U.S. Chamber GHG Protocol Comments

The U.S. Chamber of Commerce collected the following comments from a coalition of similar organizations:

"Many U.S. Chamber members are concerned that elements of the current proposal risk crossing this line. 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."