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Market Advisory: GHG Protocol Update Survey Now Open

The Greenhouse Gas (GHG) Protocol is conducting a series of surveys to collect stakeholder recommendations for new guidance and updates to the GHG Protocol’s corporate emissions inventory reporting standards, including the GHG emissions accounting rules for purchased renewable energy defined in the Scope 2 Guidance.

The GHG Protocol’s goal in updating these resources is to ensure standards for scope 1, scope 2 and scope 3 are effective in providing a rigorous and credible accounting foundation for businesses to measure, plan and track progress toward science-based and net-zero targets. While CRS is supportive of this overall goal, there is a significant risk that this update may limit or remove the ability to include purchased renewable energy in a carbon footprint, eliminating a key driver for voluntary renewable energy demand in North America.

Problematic proposals actively being considered include:

  • Removing market-based accounting from scope 2,
  • Prohibiting the use of unbundled Renewable Energy Certificates (RECs),
  • Narrowing geographic eligibility for purchased renewable energy and RECs,
  • Requiring more granular (e.g., hourly) time-based matching,
  • Transitioning to using estimated avoided grid emissions associated with purchased renewable generation to calculate scope 2, and
  • The introduction of “impact” requirements for purchased renewable energy, e.g., “additionality” testing for renewable energy projects.

In addition to supporting voluntary carbon footprint disclosure, the GHG Protocol is the primary standard identified for the quantification of GHG emissions in the proposed U.S. Securities and Exchange Commission climate-related disclosure rule and many mandatory state programs. Changes to the GHG Protocol will impact a wide variety of programs and could exacerbate inconsistent disclosure where new guidance conflicts with standard practice.

Survey responses must be submitted to the GHG Protocol using their online survey tool by March 14th. CRS will be responding to support the value and beneficial impacts of the existing Scope 2 Guidance and provide targeted suggestions for clarifications and improvements across the full suite of resources. We encourage all Green-e® participants and interested stakeholders to share their perspectives on the benefits of voluntary renewable energy markets and the credibility of RECs.

Please contact if you have any questions about potential updates or how to respond.