Leapfrog Alliance urges GHG Protocol to Prioritize Access to Electricity and Equity

The Leapfrog Alliance, a coalition of 16 nonprofits working to expand electricity access in un-electrified and under-electrified communities, calls for the forthcoming revisions to the Greenhouse Gas Protocol (“GHG Protocol”) to include and prioritize access to electricity and equity as key principles. The aim of the Leapfrog Alliance’s request is to address legacy imbalances in existing greenhouse gas accounting and disclosure frameworks and produce more complete guidance for global companies. 

The GHG Protocol’s Scope 2 Guidance currently requires that companies only apply market-based emission reduction claims from clean energy they procure in that same market. This “geographic matching” requirement in the GHG Protocol has the unintended side effect of discouraging companies from optimizing their procurement for maximum decarbonization and social benefits in communities that fall outside of their market boundary. Forthcoming revised Scope 2 Guidance must better incentivize and enable companies participating in voluntary markets to support high-impact projects in communities around the world with low access to electricity. By channeling more voluntary market demand for projects that expand clean energy access, companies can deliver catalytic finance to these communities and help them leapfrog over the fossil fuel energy-based system. 

In addition, the GHG Protocol lacks clear guidance for the treatment of power transmission and distribution (T&D) systems, thereby challenging support for the type of smaller scale distributed mini-grids that can provide local energy solutions in communities without functioning national grids. The Leapfrog Alliance’s request to the GHG Protocol includes providing equal Scope 2 accounting treatment for grid-connected, distributed mini-grid, and isolated grid projects in communities with limited electricity access. This is because the distribution of electricity generation particularly in low- and medium-income countries often relies on both a traditional grid with T&D lines serving a portion of a country’s population along with an accompanying patchwork of distributed electricity generation systems (e.g., solar mini-grids) that further extend access.

With clearer guidance and stronger incentives in voluntary markets, including by allowing companies to apply high-impact, out-of-market energy procurement toward emission reduction claims in their annual emissions reporting, corporate clean energy procurement would play a larger role in increasing financing for projects that expand electricity access in communities where it is most needed. 

Beyond the Leapfrog Alliance’s request for the GHG Protocol to include electricity access and equity as official principles in the Scope 2 revision process, the Leapfrog Alliance offers specific recommendations for enhancing the Scope 2 Guidance—specifically in Chapter 11 (“How Companies Can Drive Electricity Supply Changes with the Market-Based Method”)—to allow companies to exclude up to 10% of their annual clean energy procurement from typical geographic matching requirements if the procurement supports clean energy projects for un- and under-electrified communities. This straightforward, impact-based exemption would promote several of the GHG Protocol’s core principles, including transparency, consistency and relevance:

  • Relevance: Companies seek greater flexibility around market boundaries so they can achieve greater impact outside of their Scope 2 market boundaries, making it relevant to the decision-making needs of their internal and external users.

  • Transparency: A 10% impact-based exemption would require companies to provide a clear audit trail, verified by the relevant energy attribute certificates and any needed additional documentation, to confirm their support for clean energy in un- and under-served communities before they can apply the market-based emission reduction to their Scope 2. 

  • Consistency: A predictable, defined maximum limit of 10% across the board would enable companies to pursue higher impact options to achieve their impact goals and/or address gaps in markets in their market boundary that have insufficient clean energy supply. 

With greater flexibility around geographic matching based on a prerequisite of expanding clean energy access in un-electrified and under-electrified communities following various principles that the Leapfrog Alliance developed, the GHG Protocol has an opportunity to encourage and enable more companies to prioritize decarbonization, energy access, and equity. This impact-based prerequisite for limited geographic matching flexibility would help prevent a potential race to the bottom around corporate buyers’ procurement decisions and instead promote a race to the top. It would also help maintain existing market fundamentals that have proven powerful to incentivize companies to support clean energy globally.

The Leapfrog Alliance encourages Technical Working Group (TWG) members to consider energy access and equity in their contributions to upcoming revisions to Scope 2 and Scope 3 accounting. More specifically, these TWG members should include impact-based flexibility for geographic matching that incentives companies to support high-impact clean energy projects in un-electrified and under-electrified communities.

“What ‘counts’ really matters in greenhouse gas accounting because it shapes corporate decarbonization strategies and behavior,” said Doug Miller, Director of Market Development of Energy Peace Partners. “Now is the time for the GHG Protocol to deliver new guidance that allows and, as a result, incentivizes companies to count emission reductions from high-impact projects like Peace RECs, even if these projects fall outside of their respective geographic boundaries. This targeted exemption would attract increased financing from corporate buyers that helps underserved communities expand energy access, gain greater resilience, and avoid getting locked into fossil fuel infrastructure and carbon-intensive emission trajectories.”

"The energy transition is unfolding rapidly but unevenly. Many of the GHG Protocol's largest users are headquartered in regions where fully 100% of new power plants being built are now carbon-free. By requiring companies to build clean energy there, the GHGP is essentially mandating that corporate sustainability not drive any authentic impact. But in much of the world, new build is still 0% renewable. It's past time we let go of the old outdated assumption that local action is more authentic," said Gavin McCormick, Co-founder and Executive Director at WattTime.

”The Greenhouse Gas Protocol reviewers shouldn’t re-do the work that their predecessors have done. The basic principles of the Scope 2 Guidance still work today,” said Steven Vanholme, Programme Manager at EKOenergy ecolabel. “It’s encouraging to see how companies and others have used the Scope 2 Guidance over the past 10 years and how they have developed a wide range of market-based solutions. Let’s nurture this ecosystem of renewable energy solutions. Instead, I hope the reviewers of the Greenhouse Gas Protocol will continue where their predecessors stopped 10 years ago. Chapter 11 of the current Greenhouse Gas Protocol is an open-ended chapter about solutions consumers can apply to speed up the energy transition. I hope that the Technical Working Group will grasp the opportunity to develop that chapter, and that they will upgrade it from an often forgotten ”attachment” to an essential part of the new guidance."

“TWG members have an opportunity to accelerate the global energy transition by building on the basic principles of greenhouse gas accounting, expanding the use of market instruments, and addressing gaps in the existing Scope 2 Guidance, particularly in Chapter 11,” said Steven Vanholme, Programme Manager at EKOenergy ecolabel. “They should prioritize introducing new incentives that help channel more corporate clean energy procurement to all places with energy systems that are not yet carbon-free.”

“Attracting financing for clean energy in unelectrified and underelectrified communities promotes peace by addressing root causes of instability such as poverty, inequality, and lack of opportunity,” said Abdulrazaq Hamzat, Executive Director at Foundation for Peace Professionals (PeacePro). “The resulting benefits include improved livelihoods, healthier communities, reduced environmental stress, and strengthened social cohesion, which creates a more sustainable foundation for long-term peace and development.”

Adam White, Secretary-General of the RECS Energy Certificate Association, made the general observation that the "Greenhouse Gas Protocol is a global standard and as such it should encourage corporate reporting and efforts to cut energy related emissions, through the switch to renewables, in all countries.”

Nonprofits that would like to join the Leapfrog Alliance and become an official supporter organization should submit an application form.

About the Leapfrog Alliance

Launched in 2024, the Leapfrog Alliance is a nonprofit-led initiative to promote stronger incentives to increase corporate investment in clean electricity access in unelectrified and underelectrified communities globally. This coalition, which currently includes 16 diverse nonprofit organizations, seeks to strengthen the incentive structure embedded in corporate environmental accounting frameworks to drive increased and dedicated corporate investment in clean energy projects benefiting these communities. Learn more at https://www.leapfrogalliance.org/

Contact the Leapfrog Alliance with comments and questions via leapfrogalliance@energypeacepartners.com.