Changes to the location-based method (LBM) to encourage time and location granularity. A “should” not “shall” definition within the LBM would establish a universal hierarchy for reporting energy consumption. Where hourly, geographic data is available and feasible, it would improve on current use of grid average emission factors.

Changes to the market-based method (MBM) to:

• Allow optional time and location matching. A “may” not “shall” definition within the MBM allows organizations across a variety of sectors, sizes, and regions to pursue clean energy interventions that mutually benefit them and the broader system.

• Improve the accuracy of the residual mix. Clear definitions for residual mix emission factors will improve the accuracy and relevance of the MBM. Defaulting to a fossil-based emissions factor rather than a grid average emissions factor in the absence of residual mix ensures a conservative view on emissions impact that prevents double counting.

• Continue to evaluate Standard Supply Service (SSS). The SSS, which describes emissions from the grid electricity an organization uses, should avoid double counting and avoid inaccurately decreasing the voluntary procurement needed to achieve MBM targets.

• Clarify that the MBM does not necessarily support “use” claims. Scope 2 measures the emission factor of procured electricity, reflecting the flow of financial contracts and the flow of emission-factor claims, but not necessarily the flow of electrons or “use claims”. Guidance on appropriate “use” claims is better overseen outside GHG accounting (e.g., RE100, US FTC).

Immediate clarification that a legacy clause will protect existing long-term contracts signed prior to enactment of the updated standards. Current ambiguity is slowing new clean energy deals and stalling momentum, as organizations do not know how current actions will count toward their reporting over the full contract term. Excluding a legacy clause would penalize early movers in the market who have signed 10-20 year contracts under the current rules. This legacy clause must apply to all new requirements introduced, including both time and location matching, rather than a subset.

A new Consequential accounting statement to measure  emissions impact. This metric, currently proposed as Statement 3 under Actions and Market Instruments (AMI), would reward high-GHG-impact procurement to provide the right investment signal, increase confidence in emissions impact by aligning emissions rates with grid operation, and work for all technologies and industries. This metric should:

• Complement LBM and MBM inventory accounting. Inventory and GHG-impact both matter, but answer different questions. Statement 3 will provide more transparency on the GHG-impact of an organization’s actions.

• Be practical for target setting. This requires calculation of both induced and avoided emissions, either within Statement 3 or across Statement 1 and Statement 3, and guidance on how Statement 3 interacts with inventories in Statements 1 and 2. It also requires guidance on what claims can be made based on actions reported in Statement 3.

• Be further explored for Scope 1 and Scope 3. Consequential accounting is not yet as well understood outside Scope 2, but has the potential to be an effective tool. Testing and validation is key to ensure application to other Scopes maintains the rigor available for Scope 2 electricity use.

• Include a practical definition of additionality. Organizations need a unified, objective definition that acknowledges implementation will look different for different applications.