To maintain a robust voluntary clean energy market, energy buyers support optional granular time and location matching and recognize market realities require flexible options

The Clean Energy Buyers Association (CEBA) today sent a letter to the Greenhouse Gas Protocol’s Independent Standards Board calling for the Protocol’s ongoing Scope 2 revision process to keep hourly and location accounting optional and include increased dialogue with energy buyers. The letter notes “CEBA and its members are invested in the success of this revision, to build on over a decade of progress. The Scope 2 Guidance should continue its pivotal role in catalyzing, not limiting, corporate climate action to accelerate grid decarbonization.”

“Energy buyers’ purchasing power drives grid decarbonization, and the Greenhouse Gas Protocol should enhance its engagement with energy buyers, to ensure voluntary procurement of clean energy continues to advance,” said CEBA CEO Rich Powell. “CEBA members support keeping optional hourly and location-based accounting for emissions and recognize mandatory matching is infeasible in many markets and would hinder energy buyers’ efforts to procure carbon emissions-free electricity. The Protocol’s Scope 2 Guidance should recognize market realities and the need to preserve and enable voluntary clean energy procurement under a variety of market conditions.”

The letter emphasizes the key role of the current Scope 2 Guidance in catalyzing corporate clean energy procurement. Commercial and industrial customers in 2024 surpassed a landmark 100 gigawatts (GW) of clean energy procurement since 2014, and energy customers announced 21.7 GW in voluntary procurement deals last year alone, making 2024 the highest year to date, according to CEBA’s 2024 Deal Tracker. That momentum could be hindered without changes to the Greenhouse Gas Protocol’s ongoing revision process.

CEBA’s letter today to the Protocol’s Independent Standards Board notes that a majority of CEBA members would face serious implementation challenges with a mandatory time and location accounting approach. “Buyers are already experiencing procurement challenges in many markets under current market boundaries,” the letter states. “Tightening market boundaries in the United States and European Union would exacerbate the challenges and could lead to less procurement in those markets.”

To keep the revision process credible and ensure the revised Scope 2 Guidance will remain highly relevant, CEBA’s letter urges the Independent Standards Board to:

• Increase and enhance engagement with energy buyers.
• Make necessary adjustments before the public consultation phase.
• Align the consequential metric development to the Scope 2 Guidance timeline.