Modernizing GHG Accounting Rules and Climate Leadership Programs
Summary
The document examines the limitations of current GHG accounting, particularly the Scope 2 Market-Based method, which allows companies to claim zero emissions through annual matching of renewable energy certificates (RECs) without necessarily reducing actual grid emissions. The authors propose a dual approach: improving attributional accounting to require hourly and locational matching of carbon-free electricity (CFE) to consumption, and implementing consequential accounting to measure the actual marginal impact of company actions on the atmosphere. This framework aims to incentivize a diverse portfolio of CFE, including firm and dispatchable resources, rather than just low-cost variable renewables.
Key insights
- The current Scope 2 Market-Based method is insufficient for achieving net-zero goals because it does not accurately measure emissions from the actual supply serving electricity use, fails to value firm carbon-free electricity (CFE) and storage, and does not estimate real-world emissions reductions.
- Current accounting allows companies to report a zero Market-Based inventory (MBI) using unbundled RECs from distant sources, even if their actual electricity is supplied by local fossil fuel plants, leading to misleading environmental claims.
- The authors distinguish between attributional accounting, which allocates responsibility for emissions within a company's value chain, and consequential accounting, which assesses whether a company's actions actually reduce or increase system-wide emissions to the atmosphere.
- To improve the Market-Based method, the authors recommend that inventories reflect supply that is deliverable to the location and matches the timing of customer consumption.
- Matching deliverable CFE supply with consumption on an hourly basis is expected to create demand for a diverse mix of resources, including firm CFE and advanced storage, which are necessary for a fully decarbonized grid.
- The climate benefit of a megawatt-hour of CFE varies significantly by location and time; for example, a wind project in Kansas can have 2.3 times the emissions impact of a solar project in California.
- The authors propose a comprehensive measurement framework consisting of three metrics: an improved Scope 2 MBI for emissions from electricity use, qualitative/quantitative descriptions of incremental CFE resource development, and new consequential impact disclosures for reductions in emissions to the atmosphere.
Cite the original document
- APA
- Fisher, N., Ballentine, R., Hobbs, B. F., Cohen, A., Pablo, J., & Kaplan, I. (2024). Modernizing GHG Accounting Rules and Climate Leadership Programs. Clean Air Task Force. https://cdn.catf.us/wp-content/uploads/2024/05/08144502/modernizing-ghg-accounting-attributional-consequential-accounting.pdf
- Chicago
- Fisher, Neil, Roger Ballentine, Benjamin F. Hobbs, Armond Cohen, Jeanette Pablo, and Iain Kaplan. Modernizing GHG Accounting Rules and Climate Leadership Programs. Clean Air Task Force, 2024. https://cdn.catf.us/wp-content/uploads/2024/05/08144502/modernizing-ghg-accounting-attributional-consequential-accounting.pdf.
- Wikipedia
- {{cite report |last1=Fisher |first1=Neil |last2=Ballentine |first2=Roger |last3=Hobbs |first3=Benjamin F. |last4=Cohen |first4=Armond |last5=Pablo |first5=Jeanette |last6=Kaplan |first6=Iain |title=Modernizing GHG Accounting Rules and Climate Leadership Programs |publisher=Clean Air Task Force |date=May 2024 |url=https://cdn.catf.us/wp-content/uploads/2024/05/08144502/modernizing-ghg-accounting-attributional-consequential-accounting.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{fisher2024modernizing, author = {Fisher, Neil and Ballentine, Roger and Hobbs, Benjamin F. and Cohen, Armond and Pablo, Jeanette and Kaplan, Iain}, title = {{Modernizing GHG Accounting Rules and Climate Leadership Programs}}, institution = {Clean Air Task Force}, year = {2024}, month = may, url = {https://cdn.catf.us/wp-content/uploads/2024/05/08144502/modernizing-ghg-accounting-attributional-consequential-accounting.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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