Comments on the GHG Protocol Scope 2 Revision

This paper analyzes the implications of the proposed revision of the Greenhouse Gas Protocol Scope 2 Guidance for electricity-market dynamics and energy attribute certificate (EAC) markets. It focuses on three core technical dimensions: (1) hourly temporal matching and its systemic effects on power systems; (2) deliverability criteria and geographic constraints based on bidding zones; and (3) changes in EAC price formation and their consequences for corporate participation. Drawing on the power-systems literature and the International Energy Agency’s six-phase framework for variable renewable energy (VRE) integration, the authors argue that both hourly temporal granularity and more spatially explicit accounting are necessary prerequisites for advancing toward power systems supplied by 100% renewable electricity, particularly in systems at advanced VRE integration stages. The analysis suggests that the revised accounting rules are likely to incentivize firms to further optimize their consumption profiles in a grid-supportive manner, strengthening demand-side management practices already observable in mature electricity and EAC markets. This trend is expected to intensify under growing national commitments to clean energy deployment, rising electricity demand, and constraints on adding new generation capacity. Hourly temporal granularity is expected to enhance incentives for demand-side flexibility and energy storage, which are critical for reducing renewable energy curtailment. Increased locational granularity, in turn, can better reflect transmission constraints, address congestion, and promote investment in optimally sited generation assets. Although the proposed revisions substantially increase complexity, including operational and transactional challenges for suppliers, traders, and end-users, these burdens can be partially
alleviated by specialized EAC service providers operating on aggregation models analogous to those of energy retailers. The authors conclude that proposed changes would benefit grid decarbonization, particularly in high-VRE systems where progress might otherwise stall, and support grid-supportive demand-side management. Overall, benefits of enhanced temporal and spatial granularity in Scope 2 accounting outvalue added complexity, supported by phased implementation, exemptions for small and medium-sized enterprises, and standardized load-profile approaches. From a societal perspective, the revision supports Sustainable Development Goal 7 ”Affordable and Clean Energy” by increasing renewable energy penetration and ideally improving energy service reliability through better temporal and regional matching of generation and demand.