U.S. Chamber Comments on Proposed Revisions to Greenhouse Gas Protocol Scope 2 Guidelines

The U.S. Chamber of Commerce submitted the following comments for the 2025 draft changes to the GreenHouse Gas Protocol Scope 2 Guidelines.

"Proposed changes to the definition of Scope 2, the treatment of the Market-Based Method, and the introduction of mandatory hourly matching and geographic deliverability requirements would fundamentally alter the nature of Scope 2 accounting. These changes risk transforming Scope 2 from a tool for emissions reporting into a mechanism that implicitly directs capital allocation, constrains business operations and decision-making, and privileges certain energy procurement models over others."