LET GREEN GAS COUNT!

The AMI Standard Joint Letter, June 2026

To the Members of the Actions & Market Instruments (AMI) Working Group: 

The undersigned entities are global economic operators responsible for the production, trading, transport, and consumption of renewable gaseous fuels and their derivatives.¹ This letter was organized by the Let Green Gas Count Campaign as a follow-on to previous communications² regarding the urgent need to reflect purchases of renewable gaseous fuels within the Greenhouse Gas Protocol (GHGP), and conveys priorities of the renewable gaseous fuels industry in response to the Actions & Market Instruments (AMI) White Paper. 

The renewable gaseous fuels industry appreciates the direction of the GHGP in developing a framework that will support contractual purchases, however we remain concerned that outstanding uncertainties within the AMI White Paper could lead to the development of an unworkable standard. In completing Phase 1 of the AMI process, GHGP has an opportunity to align treatment of renewable gaseous fuels with long-standing best practices that are common across existing regulatory and voluntary market policies. With this in mind, we urge GHGP to: 

1. Uphold Recognition of Contractual Purchases and Clarify Chain-of-Custody Treatment 

GHGP must uphold recognition of contractual purchases and provide additional clarity regarding how varying chain-of-custody models fit into the physical vs. market-based inventories.

The AMI White Paper indicates that GHGP will recognize contractual purchases across scopes 1, 2, and 3. This represents significant progress toward alignment between GHGP and established practices. Varying chain-of-custody models which apply to renewable gaseous fuels purchases will be reflected in the physical and market-based inventories,³ however, additional clarity is required. 

     2. Set Achievable Quality Criteria that Include Existing Market Practices 

GHGP must set quality criteria that are sufficiently high-level to encompass established practices across existing regulatory and voluntary programs. 

The AMI White Paper describes possible quality criteria for activities that fall within the AMI Standard, which would cover renewable gaseous fuels, and are set to be established in Phase 2. Mandating quality criteria that are overly restrictive would immediately and severely limit the volume of transactions that can be reflected under GHGP. This level of misalignment could render the standard unusable for certain sectors. 

LGGC has developed the ”High-Level Recommendations”⁴ as a starting point for this discussion with the AMI Working Group. 

    3. Design an Impact Statement that Enables Reporting of Upstream Benefits and Disbenefits 

GHGP must develop its new impact statement in a way that enables transparent reporting of the renewable gaseous fuels based on life cycle assessment (LCA). 

LCA is widely utilized across regulatory and voluntary programs to (1) assure that sustainable fuels & feedstocks reduce emissions compared to their fossil fuel counterparts, and (2) realize the broad climate and environmental benefits that these technologies can achieve by valorizing consequential impacts. If GHGP wishes to align itself with functioning markets, it will be crucial for the AMI process to develop a concept for recognizing and valuing lifecycle impacts associated with molecules.  

Interoperability with Existing Regulatory and Voluntary Markets is the Goal of LGGC 

The international climate community and energy regulators have endorsed LCA and market-based purchases on a widespread basis to support the growth of renewable gaseous fuels. There are many examples of long-standing, successful programs that employ these tools; the AMI process represents an opportunity for overdue alignment between GHGP and renewable gaseous fuels markets on a global basis. 

It is the primary goal of the Let Green Gas Count Campaign to support interoperability between the GHGP and existing markets. If this does not happen, GHGP will be unusable for a wide swathe of technologies that are fundamental for reaching net zero. 

The window to get this right is narrow. We urge GHGP to complete this work in a way that reflects the investments companies are already making – and the progress the world urgently needs. 

We look forward to continued engagement with the AMI Working Group and GHGP to this end. 

This letter represents the collective views of the signatories but it should be recognised that individual signatories may express points differently or make additional points in connection with the AMI consultation. 

¹ These include but are 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. 
² Let Green Gas Count.
³ The white paper describes recognition of contractual purchases (“allows chain-of-custody models” – pg. 5) in both the physical
and market-based inventories. 
⁴ https://www.worldbiogasassociation.org/wp-content/uploads/2025/08/Recommendations-Let-Green-Gas-CountAugust-2025.pdf

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.

________________________

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.