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Responding to The GHG Protocol Survey

Due March 14, 2023

EMA Board-Approved Responses for The GHG Protocol Survey

2023-03-14_EMA Responses to GHG Protocol Scope 2 Survey.docx

Thank you for joining EMA’s discussion on the importance of voluntary market-based instruments like RECs, GOs, and EACs and how they are threatened by potential changes to the GHG Protocol. It was clear from the comments of the panelists that market-based accounting is fundamental to encouraging low carbon investing at scale.

The following are the key take-away facts we’d like to leave you with along with a call to action. 


  • The GHG Protocol is one of the most widely used global accounting standards for emissions reporting (Scope 1, Scope 2, Scope 3)
  • The GHG Protocol is revising its Scope 2 Guidance (reported emissions from electricity, steam, and heat purchases)
  • The GHG Protocol may eliminate the use of tradable renewable energy certificates (RECs), Guarantees of Origin (GOs), and other Energy Attribute Certificates (EACs) in ‘Net Zero’ accounting
  • Tradeable RECs are a critical revenue stream for renewable energy project finance transactions and are absolutely critical for driving additionality
  • Tradeable RECs provide the flexibility needed by buyers to efficiently, accurately, and cost-effectively achieve their sustainability targets
  • As a market practitioner, you have an opportunity to have your voice heard on this issue by submitting comments to the GHG Protocol 

Call to Action:

  • Submit your comments to the GHG Protocol by March 14, 2023
  • Ask EMA and your other associations (e.g. CEBI, I-REC, RTC, etc.) for more background or help on submissions
  • Join EMA's working sessions on the topic and formulate EMAs comments to the GHG Protocol - January 24th at 10:00am ET.
  • Educate the GHG Protocol by creating and submitting real-world renewable energy case studies on the value of market instruments and these mechanisms to your organization (see Sol Systems' Case Study examples below for inspiration!)

Submit your comments to the Survey on Need for GHG Protocol Corporate Standards and Guidance Updates.

EMA Fireside Chat with Michael Macrae, Senior Manager, Scope 2, Greenhouse Gas Protocol

Recorded March 2, 2023

Watch the Recording

Recording from The EMA Town Hall held on Tuesday, January 10, 2023.


Christian Hofer, Sol Systems

Doug Miller, CEBI

Jared Braslawsky, I-REC

Katrien Verwimp, AIB

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