California Air Resources Board

June 1, 2026
RE: Waga Energy Public Comments on March 23, 2026 Climate Disclosure Workshop

To whom it may concern,

Waga Energy is pleased to submit the following comments to the California Air Resources Board (CARB) related to the March 23, 2026 Climate Disclosure Workshop.

Waga Energy is a renewable natural gas producer specialized in upgrading landfill gas into pipeline-quality biomethane through proprietary purification technology. Founded in 2015, the company develops, owns, and operates projects that convert landfill gas into a local, renewable energy source. Waga Energy employs nearly 300 people and operated 36 RNG production units worldwide, with 19 additional units under construction. Through these projects, Waga Energy helps reduce greenhouse gas emissions, support circularity, and expand the supply of low-carbon gas in North America and internationally.

Thank you for your consideration of the comments herein. Waga Energy welcomes the opportunity to answer any questions or provide additional clarification if helpful.

Sincerely,

Matthias AMOGHLI
Emissions & Sustainability Specialist
Waga Energy

Introductory remarks :

Waga Energy appreciates CARB’s engagement with stakeholders as it develops the reporting framework and welcomes the opportunity to contribute to this process.
Waga Energy supports CARB’s efforts to develop a reporting framework that is rigorous, practical, and interoperable with existing disclosure systems and requirements, while also recognizing the diversity of decarbonization pathways needed to achieve California’s climate objectives.

Q’s: What accounting methods does your organization currently use for Scope 1, 2, and 3 GHG emissions? Should CARB consider allowing other accounting methods? If so, which ones and why?

CARB could consider allowing a market-based approach for certain Scope 1 emissions, including the use of a North America-wide book-and-claim mechanism for renewable natural gas (RNG), where supported by robust contractual instruments, transparent tracking, and safeguards against double counting. This would best reflect how low-carbon gas is produced, traded, and consumed across interconnected pipeline systems, where physical molecule tracing is often not feasible. It would also be consistent with emerging accounting discussions and with existing voluntary reporting practice, including frameworks such as The Climate Registry, which provides credible greenhouse gas reporting tools and protocols across North America. Such an approach could also be operationalized through platforms such as CleanCounts (formerly M-RETS), which supports transparent tracking of environmental attributes across North America. Recognizing this approach would help accelerate demand for RNG as a practical decarbonization solution, especially in hard-to-abate sectors, while preserving the financial and environmental value of using pre-existing natural gas infrastructure rather than requiring costly new energy delivery systems. In addition to reducing methane emissions from waste and increasing the supply of low-carbon energy, RNG can support an efficient transition to a low-carbon economy by leveraging existing pipelines, interconnections, storage assets, and end-use equipment already in place.

Q’s: What criteria should emission factors meet to be used in this program? How should reporters document and explain their use of a particular emission factor, including proprietary models? How should reporters document and explain when changing EFs from a prior year?

CARB could consider allowing the use of supplier-specific emission factors where they are based on robust, transparent, and verifiable data, as these factors can better reflect actual project- and supply-chain conditions than generic default values. Reporters should clearly document the source, methodology, system boundaries, assumptions, and verification status of any such factors to ensure consistency and auditability. CARB should also allow the use of scientifically grounded calculation tools such as the Biogas Carbon Accounting Tool (Biogas CAT) where appropriate, particularly for landfill gas to RNG pathways, because these tools can more accurately capture site-specific performance and the emissions benefits associated with enhanced landfill gas capture. This is especially important in cases where improved methane collection can lead to very low or even negative carbon intensity outcomes that standard default emission factors may fail to reflect.

Additional Comments

In addition to GHG metrics, CARB could consider encouraging disclosure of a complementary material footprint indicator, for example expressed in kilograms of metal use, to provide greater visibility into broader resource-intensity trade-offs across decarbonization pathways. Such a metric would not replace emissions accounting, but could help decision-makers better understand infrastructure and material demand implications, particularly when comparing energy solutions that rely on significantly different levels of new equipment, metals, and system build-out. This type of supplemental indicator is increasingly relevant in broader climate accounting discussions as stakeholders seek a more complete view of environmental performance beyond greenhouse gas emissions alone.

Conclusion :
Waga Energy would welcome the opportunity to continue its dialogue with CARB as this initiative moves forward. We believe ongoing communication with stakeholders will be essential to ensure a successful, practical, and credible implementation framework, and we remain available to provide further input, technical perspective, and industry feedback as needed.