Insufficient Stakeholder Consultation / Allow Anonymity (Sept 29, 2025)

The Emissions First Partnership, a 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 pertaining to Standard Development and Revision Procedures 4.2.1 and 4.5.1. 4.2.1 states: “During the development or revision of a standard, care shall be taken to ensure as balanced a stakeholder group as possible has been engaged for TWG participation and to provide comments and feedback during the public consultation.”

The GHGP consultation process scheduled to launch mid-October requires respondents to publicly attribute comments to their organization (4.5.1), without providing an option for confidentiality or anonymity. Allowing no option for either confidentiality (names are known to GHGP only) or anonymity (no one, including GHGP, knows who submitted) will compromise balanced stakeholder input, a tenet of 4.2.1, by reducing critical inputs from protocol users - especially buyers and developers - who have valuable insights to bring to the process and on whose regular use the success of this protocol depends. Many companies prefer not to put their name on such comments and should have an option to submit anonymously so that their feedback is received by the GHGP. Without this option, the GHGP risks limiting comments from companies and practitioners and distorting the feedback it will receive. This violates its principle of balanced stakeholder engagement.

The Emissions First Partnership will submit public comments for attribution in response to the process, but is concerned about the wider chilling effect of attribution to individual companies on provided needed feedback on this important issue. The GHGP allowed for anonymous responses to the survey process, which closed in March 2023 and the Emissions First Partnership requests that this precedent serve for the management of the feedback process on the proposed revision. Our ask is to revise 4.5.1 to allow for a confidential or anonymous option.