Industry Feedback on the need for Scope 3 Standard Revisions

The Greenhouse Gas Protocol (GHG Protocol) is a collaboration of multiple groups that guide the development of greenhouse gas accounting and reporting standards. The GHG Protocol published the first edition of the Corporate Standard in 2001 and has since published seven more standards as well as numerous guidance documents to assist organizations with the quantification of their environmental footprint. Recently, the GHG Protocol requested feedback on their standards, as there has been further examination of Scope 1, 2 and 3 emissions for organizations, as well as updated best-practice methodologies and emission factors since the standards’ publications. A high-level summary of these suggestions is described within this blog post.

While many comments were received about the Corporate Standard and the Scope 2 Standard, the largest number of comments were received regarding the Scope 3 Standard. Within the release of feedback on the Scope 3 Standard, The GHG Protocol was very clear that the feedback received does not guarantee updated documentation; however, Brightspot has noted that in the feedback received, there were many echoing suggestions that could advocate for updated documents sooner than later.

There were noticeable trends within the feedback about shifting the optionality of (1) sources and (2) methodologies within the documents to more stringent requirements. Most of the comments supported tightening the requirements for reporting, promoting uniformity between reporting entities for transparent and equitable comparisons between similar entities.

Comments also consistently recommended the exclusion of any spend-based emissions methodology, as these methodologies introduce uncertainty and do not align with the ISO 14064-1 principles. Commenters also noted, however, that the use of spend-based factors is often applied by entities where specific data may not be available or may not be available in the foreseeable future; therefore, excluding this methodology may stop entities from reporting all together, rather than encouraging more accurate reporting.

Feedback was also provided to The GHG Protocol to more effectively combine greenhouse gas guidance and revisions, as the variety of resources (Corporate Standard, Scope 2 Guidance, Scope 3 Calculation Guidance, etc.) often creates a barrier to entry for organizations. Commenters also recommended harmonizing resources to ensure consistent guidance is provided. Examples of harmonization include enhanced clarification around the categorization and reporting of leased assets and the minimum sources to include in Scope 3 inventories.

One of the areas of GHG reporting that has become increasingly important, but difficult to quantify accurately, are investment emissions. Many comments were directed to enhance the guidance for this chapter to include further details for both financial and non-financial focused organizations.

Lastly, feedback was provided to The GHG Protocol regarding third-party assurance, noting that respondents wanted to see strengthened requirements for assurance providers and alignment with international standards (ISO 14064). Other respondents recommended only undergoing assurance activities once an organization has primary data to back up their emissions inventory.

The GHG Protocol has stated that the feedback received does not indicate upcoming changes to their documents; however, the feedback may shed some light on where The GHG Protocol should focus their attention in the coming months to years.

If you have any questions about the feedback or corporate inventories, or if you are interested in working with Brightspot to quantify or verify your corporate inventory, you can reach us at info@brightspot.co