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World Resources Institute responds to GHG Protocol Joint Letter coordinated by WBA

As we wrote here, WBA has coordinated a joint letter with close to 60 signatories to the World Resources Institute (WRI) to highlight the huge impact that the newly drafted ‘Land Sector and Removals Guidance’ under the GHG Protocol 1is having on biomethane certificates and therefore on the global biogas sector.

The GHG Protocol – administered by the WRI – is globally recognised as the leading GHG accounting standard. Until recently, corporates wanting to decarbonise their emissions purchased biomethane certificates and reported this as part of their Scope 1 emissions accounting2, but this will no longer be possible under the proposed new guidance.

With only 7 years remaining to the 2030 target of the Global Methane Pledge, we need biogas to recycle the over 105 billion tonnes of organic wastes that humans generate, which would otherwise emit methane. The biogas sector alone could achieve half of the Global Methane Pledge, while delivering one third of today’s global natural gas consumption and a 10% reduction in total global greenhouse gas emissions. Biomethane certificates are pivotal to achieve the sector’s potential.

The response of Pankaj Bhatia, Director of the GHG Protocol, showed that the WRI took onboard the sector’s concerns and request to remove the criticalities of the new Guidance. He wrote:

Dear Charlotte,

Thank you for your letter. We take your concerns and feedback seriously.

We have heard feedback through the Review Group that many stakeholders would like Annex B to be removed, pending the upcoming process to evaluate market-based accounting more generally under the GHG Protocol. We will decide the next steps for Annex B through the Advisory Committee and Technical Working Group including deciding whether to remove part or all of Annex B.

Next steps in the process:

Compile feedback from the Review Group (the GHG Protocol secretariat is currently working through over 3300 individual comments from over 300 reviewers received during the public consultation phase)

Compile feedback from Pilot Testing Group (comprised of over 150 pilot testing companies and organizations); pilot testing is still underway with feedback due February 28

Identify and raise key issues from Review Group and Pilot Testing feedback for the Advisory Committee and Technical Working Group in Q2 2023, one of which will be Annex B.


With regard to Annex B, there are multiple potential options arising from the Review Group feedback for the Advisory Committee and Technical Working Group to consider, including: removing Annex B altogether; amending Annex B to refer only to the forthcoming process to resolve the market-based accounting issue more generally across sectors; amending Annex B to include text from the Scope 2 Guidance Appendix A from 2015 while referring to the forthcoming process to evaluate market-based accounting more generally; or other options. We will take these (or other options as we continue to analyze Review Group and Pilot Testing feedback) to the Advisory Committee and Technical Working Group for resolution in ~Q2 2023, prior to publication of the Land Sector and Removals Guidance in ~Q3 2023.

Meanwhile, the GHG Protocol is beginning a broader process to evaluate the role of market-based instruments holistically, in partnership with other key players such as the Science Based Targets initiative. For further background please see the market-based accounting memo.

The first step in this process is the global survey now underway to collect stakeholder input on the need for updates or additional guidance to the current set of standards, including on market-based accounting. We invite your participation in the surveys as well as your proposals for how to address specific accounting issues. The deadline has been extended to March 14.

We appreciate your comment that “The biogas industry recognizes, however, the importance of ensuring that biomethane certificates do indeed evidence real decarbonization and additionality, and is therefore committed to working with the WRI and WBCSD to ensure robust criteria are developed.” We encourage the WBA to submit a proposal through the survey process for how to account for GHG emissions from biomethane in a robust way that meets these objectives and criteria. This would be an important step forward to find a solution to this issue.

Best regards,


We are currently coordinating a response to the WRI’s surveys, and we will work with the WBA GHG Protocol Working Group on Pankaj’s request to share a proposal for how to account for GHG emissions from biomethane in a robust way.

Please contact Leanne Williams at if you are interested in taking part in the working group.

WBA is part of the official Technical Working Group of the WRI, so we will make sure to raise the same concerns in future meetings of the group.

We will also continue to call on the WRI to remove the proposed new Guidance and reinstate the previous guidance as quickly as possible.



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