Public Statement to the ISB & Steering Committee of the GHG Protocol
Regarding Scope 2 Guidance Revisions
As the GHGP reviews public comments to their proposed Scope 2 revisions, we urge the Secretariat, Independent Standards Board, and Steering Committee to make hourly- and strict-deliverability-matching in the Market Based Method (MBM) optional, but not mandatory, by following a “may” rather than a required “shall” approach.
Since its publication in 2015, the GHGP Scope 2 Guidance has played a critical role in enabling over 250 gigawatts of clean energy projects around the world, delivering new carbon-free electricity (CFE) to grids, avoiding hundreds of millions of tons of carbon emissions, and catalyzing billions of dollars in economic investment.
We share the ambition to further accelerate CFE deployment and believe that achieving global greenhouse gas reduction goals depends on robust, voluntary demand for CFE. As this crucial guidance undergoes its first significant update in a decade, we are extremely concerned that the proposed revisions to market-based accounting which would require voluntary buyers to match CFE purchases to individual company load on an hourly and physically deliverable basis could:
-
Result in limited benefits to carbon accounting accuracy¹,²
-
Drive inefficiencies in private-sector action³,⁴, slowing system-wide decarbonization²,⁵,⁶,⁷,⁸
-
Discourage voluntary clean energy procurement, potentially dramatically⁹,¹⁰,¹¹,¹²
-
Increase electricity prices for individuals⁴ and companies¹²,¹³,¹⁴
To drive critical climate progress, it's imperative that we get this revision right. We strongly urge the GHGP to improve upon the existing guidance, but not stymie critical electricity decarbonization investments by mandating a change that fundamentally threatens participation in this voluntary market, which acts as the linchpin in decarbonization across nearly all sectors of the economy. The revised guidance must encourage more clean energy procurement and enable more impactful corporate action, not unintentionally discourage it.
Signed,
83 signatories, representing 52,000+ organizations, headquartered in 9 countries, operating in 220 countries & territories (every corner of the globe), with $9.4+ Trillion in annual revenues, employing 104+ Million people, and responsible for procuring, facilitating, and/or producing over 218 GW of carbon-free electricity projects.
[1] Greenhouse Gas Accounting Institute. May 30, 2025. Limitations of Hourly Matching Claims for Scope 2 Reporting. https://ghginstitute.org/2025/05/30/hourly-matching-limitations-for-scope-2-reporting/
[2] Hogan, Bill. Harvard University December 12, 2025. Scope 2: Physical Power Usage Accounting Is Fictional, Pricing And Marginal Impact Accounting Are Real. https://whogan.scholars.harvard.edu/sites/g/files/omnuum4216/files/2025-12/Hogan_GHCP_121225.pdf
[3] Open Letter: Expert Consensus on Carbon Impact. Accessed May 19, 2025.https://expertconsensusoncarbonimpact.com/
[4] TCR, June 2023. A Comparison of Strategies for Tackling Corporate Scope 2 Carbon Emissions. https://tcr-us.com/paths-to-carbon-neutrality-tcr-white-paper.html
[5] E3, Consequential Impacts of Voluntary Clean Energy Procurement, July 2024. https://www.ethree.com/wp-content/uploads/2024/07/E3_VoluntaryCorporateProcurement_HourlyEmissions_June-2024.pdf
[6] McKinsey & Co. Rethinking your company’s clean power strategy. February 12, 2025. https://www.mckinsey.com/industries/electric-power-and-natural-gas/our-insights/rethinking-your-companys-clean-power-strategy
[7] Johns Hopkins School of Engineering & REsurety, February 27, 2026. Carbon Impact of Intra-Regional Transmission Congestion https://www.cell.com/action/showPdf?pii=S2949-7906%2825%2900273-3
[8] Sofia, Sarah and Dvorkin, Yury. Resurety and Johns Hopkins University. October 14, 2024. Carbon Impact of Intra-Regional Transmission Congestion. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4972564
[9] Clean Energy Buyers Association, Open Letter to GHGP ISB, May 2025. https://cebuyers.org/blog/ceba-calls-for-immediate-changes-to-greenhouse-gas-protocols-scope-2-revision-process/
[10] Brander, Matthew. University of Edinburgh Business School, November 10, 2025. Six Things Wrong with the GHG Protocol’s Proposals for Market Based Scope 2 Accounting. https://www.bccas.business-school.ed.ac.uk/sites/cbccs/files/2025-11/Six-things-wrong-with-the-GHG-Protocols-proposals-for-market-based-scope-2.pdf
[11] Resources for the Future, December 10, 2025. How Will Changes to the GHG Protocol Affect Long-Term Contracts? https://www.resources.org/common-resources/how-will-changes-to-the-greenhouse-gas-protocol-affect-long-term-contracts/
[12] WattTime, Aug 12, 2025. Evaluating the Impacts, Costs, and Consequences of Proposed Scope 2 GHG Emissions Reporting Standards. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5375940
[13] The Electricity Journal, TCR, April, 2024. Cost and emissions impact of voluntary clean energy procurement strategies https://www.sciencedirect.com/science/article/pii/S1040619024000186?via%3Dihub
[14] Brattle Group Expert Testimony before MN PUC, March 19, 2025. https://www.brattle.com/wp-content/uploads/2025/03/Expert-Testimony-of-Dr.-Kathleen-Spees-and-Dr.-Long-Lam-before-the-Minnesota-Public-Utilities-Commission.pdf