“We, the 31 listed signatories representing experts in energy systems modeling, carbon impact analysis, and carbon accounting across academic, non-governmental organizations and commercial organizations, [assert that] no expert consensus has been established that 24x7 energy matching is the only—or even necessarily the most effective—method for incentivizing real-world carbon-reducing decisions and rigorously measuring carbon impact of decisions.”
“Mandatory hourly matching’s high costs would likely kill so much clean energy procurement, it would increase total long-run emissions.”
“This higher temporal and market boundary matching proposal . . .could have unintended consequences for corporate GHG target setting, project financing, and renewable energy market mechanisms, potentially slowing the clean energy transition.”
“Unilaterally applying this 24/7 matching asset-level framework leads to unintended consequences that could slow decarbonization and undermine the approach’s intent. Companies seeking the most impactful clean-energy strategy should instead make power investments using an integrated, grid-level lens that encompasses the state, power market region, or even country in which they operate.”
“Current proposals for how to implement 24/7 would add substantial double counting and deliverability issues to MBM, which could actually make carbon accounting significantly less accurate.”
“Investing in renewable energy projects across the Global South can yield 2x to nearly 3x greater climate benefit vs. renewables projects in countries of the Global North...[where] some of 24/7 CFE’s biggest proponents operations and data centers are overwhelmingly located (in the EU, US, and other Global North locations).”
“Through several case studies, we find that load that is 100% hourly-matched through load-shifting will often result in significant net operational emissions, and sometimes even increase net emissions relative to annual-matching.”
“Voluntary demand for clean energy is highly price-sensitive, meaning that increases in the cost and risk of clean energy procurement stemming from mandatory use of stringent accounting frameworks, such as hourly matching, is likely to lead to a significant contraction of the voluntary market, potentially raising systemwide emissions due to lower investment in clean energy.”
- E3, 2024
“Unlocking ‘cross-border’ corporate procurement of renewables for maximum decarbonization impact could allow for a faster, cheaper, and more equitable energy transition — 1.7 billion tonnes of CO2 could be saved over the next 15 years [by not requiring companies to buy renewable power] within the same ‘market boundary’ as their demand.”
“Removing market boundaries for scope 2 emissions reporting [and focusing on emissions impact] could help to drive $85 billion of investment into developing economies by 2040.”
“Hourly energy matching . . .is the least cost-effective strategy at carbon emissions reduction. [L]ocalizing energy procurement typically increases costs and net carbon footprint, resulting in more money spent but fewer carbon emissions displaced.”
“Tight market boundaries may limit supply and induce higher prices, slowing global renewable capacity growth. This risk may be accentuated in locations with relatively high prices and limited or non-existent procurement options. This dynamic will likely occur in a voluntary market with low demand elasticity. In other words, the current RE voluntary market design may not give buyers enough incentives and recognition to stabilize the demand with high RE prices.”
“Many markets still do not allow corporate PPAs, resulting in limited procurement options. Malaysia, South Africa, Turkey, New Zealand, and Saudi Arabia are just a few examples of places where this happens. Many companies ... thus find themselves limited to unbundled EACs and/or contracts with suppliers without having any additional impact on the grid.”
“Hourly energy matching is the least efficient strategy at displacing carbon emissions.”
“Carbon matching, a strategy that directly accounts for carbon emissions... is more cost-effective than any of energy matching strategies analyzed.”
- Tabors Caramanis Rudkevich, 2023
“24x7 matching of individual generation and load is not workable.”
"Emissions impact ... under annual time-matching requirements is heavily dependent on underlying modeling frameworks of computer models,"
“enforcing an hourly time-matching requirement in the near-term, when the risk of high emissions from annual time-matching is low, creates additional cost and implementation barriers for scaling up manufacturing that wants to use carbon-free electricity.”
“Imposing stricter time and location accounting requirements at the organizational level is inefficient and infeasible for most buyers and may curtail ambitious global climate action...undermin[ing] the relevance and impact of the Protocol, reverse more than a decade of progress, and jeopardize future global climate action.” (CEBA webinar on the Scope 2 rewrite process here, minutes 10-25)
“70% of respondents indicated they have current clean electricity contracts that would no longer be eligible under smaller market boundaries, which threatens their ability to achieve current and future clean energy targets.” and “Nearly 80% of respondents lack confidence that they would be able to procure time-matched clean electricity within smaller market boundaries.”
“BCSE strongly urges the GHG Protocol to preserve and strengthen market-based accounting options in the Scope 2 framework....Preserve flexibility in accounting and procurement options that can be reflected in the scopes, including non-hourly matched unbundled EACs, utility-delivered clean energy, and long-term PPAs from resources operating in the same national market. Additional tools, such as hourly matching or deliverability metrics, can be encouraged as voluntary enhancements but should not
become minimum requirements.”
“At a time when clean energy companies face significant global and domestic headwinds, an overly restrictive approach for GHG reporting requirements that shrinks the number of voluntary purchasers could be a breaking point for many companies in the clean energy market.”
“The voluntary procurement of clean energy is critical for mitigating risks for project development and attracting investment. By providing a stable revenue source for solar, wind, energy storage, and other clean energy projects over a defined period, offtake agreements from corporations and other entities help to enable the financing required to construct new projects – expanding affordable, reliable, and clean power across the U.S. power grid.”
“[M]arket impacts of requiring “deliverable” hourly procurement, despite the implementation constraints on both the supply and demand side of the market and unclear incremental climate benefits, may risk reducing corporate participation in voluntary clean energy markets, potentially increasing long-run global emissions. Taken together, potential new hourly deliverability requirements would also likely perpetuate and deepen the clean energy finance gap in historically underserved regions by discouraging new project investments in geographies that do not offer “deliverable” hourly load matching and where many rely on distributed energy systems.”
"EPP urges the Greenhouse Gas Protocol Secretariat and ISB to ensure the delivery of complete Scope 2 guidance considering all Greenhouse Gas Protocol users in all markets across all use cases, especially for the most ambitious corporate clean energy strategies that prioritize energy access and decarbonization optimization."
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