Half the Picture: Why the GHG Protocol's Consequential Metric Falls Short

The Greenhouse Gas Protocol (GHGP) recently published its public consultation on consequential electricity sector emissions impacts, an important step toward providing guidance on marginal emissions. However, the proposal diverges significantly from the robust, comprehensive framework recommended by its own Technical Working Group (TWG).

While we applaud the GHGP’s effort to advance consequential accounting, the proposed methodology captures only a fraction of the full picture, creating an incomplete and potentially misleading measure of corporate impact. The core issue? The proposal doesn't put forward a method for calculating the emissions caused by electricity consumption, reducing the consequential metric to a single-sided calculation. It is important to know both impacts from consumption and impact from procured generation in order to understand the difference between them - something that can enable target-setting and recognition frameworks.

The Critical Omission: Emissions from Load

The TWG’s proposed Marginal Impact Method (MIM) was designed to provide a complete view of a company's actions on the electricity grid. It recognized that an action - like procuring clean power or increasing electricity demand - has both positive and negative consequences that must be measured together.

In stark contrast, the GHGP public consultation focuses primarily on avoided emissions from clean energy procurement. This is only half the MIM equation. It allows companies to claim credit for clean energy additions without fully accounting for the emissions they simultaneously cause by consuming grid power, especially during high-emissions times.

As members of the TWG Consequential Subgroup explained in their public statement:

"The subgroup's proposal, in contrast, introduces a net impact equation that captures both emissions caused by electricity consumption and those avoided (or caused) through energy procurement. This provides a complete and comparable picture of system-level impacts." 

By focusing only on avoided emissions, the proposed metric cannot properly contextualize those benefits. Without measuring the emissions caused by consumption, organizations lack the necessary insight to make holistic decisions on load shifting, storage deployment, and where to locate operations for true system-level abatement.

Pushing Consequential Impact Out of Scope 2

Beyond the flawed calculation, the GHGP consultation signals a critical step backward regarding the application of the consequential metric.

The TWG initially focused on delivering near-term, actionable recommendations for consequential accounting specifically within the Scope 2 Guidance for the electricity sector. The intent was to complement the location-based and market-based methods, giving companies a third, impact-based metric.

Instead, the public consultation positions the materials primarily as input for the broader Actions and Market Instruments (AMI) workstream. This shift effectively removes the consequential metric from immediate, mandatory inclusion in the Scope 2 Guidance, pushing it into a sector-agnostic, long-term framework.

For the electricity sector - where marginal emissions are clearly understood and urgently needed for decision-making - this delay undermines the opportunity for immediate, impactful change and prevents companies from using consequential data to inform their decarbonization strategies now.

The Call for Full Transparency

Accurate climate accounting demands transparency and completeness. The GHGP's move to a single-sided metric, and its reclassification away from immediate Scope 2 relevance, risks diluting the usefulness of consequential data.

The full details comparing the TWG’s complete MIM proposal and the GHGP’s simplified approach are laid out clearly in the TWG’s materials: Appendix Table Comparison.

The path to genuine climate leadership requires adopting a method that evaluates the differential positive and negative impacts a company takes, ensuring companies account for both the emissions they avoid and the emissions they cause. Anything less is a half-truth, and our planet deserves the complete picture.