Seventeen leading energy experts urge Greenhouse Gas Protocol to advance scope 2 accounting reforms to preserve its credibility
Seventeen energy modeling and emissions accounting researchers today published an open letter to the Greenhouse Gas Protocol (GHGP) urging it to advance proposed updates to the scope 2 market-based method (MBM) for corporate emissions accounting, directly countering public requests to maintain a status quo that would undermine the Protocol’s accuracy and credibility.
The letter, addressed to GHGP Chief Executive Officer Tim Mohin, articulates several points of consensus on the research underpinning the proposed MBM update. Its signatories include researchers from Princeton University, TU Berlin, the University of Edinburgh, UNSW Sydney, the Colorado School of Mines, the Technical University of Denmark, and other institutions.
The researchers are unanimous that the current scope 2 MBM “does not constitute a legitimate value chain emissions inventory,” as it allows companies to claim clean electricity consumption where “no credible physical relationship exists between generation and demand.” Under current rules, companies may purchase renewable energy certificates from any location at any time, regardless of when or where they actually consume power. The letter cites an extensive body of peer-reviewed research finding that this approach “incentivizes clean electricity procurement actions with minimal impact on real-world emissions.”
The proposed MBM update would require companies to match clean power consumption to the actual time and place of their electricity use, through standards known as hourly matching and deliverability. The signatories back these requirements and recommend the proposal be further strengthened with an explicit age-based incrementality requirement, which would limit companies from claiming credit for existing plants that would have operated regardless of corporate procurement decisions. Even without that addition, the letter states, the current proposal includes a “soft” incrementality requirement that “makes zero market-based scope 2 emissions genuinely difficult to reach in many regions, and meaningful impact therefore much more likely than under the current MBM rules.”
The letter also addresses a central argument from critics of the reform: that the new standard would make it harder for companies to claim zero scope 2 emissions. The researchers acknowledge this is true and argue it is a feature, not a flaw.
“We agree and contend that this is a strength rather than a defect,” they write. “In addition to making the progress companies report towards such a target more credible, impactful, and differentiable, the added difficulty may increase their motivation to also pursue out-of-scope decarbonization strategies.”
Wilson Ricks, an energy systems researcher at the Clean Air Task Force (CATF) and a member of the GHGP technical working group that authored the proposal, is among the signatories.
“The effort to maintain the status quo has tried to frame legitimate disagreement about the proposal’s scope and specifics as evidence that there’s no consensus on the fundamental direction,” said Ricks. “This letter makes clear that the researchers who produced much of the underlying literature agree on two key points: that the current method is broken, and that the proposed reforms move in the right direction.”
Read the full letter here.
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Clean Air Task Force (CATF) is a global nonprofit organization working to safeguard against the worst impacts of climate change by catalyzing the rapid development and deployment of low-carbon energy and other climate-protecting technologies. With 30 years of internationally recognized expertise on climate policy and a fierce commitment to exploring all potential solutions, CATF is a pragmatic, non-ideological advocacy group with the bold ideas needed to address climate change. CATF has offices in Boston, Washington D.C., and Brussels, with staff working virtually around the world. Visit catf.us and follow @cleanaircatf.
