Response to GHG Protocol Scope 2 Public Consultation

#Table of Contents

• Response Table

#Response Table

This response to the GHG Protocol Scope 2 Proposed Revisions Public Consultation was drafted by the Policy Working Group, primarily led by Henry Richardson and Ryan Sholin. The full list of questions and the Policy WG’s selections are detailed in this sheet.

The official GHG Protocol context document, which contains the questions, is available here (PDF).

Question #	Question Text	Draft GSF Response
18	Please provide any feedback on the proposal to refine the definition of scope 2, to emphasize its role within an attributional value chain GHG inventory and clarify that scope 2 must only include emissions from electricity generation processes that are physically connected to the reporter’s value chain, excluding any emissions from unrelated sources? Please note that feedback on specific changes to the location- and market-based method can be provided in sections 4 and 5.	The Green Software Foundation’s (GSF) mission includes enabling software engineers to reduce carbon emissions through their choices and actions. In alignment with this, the GSF thinks that the purpose of carbon accounting should be to enable actions by practitioners to reduce emissions. The GSF has developed the Software Carbon Intensity (SCI) standard to enable software developers evaluate the emissions impact of their software and identify actions to reduce that impact. The GSF has identified three three activities that reduce the carbon emissions of software; energy efficiency, carbon awareness, and hardware efficiency. Carbon aware operations directly relates to Scope 2 because of the time and location of software operation. More closely tying the measurement of the emissions of electricity to more granular spatial and temporal requirements enables software engineers to make better informed decisions. The current Scope 2 guidance falls short by using annual averages and overly broad geographic boundaries which does not enable these actions. The GSF strongly supports clarifying Scope 2 as emissions from generation physically connected to the reporter’s value chain. This emphasis on physical connection/deliverability is critical for ensuring the attributional inventory accurately reflects the grid mix the consumed electricity originated from. This forms the essential baseline for all high-fidelity attributional carbon accounting.
19	Please provide any feedback on the proposal to clarify the LBM definition to reflect scope 2 emissions from generation physically delivered at the times and locations of consumption, with imports included in LBM emission factor calculations where applicable? Please note that feedback on specific changes to the location-based method can be provided in section 4.	The GSF advocates for the highest possible resolution in carbon accounting. We agree that the LBM definition should reflect emissions from generation physically delivered at the times and locations of consumption. To enable carbon-aware operations, the GSF recommends that “times of consumption” defaults to hourly or sub-hourly granularity as the highest-quality requirement. Aligning carbon accounting to hourly or sub-hourly time periods makes it possible for organizations to get proper credit for shifting computing workloads to times of day when the carbon intensity of their regional grid is lower.
20	Please provide any feedback on the proposal to clarify the MBM definition to retain its existing basis, quantifying Scope 2 from contractually purchased electricity via contractual instruments, while specifying temporal correlation and If deliverability when matching instruments to consumption? Please note that feedback on specific changes to the market-based method can be provided in section 5.	The GSF does not emphasize market-based measurement of carbon emissions, as we are focused on reducing the location-based and real-time emissions impact of software development.
21	Please provide any feedback on the proposed purposes of the location-based method.	The GSF supports the proposed LBM purposes, especially “Enabling abatement planning and reduction target-setting.”
22	Please provide any feedback on the proposed purposes of the market-based method.	The GSF does not emphasize market-based measurement of carbon emissions, as we are focused on reducing the location-based and real-time emissions impact of software development. If market-based guidance updates lead to the reduced carbon intensity of global grid regions that are home to large numbers of data centers, that will align with our mission.
23	On a scale of 1-5, do you support the update to the location-based emission factor hierarchy to identify the most precise location-based emission factor accessible according to spatial boundaries, temporal granularity, and emission factor type (consumption or production)? a. Scale of 1 (no support) – 5 (full support) Pleased note this question only relates to the structure of the hierarchy, subsequent questions will address its intended use.	5 (Full Support)
24	Please provide your reasons for support, if any (select all options that apply) a. Agree that guidance on selecting location-based emission factors should be presented as a hierarchy b. Enhances the accuracy and relevance of the location-based method c. Enables use of emission factors that support abatement planning and target-setting d. Improves use of location-based method to provide risk and opportunity assessment related to consumption of grid electricity e. Aligns with emission factors used by your organization for location-based emissions reporting f. Aligns with emission factors used for mandatory or voluntary reporting in your region g. Prioritizes consumption-based factors that include imports/exports over production-based factors h. Clarifies application of the EF hierarchy (spatial > temporal > consumption-based > production-based) i. Agree with listing the most precise temporal granularity as “hourly” j. Agree with listing the most precise spatial boundary as “local boundary” k. Agree that the proposed spatial boundaries reflect electricity deliverability in your region l. Other (please provide)	a, b, c, d, g, h, i, j
25	Please provide comments regarding your reasons for support.	We support increased granularity for location based accounting as that enables better decision making about the timing and location of software electricity consumption. This is important to the GSF to enable clearer action by software practitioners. The use of annual average emissions data does not incentivize load shifting of software to reduce emissions. Carbon-aware computing practices fundamentally depend on the ability to access and utilize the most granular (hourly or sub-hourly) and localized emission factor data available. This hierarchy drives reporters toward the necessary high-fidelity data required for load shifting, moving reporting beyond static annual averages toward abatement-focused transparency.
35	On a scale of 1-5 do you support the new definition of accessible: publicly available, free to use, and from a credible source? a. Scale of 1 (no support) – 5 (fully support)	5 (Fully Support)
36	Please provide your reasons for support, if any. Select all options that apply. a. Definition supports feasibility and lower-cost reporting b. Supports transparency and public verifiability of emission factors c. Implements a common comparability baseline across reporters d. Creates data equity for smaller reporters and underserved regions e. Encourages open publication of emission factors f. High quality accessible emission factors already exist for most markets globally today g. Ensures reporters can immediately apply the updated LBM hierarchy h. Clarifies reporting requirements i. Other (please explain)	a, b, d, c, e, h
37	Please provide comments regarding your reasons for support.	Accessible data is important to our members and a significant barrier to enabling our membership to implement software solutions that reduce emissions. The GSF advocates for open standards and data necessary to measure and reduce carbon. High-quality, granular (hourly/local) data is currently a key barrier to widespread adoption of carbon-aware computing, especially for smaller organizations. Ensuring data is publicly available and free to use is crucial for data equity and for scaling green software practices globally, as it lowers the barrier to entry for accurate measurement and abatement.
40	Which entities should qualify as credible sources (select all options that apply) a. Government agency b. System operator c. Recognized registry d. Accredited statistics body e. Independent methodology meeting minimum criteria (outlined in question 42) f. Other (please specify and explain)	a, b, c, d, e
41	Please provide additional comments concerning your selected credible sources, including at least one example per region you operate in or have experience with, if possible.	System Operators (b) and credible Independent Methodologies (e) are particularly important for providing the high-resolution data needed for the GSF’s SCI framework. Europe: ENTSO-E (Transmission System Operators data). North America (US/Canada): Balancing Authorities/ISOs (e.g., PJM, CAISO, ERCOT) or third-party data providers that meet minimum criteria. Current data providers used by GSF members include the IEA, EPA eGRID, Electricity Maps, WattTime, and others, with an emphasis on the granular and localized data provided by Electricity Maps and WattTime.
42	If you selected independent methodologies in question 40, please describe what documentation or assurance (if any) is needed for it to be recognised as a credible source? (select all that apply, then add brief detail): a. Publicly documented methods and system boundaries b. Update cadence (e.g., annual) and version control c. QA/QC procedures and uncertainty disclosure d. Governance/independence and conflict-of-interest safeguards e. Geographic/system boundary and temporal coverage fit for use f. Other (please explain)	a, b, c, d, e.
43	Please provide any additional comments concerning your selected minimum criteria in question 42	The minimum criteria are essential for establishing trust. Specifically, for high-granularity factors (hourly/sub-hourly), the methodology must clearly define how the factors are derived from real-time production/import data, including assumptions made when modeling hourly/sub-hourly data from annual or monthly numbers, where more granular data is not yet available.
146	Considering the full set of proposed revisions to the market-based method as discussed previously in this consultation, would the existence of a separate metric outside of scope 2 to quantify the emissions impact of electricity-related actions change your perspective on the proposed revisions? a. Yes b. Somewhat c. No d. I do not support the development of impact metrics outside the scope 2 inventory.	Yes
147	147. If you answer “yes” or “somewhat” to question 146, which of the following rationale captures your views (select all that apply). a. Allows for continued investment in electricity projects outside of my deliverable market boundary b. Provides a complementary metric to quantify actions such as energy storage or demand response c. Causes less disruption of existing electricity procurement practices d. Provides additional relevant information for users of GHG data e. Provides additional approaches for target setting f. Other (please specify)	b, d, f
148	148. Please provide comments regarding your selected choices in question 147.	The primary goal of the GSF is to enable software developers to accurately measure and reduce the emissions of software. We support the development of an impact metric that leads to action through more granular and reliable measurement of carbon emissions from software operations. A successful impact metric should capture the emissions reduction benefits of carbon-aware software actions, such as shifting workloads to match real-time clean energy availability. By rewarding these high-integrity, abatement-focused operational changes, the metric will incentivize the widespread adoption of green software practices and ensure the reported outcomes genuinely reflect reduced climate impact.
152	In your view, balancing scientific integrity, climate impact, and feasibility, what scope 2 revisions or combination of revisions are most appropriate? Please address each of the three core decision-making criteria: integrity, impact, and feasibility in your answer, and describe how the approach satisfies each criterion.	With emphasis on LBM revisions: The GSF’s preference is to establish hourly granularity as the preferred quality standard for carbon accounting. Integrity: Granular LBM factors significantly increase scientific integrity by grounding the methodology in the physical and temporal reality of electricity generation. It ensures LBM reflects the actual grid mix at the time of consumption. Impact: High-fidelity data is essential for driving meaningful climate impact in the digital sector. It enables carbon-aware computing (e.g. load shifting, flexible consumption), creating operational incentives to consume energy when the grid is clean, which directly supports grid decarbonization and accelerates the development of necessary clean technologies (e.g., storage). Feasibility: Feasibility is addressed by the proposed exemptions and fallback metrics and accessibility requirements. However, the hourly or sub-hourly data required by the proposed revisions is increasingly available from System Operators and credible third-party providers. By establishing the highest temporal resolution data standard as the preferred path, the GHG Protocol creates a strong market signal to further improve data accessibility and quality globally.