The Greenhouse Gas Protocol is currently considering revisions to its framework for attributing “Scope 2” emissions, or emissions from individual electricity consumers. In our comments, we recommend that the proposed changes should prioritize accuracy, comparability, feasibility, and real emissions impact in standardizing the measurement of firms’ emissions. In particular:
- Accounting should reflect real-world emissions both under the location-based method and the market-based method.
- Accounting should incentivize additional emissions reductions while maintaining transparency and comparability across firms and regions.
- Changes that could increase the administrative burden of accounting should be balanced against the risk of undermining participation.