It seems inevitable that, if things progress as my sources tell me, there will be a huge backlash from corporates against the Greenhouse Gas Protocol. The Protocol is going through a revision at the moment, but the Protocol itself is so complex and the review process so opaque, few people know about the direction of travel. I certainly can’t claim to know everything about it myself. I can only report what I’ve been told, and I’d be delighted to be proven wrong.

Firstly, why is the RTFA looking at this? One of our members, with a large and expanding fleet of trucks running on biomethane, has been told by its auditors that it will need to stop reporting the (virtually zero) GHG emissions associated with that biomethane under scope 1. That undermines its whole raison d’être for converting to biomethane. If they had purchased the biomethane from a dedicated supply line (e.g., via a road tanker) it would be okay, but because it is mass balanced over the grid it is not.

A recent survey indicates a possible intention to take the same approach with electricity, so if a corporate buys renewable electricity direct from a private wire connection to a wind farm it will be okay. If it buys it mass balanced over the grid (i.e., via a PPA), it will not be okay.

This will completely undermine the whole rationale of getting corporates to report their GHG emissions, because exercising choice over their energy purchases is one of their main means of decarbonising their activities.

So why is the GHG protocol viewing “market-based instruments” in this way? What is the problem?

Is it because by buying green it leaves less to go around for others? In other words, if it takes that green gas or electricity out of the shared grid, it only goes to make the average grid stuff browner?

Or is it because there is a risk that there is some double claiming of renewables? Because the renewable gas or electricity might simultaneously be being claimed by the corporate with the PPA or green gas contract, as well as being claimed by other corporates who report a slightly lower carbon intensity factor for their grid-purchased energy on account of it containing a portion of renewables?

Or is it not about number counting at all, but about whether it’s made any difference? i.e., has there been any additionality? Has that purchase enabled that wind farm or biogas plant to be built – or would it have happened anyway on account of (in the UK context) the Renewables Obligation / Renewable Heat Incentive / Renewable Transport Fuel Obligation?

To put that question another way – the corporate isn’t footing the bill for that renewable energy as it was paid for by all electricity consumers / taxpayers / motorists…. So why should they claim the credit?

This is a real dilemma.

Greenwashing and double claiming of environmental credentials are unacceptable. If the purpose of the GHG Protocol is to prevent these (i.e., its purpose is an inventory), then it must be able to do that without disengaging corporates who are trying to do the right thing.

If the purpose of the GHG protocol is to drive additionality, then it faces the challenge of reconciling the regulatory approaches for driving environmental investments with the voluntary market. That can be challenging even on a policy-by-policy level, let alone trying to do it on a global basis.

There needs to be some clarity on this and soon, otherwise there will be a whole lot of disengaged corporates just when the world needs them to do all they can to bring down GHG emissions. Both forces are needed – the push of Government regulation, and the pull of green corporate demand.


useful links

RTFA note on the GHG Protocol changes

RTFA’s Answers to selected questions in GHG Protocol Survey

These slides produced by the Green Gas Certification Scheme in October 2022 explain the impact of the draft GHGP “Land Sector and Removals Guidance” on biomethane producers and consumers