Key facts
- GHG Protocol is revising its scope 2 standard for indirect emissions from purchased energy.
- The consultation focused on changes to renewable energy certificate (REC) use and reporting methodologies.
- Most respondents opposed mandatory hourly grid-based matching for electricity consumption.
- A majority supported an exemption from hourly matching for smaller organizations.
- Respondents largely opposed a requirement for RECs to come from generators on an electrically linked grid.
- A 'grandfathering' clause for existing contracts received strong support.
The Greenhouse Gas Protocol (GHG Protocol) has released a summary of responses from its public consultation on proposed revisions to its scope 2 standard, which governs indirect emissions from purchased energy. The feedback will inform a second public consultation later this year, with the updated standard expected in 2027.
The consultation addressed several key areas, including the use of renewable energy certificates (RECs) and changes to market and location-based reporting methodologies. A total of 1,072 responses were received from 56 countries.
GHG Protocol also confirmed its intention to integrate its carbon accounting standards with those of the International Organisation for Standardisation (ISO), a move initially announced last year. A public consultation for this integrated corporate standard is scheduled for the second quarter of 2027.
Feedback on proposals for hourly, grid-based matching of electricity consumption was largely negative, with 70% of 909 respondents offering little to no support. Objectors cited concerns about increased reporting burdens and costs potentially discouraging participation in voluntary renewable procurement schemes like RE100. Many suggested making hourly matching optional.
However, a proposed exemption from hourly matching for smaller organizations, allowing monthly or annual matching, received strong support, with 76% of 748 respondents in favour. Supporters believe this would create a more equitable reporting approach and encourage continued voluntary procurement from smaller entities.
Regarding deliverability requirements, a proposal that buyers could only procure RECs from generators connected via an electrically linked grid faced opposition. Of 875 respondents, 59% were against this revision, citing concerns that narrower market boundaries could deter investment in high-decarbonisation potential areas and reduce the attractiveness of long-term power purchase agreements (PPAs).
Responses to proposed changes for the location-based method, prioritizing precise location information and temporal granularity, were mixed, with 40% in favour and 44% against. Opponents argued that local spatial boundaries may not always reflect actual electricity delivery at scale.
A new 'standard supply service' (SSS) term to account for renewable electricity from publicly funded or mandated resources also drew mixed reactions. While 49% of 522 respondents supported its introduction, many expressed concern that classifying state-supported generation as SSS could significantly reduce the pool of available RECs for the voluntary market, particularly impacting markets like Japan, Taiwan, and Malaysia where feed-in-tariff programs dominate.
Broad support, around 90% of 801 respondents, was given to a 'grandfathering' clause. This provision would allow eligible pre-existing contracts to count towards market-based consumption even if they do not meet updated requirements, aiming to maintain market confidence in long-term contracts and ensure early adopters are not disadvantaged.