landfills) in response to changes to Part 115, emissions reduction can be achieved beyond what is possible through the collection systems.  Landfill waste diversion methods and programs are achievable at various scales, from residential compost bins, commercial compost operations, industrial pollution prevention and source waste reduction, and internal policy changes in food businesses. 

By including waste diversion programs and practices in materials management plans, municipalities have the capacity to directly impact LFG emissions in their own backyards, providing both fine and broad scale benefits. 

Ideally, these goals will also be represented in the best practice guidelines for landfills that EGLE is producing, encouraging landfill operators to invest in diversion solutions as part of their long-term business strategies.

Citations:

• Michigan’s Methane Problem: What We Can Do to Limit Pollution. 2025. Ecology Center.
• Senate Bill 271 of 2023 (Public Act 235 of 2023)
• 2024 Economic Impact Potential and Characterization of Municipal Solid Waste in Michigan. 2024. Michigan Sustainable Business Forum.
• LMOP Landfill and Project Database. 2024. US Environmental Protection Agency.
• Michigan Food Waste Roadmap: A Plan to Reduce Food Waste and Loss in Michigan by 50 Percent. 2024. Michigan Sustainable Business Forum.