The Market Reality:
Defending the Engine of Clean Energy Finance
Corporate demand for voluntary clean energy has been the fundamental driver of the energy transition, spurring the development of nearly 200 gigawatts of additional clean energy capacity over the past decade. However, a rigid hourly matching mandate puts the financial engine driving this deployment at risk.
The Bottom Line:
Nearly 80% of surveyed corporate clean energy buyers lack confidence that they will be able to procure time-matched clean electricity under tighter geographic boundaries. By prioritizing accounting optics over real-world impact, the proposed rules threaten to force everyday businesses out of the market and freeze clean energy project financing.
Explore the Data
What happens when theoretical accounting rules collide with the physical realities of the power grid? Explore our original case studies, data analyses, and market reports to see how a mandatory 24/7 approach will stall clean energy financing and leave everyday businesses behind:
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A Preliminary Look at Public Responses to the GHGP's Scope 2
Pragmatic Scope 2, January, 2026
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Carbon Accounting Research Map: What Do Experts Support?
Pragmatic Scope 2, January, 2026
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Carbon Accounting Changes: Will Your Energy Bill Rise?
Pragmatic Scope 2, January, 2026
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Why Experts Say Hourly Matching Is a Fictional Fix
Pragmatic Scope 2, January, 2026
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Case Study: Caught in the Middle - How Hourly Matching Reduces Impact for Distributed Loads
Pragmatic Scope 2, October, 2025
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Case Study: Optics over Impact
Pragmatic Scope 2, November, 2025
Public Comment Repository
Why the Market Urges Alternative Methods
Clean energy buyers and developers warn that the current Scope 2 proposals are structurally biased against everyday businesses and will actively harm project financing.
Clean Energy Needs to be Accessible for Everyday Businesses:
Everyday businesses—like retail, hospitality, and manufacturing chains—have distributed energy loads. To buy clean energy at the scale required to finance new projects, they must bundle their demand across multiple regions. Strict deliverability and hourly matching rules effectively ban this aggregation model, creating a framework structurally impossible for most of the U.S. clean energy economy to use.
Clean Energy Financing is Crucial to Development:
Without the ability to aggregate load, mid-market buyers will be forced away from impactful, long-term Power Purchase Agreements (PPAs). Instead, they will be pushed into short-term spot market purchases for certificates from existing projects, which fails to provide the long-term revenue certainty developers need to finance and build new clean energy generation.
Rising Energy Costs Are On the Horizon:
Attempting to optimize power for individual corporate buyers rather than the overall grid is highly inefficient. If large corporate customers 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%.
What the Market Recommends Instead
To maintain the momentum of the voluntary market, corporate buyers and developers advocate for preserving flexibility:
Preserve the PPA Engine:
Long-term PPAs and Virtual PPAs (VPPAs) must remain viable tools for companies of all sizes, as they are essential instruments for blunting wholesale electricity price fluctuations and preventing financial distress for new clean energy projects.
Embrace a "May, Not Shall" Approach:
Hourly matching and deliverability metrics should be encouraged as optional, voluntary enhancements ("may") for the few companies that have the concentrated load and capital to afford them, but they must not become minimum requirements ("shall") 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 today to learn how your business will be impacted by 24/7 rules.