Public Statement from Members of the GHG Protocol Scope 2 TWG Consequential Subgroup

Published November 2025

As members of the Scope 2 Technical Working Group ("TWG") and its Consequential Subgroup, we share this statement to complement the Electricity-Sector Consequential Methods Public Consultation and to support stakeholders in providing informed and meaningful feedback. This statement and accompanying materials were authored in our individual capacities, and do not reflect the positions of the GHG Protocol, its Secretariat, or the broader Scope 2 TWG.

In February 2025, the Greenhouse Gas Protocol ("GHG Protocol") Secretariat convened a subgroup of experts within the Scope 2 TWG to develop an accounting methodology for quantifying the marginal emissions impacts from electricity consumption and procurement. The subgroup's purpose was to recommend how organizations can quantify and report consequential GHG impacts from their electricity-related actions, with the intention that this method would be applied as part of a comprehensive report alongside the Scope 2 location-based and market-based methods.¹²

While the public consultation survey refers to the subgroup's work, several elements of the proposal submitted to the Independent Standards Board ("ISB") in June 2025 are not captured in the consultation materials. Some of these elements did not receive majority support from the ISB or were challenged by the ISB upon review, but we believe deserve consideration in the active debate over the direction of consequential method.

To ensure transparency and support stakeholder understanding, we are sharing the key elements of the subgroup's marginal impact method ("MIM") proposal submitted to the ISB. A comparison between the public consultation materials and the subgroup's proposal is included in an appendix. We note the following material differences:

• Core calculation: The public consultation focuses only on avoided emissions from projects outside corporate inventories, reflecting feedback provided by the ISB in July 2025 regarding their preferred direction for this element of the methodology.³ The subgroup's proposal, in contrast, introduces a net impact equation that captures both emissions caused by electricity consumption and those avoided (or caused) through energy procurement. This provides a complete and comparable picture of system-level impacts. The benefits of using both elements is it enables better decision-making and abatement planning, offering insights not reflected in location- or market-based reporting. Without both metrics, avoided emissions cannot be properly contextualized or compared, e.g. when a company increases load at times or locations with high marginal emissions. In addition, energy storage projects, which are seen as a key requirement to transitioning the grid to 100% clean energy, both consume and produce electricity, which inherently requires both actions to be measured under a consequential method.
• Approach to additionality: The public consultation lists several possible additionality tests for general stakeholder input. The subgroup's proposal introduces a structured decision tree to show how these tests could be applied in practice based on specific attributes of electricity projects and markets. The ISB provided feedback in July 2025 that this approach would not be sufficiently rigorous.³ It was intended, however, as a practical starting framework for stakeholder review and refinement through the consultation process.
• Intended application: The public consultation positions the materials primarily as input to the broader Actions and Market Instruments ("AMI") workstream, aimed at developing sector-agnostic guidance over time to quantify and report consequential impacts of actions across all scopes. The subgroup's proposal focused on delivering near-term, actionable recommendations to advance consequential accounting within the Scope 2 Guidance for the electricity sector, with the potential to expand to other scopes and sectors over time.

We remain supportive of the GHG Protocol's objective to develop clear, credible, and implementable standards and guidance. Our aim in sharing these details is to help stakeholders fully understand the context of the current consultation and to ensure that public feedback reflects the range of technical options under consideration.

Signed,

8 Members of the Scope 2 Technical Working Group Consequential Subgroup

¹ GHG Protocol Scope 2 Progress Update, June 11, 2025. https://ghgprotocol.org/sites/default/files/2025-02/S2-Meeting9-Presentation-20250305.pdf

² Scope 2 TWG Meeting #9, March 5, 2025, 8.

³ Scope 2 TWG Meeting #17, July 28, 2025, 15.