In late 2024, Green Strategies issued a survey to companies to ask how potential changes to the Greenhouse Gas Protocol’s (the Protocol) Scope 2 Guidance might impact their clean electricity procurement practices. We recently released our results in a report, How Scope 2 Revisions May Change Clean Electricity Procurement Strategies.
Why did we do this survey? Because Scope 2 Guidance rewrites are underway now for the first time in a decade – and to date, little research has been done on how leading reform proposals might impact the clean energy procurement practices of the companies that drive the voluntary renewable energy market. After attending the recent CEBA Summit, we know many companies are just beginning to understand the changes that are on the table and want their voices heard.
Our survey asked how procurement may change under three different scenarios which align with major stakeholder-proposed revisions now under consideration: 1) smaller market boundaries; 2) smaller market boundaries and hourly-matching requirements; and 3) changes to impact accounting.
So, what did we find?
Scenario 1: Smaller Market Boundaries
Under current Scope 2 rules, companies reduce Scope 2 inventories by matching their consumption with clean electricity purchased within eligible market boundaries. The United States and European Union are individual markets. Proponents of smaller market boundaries argue that narrower location-matching requirements may be a good way to tie greenhouse gas inventories to actual emissions more closely. Our survey identified buyer/practitioner concern with smaller boundaries:
The theory of change for smaller market boundaries is also that it will encourage companies to engage utilities and policymakers. However, nearly 60% of companies said they would not increase engagement with policymakers , and an additional 26% were unsure. Respondents were split on whether they would increase engagement with utilities. Some individual companies cited budget constraints, whereas others were skeptical that utilities would be receptive to increased pressure.
Scenario 2: Smaller Market Boundaries and Hourly Matching
A second scenario asked respondents to consider both smaller market boundaries and a requirement to match clean electricity purchases to energy use on an hourly basis. Our survey found that nearly 80% of respondents lack confidence that they would be able to procure time-matched clean electricity within smaller market boundaries. Respondent insights indicated concern over higher costs and whether suppliers will be able to provide resources that meet time and location criteria.
Approximately two-thirds of respondents expressed that they would likely increase procurement of firm and dispatchable carbon-free energy resources (resources that can be available quickly at all times when needed) – if they were available, though many said they would only increase these purchases if costs were minimal.
Scenario 3: Changes to Impact Accounting
Scenario 3 would permit companies to procure outside current GHG procurement boundaries, require that projects demonstrate meaning generation from new sources, as opposed to pre-existing), and separately report displaced emissions from their procured electricity. While most respondents said they would procure the same overall volume of clean electricity, approximately 60% of respondents indicated that the flexibility to procure outside of existing market boundaries would allow them to increase the carbon impact of their clean electricity purchases. Approximately 60% of respondents indicated that even with broader boundaries, they would not necessarily increase their procurement, while 22% indicated they would procure more.
What does this mean?
We need more insight into buyer perspectives and potential behavior changes resulting from updates to the Scope 2 Guidance. We presented the results of our survey during a conversation table at the 2025 CEBA Spring Summit. There was a lot of interest from attendees – many may have been aware generally of the Protocol updates but were less aware of the specific proposed changes. These conversations underscored what we found with the survey –some potential Scope 2 changes may inhibit company procurement of clean electricity.
The Protocol should update and adopt reforms to address existing shortcomings, but it needs to consider the likely impact of these changes. Existing reform proposals may disrupt the ways that many companies currently transact for clean electricity, and the Protocol should consider how it can stay usable and relevant in order to allow companies to keep expanding clean electricity. If you represent a corporate buyer of clean electricity, or are otherwise a clean electricity practitioner, now is the time to make your voice heard on Protocol updates. What would work for you? What improvements would you suggest? We anticipate that the public comment period will be open in the fall of 2025, but engaging members of the Technical Working Groups and other relevant stakeholders now is also critical.
