Outside the city limits of Green Forest, Arkansas, a proposed poultry litter-to-biogas plant has prompted an important discussion about how this type of development should be understood and evaluated.
The proposed facility, advanced by SusBDe and Pelican Biogas, would process approximately 100,000 tons of poultry litter and Dissolved Air Flotation (DAF) sludge of the slaughterhouses per year, generating over 35 million cubic meters of biogas annually.
SusBDe’s primary business model is the development and operation of commercial-scale anaerobic digestion facilities that receive, process, and convert organic feedstocks into renewable energy. While the company also describes aspects of its technology as nutrient recovery, its principal business activity is the production of biogas through an industrial process.
Is it simply an extension of agriculture because its feedstocks originate from poultry operations? Or is it a separate industrial enterprise that happens to be located near the source of its raw materials?
The biogas industry itself has argued for the latter distinction.
In comments submitted to the U.S. Census Bureau regarding revisions to the North American Industry Classification System, the American Biogas Council petitioned for creation of a separate NAICS classification for biogas systems, arguing that the industry has matured into a distinct economic sector whose primary economic activity is biogas production.
The council further explained: “Clarification is needed because biogas systems are not farms or wastewater facilities. They are often located at these facilities because that’s where the source feedstock is located, but they create totally separate functions, and especially in the case of farms, separate business entities. The primary function of a biogas system is not to grow livestock or crops and it is not to clean wastewater.”
The Coalition for Renewable Natural Gas has advanced a similar position. In a 2023 petition to the Office of Management and Budget requesting separate NAICS industry codes for RNG production facilities, the coalition explained: “RNG production facilities are most often owned or operated by separate entities whose business and operations are distinct and easily distinguishable from the feedstock source itself.
“RNG industry developers generally secure biogas rights from the organic waste feedstock owner… RNG project developers often share revenue from the sale of RNG or monetization of associated environmental credits with the feedstock owner in the form of a royalty, but the RNG project developer separately raises the necessary capital and is responsible for overseeing or subcontracting all of the engineering, design, construction, operations and maintenance of the RNG production facility (a completely separate business from operating a landfill, wastewater treatment facility, livestock or agricultural operation, dairy, etc.).”
Both industry organizations recognize that these facilities are separate business enterprises—not simply extensions of the farms, landfills, wastewater treatment plants, or agricultural operations that supply their feedstocks.
A facility receiving approximately 100,000 tons of poultry litter and DAF sludge each year and converting those materials into renewable natural gas is more than a traditional farm operation. It is a separate enterprise with its own infrastructure, financing, utility demands, transportation network, workforce, and environmental responsibilities.
If a biogas facility is, as the industry itself maintains, a separate industrial enterprise, then it should receive the same careful scrutiny, transparency, and accountability expected of any other industrial development, and should be evaluated as separate businesses.
Evaluation of the proposed project should therefore focus on its identity as an industrial-scale biogas operation, including its resource demands, infrastructure needs, public safety considerations, financial structure, and overall environmental footprint.
That means asking straightforward questions: How much water and electricity will the facility require? What road improvements or traffic management will be necessary? What are the expected impacts of truck traffic, noise, odor, air emissions, and industrial activity? What monitoring and reporting will verify that the facility operates as proposed? How will emergency response, fire protection, and public infrastructure be affected? To what extent does the business model depend on federal tax incentives, renewable energy credits, carbon markets, USDA programs, grants, loans, or other public financing mechanisms? What long-term financial assurances exist to protect the public if operations cease or ownership changes?
As demand for electricity continues to grow and some AI data centers and other energy-intensive industries explore renewable natural gas as part of their energy strategies, local governments may see increasing interest in industrial-scale biogas and RNG facilities. That possibility makes it even more important for counties and the state to establish consistent standards for evaluating these projects before they are proposed or expanded.
As Arkansas considers proposals for industrial-scale biogas and renewable natural gas facilities, county judges, quorum courts, planning commissions, and state regulators should evaluate these projects according to their actual industrial operations—not merely the source of their feedstocks or the labels used to describe them. Before permits are issued or public incentives are extended, communities deserve complete, transparent information about water use, electrical demand, transportation impacts, emergency response, nutrient management, environmental safeguards, and long-term financial assurances.
Good public policy depends on informed decision-making, consistent standards, and accountability to the communities these facilities are intended to serve.
Dane Schumacher