Green Strategies, the NorthBridge Group, and Clean Air Task Force offer comments on the Federal Trade Commission’s (FTC) Guides for the Use of Environmental Marketing Claims (Green Guides).

We find that the FTC’s reexamination of the Green Guides is timely given the mounting demand for and marketing claims about sustainable products. We respond to the FTC’s notice of regulatory review to offer insights on how the Green Guides may be updated to reflect the current landscape of renewable energy and sustainability marketing claims.

Green Strategies, Clean Air Task Force, and the NorthBridge Group Comments on the Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims

The Greenhouse Gas Protocol is considering revisions to its Scope 2 Guidance for the first time in about a decade – and not a moment to soon. We have seen rapid changes in the carbon accounting and clean energy procurement ecosystems over that period, including an increasing push for real climate impact. As the predominant greenhouse gas accounting framework, the Greenhouse Gas Protocol is in a strong position to influence the entire “rules and rewards ecosystem” of carbon accounting and should consider how its Guidance can best reflect and support an evolving clean energy marketplace.

We submitted a survey response, as well as three proposals (Standardized Reporting Format, Market-Based Modernization, and Emissions Impact Disclosure), during the Protocol’s Scope 2 Guidance stakeholder engagement process, on how the Protocol can modernize its Scope 2 Guidance to better reflect the current status of the clean energy marketplace and grid decarbonization.

Briefly, we identified three main problems with the Protocol’s Scope 2 Guidance:

1. Market-based accounting rules lead to inventories that are not a true and fair account of a company’s emissions from electricity use.
2. The rules dissuade companies from making the types of procurements needed to decarbonize the grid in all places and at all times.
3. The rules allow and incentivize interventions to achieve inventory reductions that may have little relation to any actual emissions reductions, thus undermining the Protocol’s theory of change that attributing emissions to a company through an inventory and asking that those inventories be disclosed will lead to impact.

To address these problems, we propose several changes:

1. For the purpose of reporting emissions in Scope 2 inventories, the Guidance should narrow the geographic boundary for matching of purchased energy attribute certificates (EACs) and consumption.
2. For the purpose of reporting emissions in Scope 2 inventories, the Guidance also should introduce more specific criteria that encourages the matching of EACs and consumption on a narrower time basis than annually.
3. In parallel to preparing Scope 2 inventories, the Guidance should add provisions for reporting entities to discuss and estimate GHG reduction impact from procurement.

We encourage you to read more in our summary below, and to check out our full responses and proposals.

GHG Protocol Scope 2 survey and proposals summary - March 2023