Mandatory Scope 2 Hourly Load-Matching, the current GHGP-favored proposal, risks clean energy growth
The Greenhouse Gas Protocol Independent Standards Board (ISB) recently approved the draft revisions to the Scope 2 Guidance (2015) for a 60-day public consultation, expected to begin in October 2025. This revision is focused on improving accuracy, marking the first major update in a decade, and will redefine how companies report emissions from purchased electricity.
Part of that effort has led to the ISB's inclusion of a highly debated hourly and location requirement for the matching of clean energy claims to energy use. While all are in agreement that the 2015 requirements need improvement, requiring locational hourly-matching as the only option for Market-Based Scope 2 emissions reduction has adverse effects on actual clean energy development and procurement.
About Pragmatic Scope 2
The Reality
The mandatory hourly-matched Carbon-Free Energy (CFE) argument stresses that it's the most reliable way to ensure the integrity of projects that are matched to energy use. The theory is that it's more likely one's load could be covered by clean power when the project is generating at the same time, within the same grid-region. While good intentioned, the key word in this argument is theory.
The reality is that modern grids are complex, and there is no way to ensure that the energy you're using came from a specific generator on the grid, no matter how close in proximity or time you are. In practice, the proposed hourly-matching system introduces an insurmountable amount of complexity for most clean energy buyers, inadvertently reducing their participation in impactful clean energy development in exchange for a theoretical accuracy claim. Many of these groups are currently procuring clean power in areas that reduce 2-3x more carbon than their own grid-regions, and would have to turn to less impactful options if the proposed revision goes through.
Pragmatic Scope 2's Goal Is Impact
Pragmatic Scope 2 is built by and for the leaders who want to drive impact.
Those on all sides agree that the focus should be on integrity, impact, and feasibility. But while well intentioned, the decisions made by the ISB are on track to stray from that focus and revise Scope 2 guidance in ways that make it harder for companies to participate in impactful voluntary clean energy markets.
What matters most is catalyzing investment towards more clean energy, and prioritizing flexibility for its development in the areas that need it most. If hourly matching is possible for a clean energy buyer, that's great, but it can't be the only avenue such that we prevent all other impactful development. The clean energy transition is at risk, and the planet is indifferent to when or where carbon is emitted - it just needs less of it.
What's at Stake: Voluntary Market Momentum
Today, buyers have options, and they've used them to buy over 200 GW of clean energy globally.
But, experts are worried. "We fear that many corporate clean energy buyers may pull back on investments in clean energy... and jeopardize future global climate action."
Clean Energy Buyer's Association, May 2025
This website uses cookies.
We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.