Thank you to the Greenhouse Gas Protocol for the transparent Scope 2 Public Consultation Summary, reflecting clear attention to stakeholder feedback and willingness to consider alternative pathways to the most effective decarbonization.

Nearly 1,100 stakeholders from 56 countries weighed in, across companies, utilities, industry groups, consultants, NGOs, and governments.

The feedback on hourly matching was clear:

• 70% of respondents oppose mandatory hourly matching

  • The majority of respondents from every continent opposed

  • 53% of academics and 50% of NGOs did not support

  • The only groups with majority support were GHG reporting programs and software providers, the latter of which stands to benefit from these requirements.

• 87% of the opposed felt hourly matching could discourage participation in clean energy markets, and 86% felt it would impose undue administrative burden

In other words, respondents from all groups and all regions said that hourly matching would limit clean energy deployment, reducing impact and slowing decarbonization. Feedback was also pronounced on other key topics:

• 90% support a legacy clause that honors existing contracts

• 59% oppose deliverability, with 87% of the opposed saying it would reduce impact by limiting investment in key regions

Finally, there were strong signs of support for improving Scope 2 reporting in other ways:

• 59% support updating residual mix emissions factors and only 30% oppose revising Standard Supply Service (SSS) guidance

• 84% supported an optional “may” rather than required “shall” approach to hourly matching, enabling multiple theories of change for decarbonization

• 70% support marginal emissions rates for quantifying the emissions impact of clean energy projects

Tim Mohin, GHGP CEO, said in the summary release that “our vision is decarbonization. That's why we do what we do”. We agree. We welcome the GHGP’s revised schedule for updates, and look forward to continued collaboration toward affordable, reliable, decarbonized electricity, everywhere, all the time, for everyone.