Insufficient Stakeholder Consultation / Extend to 120 Days (Nov 6, 2025)

The Emissions First Partnership’s coalition of 32 organizations, including buyers, developers and NGOs responsible for more than 50GW of combined clean energy procured globally since 2008, respectfully submits the following complaint under the GHG Protocol Complaints and Concerns Procedure 2.2.1 i (“failure to conduct required public consultations”) related to the insufficient duration of the public consultations for the Scope 2 and Electricity Sector Consequential Methods (see GHG Protocol Public Consultations, available at GHG Protocol Public Consultations | GHG Protocol (October 20, 2025)).

The Emissions First Partnership values the GHGP’s focus on educating stakeholders on the proposed revisions and the time dedicated to developing support materials. We agree with the GHG Protocol that public consultation is a “critical component of the GHG Protocol’s Standard Development and Revision procedure.” However, the 60-day calendar duration of the public consultations is inadequate to provide a meaningful “opportunity for all stakeholders to contribute feedback on key topics related to the GHG Protocol standards and guidance” and threatens the integrity of the revision process. For many stakeholders, this is not enough time to engage with the content published by the GHG Protocol and prepare useful feedback, especially given that the period overlaps with several public holidays and competing events.

We therefore ask the GHG Protocol to extend both public consultations to at least 120 calendar days. We recognize the importance of not delaying the overall revision process, and we do not believe a 120-calendar day consultation period will impact the schedule.

The 60-calendar day period is inadequate for the following reasons:

• Stakeholders will need to undertake a substantial amount of work to review materials for two public consultations: Scope 2 and Consequential Accounting.

• The consultation materials are informative, but lengthy.

• Stakeholders, especially those that do not closely follow the revision process, may also need to contend with over two years of background information including, but not limited to: Survey Responses (2022-2023), Terms of Reference (Sept. 2024), Governance Documents (Sept. 2024), TWG Presentations and Meeting Minutes (Sept. 2024-Sept. 2025), and several GHGP blogs and newsletters.

• The public consultations include 235 questions; many requiring expertise and detailed information that takes time to source and draft. Many of the 235 questions require respondents to gather organizational information that is likely housed in different departments. The questions included in Electricity Sector Consequential Methods require expertise on marginal emissions and their calculations. The GHGP provides background information on the differences between attributional and consequential accounting, but that adds to the burden described in the first point above.

• With the current section 4.5.2 of the Standard Development and Revision Procedure V1.1, stakeholders who need assurance that their responses will be kept confidential need to submit a request and wait for approval before they submit. Some Emissions First members have shared that they need time to secure approvals once they have responses drafted, which takes time. Many companies need internal approvals from leadership as well as legal review. In the US, this could require thoughtfully developed responses by November 21 (ahead of the Thanksgiving holiday week) which is only 31 calendar days. An extension to 120 days total would add significantly to the quality of responses the GHGP receives.

• There are 16 non-working weekend days between October 20 and December 19. There are also observed holidays. In the US, these include Veterans Day (November 11) and Thanksgiving (November 27-28). In addition, this period includes Hanukkah (December 15-22); several Indian holidays including Diwali (October 20) and Guru Nanak Jayanti (November 5); and two public holidays observed in several parts of Europe (All Saints Day on November 1; Feast of the Immaculate Conception on December 8).

• There are significant events that require time from GHGP users between October 20 and December 19: The United Nations Climate Change Conference (CoP30) in Belem takes place November 10-21. Additionally, RESource and VERGE took place in late October. Many members of the Emissions First Partnership are engaged in these in addition to wanting to provide thoughtful responses to GHGP.

• With other open comment periods overlapping; respondents should be allowed to consider the bigger picture on consequential accounting before commenting on other revisions: The public consultation period of the Science Based Targets initiative’s Corporate Net-Zero Standard starts on November 6. Additionally, the Actions and Market Instruments (AMI) Technical Working Group (TWG) is currently producing a white paper, expected in December 2025, to cover key concepts, principles, and approaches. We have reason to believe the AMI TWG will release the white paper for public comment in the first quarter of 2026. Stakeholders should have the opportunity to simultaneously consider the white paper along with the proposed revisions to the Scope 2 Guidance and the feedback received from the Electricity-Sector Consequential Methods consultation period.

Proposed corrective action: Extend the duration of the two public consultation periods so that it has a meaningful overlap with any comment period for the public white paper coming out of the AMI TWG in Q1 2026, but not to be less than a minimum of 120 days.