GHG Protocol Scope 2 Survey: Ever.green's Response Guide

Time is running out. The Greenhouse Gas Protocol's survey on proposed Scope 2 changes closes December 19, 2025. This is your opportunity to influence guidelines that will significantly reshape how renewable electricity is purchased, claimed, and valued with direct implications on the voluntary markets and revenues from renewable energy certificate (REC) sales.

Your voice matters. Your feedback matters. We encourage everyone in renewable energy, owners, operators, buyers, and sellers, to review the proposed changes and respond by December 19.

The main survey is extensive, containing 183 questions with many requiring thoughtful, open-ended responses. You're not required to answer everything, but we encourage you to complete as many questions as possible. This guide will help you understand what's proposed, why it matters, and where to focus your input.

‍

‍

If you have limited time to commit to this, we recommend at least answering these questions as follows in the GHG Protocol Survey:

What’s actually changing and why it matters

What stays the same:

• Maintain dual-reporting structure (location-based and market-based methods)
• RECs remain usable in the market-based method (with new restrictions)

Changes to scope 2 definition:

• Redefine scope 2 market-based method to eliminate consideration of market instruments (RECs) you have contracted and purchased if you can not narrowly match it to electricity you consumed. (Question 18)

Changes to market-based method:

• Hourly + location matching required (the big change): Unless exempt, RECs must come from the same hour and location where you use electricity (Questions 18-18)
• Residual mix: Updated definition; where unavailable, use fossil-only rates (Questions 118-123)
• Standard Supply Service: Companies can claim their pro-rata share (Questions 97-112)

Feasibility (implementation) measures:

• Load profiles allowed to convert annual/monthly data to hourly when needed (Questions 76, 80-82)
• Exemption thresholds for smaller organizations (Questions 70, 153-170)
• Legacy protections and phased implementation being considered for existing contracts (Questions 171-178)

Changes to location-based method:

• More granular emissions factors: Use the most precise location-based and time-based emissions factors that are publicly available, free, and from credible sources (Questions 23-51)

Everyone agrees on one thing: long-term contracts (PPAs and VPPAs) are how new renewable energy projects get financed and built. These contracts de-risk projects and enable clean energy that wouldn't otherwise be built by providing the revenue certainty developers need to secure financing.

The proposed rules make these contracts more complicated, costly, and sometimes impossible. Companies will shift to easier options: buying from existing projects (which adds no new clean energy) or exiting voluntary markets entirely.

The outcome: fewer renewable energy projects get built, even as emissions accounting becomes more "accurate.”

‍

What this might look like

A corporate buyer in New York will no longer be allowed to sign a long-term forward contract (Virtual PPA or High-impact REC strip) with an out-of-state solar farm (e.g., in Pennsylvania or West Virginia), even if that solar farm avoids significantly more emissions than a project in New York.

And for buyers that are distributed across regions, they will need to do a separate contract for each region instead of being able to aggregate their demand across regions to be large enough for a single contract.

And instead of one 10-year forward contract for 10,000 MWh / year, the buyer must procure for each hour, based on their hourly electricity consumption.

What Ever.green is advocating for

We're advocating for:

• Maintaining today’s definition of scope 2 which splits consumed and purchased into two methods
• Making granular matching (hourly+location) optional (companies “may” instead of “shall” match RECs to the hour and location of usage)
• Broadening exemptions that better target large electricity consumers and give others more flexibility to continue using impactful long-term forward contracts
• Strengthening legacy protections for existing contracts companies made with projects based on today’s guidelines
• Extending phase-in periods that give markets time to adapt
• Adopt the improvements that bolster the integrity of impact and accuracy of emissions accounting

We're not trying to preserve the status quo, we're trying to preserve and expand the mechanisms that everyone agrees drive new renewable energy deployment.

Our survey responses reflect our opposition to making long-term forward contracts more expensive and risky while also less accessible and valuable.

What happens next

The survey closes on December 19, 2025. This is the best opportunity to help shape these rules.

GHG Protocol expects to finalize the guidelines by the end of 2027. Companies could be required to use them as soon as 2029 for reporting on 2028 emissions.

That timeline might feel far away. But long-term PPAs are being negotiated right now. Projects are being financed right now. Uncertainty about future accounting rules is already affecting decisions. The time to act is now.

‍

‍

Your voice matters - here’s how to use it

We encourage you to review our comprehensive survey responses, learn from them, adapt them, or completely disagree with them.

Submit your own response. Don't sign onto someone else's comments. Your individual perspective carries weight. Every voice counts.

Resources to help you respond

• Essential Questions → Short on time? Start here.
• Ever.green's Survey Responses → Want detailed guidance and commentary?
• Blank Survey Template (also available as Word Doc) → Want space to draft your answers first and/or collaborate with others?

Share this with others who should participate. The December 19 deadline applies to everyone who cares about making corporate climate commitments drive real-world impact.

Need deeper context?

1. Paper: Limitations of Hourly Matching for Scope 2 Reporting
2. FAQ: Limitations of Hourly Matching Claims

Guidance & resources from others:

1. GHG Protocol's Public Consultations homepage
2. Clean Energy Buyers Association (CEBA) Scope 2 Toolkit
3. Center for Resource Solutions (CRS) Scope 2 Perspective

If you have questions or want to discuss specific survey questions, please reach out to our team at hello@ever.green

‍

‍

Important: Public Record Notice

• All survey responses become part of the public record.
• You can request your name be withheld if privacy is a concern with question 3 in the survey (not recommended)
• You can also submit separate confidential information in addition to (but not instead of) your survey response here.

‍

‍