WattTime’s Formal Complaint to the Greenhouse Gas Protocol on the Scientific Merit of its Scope 2 Proposal Claims

In collaboration with leading researchers on carbon accounting, WattTime submitted a formal complaint to the Greenhouse Gas Protocol (GHGP) on January 7, 2026, challenging the scientific merit of the emissions reductions claims underlying its Scope 2 proposal for deliverable, hourly matching. In particular, WattTime has challenged the assumption that the GHGP’s outlined approach will reduce system-wide carbon emissions. 

The GHGP’s vision is “that all private and public entities account for their GHG emissions, enabling an acceleration in reductions in line with the global warming limits required by climate science.” In addition, the GHGP’s Governance Overview identifies supporting “ambitious global climate action and programs” as one of three core criteria guiding decisions on framework revisions — making climate impact a stated driving force of the revisions process. 

Despite these clear goals, the GHGP put forward a deliverable (or local-only), hourly matching framework that lacks an additionality requirement. Additionality — or the concept that procurement meaningfully contributes to new clean energy capacity on the grid — is key to ensuring real carbon impact. 

Overwhelming academic evidence demonstrates that, without an additionality requirement (one of the so-called “Three Pillars”), this proposal will fail to drive emissions reductions further than the current annual matching framework. As a result, the proposal does not align with GHGP’s own stated vision or with established climate science. 

WattTime submitted the complaint under Section 2.2.2 of the GHGP’s Complaints and Concerns Procedure, which states that complaints have merit if they identify “a factual error, outdated scientific assumption, or methodological flaw that can be substantiated with peer-reviewed literature or authoritative sources.” 

In the spirit of transparency and clarity, and for the benefit of all energy and sustainability stakeholders seeking to better understand the potential impacts and limitations of the current GHGP Scope 2 carbon accounting proposal, WattTime is making its formal complaint available for all to review. 

We encourage you to read the complaint using the link below, send us your questions, and continue to engage in the GHGP revision process via the public comment period (now open until January 31, 2026), by submitting complaints, or otherwise making your voice heard.

Read WattTime’s formal complaint here:
Scientific Accuracy Complaint Against the Greenhouse Gas Protocol’s Proposed Scope 2 Update: The Need for Additionality

Note: Additional signatories included here may be speaking in a personal capacity and not on behalf of their employers.