Third Way and over 60 stakeholders including Green Strategies, Inc., sent a letter urging Congressional leaders to continue to channel funds towards Department of Energy (DOE) innovation activities as part of FY2024 appropriations. DOE has a key role in supporting the research, development, demonstration, and deployment (RDD&D) of both commercial and early-stage clean energy technologies. The DOE has an even more crucial role in bridging the innovation “valley of death” that sometimes befalls early-stage technologies. Annual investments can help ensure an array of offices and programs receive funding necessary to continue creating jobs, strengthening energy security and reducing emissions.

Signatories span from the political spectrum and include the carbon-free energy industry, environmental NGOs, and investment groups and thank Congress for their leadership and continued commitment to clean technology RDD&D.

Further details and the full letter are available in the Third Way Press Release.

The letter was also featured in Politico’s Morning Energy.

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.

Green Strategies commends the Greenhouse Gas Protocol for undertaking a revisions process for its Scope 2 Guidance and has recommended minor changes that we believe would improve the greenhouse gas reduction impact of an updated Scope 2 Guidance.

Please view a copy of our responses to the Greenhouse Gas Protocol’s Scope 2 Guidance Survey here.

Green Strategies and the NorthBridge Group also submitted three proposals to the Greenhouse Gas Protocol on additions to include in an updated Scope 2 Guidance: a Standardized Reporting Format, Market-Based Modernization, and Emissions Impact Disclosure.

*Update April 5, 2023*

We have published a summary of these proposals as well as our survey responses on our website and social media.