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Eighteen years ago today, on Earth Day 2008, Sustainability Roundtable, Inc. was founded to help leading global enterprises meet the challenge of corporate sustainability with the seriousness it requires.

On our 18th anniversary, we are proud to be among 65 signatories to a public statement to the Independent Standards Board and Steering Committee of the Greenhouse Gas Protocol regarding the revision of the Scope 2 Guidance.

The statement was organized and coordinated by a broader coalition of corporate clean energy buyers, developers, researchers, and advocacy organizations. SR Inc is one signatory among many. The full statement and signatory list are available at maynotshallscope2.com.

A Coalition Defined by Practice

The signatories represent 33,500+ organizations, headquartered in 15 countries, operating in 220 countries and territories, with $4.6+ trillion in annual revenues, employing 48+ million people, and responsible for procuring, facilitating, or producing more than 300 gigawatts of carbon-free electricity projects worldwide.

The signatories include corporate buyers such as Amazon, Apple, Salesforce, General Motors, Mars, Corning, Trane Technologies, FedEx, Hewlett Packard Enterprise, Patagonia, eBay, Honda, Dollar Tree, and Steel Dynamics, alongside research and advocacy organizations including Ceres, ACORE, E3, REsurety, WattTime, the American Clean Power Association, and the Solar Energy Industries Association. It is a coalition of buyers, developers, advisors, standards experts, academic researchers, and NGOs. It is defined less by position than by practice.

What the Coalition Is Asking

The GHG Protocol's Scope 2 Guidance, first published in 2015, has played a foundational role in the voluntary clean energy market. Since its publication, more than 250 gigawatts of clean energy projects have come online worldwide, enabled in significant part by the Market-Based Method it introduced.

This is the first significant revision of that guidance in a decade.

The proposed revisions would move the Market-Based Method toward a required hourly and physically-deliverable matching standard. The coalition's position is measured, and singular:

Keep hourly and strict-deliverability matching optional, not mandatory. A "may," not a "shall."

The coalition shares the ambition to further accelerate carbon-free electricity deployment. It does not believe this particular revision achieves it.

Why We Were Proud to Sign

For 18 years, SR Inc has advised leading operating companies on the practice of voluntary clean energy procurement. Through our Net Zero Consortium for Buyers, Member-clients have now committed more than $2 billion in long-term agreements, enabling over 1.5 gigawatts of new clean energy capacity on three continents.

We know this market from the buyer's seat. We see what drives deals to close, and what drives them to collapse. The coalition's position is one we recognize as grounded in the reality of that market.

The record is clear. Voluntary corporate procurement has delivered roughly 40% of new U.S. clean energy capacity over the past decade. It is the single largest private-sector driver of grid decarbonization we have.

The research is equally clear. Independent work from Harvard, Johns Hopkins, McKinsey, the GHG Management Institute, the University of Edinburgh, REsurety, WattTime, the Brattle Group, and Resources for the Future converges on a consistent set of findings:

• Mandating hourly and locational matching would raise costs substantially. WattTime estimates corporate PPA costs could rise by 200 to 1,200 percent. McKinsey finds household electricity prices could rise by as much as 26 percent.
• It would not necessarily reduce emissions. Johns Hopkins finds 100% hourly-matched procurement can produce higher net system emissions than annual matching. McKinsey finds batteries managed for individual-company 24/7 can increase system-wide emissions, while the same batteries managed at grid level reduce them.
• It would contract the market that has built the progress. 80 percent of U.S. corporate clean energy buyers have indicated they would exit the voluntary market if strict geographic and hourly boundaries are mandated.

A Natural Extension of Our Advisory Work

Signing this statement was, frankly, a no-brainer. The coalition's position is the position we have lived with Member-clients for years, in boardrooms, procurement reviews, strategy offsites, and monthly working sessions.

Through SBER, our Member-clients test the procurement strategies that will meet their ambition and their operational reality. Through NZCB, we co-design and structure the aggregated VPPAs that bring those strategies into effect, including long-duration agreements across the US, Europe, and India. Through our Compliance Collaborative for Mastering Mandatory Reporting, we help Member-clients build the reporting systems that will eventually have to comply with whatever Scope 2 ultimately becomes.

That breadth of practice is why this revision matters so directly to the companies we serve. A rule that works for a data center operator with concentrated load in a single grid region is not the same rule that works for a retailer with thousands of dispersed locations, or a life sciences company with specialized load profiles across four continents. One mandatory methodology does not serve that diversity. A well-designed set of options does.

Whatever form the revised Scope 2 guidance ultimately takes, SR Inc will continue doing what we have always done: helping Member-clients navigate the specifics of their own decarbonization strategy, structure procurements that actually get built, and report on the result with evidence that holds up to assurance. We are proud to take a proactive stance in helping shape the market alongside our clients, not just react to it.

A Standard Worth Strengthening, Not Breaking

The GHG Protocol is the world's most widely used greenhouse gas accounting standard. It underpins disclosure frameworks from California's SB 253 to the ISSB Standards adopted in roughly 40 jurisdictions accounting for almost 60 percent of global GDP. Its revisions matter far beyond corporate reporting. They shape capital flows, regulatory frameworks, and the pace of the energy transition itself.

The coalition supports strengthening Scope 2. The next version should reflect the diversity of load profiles, buyer sophistication, and market maturity that the past decade of voluntary procurement has revealed. It should encourage more impactful corporate action, not less.

Hourly matching is a powerful tool for the most sophisticated buyers. It should remain available to them. It should not be mandated for everyone.

A Message to Readers Who Share This Work

If your organization is a voluntary clean energy buyer, a developer, a financier, or a reporter on this work, the coalition's statement is worth a read. Consider whether adding your voice to it is right for you.

If you lead sustainability, operations, finance, or strategy at a company that buys clean energy, we encourage you to share the statement with your teams and internal stakeholders. The GHG Protocol's revision process is open, and the Independent Standards Board is listening.

On this Earth Day, in this 18th year of our firm, we are grateful to the companies, NGOs, developers, and experts who organized this statement, and proud to be among those who signed it.

The full statement, the complete list of signatories, and the supporting research are available at maynotshallscope2.com.

Sustainability Roundtable, Inc. is a certified B Corporation founded on Earth Day 2008. Through the Sustainable Business & Enterprise Roundtable (SBER), the Net Zero Consortium for Buyers (NZCB), and the Compliance Collaborative for Mastering Mandatory Reporting (CCC for MMR), we advise nearly 100 leading global companies on the practice of corporate sustainability.