Lack of Transparent Decision Making / Include Consequential (Sept 29, 2025)

1. Basis for Complaint: Non-Transparent Decision-Making

The decision not to advance the Impact Accounting method for public comment in parallel with the hourly matching methods for Inventory Accounting represents a non-transparent and unexplained deviation from previously established public expectations and the recommendations of the Technical Working Group.

Publicly Set Expectations: The GHG Protocol's public blog post from June 2025, "Scope 2 Technical Working Group Progress Update", set a clear expectation for stakeholders.

It stated: "The consultation draft is expected to include proposed updates such as the hourly and regional matching methodology, the Marginal Emissions Impact metric, and associated feasibility provisions..."

The public was led to believe that Impact Accounting would be presented for feedback simultaneously with Inventory Accounting, allowing for a comprehensive review of the proposed changes. That communication also states that the two approaches, inventory metrics and impact accounting, work together as two parts of a complete framework:

“This combined framework reflects a core principle of the Scope 2 update: Inventory reporting is being refined to ensure consistency, comparability, and scientific alignment in how emissions from electricity use are measured. Impact reporting offers a complementary way to account for emissions reductions from clean energy actions that occur outside a company’s direct electricity use.”

Disregard of Technical Working Group Recommendation: The Scope 2 Technical Working

Group (TWG), the multi-stakeholder body responsible for developing the technical content of the standards, provided overwhelming support for the parallel development. The minutes from the June 25, 2025 meeting confirm this, with a vote on question 12 showing that showed 31 out of 42 respondents voted yes to support "continued development of [Impact Accounting] as a complementary methodology [to hourly matching]" According to the Technical Working Group Terms of Reference, the TWGs mandate is to "make recommendations on the content of standards to the Secretariat, for ultimate consideration by the ISB where relevant and applicable." The ISB's decision to derail this recommendation without public explanation falls short on the GHGP’s commitment to transparent decision-making.

2. Basis for Complaint: Inadequate Public Consultation By separating the public comment periods for the two methodologies, the GHG Protocol is hindering the ability of stakeholders to provide effective and informed feedback, thus failing to meet the public consultation standards.

The GHG Protocol's Standard Development and Revision Procedure states that a key step in the process is to support "clearly identified opportunities for stakeholders to contribute". An effective public consultation must allow for a holistic evaluation of the proposed changes. As the GHG Protocol itself acknowledged in its June blog, the required hourly matching and regional matching of inventory accounting could create significant feasibility challenges. It also noted that these challenges could be addressed by the alternative Impact Accounting method. Further, it noted that Scope 2 inventory reporting revisions (LBM and MBM) are intended to improve credibility, but do not measure impact. It stated that the purpose of revisions are so that “reported electricity emissions better reflect when and where electricity is actually used. This approach supports more credible inventory reporting”.

The Marginal Impact Method is designed to assess impact: “the impact metric provides a way to more accurately and transparently account for its broader climate benefit.” Without the details of the Impact Accounting method being shared in parallel, stakeholders cannot provide informed public comments on how the two methods can and should complement one another, or not. The efficacy of the public consultation is compromised when the interdependent nature of these two methodologies is not respected.

3. Desired Outcomes - We request the following actions to be taken to rectify this matter:

• A public explanation from the GHG Protocol ISB detailing the specific reasons for its decision not to advance the Impact Accounting methodology in parallel for public comment on Scope 2, particularly in light of the TWG's strong support.

• The release of a draft Impact Accounting document for public comment, focused on Scope 2, running in parallel with the current public consultation for the Scope 2 Inventory Accounting methods.

• A public commitment to a timeline for Scope 2 Impact Accounting that moves in parallel to development of Inventory Accounting methods.

Thank you for your consideration of this formal complaint. We look forward to a prompt and transparent resolution.