Fwd: Consultation - TNFD Alternate Fuels Sector Guidance (due 5 May)

[coordinación]

---------- Forwarded message ---------
De: Policy Support at WBA <policy...@worldbiogasassociation.org>
Date: jue, 30 abr 2026 a la(s) 8:30 a.m.
Subject: Consultation - TNFD Alternate Fuels Sector Guidance (due 5 May)
To: Policy Support at WBA <policy...@worldbiogasassociation.org>

Dear WBA members,

WBA is seeking to respond to the TNFD Draft Sector Guidance for Alternate Fuels.

TNFD Draft Sector Guidance for Alternate Fuels

The Taskforce for Nature-Related Financial Disclosures (TNFD) Alternative Fuels guidance is a sector-specific document that can be used by companies to identify and disclose nature-related risks and opportunities across the fuel transition value chain. For the biogas sector, it is relevant because it provides tailored metrics for assessing dependencies on land, water, and organic feedstocks while highlighting the environmental benefits of waste-to-energy circularity. Biogas stakeholders can utilise this in their reporting on biodiversity and ecosystem impacts to meet the growing transparency demands of green investors.

In our draft response we welcome the development of this framework and its recognition of value chain impacts but highlight several areas where the framework could be strengthened, providing recommendations to improve its clarity, proportionality, and applicability for the biogas sector.

Key points include:

• Recognition of avoided impacts: The draft guidance should better account for avoided impacts, particularly methane capture from waste and the negligible land-use footprint of waste-based feedstocks. 
• Improved metrics and clarity: Recommendations include clearer treatment of waste-based and rotational crop-based feedstocks in land-use metrics, refinement of pollution and allocation methodologies, and inclusion of additional metrics such as landfill diversion and methane leakage. 
• Digestate as a nature-positive outcome: Greater recognition is needed for digestate’s role in replacing synthetic fertilisers and improving soil and water health. 
• Biogas as a circular economy catalyst: Biogas should be treated not just as a fuel, but as part of an integrated circular economy linking waste management, energy, and agriculture. 
• Alignment with existing frameworks: Greater alignment with existing standards (e.g. RED III, ISCC) is encouraged to reduce reporting burden and improve consistency and feasibility.
• Proportionate reporting requirements: The framework should reflect the structure of the sector, including SMEs, through tiered reporting, use of proxy data, and phased implementation timelines. 
  
  

Members are requested to provide feedback on the draft WBA response by end of day Monday 4th May, covering general feedback drafted for TNFD and on the responses to the pointed questions. All feedback will be greatly appreciated and taken into consideration when finalising our consultation response. We have included page numbers for the relevant section of the draft guidance for ease of reference.

Kind regards,

WBA Policy Team

Policy Support Team
e: policysupport@worldbiogasassociation w: www.worldbiogasassociation.org Fifth Floor, Riverside Building, Country Hall, Westminster Bridge Rd, London, SE1 7PB UK
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