Japan Gas Association turned in open letter GHG Protocol Secretariate
on the revision of the GHG Protocol
January 31, 2024
The Japan Gas Association
In full awareness of the urgent need to act on climate change, Japan Gas Association(JGA) is aiming to substitute natural gas with e-methane up to 90% by the year of
2050. e-methane is produced from power and CO2 which will not increase the overall
CO2 concentration in the atmosphere.
Aiming to reflect the environmental benefit of emerging new carbon recycled fuels in
GHG Protocol, JGA together with other 17 companies, associations, and organizations
turned in open letter on January 25th (JST) to GHG Protocol Secretariate to advocate
for a pivotal update to the Greenhouse Gas Protocol (GHG Protocol) which isscheduled to be updated this year.
In the open letter, we proposed the inclusion of a market-based approach for carbon
recycled fuels, including e-methane, e-fuels and Sustainable Aviation Fuels in Scope
1 as for Market-based approach, use of certificate, already available for power in
Scope 2.
This proposed update can help reshape the landscape of emissions reduction
strategies and redefine the role that low-carbon fuels can serve as a positive solution
towards a more sustainable future.
GHG Protocol, a widely recognized and respected framework for accounting andreporting greenhouse gas emissions, should reflect the evolving needs of our time.
Incorporating market-based accounting into the Scope 1 emissions reporting would
have a profound impact on how businesses measure and manage their emissions,and how quickly they transition to a low-carbon economy.
In submitting the open letter, we received warm gratitude from the GHG Protocol
Secretariat for our interest in the revision and exchanged opinions with the GHG
Protocol Secretariat on our proposal.

JGA will continue to communicate with the GHG Protocol Secretariat, aiming todevelop rules that recognize the emission reduction benefit of recycled carbon fuels
including e-methane, which will contribute to the achieving of a true decarbonizedsociety.
For further inquiry please contact below
JGA Public Relations Section
Yohei Kagawa, Mr.
Phone +81-3-3502-0112
Email kagawa.yohei@gas.or.jp

Proposal for Inclusion of Market-Based Accounting in Scope 1 of
the GHG Protocol Update
25 January 2024
Dear GHG Protocol Secretariat,
In full awareness of the urgent need to act on climate change, the undersigned companies,
associations, and organisations together advocate for a pivotal update to the Greenhouse
Gas Protocol (GHG Protocol). We propose the inclusion of a market-based approach andthe recognition of low-carbon fuels1 certificates in the GHG Protocol's Scope 1 inventory.
This proposed update can help reshape the landscape of emissions reduction
strategies and redefine the role that low-carbon fuels can serve as a positive solution
towards a more sustainable future.
The urgency of addressing climate change is undeniable. That’s why we believe that the
GHG Protocol, as a widely recognized and respected framework for accounting andreporting greenhouse gas emissions, should reflect the evolving needs of our time.
Incorporating market-based accounting into the Scope 1 emissions reporting would have a
profound impact on how businesses measure and manage their emissions, and how quickly
they transition to a low-carbon economy.
Implications for the Inclusion of Market-Based Accounting in Scope 1 GHG Protocol
This proposal follows the already established market-based approach in Scope 2 GHG
Protocol that has been instrumental in increasing renewable electricity use. By allowing theusage of low-carbon fuel certificates within Scope 1 inventory calculations, we can unlock a
multitude of benefits:
Greater Real-World Impact: By integrating market-based solutions, the GHG
Protocol update will have a tangible and measurable impact on emissions
reduction, aligning with the global climate goals outlined in the Paris Agreement.
Global Leadership: Embracing a market-based approach demonstrates ourcollective commitment to leading the fight against climate change. This approach
has already gained traction and success in the renewable energy sector, and it's
time for us to extend its reach through the GHG Protocol.
More Flexibility and Viability: Businesses often face challenges whentransitioning to low-carbon alternatives due to infrastructure limitations andtechnological barriers. Allowing the use of certificates enables businesses tomake meaningful emissions reductions using the existing infrastructure anddemand-side facilities without compromising operational viability, and paving the1

Low Carbon fuels are fuels that have fewer emissions, resulting in a lower carbon footprint compared to
traditional fossil fuels. They can be used to generate electricity for industrial facilities, heat and power systems.
These fuels either reduce lifecycle carbon emissions or recycle carbon. They are produced through various
methods, including biological and chemical processes or a combination of these processes. Examples of lowcarbon fuels include sustainable aviation fuel, biodiesel, biomethane, e-fuels and e-methane. Reference:“Low Carbon Fuels and Energy Sources Basics” Energy.gov, accessed October 31, 2023

way for more technological advances.
Stronger Market Incentives: Including low-carbon fuel certificates in the Scope
1 inventory will create a strong economic incentive for industries to shift towards
greener energy sources. This would stimulate demand for low-carbon fuels anddrive innovation and investment in their production.
The net-zero energy systems of the future will be a combination of various technologies
impacting how we produce and use energy. Alongside electrification, green hydrogen, andsustainable bioenergy, Carbon Capture and Utilisation (CCU) technologies applied torecycled carbon fuel generation will play a major role in reducing and removing emissions
across key sectors to balance emissions that cannot be avoided – a critical part of the “net”
zero goals. Therefore, there is also a need in the future to provide new guidance onemissions accounting for recycled carbon fuels or CCU technologies that are not currently
included in GHG protocols.
The time for action is now
We need all stakeholders to work together to drive this essential update to the GHG
Protocol. In championing this cause of the inclusion of a market-based approach into
the GHG Protocol update, we are signing this open letter and joining forces with agrowing number of partners from a variety of industries that commit to sustainable practices
and innovation. Together, we can influence policy changes that have far-reaching
implications for the future of our planet and generations to come.
We trust the WRI and the WBCSD will therefore consider this issue seriously.
Sincerely,Our Signatories (by alphabetical order)

About Daigas GroupThe Daigas Group was launched in 2018 as a group brand of a corporate group led by Osaka Gas,
the second largest gas supplier in Japan with a history going back more than one century. Osaka Gas
aims to achieve carbon neutrality across Daigas Group by 2050 as a goal set in the Carbon Neutral
Vision released in January 2021 and Energy Transition 2030 released in March 2023. To realize thisambition, the company pursues net zero solutions, including e-methane, and drives e-methane
technology development through R&D activities and demonstration projects in Japan to promote its
wide usage. It also proceeds with several feasibility studies to produce e-methane in strategic
locations, such as North America, South America, Australia, the Middle East, and Southeast Asia.

About European Biogas Association
The European Biogas association, founded in February 2009, is committed to the deployment ofsustainable biogas and biomethane production and use throughout the continent. The EBA fully
believes in the future potential of renewable gas in europe. EBA counts today a well-establishednetwork of nearly 250 national associations and other organisations covering the whole biogas andbiomethane value chain across europe and beyond.

About Eurogas
Founded in 1990, Eurogas is an association of 94 companies and associations, spanning the entire
length of the gases value chain. Its members cover wholesale and retail gas markets, the distribution

of natural renewable and low carbon gases and their derivatives and the use of gas in transport.
Eurogas also represents technology providers including companies active on value chain methane
emissions management.
Eurogas is committed to accelerate the transition to climate neutrality through dialogue and advocacy
on optimising the use of gases. Together with its members it produces research, responds toconsultations, provides input to studies, analyses the impact of EU political and legislative initiatives,and communicates key findings to EU stakeholders. An established structure of expertise ensuresthat Eurogas’ views are defined and endorsed by experts in the energy field.

About European Renewable Gas Registry
ERGaR is the European Renewable Gas Registry. It facilitates the cross-border trade of renewable
gas certificates in Europe. Furthermore, it provides a forum for all stakeholders in the renewable gas
certification supply chain.

About Francegaz
France gaz (www.francegaz.fr ) represents the French gas industry, responsible for all fuel gases(natural gas, renewable gases, liquid gases, hydrogen). It brings together gas players across theentire gas chain, committed to producing renewable gases, aiming for carbon neutrality by 2050,
ensuring France's security of supply, and enabling all customers to be committed players in theenergy transition. A member of the Conseil Supérieur de l'Énergie and Medef, France gaz is also amember of the European associations Eurogas and Marcogaz, as well as the International Gas
Union.

About Hycamite
By splitting methane, Hycamite produces affordable, clean hydrogen and solid, high-value
industrial-grade carbon products. Hycamite is a fast-growing and award-winning company founded in
Kokkola, Finland in 2020 to fight climate change. Hycamite’s technology is a thermo-catalytic
decomposition (TCD) process based on the company’s proprietary family of catalysts. The technology
is a product of more than 20 years of research at the University of Oulu.
Hycamite’s mission is to decarbonize industry, and our vision is to pave a clean way for our customers
with the most profitable decarbonization solutions.

About International Gas Union
The International Gas Union (IGU) is a global organisation, which represents more than 150 membersin over 80 countries, covering more than 90% of the global gas value chain. The members of the IGU
are national associations and commercial entities of the gas industry worldwide, engaged in every
aspect of the gas supply chain, from production of natural, renewable, hydrogen and other low andzero-carbon gases through their transportation, delivery, and all the way to end-use. www.igu.org

About the Japan Gas Association
The Japan Gas Association (JGA), an organisation of city gas utilities, contributes to the economy
and people’s welfare in Japan by promoting the sound development of the general gas utility businessas well as the major gas-related projects and gas pipeline projects and by coordinating the stableenergy supply, ensuring safety and addressing environmental issues. JGA has approximately 200
member companies. In November 2020, JGA declared that the gas industry would take on thechallenge of "carbon neutralising gas in 2050," and expressed its determination to realise adecarbonized society.

About Mitsubishi
Mitsubishi Corporation (MC) is a global integrated business enterprise that develops and operates
businesses together with its global network of around 1,700 group companies.MC has 10 BusinessGroups that operate across virtually every industry: Natural Gas, Industrial Materials, Chemicals
Solution, Mineral Resources, Industrial Infrastructure, Automotive & Mobility, Food Industry,
Consumer Industry, Power Solution and Urban Development. Through these 10 Business Groups
plus the addition of its Industry Digital Transformation Group and Next-Generation Energy BusinessGroup, MC’s current activities have expanded far beyond its traditional trading operations to include
project development, production and manufacturing operations, working in collaboration with ourtrusted partners around the globe. With an unwavering commitment to conducting business withintegrity and fairness, MC remains fully dedicated to growing its businesses while contributing to aprosperous society.

About Mitsui O.S.K Lines
MOL, headquartered in Japan, is a leading shipping company, operating on a global scale with about
800 vessels in service. The company develops various social infrastructure businesses centered on
ocean shipping, as well as technologies and services to meet ever-changing social needs including
environmental protection. The MOL fleet includes dry cargo ships, liquefied natural gas (LNG)
carriers, car carriers, and tankers. In addition to the traditional shipping businesses, MOL also offers
wellbeing & lifestyle businesses such as real property, terminal operation, and ferry service, as well associal infrastructure businesses such as logistics and offshore wind power. With one of the largest
merchant fleets and about 140 years of history, experience, and technology, MOL will make a leap
forward to become a global social infrastructure company, support people's daily lives from the blue
ocean, open the way to a prosperous future, and deliver new value to all stakeholders.

About Saibu Gas Holdings
Saibu Gas Holdings Co., Ltd. supplies gas energy in Northern Kyushu region as its core business andexpands into power and other energy sectors as a “comprehensive energy and lifestyle services
company”.
In September 2021, Saibu Gas Holdings Co., Ltd. formulated a guideline named “Saibu Gas Group
Carbon Neutrality 2050”and declared that we are committed to realizing the decarbonized society.

About Santos
Santos provides reliable, affordable energy for progress and seeks to provide lower carbon energy
over time. We are a global energy company with operations across Australia, Papua New Guinea,
Timor-Leste and the United States. Santos is an important Australian domestic gas supplier and LNG
supplier in Asia. The company is committed to supplying critical fuels such as oil and gas, and abating
emissions through carbon capture and storage, energy efficiency projects, use of renewables in ouroperations and high-quality offsets. Santos will also seek to develop low-carbon fuels as customer
demand evolves.

About The Scheduled Airlines Association of JapanThe Scheduled Airlines Association of Japan is an industry organization consisting of 19 Japanesescheduled air carriers. We work to solve various problems in the air transport business and topromote sound development of the air transport business in Japan.
We contribute to " development of the Japanese economy" and the realization of a "sustainable
society including decarbonization" through the air transportation business.

About South Pole
South Pole, recognised by the World Economic Forum as a Social Enterprise, has been at theforefront of decarbonization since 2006. With its global climate solutions platform, South Poledevelops and implements comprehensive strategies that turn climate action into long-term business
opportunities for companies, governments and organisations around the world. South Pole is also a
leading project developer and has provided nearly 1,000 projects in over 50 countries with climate
finance to reduce over a gigaton of CO2 emissions, and to provide social benefits to less privileged
communities who are particularly vulnerable to climate change.

About STX GroupSTX Group is a leading global environmental commodity trader and climate solutions provider.
For over 25 years, STX teams have been at the forefront of the global transition towards a
low-carbon economy. By leveraging its expertise in accurately pricing pollution and emissions, it
has helped to cultivate trust in market-based solutions to the decarbonization of the economy.
With its trading and Corporate Climate Solutions offerings, STX ensures that money flows tohundreds and thousands of projects that make the world a greener place, while providing
corporations with the certified proof-points of their contributions to environmental progress.
After acquiring Vertis and its subsidiary Strive in December 2021, the STX Group now boasts a
diverse team of nearly 500 employees from over 50 countries. Headquartered in Amsterdam,
the Netherlands, STX Group has 13 offices around the world and an annual trading volume ofover EUR 4 billion. For more information, please visit https://stxgroup.com/

About Toho Gas
Based on "Toho Gas Group 2050 Carbon Neutrality Initiative", we are promoting low carbonizationand decarbonization at customer locations, with the pivot being the three types of energy of gas,hydrogen, and electricity, and tackling the challenge of achieving carbon neutrality in our entire value
chain.

About Tokyo Gas
Tokyo Gas is the largest city gas supplier in Japan and a Japanese integrated energy company withdiverse businesses spanning electricity generation, energy retailing, engineering solutions, upstream
LNG, and real estate development. As part of the Tokyo Gas Group’s management vision “Compass
2030,” Tokyo Gas has been taking actions to realize a decarbonized society by tackling the challengeof achieving “Net-Zero CO2.” As an energy provider for the Tokyo metropolitan area, Tokyo Gas
supports its customers’ decarbonization efforts by promoting the sophisticated use of LNG. At thesame time, Tokyo Gas focuses on renewable energy power plant development, CCUS utilization,hydrogen production technology development, and commercialization of e-methane(e-NG) and otherhydrogen carriers. In order to establish supply chains for e-methane(e-NG), Tokyo Gas is currently
carrying out feasibility studies in North America, Malaysia, Australia, and other regions with trading
companies and global energy companies. Tokyo Gas will lead the transition to a decarbonized society
by achieving both stable energy supply and decarbonization.

About World Biogas Association
The World Biogas Association is the global trade association for the biogas, landfill gas and anaerobic
digestion sectors, dedicated to facilitating the capture, treatment and recycling of the 105bn tonnes ofmethane-emitting organic wastes generated by humans every year through biogas. We seek tosupport all organisations working in the biogas industry at the international level across the world toachieve this, including: national associations; biogas operators and developers; supply chain; watercompanies; the agricultural sector; waste companies; and academic & research institutions.
www.worldbiogasassociation.org