LET GREEN GAS COUNT!

The Joint Letter, February 2025

“LET GREEN GAS COUNT!”

GHG Protocol should fully recognise robust market instruments in end-users’ scope 1 emissions inventories

To the attention of the members of the Greenhouse Gas Protocol governance bodies,

We, the undersigned, represent economic operators globally responsible for the production, trading and/or consumption of renewable gaseous fuels and their derivatives. We value the Greenhouse Gas Protocol (GHG Protocol) Corporate Standard as an important tool for companies all over the world to structure their decarbonisation efforts. The GHG Protocol withdrew guidance that previously provided a necessary investment certainty on the renewable gas market.

Renewable gases and their derivatives² are necessary to decarbonise the industry, transport and building sectors. Many of the decarbonisation strategies across the globe rely on their urgent deployment. A prerequisite for this deployment is the use of a market-based approach as it uniquely overcomes economic, technical and environmental barriers and inefficiencies that arise from the requirement for a physical (local) connection. Robust market instruments enable the supply of decarbonised products to a much wider pool of consumers that cannot have local access to such products.

We understand and appreciate that the GHG Protocol is in the process of revising its standards with a view to clarifying the use of a market-based approach. While this revision is ongoing, certainty must be provided and rules established: an interim statement, based on the previous guidance, should make clear that market-based instruments will be recognized at the end of the revision process. Since the withdrawal of the former Scope 2 Guidance Annex, market actors are lacking a framework giving them certainty to invest, and the August 2023 ‘Interim Update on Accounting for Biomethane Certificates’ has not provided clear steering.

The industry and the decarbonization of society cannot afford further delay.

We look forward to continued engagement in the GHG Protocol’s standards development process to provide more clarity and guidance on the use of renewable gas certificates.

Download the joint letter.

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¹ https://ghgprotocol.org/blog/interim-update-accounting-biomethane-certificates

² not limited to biomethane, hydrogen, e-methane and CO₂. They are used as fuels and feedstocks for applications such as sustainable aviation and maritime fuels and carbon-based chemicals and materials.

The Corporate End-User Letter, November 2025

In November 2025, the organising coalition behind the Let Green Grass Count campaign presented a follow-up letter to the GHG Protocol’s Co-Directors, Pankaj Bhatia (World Resources Institute) and Maia Kutner (World Business Council for Sustainable Development).

Dear Ms Kutner and Mr Bhatia,

We write to you as corporate and end-consumers of renewable gases¹, committed to the decarbonisation of our operations in alignment with urgent and imminent global climate targets. This letter follows up on the most recent letter sent to you by more than 200 companies and associations active in the renewable gases value chain².

The current absence of clear, interim guidance for renewable gas reporting under Scope 1 has left a critical gap for companies like ours – those that rely on renewable gases, supported by credible certification schemes, as a decarbonisation pathway where electrification is not feasible. This uncertainty severely undermines our ability to meet GHG reduction targets and, in turn, is stalling investment in renewable gas production, infrastructure and procurement.

We understand that since February 2023 recognition of market-based instruments has been under discussion within Greenhouse Gas Protocol workstreams, currently in the ongoing Actions and Market Instruments (AMI) Technical Working Group. We are increasingly concerned by signs in the AMI work programme that could delay the revision process beyond the projected – and already late – deadline of 2028 for the end of the process.

In this context, we feel compelled to reiterate and escalate our call for action: the Greenhouse Gas Protocol should take bold action to ensure that the workstream on the Market Instrument Guidance not only stays on track, but is actually fast-tracked. Additionally, we urge the Greenhouse Gas Protocol to issue an interim statement providing certainty that the revision process will eventually recognise robust market-based instruments in GHG inventories. This will offer clarity and confidence for stakeholders as final standards are being developed.

These two actions could be undertaken in line with the GHG Protocol’s internal procedures, which provide the Secretariat with the necessary flexibility to submit a proposal for an interim statement to the Steering Committee³. During Mr Bhatia’s meeting with the leadership of the European Biogas Association and RNG Coalition at New York Climate Week in 2023, it was agreed that there is urgency “to define a reliable and solid methodology for biomethane certificates, as more and more companies using the GHG Protocol framework look to biomethane to decarbonise their activities”⁴. It was also agreed that the organisations would host a joint workshop in 2024. To date, no additional clarity has been provided by the GHG Protocol on this matter, and planning for a workshop was cancelled by the World Resources Institute.

We would be open to contributing to this process and welcome opportunities to engage in your work. A timely signal from the GHG Protocol would send a powerful message to the market and help ensure that renewable gases continue to play their essential role in delivering on global climate goals.

Respectfully,

¹ Includes hydrogen, biogas, biomethane and e-methane.
² Let Green Gas Count.
³ As per Sections 2.2.1.ii of the Governance Overview; 3.2.1 and 5.3.1 of the SC Terms of Reference.
⁴ European Biogas Association to cooperate with global GHG Protocol in developing rules for the reporting of biomethane purchase (25 September 2023).

With this form organisations can register as co-signatory of this joint letter with respect to the use of renewable gas certificates within the GHG Protocol framework. The joint letter is an initiative by the World Biogas Association, Eurogas, European Biogas Association, and the Renewable Natural Gas Coalition. By filling in this form the organisation’s contact person agrees with the organisation’s name and logo to be published publicly on the joint letter and used during the related outreach. The contact person also agrees to be contacted regarding any activities related to the advocacy on this topic.