July 2026
Gold Standard Foundation
Standards & Certification
Submitted via the SASS public consultation
Re: Public consultation on the draft Safe Sanitation Services (SASS) methodology (GS4GG PAA M400-XX)
Dear Gold Standard Secretariat,
We write as members of the Millennium Water Alliance (MWA) Climate Finance Technical Working Group (TWG) and allied organisations working to deliver safe sanitation services in low- and middle-income countries. We welcome the development of the Safe Sanitation Services methodology and appreciate Gold Standard's continued engagement with the WASH sector. A robust, workable sanitation methodology can unlock carbon finance for services that avoid methane emissions while advancing SDG 6.2, and we want this methodology to succeed.
Our working group previously submitted consensus feedback on the update to the Gold Standard Safe Drinking Water (TPDDTEC) methodology. Several of the concerns raised there, in particular on the Downward Adjustment Factor, the treatment of suppressed demand, the definition of common practice, and the cumulative effect of stacked conservativeness adjustments, apply directly to the SASS draft. We restate them here in the sanitation context alongside new, sanitation-specific feedback.
The draft caps the methane correction factor for suppressed-demand (open defecation) populations at 0.5 and applies a further 5% deduction (ADJSD), based on the assumption that the counterfactual is a basic pit latrine. In many of our members' contexts in Sub-Saharan Africa, the realistic counterfactual is a wet pit latrine with a high water table, for which the IPCC MCF is 0.7. A single uniform cap does not reflect the diversity of baseline sanitation conditions. We request that Gold Standard allow a regional adjustment where hydrogeological data supports a higher counterfactual MCF.
The 0.66 Usage Adjustment Factor is applied to the entire unadjusted baseline, already a 34% reduction. It then compounds with the suppressed-demand cap, the 5% suppressed-demand deduction, the Operational Fraction, the Collection Compliance factor, and the Downward Adjustment Factor. Taken together, these layers may reduce creditable volumes by 60–70% for a typical container-based sanitation project in East Africa, to the point where projects become financially unviable. We request that Gold Standard publish a worked example showing total credit volume with all conservativeness layers applied, clarify how the layers interact, and confirm that the cumulative effect is intentional rather than an artefact of stacking independent discounts.
The required Baseline Scenario Survey at 90/10 precision is resource-intensive for organisations operating across multiple cities or countries. We request clarification on whether recognised sector datasets (JMP, MICS, DHS, government WASH surveys) can supplement or replace primary data collection in establishing baseline pathway proportions, particularly for Programmes of Activities spanning several countries.
The mass-balance chain-of-custody assessment required for CCy assumes infrastructure such as weighbridges and intake tank gauges that many faecal sludge management providers, particularly manual emptiers and operators in informal settlements, do not have. We request clearer guidance on acceptable proxy methods, such as container counts and standard fill-weight assumptions, that can satisfy the mass-balance requirement without prohibitive infrastructure investment.
The additionality test requires demonstrating that safe sanitation is "not yet the norm," but the draft does not define a quantitative threshold. Pit emptying may be common in rapidly urbanising areas, yet verified safe treatment of collected sludge is extremely rare. We recommend that Gold Standard adopt a quantitative common-practice threshold aligned with the JMP "safely managed sanitation" service ladder. In most SASS-eligible markets, safely managed coverage is below 20%, which should satisfy the not-common-practice test by default; stating this explicitly would reduce the burden of per-project assessments.
Including all distributed units in the OFy sampling frame is appropriately conservative, but service providers naturally lose customers over time. We request clarification on the treatment of units formally decommissioned by the service provider, as distinct from units abandoned by users.
We support strong safeguards on treated-product safety. However, forfeiting all emission reductions for a batch on any pathogen exceedance treats a minor single-parameter exceedance the same as a major failure, and denies credit for methane avoidance that did in fact occur upstream of the treatment quality issue. Consistent with our drinking water feedback on Water Quality Risk penalties, we recommend a tiered or proportional approach, for example partial crediting where some but not all safety parameters are met, or an allowance for re-treatment within a defined window.
The IPCC 2019 regional default for Africa (0.037 kg BOD/person/day) may underestimate organic load in some sub-regions. The draft permits measured values but does not specify the measurement protocol. We request clear guidance on acceptable methodologies for projects seeking to demonstrate higher-than-default BOD.
Shifting household baselines to zero when a municipal sewer expands into the activity boundary is appropriate only if that system actually delivers safely managed sanitation. In many cities, sewer pipes exist but are non-functional or discharge untreated sewage. We request that the trigger be defined against the JMP "safely managed" standard, including functional treatment, rather than physical pipe presence.
The requirement to demonstrate homogeneity across technology, geography, and system age before pooling samples is reasonable, but the hard cap of 10 VPAs appears arbitrary. For providers operating uniform container-based systems across 20 or more cities, the cap unnecessarily increases MRV costs. We recommend allowing larger pools where homogeneity is demonstrated and validated.
As we argued in the drinking water consultation, the DAF is a programme-level tool that creates revenue unpredictability when embedded in methodologies. If it must apply to SASS, it should not compound with the conservativeness already built into the methodology (the UAF and suppressed-demand cap), it should be set at a level that preserves project financial viability, and it should be fixed and transparent at project registration so developers can model revenues. These principles apply with greater force to sanitation, where financial margins are thinner than in water treatment. At minimum, we request sector-specific DAF guidance recognising the UAF as an existing ambition signal.
The draft does not define how Ongoing Financial Need is assessed at crediting period renewal. A sanitation service that has grown because of carbon revenue should not be disqualified for that success when withdrawing the revenue would collapse the service. We recommend a transparent, auditable "continued service dependency" test, for example: carbon revenue constitutes more than a defined share of total service revenue, and without it the service would operate at a loss or cease operations.
The indicative cradle-to-gate factors drawn from the UK-centric ICE database may not reflect manufacturing in project countries, and project-specific EPDs are expensive to obtain. We encourage Gold Standard to consider regionally appropriate defaults.
Annex 1 is listed as "to be added in the final version," which prevents stakeholders from reviewing the practical monitoring requirements during this consultation. We request that Gold Standard share Annex 1 before the consultation closes, or provide a supplementary consultation window covering the monitoring schedule.
We offer this feedback in a constructive spirit and would welcome a consultation session with the Gold Standard team to discuss any of the points above. Our members operate sanitation and water programmes across the geographies this methodology targets, and we are glad to contribute operational data, worked examples, or pilot participation to support finalisation.
Respectfully submitted,
The undersigned members of the Millennium Water Alliance Climate Finance Technical Working Group and allied organisations
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