The Expert Consensus:
Carbon Accounting Must Focus on Real-World Impact
From leading grid academics to the world's largest clean energy buyers, the consensus is clear: hourly energy matching has significant shortcomings that limit its real-world applicability, procurement, and impact.
The Bottom Line:
31 leading grid experts and researchers representing 11 top academic institutions have publicly signed an open letter stating there is no expert consensus that 24/7 hourly matching is the only—or even most effective—method for incentivizing real-world carbon reductions.
Explore the Data
We have curated the most critical testimony, open letters, and market analyses from the industry's top voices. Explore the selection of expert opinions below, or dive into our fully transparent, interactive database containing all 200+ analyzed sources.
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Brattle Group: Expert Testimony United States of America Before the Minnesota PUC
Comments of Dr. Kathleen Spees and Dr. Long Lam, March, 2025
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CEBA Calls for Immediate Changes to Scope 2 Revision Process
CEBA, May, 2025
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ACORE Letter to the GHG Protocol Independent Standards Board
ACORE, April, 2025
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GHG Management Institute: Limitations of Hourly Matching Claims
GHG Institute, May 2025
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Ever.Green FAQ
Ever Green, August, 2025
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Jigar Shah: Voluntary Markets, The Key to Unlocking More Clean Energy
LinkedIn, April 2025
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Expert Consensus on Climate Impact
Letter from Lawmakers regarding 45V, September, 2024
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McKinsey: Rethinking Your Company's Clean-Power Strategy
Mckinsey, February, 2025
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REsurety: GHG Protocol Prioritizes Looking Good Over Doing Good
Utility Drive, September, 2025
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University of Edinburgh: Six things wrong with the GHG Protocol’s proposals for market-based scope 2 accounting
University of Edinburgh Business School, November, 2025
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Harvard: Scope 2: Physical Power Usage Accounting Is Fictional, Pricing And Marginal Impact Accounting Are Real
Harvard, December, 2025
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ZeroGrid: Expert Consensus Support for a Rigorous Definition of "Deliverability" in Scope 2 GHG Accounting
ZEROgrid, April, 2025
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Resources For the Future: How Will Changes to the Greenhouse Gas Protocol Affect Long-Term Contracts?
Resources.org, December, 2025
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Johns Hopkins University: Some Considerations for Scope 2 Accounting
Greenhouse Gas Protocol, 2015
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WattTime: Formal Complaint to the Greenhouse Gas Protocol on the Scientific Merit of its Scope 2 Proposal Claims
Watt Time, January 2026
Why the Experts are Concerned
Grid operators, economists, and former policymakers warn that the current Greenhouse Gas Protocol proposals are inconsistent with the physical realities of the power grid.
The Laws of Physics Do Not Comply:
Experts note that electricity mixes on the grid, making it physically impossible to trace an electron from a specific generator to a specific consumer. Attempting to mandate physical matching of contracted load and generation is an "accounting fiction".
Costs for Everyday Consumers Would Increase:
If large corporate buyers isolate their loads from the rest of the grid to achieve strict 24/7 matching, utilities are left to procure resources for a more volatile load pattern, which could drive up electricity prices for residential customers by up to 26%.
Clean Energy Financing:
Adding strict hourly matching and deliverability constraints complicates long-term Power Purchase Agreements (PPAs). Experts warn this will disincentivize companies from signing the very contracts necessary to finance new wind and solar development.
What the Experts Recommend Instead
Instead of forcing a costly "one-size-fits-all" mandate, the market and academic consensus points toward pragmatic, high-impact alternatives:
Grid-Level Impact:
Companies should abandon the individual, asset-level 24/7 framework and instead evaluate their power investments using an integrated, grid-level lens to maximize marginal-emission reductions.
Flexible "May, Not Shall" Guidance:
Hourly matching and deliverability should be encouraged as optional, voluntary enhancements for the few companies that can afford them, but they must not become minimum requirements that lock the rest of the market out.
Contact us
The fight for a pragmatic Scope 2 standard is ongoing. We are actively gathering support to show the GHGP the real-world consequences of a 24/7 mandate.
If your organization relies on load aggregation or long-term PPAs, we need to hear from you. Contact us to today to learn how your business will be impacted by 24/7 rules.