This paper discusses the key issues with developing a GHG offsets methodology for bus fleet upgrades, including options for setting a performance threshold for identifying those projects that should receive credit. A performance standard sets a threshold emissions level that is significantly better than the average emissions performance for a specified service. In this case, we expect the threshold to be set by reference to the emissions performance of bus fleets. If a project for improving fleet performance has emissions that are equal to or better than the threshold, then the project would be considered to exceed the "business-as-usual" (BAU) performance and would be eligible for registration of emission reduction credits.