| 18 |
Redefining scope 2: We recommend that GHGP keep the existing Scope 2 definition, which properly
reflects how companies purchase and are assigned electricity, and avoid adding “physical connection”
language that misrepresents how electricity markets and certificates work.
|
Scope 2 was designed to track what companies buy, not what electrons physically hit their meter. If you
redefine it as “only what flows to your building,” you erase the ability to count long-term contracts that
actually finance new clean energy.
|
| 70 |
Threshold for hourly exemption:
(c) 50 GWhs
|
The highest threshold will do the least damage to reducing the pool of buyers that can sign PPAs and/or
purchase RECs from projects.
|
| 71 |
Hourly support:
(1) No Support
|
Hourly matching sounds precise, but it makes long-term contracts much harder to sign, which means fewer
new projects get built.
|
| 74 |
Reasons for concern:
Select reasons for concern #1, 2, 4, 7, 8, 9
|
It raises costs, breaks scalable procurement, discourages PPAs, reduces participation, and does little to
improve real-world emissions.
|
| 83 |
Market-boundary support:
(1) No Support
|
Narrow geographic rules make accounting look stricter, but they push money away from the places where
clean energy is most needed and most impactful.
|
| 86 |
Reasons for concern:
Select reasons for concern #1-4, 8-9
|
You cannot physically trace electrons anyway, so tight boundaries only destroy flexibility and financing
without improving accuracy.
|
| 88 |
US market-boundary:
(e) Other
|
None of the proposed maps really reflect how power flows or how contracts work. Bigger regions are better
for impact.
|
| 91 |
Propose different market-boundary: Boundaries based on synchronous grids (Eastern Interconnection, Western Interconnection, and ERCOT).
|
Power markets are continental-scale systems. Accounting should reflect that, or you break the economics that fund new clean energy.
|
| 97 |
Support SSS guidance:
(1) No support
|
The proposed rules would distort markets and penalize companies that try to do better than their utility’s default mix.
|
| 100 |
Reasons for concern:
Select reasons 1-4
|
It risks double-counting, weak incentives, and confusing signals that do not actually drive new clean power.
|
| 107 |
Distribute SSS without RECs:
No
|
If you remove RECs, you remove proof of ownership and create double-counting. That destroys market
credibility.
|
| 130 |
Feasibility measures:
(1) Insufficient
|
They would be extremely expensive, complex, and slow, especially for companies with many sites or global
operations.
|
| 139 |
Change in procurement cost:
(5) Much more
|
Fragmented hourly and local procurement dramatically increases transaction and compliance costs without
proportional climate benefit.
|
| 146 |
Does impact metric change your mind?:
(c) No
|
The modeling shows benefits only at very high cost and under unrealistic participation assumptions. |
| 152 |
Overall revisions needed:
(1) Add options that allow for and recognize different kinds of impactful action including long-term
forward contracts which are made more difficult, costly, and unattractive by requiring hourly matching and
deliverable market boundaries. (2) A pathway that uses hourly matching and deliverable market boundaries
to improve the impact of voluntary markets needs a third pillar that addresses incrementality.
|
The rules ignore the single most important driver of clean energy: long-term contracts that make projects
financeable.
|
| 153 |
Exemptions for hourly matching:
(5) Fully support
|
Without broad exemptions, most buyers cannot practically participate in meaningful clean-energy
procurement.
|
| 163 |
Which exemption is appropriate?:
(c) Option 3
|
The rules should protect the ability to aggregate load and sign big, bankable contracts. |
| 171 |
Legacy clause:
(5) Fully support
|
Companies signed contracts under the old rules to build new projects. Retroactively invalidating them
would be unfair and would destroy trust in the system.
|
| 173 |
Reasons for support of legacy contracts: Contracts signed prior to implementation of new Scope 2
Standards (post phase-in period) should be honored for the duration of the contract as addressing a
company’s Scope 2 inventory under the current rules.
|
If existing contracts can be invalidated for addressing sustainability goals by rule changes, no one will
sign the next generation of climate-critical deals.
|
| 181 |
Transition approach:
(a) Legacy clause
|
Protect existing commitments while evolving the rules. Stability is essential for climate finance. |
