2.5 Energy use (gas and electricity)

2.5.1 Treatment of renewable electricity in Scope 2 emissions

This guidance details how the carbon attributes of renewable energy in the form of energy attribute certificates (EACs) are accounted for in Scope 2 of the GHG inventories that underpin CarbonNeutral® certifications.

The “Scope 2 Guidance” amendment to the GHG Protocol, published in 2015 after four years of development and industry consultation, provides guidance for how corporations should measure emissions from electricity and energy purchases, including renewable energy, and covers:

• Requirements: Accounting and reporting requirements which entities must meet to be in conformance with the GHG Protocol Corporate Standard

• Quality Criteria: A list of Scope 2 quality criteria that all electricity purchasing instruments, termed “contractual instruments,” need to meet in order to be used in market-based method accounting

• Recommendations: Additional features entities are recommended to disclose include their electricity purchases, as well as other metrics such as total electricity, steam, heating, and cooling consumed and what percentage of a corporation’s operations have market-based method data available

From the date of publication of the GHG Protocol Scope 2 amendment, entities using the GHG Corporate Protocol to meet the GHG inventory requirements of The CarbonNeutral Protocol are required to meet its Scope 2 Guidance, as officially amended from time to time by the WRI.

Entities using any other GHG inventory standard recognized under The CarbonNeutral Protocol are subject to The CarbonNeutral Protocol’s original requirements that:

1. Zero emissions may only be claimed when double-counting is avoided. Evidence should be made available to establish either that the renewable electricity is not supplied to the national grid in the country concerned; or, that the benefit of the renewable energy is not included within national average grid factors or any other reporting factors
2. Emissions from energy supplied as “green,” “clean,” or “low-carbon” can be treated as zero where the energy consumed has been fully offset by the supplier or a third party using carbon credits that meet the requirements of The CarbonNeutral Protocol (as detailed in Technical Specifications 4.2.1)

For more information see: RECS International, 2020, Maximising the reliability and impact of buying renewables: guidance for market participants, https://recs.org/app/uploads/documents/Maximising-reliability-and-impact-guidance_FINAL.pdf&file_type=documents.

2.5.2. Treatment of Energy Attribute Certificates (EACs) in Scope 3 emissions

This guidance details how EACs may be applied to emissions resulting from:

• Electricity consumption in the use phase of CarbonNeutral® product and product-as-a-service certifications
• Electricity consumption from employee homeworking and remote work
• Transmission & Distribution (T&D) losses

This guidance – first published in January 2022 – is the result of market guidance and is expected to be reviewed and updated once new guidance becomes available from the GHG Protocol and/or other recognised standards.

There is a lack of consensus on the use of EACs for Scope 3 emissions, and so companies should consider that doing so may be outside of the scope of the existing version of the GHG Protocol guidance. Appropriate disclosures should be made to ensure that such treatments and decisions are clearly documented an explained. Consideration should also be given to the view of assurance providers, and it is recommended that the company consults with its auditors. 

Where electricity-derived emissions in Scope 3 have already been addressed within the supply chain, for instance, a supplier has already purchased EACs, this may be reported as a marketbased figure by the company. In this case, the company should request evidence to support this treatment. 

Use phase of CarbonNeutral products and products-as-a-service

The following requirements must be met when EACs are applied to use-phase emissions: 

• The emissions to which EACs are applied as part of CarbonNeutral® product or CarbonNeutral® productas- a-service certifications must be those from electricity consumption in the use phase 
• Use-phase emissions for the entirety of the product lifespan must be reduced to zero through the application of EACs and/or all remaining emissions must be offset through carbon credits to ensure a valid use of CarbonNeutral®. 
  • The GHG Protocol Scope 2 Guidance recommends matching the consumption period of electricity to the generation period. Therefore, vintage of EACs must match the period of electricity consumption as closely as possible. If EACs cannot be applied for the entirety of the product lifespan, entities must ensure that remaining emissions from the entire use phase are offset via carbon credits.
  • For example, in the case of a product whose lifespan is seven years, if EACs are procured for years 1 and 2 but are unavailable for years 3-7, then carbon credits equivalent to the estimated electricity emissions for years 3-7 must be held in inventory until EACs are purchased and retired. At the end of the certification period, upon reconciliation of the actual product use, a sufficient quantity of EACs and/or carbon credits must be retired. 
• CarbonNeutral products and products-as-a-service (PaaS) must calculate emissions for a defined function, as well as the duration and level of the service provided by the product, referred to as the use phase, as defined in the GHG Protocol Product Life Cycle Accounting and Reporting Standard
• EACs must be retired/cancelled as appropriate for a specific market. The retirement shall be made on behalf of end users of the product or product-as-a-service where practical and possible
• Methodologies and assumptions for determining electricity consumption for the use phase must be provided as described in Technical Specification 2.2
• Use-phase emissions must be reported using both a location-based and market-based method (i.e., with and without the application of EACs)

Use-phase emissions shall be determined according to the following requirements:

• Primary data must be used where available
• Use data must be attributable to the country/region where the electricity is being consumed by the product or product-as-a-service. Where actual location is not available, a reasonable estimate of the country or region must be made
• Disclosure in the product or product-as-a-service terms and conditions must be made referencing the retirement of EACs on end users’ behalf

Employee homeworking

The following requirement must be met when EACs are applied to electricity consumption from employee homeworking and remote work:

• The location of electricity consumption must match the location of the EAC, e.g., US employees must use North America RECs

Transmission & distribution losses 

The following requirement must be met when EACs are applied to electricity from transmission & distribution losses: 

• The location of the electricity losses must match the location of the EAC, e.g. UK-based grid losses must be addressed by REGOs. 
• The calculation method used to calculate and report T&D losses must be disclosed. 
• For example, a 7% grid loss rate for 100 MWh consumption would result in 7 MWh T&D losses. A company would need to purchase 107 MWh EACs to cover both scope 2 and 3.3 emissions associated with T&D. 

2.5.3 Market-based Scope 2 reporting declaration to support CarbonNeutral® certification

This guidance details the disclosure requirements for organizations seeking to make a market-based Scope 2 reporting declaration in support of CarbonNeutral® certification. The disclosure only needs to be made when the party supplying the contractual instrument is not the primary CarbonNeutral® certifier, for example, when an entity sources renewable electricity directly from a utility company.

The disclosure table will be provided by the CarbonNeutral® certifier upon request. A column should be added to the table to account for each contractual instrument claim made within a corporate GHG inventory. Often this will involve engaging the contractual instrument supplier to determine the appropriate form of evidence that can be supplied to substantiate a market- based claim. The disclosure table should be completed at the time of preparing the GHG inventory and should be signed by an organization representative to warrant that the information provided is up to date, accurate, and that the CarbonNeutral® certifier can rely on the information.

When an entity’s location is neither consuming renewable energy nor applying EACs to reduce their Scope 2 emissions, and the emissions associated with its energy use, for examples through a published residual mix emissions factor, is available, then the residual emissions factor(s) must be applied, resulting in a market-based total for Scope 2 emissions.

2.5.4 How to report GHG emissions from green gas certificates

Green gas certificates are relatively new products that are being adopted by businesses to manage their Scope 1 GHG emissions.

Green gas, known also as biogas, refers to calorific gas produced by the breakdown of organic matter, through anaerobic digestion or fermentation. Feedstocks include biodegradable materials such as manure, sewage, municipal water, green waste and plant material.

Before biogas can be introduced to the gas grid it needs to be upgraded to pipeline quality natural gas standards. This upgraded gas becomes biomethane, which can be used for any purpose currently satisfied by conventional natural gas.

Injecting biomethane into the natural gas grid displaces the need for a unit of conventional natural gas. Therefore, certificates and contracts are the only practical means of tracking the green gas from production to end use. Projects such as the Green Gas Certification Scheme aim to provide a certified means of tracking green gas injected into the grid through to end user consumption claims, similar to renewable electricity tracking schemes such as I-REC (International REC standard) and EECS-GO (European Energy Certificate System – Guarantee of Origin).

Clear guidance on extending market-based reporting approaches to renewable gas is still forthcoming. In their Technical Note: Accounting of Scope 2 emissions, the CDP recommends referring to the GHG Protocol’s Scope 2 Guidance when using green gas certificates.