FAQs

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For the first time in a decade, the Greenhouse Gas Protocol (GHGP) is rewriting its rules for how companies can count the GHGs emitted from their purchased electricity. No future updates are planned, so it is critical to get any update right today. In Summer 2025, a key governance body of the Protocol will review the leading proposal to update the rules for accounting for purchased electricity GHGs ahead of a public consultation window this Fall. We have an opportunity to speak directly to this governance body now.

The PCAA works to ensure that the public, rule makers, and thought leaders hear the broad consensus perspective that markets work best when energy customers can use a broad suite of procurement approaches.  In particular, PCAA brings the perspective that energy customers should not be required to procure clean energy that is matched to their load hourly and geographically. 

The proposed rule changes would force clean energy buyers to match clean electricity purchases to their own facilities’ electricity use on time (hourly) basis and narrow geographic (grid region) basis (aka “load matched 24/7”). 

Under today’s rules, a company can match any megawatt-hour of its electricity consumption with clean electricity that it buys over the course of a year and across broad geographies (potentially the whole United States or Europe). 

This flexibility allows companies to source clean electricity on a cost-competitive basis and from locations where project development is feasible. It also permits companies to target projects on the dirtiest grids (regardless if they have buildings near the project or not) and maximize decarbonization impact.

Most organizations are likely to slow down or completely stop buying clean electricity if required to match the location of the clean electricity projects to where they have electricity load and match the purchases to their use on an hourly basis. Projects might not exist where companies have facilities; markets in those locations might prohibit direct procurement of power; the costs will increase significantly; and the deals will be dramatically more complex.Previously effective transaction types will become more difficult. For example, many organizations use annual “virtual power purchase agreements” (VPPAs) with large-scale wind and solar projects to cover their electricity use across the United States or Europe. Under load-matched 24/7’s location matching requirements, a company could only match its electricity use within the same region as the wind or solar project. For locations where organizations already have few opportunities to buy clean electricity, load-matched 24/7 may leave companies with few or no options.

There are critical gaps in the availability of data to do load-matched 24/7 accounting. Companies typically do not have hourly consumption data, while other inputs (hourly grid emissions data, hourly project production data) are rarely available. GHGP may propose that companies use modeling or proxy data to supplement data that is available, but these sources are relatively unfamiliar to companies and untested.

Rather than require load-matched 24/7, GHGP could make it optional and maintain incumbent rules. GHGP will likely propose other updates and reforms to GHG accounting rules, but other anticipated provisions are unlikely to disrupt procurement options.

Feasibility: Experts indicate that 24/7 procurement likely comes at a significant cost premium, while alternative strategies can achieve higher impact in reducing emissions with greater efficiency (see McKinsey, 2025; Tabors, 2023; Olson et al, 2023; Riepin 2024). 

Integrity: There is concern that the current proposal for 24/7 load matching would be difficult for corporations to implement and could lead to double counting and deliverability issues. If Integrity is to be a focus, it's hard to argue that the new rules will be more accurate.

Impact: The most impactful clean energy strategy should make power investments using an integrated, grid-level lens that encompasses the state, power market region, or even country of operations. 

If companies are forced to procure only for their own loads,  assets or buildings, we've lost our systems approach. This will push the dirty power to smaller companies, households, and individuals. Carbon is everyone's challenge, so creating a world of have and have nots does not serve anyone.

If you're looking for more data to support this concern, McKinsey’s analysis shows that requiring companies to match their load hourly and geographically ‘leads to unintended consequences that could slow decarbonization. Companies seeking the most impactful clean-energy strategy should instead make power investments using an integrated, grid-level lens that encompasses the state, power market region, or even country in which they operate.

In addition, WattTime’s analysis shows that ‘mandatory hourly matching’s high costs would likely kill so much clean energy procurement, it would increase total long-run emissions.’

We can all agree that the current market-based approach to Scope 2 accounting could be improved, and that voluntary markets could do with great accountability, integrity, and measurability.

However, the voluntary market has enabled over 100 GW of clean energy to come online since 2008 through corporate purchases. The PCAA's concern is that forcing mandatory load matching will shrink the size of this market and make it harder for buyers to reach their emissions reduction goals -- for some smaller players, it may even mean giving up. 

The IEA is unequivocal that the world needs 1200 GW of new renewable capacity added every, single year (that’s 3x current numbers) to achieve climate goals.  Governments won’t get there through mandates alone–we need robust, flexible voluntary markets.

As ACORE, a leading voice on renewable energy, says, ‘at a time when clean energy companies face significant global and domestic headwinds, an overly restrictive approach for GHG reporting requirements that shrinks the number of voluntary purchasers could be a breaking point for many companies in the clean energy market’.”