Open Letter: No to Mandatory Load-matched 24/7 CFE

As the GHG Protocol (GHGP) Scope 2 guidance undergoes its first significant update in a decade, we are extremely concerned that the proposed revisions to market-based accounting, which require voluntary buyers to match CFE purchases to their individual load on an hourly and physically deliverable basis ("load-matched 24/7 CFE"), will:

1. Result in limited benefits to carbon accounting accuracy.
2. Drive inefficient private-sector action, impeding system-wide decarbonization, and
3. Discourage participation in voluntary clean energy procurement markets.

These outcomes run counter to GHGP’s stated objectives and will not accelerate our path to CFE for all people, everywhere, all the time.

For now, the proposed changes may only impact the largest buyers - those that use over 10 GW per year (to put it in perspective, that’s about 7% of the wind or solar capacity in the US at the end of 2023). But those buyers are the drivers of the voluntary market – it’s critical that we hold them to the highest accounting standards while ensuring the continued success of a robust voluntary market.

Follow along to see how this action catalyzes change in the Scope 2 revision process.