July 11, 2025

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To the GHGP Secretariat and Independent Standards Board,

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The Emissions First Partnership (EFP) is a coalition of leading corporate clean energy buyers and technical experts committed to ensuring that corporate clean energy investments deliver the greatest possible decarbonization impact. Our members have collectively supported over 50GW of global clean energy procurement since 2008. As practitioners with extensive experience aligning investment decisions with the Greenhouse Gas Protocol (GHGP), we deeply value the GHGP’s track record of setting standards to shape clean energy accounting and the procurement behaviors it drives. The scope 2 accounting standards have been instrumental in accelerating grid decarbonization to bring over 200 GW of clean energy onto the grid over the past two decades. 

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We are also grateful for the work underway to revise GHGP standards as we, too, recognize the need for improvements in scope 2 accounting. We created the Emissions First Partnership because we recognized the opportunity for improvements over the status quo - specifically, the imperative to more precisely measure emissions impact. In that spirit of continuous improvement, we respectfully submit the following considerations and recommendations:

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1. We urge careful consideration of unintended consequences of the proposed Market-Based Method (MBM)

 

The MBM is the most widely used method for voluntary scope 2 target setting and decarbonization efforts. As such, we urge careful consideration of the potential effects of the proposed changes on the voluntary market. In particular, the focus on MBM to support a use claim may result in unintended consequences that move the MBM farther away from its stated goals of Impact, Feasibility and Scientific Integrity. 

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Impact

The current MBM proposal (aka “hourly matching”) does not measure impact nor does it necessarily incentivize or recognize companies taking impactful actions. In many cases, hourly matching may increase emissions despite enabling companies to claim a MBM reduction. As an example, hourly matching of wind in West Texas (a low carbon intensity area) to load in East Texas (a high carbon intensity area) drives net emissions up. A study from Tierra Climate also shows that energy storage optimized to meet a company’s own load may inadvertently increase grid emissions. In both cases, a company could claim a lower MBM while increasing emissions to the atmosphere.

 

The current MBM proposal would steer companies toward procuring clean energy that align with their own hourly and regional usage. This could divert investment away from projects that deliver the greatest system-level decarbonization benefits, such as adding incremental clean energy resources on dirtier grids or in under-resourced areas. Moreover, when individual companies attempt to pursue hourly matching in isolation, it can result in redundant infrastructure, overbuilt battery capacity, increased costs to customers, and inefficient use of grid resources. A coordinated, grid-wide emission reduction approach would avoid this narrow focus on an individual company’s “physical” inventory and instead drive more efficient decarbonization progress. 

 

While we share the goal of advancing a decarbonized grid that operates every hour of the day on clean and renewable resources, requiring individual hourly accounting in scope 2 MBM decreases decarbonization efficiency and causes unintended consequences for the grid and the renewable energy market. 

 

Should the GHGP continue down this path, it is critical that it makes clear that the proposed MBM does not reflect impact, but is limited to a strict usage claim. This will ensure companies and standard setting bodies appropriately and accurately leverage the revised MBM. 

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Feasibility for voluntary action

For companies working to take meaningful voluntary action to reduce their reported MBM, the proposed revisions will actually introduce a number of commercial feasibility challenges that point them towards less impactful procurement pathways. 

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Requiring companies to match each hour of consumption with clean energy purchases within tighter market boundaries reduces the economies of scale often critical for a company to meet minimum demand thresholds to participate in a PPA transaction. In many instances, this would force buyers who lack the scale of load in that boundary or at that time to move away from PPA transactions and instead  rely on spot market unbundled attributes.  

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In addition to commercial feasibility challenges, the proposed changes will create numerous accounting challenges. We urge the consideration of the complex reporting and data collection burdens these changes may create, including directing limited resources away from action and adding barriers to participation in voluntary clean energy procurements – particularly among smaller or less-resourced companies. 

In addition to recognizing the potential chilling effect these changes might have on the voluntary market, we urge the GHGP to better evaluate data availability globally and provide tools to support these changes. 

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Scientific Integrity

While we appreciate that tighter market boundaries are intended to better reflect deliverability and support use claims, these still overlook the role of transmission congestion in determining whether clean energy can actually reach the point of consumption. A recent analysis by a diverse group of grid modeling experts shows that the various proposals using tighter market boundaries still fail to ensure physical deliverability. Without physical deliverability tests, it’s unclear if hourly accounting will offer meaningful improvement to inventory accuracy.

  

We greatly appreciate the efforts underway to drive improvements over the status quo. We share the goal of improving scope 2 accounting, but have concerns about the current MBM proposal and how it could limit participation in voluntary markets and result in unintended consequences. If not careful, the result could be the worst of both worlds – inventory accounting that fails to meaningfully improve accuracy, while impeding voluntary market actions, and decreasing impact. 

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2. Adopt Impact Accounting on the same level and timeline as MBM to better reflect real-world impact

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We strongly urge the GHG Protocol to require an impact metric, reported on the same level and timeline as MBM and LBM, with clear guidance on the impact claims supported by the net emissions impact calculation. The inclusion of an impact metric is a critical complement to attributional (or allocational) inventories – which are designed to allocate the responsibility for emissions between different parties, not directly measure the impact of actions. 

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Adopting an impact metric as a required disclosure would drive greater visibility into the emissions impact of a company’s actions, smarter clean energy investments, and a pathway to value meaningful global action not currently valued in an inventory. As such, we support the proposed formula of Consumption Emissions Impact (CEI) - Procurement Emissions Impact (PEI) = Net Impact which reflects the emissions outcome of a company’s consumption and procurement actions. It’s important to note that by leveraging granular time and location historic data in this calculation, the impact metric avoids many of the pitfalls of trying to forecast future impacts.

  

We support an impact metric that is accessible to a broad group of companies. Today, this approach is more feasible than ever as the data necessary is increasingly available from NGOs and ISOs reflecting more accurate time- and location-specific emissions rates for each grid. Similar to the revised MBM, we urge GHGP to evaluate data availability globally and provide tools to support these changes. We also urge the GHGP to ensure that any requirements for impact or causality are accessible to a broad base of companies.

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Lastly, it’s critical for the GHGP to keep in mind that the impact method is only as effective as its ability to be used by reporting entities to communicate progress. The GHGP should provide a clear blueprint for claims this metric can enable and engage standard setting bodies (like SBTi) to ensure there is a clear articulation of how an impact metric can and should be used to help inform company progress toward targets.

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In Conclusion

The GHG Protocol has played a critical role in driving climate progress for over two decades, including over 200 GW of voluntary clean energy development. Much of this success is thanks to commercial flexibility—enabling companies to tailor strategies to their operations and market realities. The next iteration of the protocol should improve accuracy of the inventory and require reporting entities to assess impact. As such, it is essential to have both a credible inventory through attributional accounting and, of equal importance, impact accounting to incentivize and measure impact. 

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Input from a broad stakeholder perspective is also essential to create a robust standard grounded in academic rigour that is tenable to GHGP users. Although additional representation from practitioners has been added in recent months, we feel the TWG would benefit from further representation from practitioners, particularly companies navigating complex market conditions and with a diverse set of procurement experiences.

At this critical moment for climate action, we are grateful for the dedication of the Secretariat, ISB, Steering Committee, and TWG. A revised scope 2 framework that prioritizes emissions impact will unlock the next wave of private-sector climate leadership.

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Respectfully,

 

The Emissions First Partnership