Green Strategies, the NorthBridge Group, and Clean Air Task Force offer comments on the Federal Trade Commission’s (FTC) Guides for the Use of Environmental Marketing Claims (Green Guides).

We find that the FTC’s reexamination of the Green Guides is timely given the mounting demand for and marketing claims about sustainable products. We respond to the FTC’s notice of regulatory review to offer insights on how the Green Guides may be updated to reflect the current landscape of renewable energy and sustainability marketing claims.

Green Strategies, Clean Air Task Force, and the NorthBridge Group Comments on the Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims

The Greenhouse Gas Protocol is considering revisions to its Scope 2 Guidance for the first time in about a decade – and not a moment to soon. We have seen rapid changes in the carbon accounting and clean energy procurement ecosystems over that period, including an increasing push for real climate impact. As the predominant greenhouse gas accounting framework, the Greenhouse Gas Protocol is in a strong position to influence the entire “rules and rewards ecosystem” of carbon accounting and should consider how its Guidance can best reflect and support an evolving clean energy marketplace.

We submitted a survey response, as well as three proposals (Standardized Reporting Format, Market-Based Modernization, and Emissions Impact Disclosure), during the Protocol’s Scope 2 Guidance stakeholder engagement process, on how the Protocol can modernize its Scope 2 Guidance to better reflect the current status of the clean energy marketplace and grid decarbonization.

Briefly, we identified three main problems with the Protocol’s Scope 2 Guidance:

1. Market-based accounting rules lead to inventories that are not a true and fair account of a company’s emissions from electricity use.
2. The rules dissuade companies from making the types of procurements needed to decarbonize the grid in all places and at all times.
3. The rules allow and incentivize interventions to achieve inventory reductions that may have little relation to any actual emissions reductions, thus undermining the Protocol’s theory of change that attributing emissions to a company through an inventory and asking that those inventories be disclosed will lead to impact.

To address these problems, we propose several changes:

1. For the purpose of reporting emissions in Scope 2 inventories, the Guidance should narrow the geographic boundary for matching of purchased energy attribute certificates (EACs) and consumption.
2. For the purpose of reporting emissions in Scope 2 inventories, the Guidance also should introduce more specific criteria that encourages the matching of EACs and consumption on a narrower time basis than annually.
3. In parallel to preparing Scope 2 inventories, the Guidance should add provisions for reporting entities to discuss and estimate GHG reduction impact from procurement.

We encourage you to read more in our summary below, and to check out our full responses and proposals.

GHG Protocol Scope 2 survey and proposals summary - March 2023

Green Strategies commends the Greenhouse Gas Protocol for undertaking a revisions process for its Scope 2 Guidance and has recommended minor changes that we believe would improve the greenhouse gas reduction impact of an updated Scope 2 Guidance.

Please view a copy of our responses to the Greenhouse Gas Protocol’s Scope 2 Guidance Survey here.

Green Strategies and the NorthBridge Group also submitted three proposals to the Greenhouse Gas Protocol on additions to include in an updated Scope 2 Guidance: a Standardized Reporting Format, Market-Based Modernization, and Emissions Impact Disclosure.

*Update April 5, 2023*

We have published a summary of these proposals as well as our survey responses on our website and social media.

Green Strategies, the Clean Air Task Force, and The NorthBridge Group are pleased to submit comments in response to the EPA’s RFI on Low Emissions Electricity Programs and Greenhouse Gas Corporate Reporting.

The EPA received $5 million from the Inflation Reduction Act to improve standardization and transparency of corporate climate pledges, and requested input on how best to carry out this task. The questions posed by the EPA are timely. The past decade has seen major strides in deploying and lowering the costs of wind and solar resources, largely through voluntary first-generation procurement of clean energy by major corporations and the Federal government. Now, clean energy buyers are looking to next-generation voluntary procurement to maximize carbon reduction benefit and to scale advanced carbon-free technologies for full grid decarbonization.

We suggest that the EPA can better spur high-impact next-generation procurement through improving the granularity, accessibility, transparency, and comparability of electric system data. We provide our full comments, along with a summary of our specific recommendations, in the pdf below.

The Biden administration has set an ambitious goal to transition to a carbon pollution-free electricity sector by 2035. Meeting this goal will require matching 100% of grid consumption with carbon-free energy in every hour of the year. The EPA is in a strong position to support next generation procurement through standardizing existing data, encouraging generation and emissions data reporting on an hourly basis, and providing guidance where there are data gaps. We applaud the EPA for its ambition to improve the ecosystem of corporate climate commitments and tracking.

CATF NorthBridge and Green Strategies Comments on EPA-HQ-OAR

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Clean Air Task Force is a global nonprofit organization working to safeguard against the worst impacts of climate change by catalyzing the
rapid development and deployment of low-carbon energy and other climate-protecting technologies. With 25 years of internationally recognized
expertise on climate policy and a commitment to exploring all potential solutions, CATF is a pragmatic, non-ideological advocacy group working
to address climate change. CATF has offices in Boston, Washington D.C., and Brussels, with staff working virtually around the world.

The NorthBridge Group is a leading economic and strategic consulting firm serving the electricity and natural gas sectors, including regulated
utilities, competitive generators and energy suppliers, and other companies and organizations active in the energy space. The Firm’s clients
include some of the largest utilities in the United States, players in the fast-changing competitive markets, climate policy organizations, and very
large power users. The foundation of NorthBridge’s work is a combination of market insights, policy and regulatory expertise, perspectives on the
energy transition, and rigorous analytic and economic skills. NorthBridge is a leader in formulating and evaluating investment and operational
strategies to satisfy climate-related goals.

Green Strategies is a clean energy and sustainability management consulting firm founded in 2001. Green Strategies has worked with some of
the world’s largest companies, financial institutions, and leading innovative solution providers to help them align their business strategies with
sustainability and decarbonization best practices. Green Strategies has pioneered the concept of “climate capitalism” – the notion that sustained
business value creation and competitive advantage are best achieved by incorporating climate considerations and emissions mitigation into
business and investment strategies.