Extract: 24/7 Carbon-Free Electricity technical criteria and appendices

This page contains excerpts from the Climate Group’s 24/7 Carbon-Free Electricity Technical Criteria document published on May 29, 2025. 

The contents on this page reflects the parts of the technical criteria that are most relevant to the Green Web Foundation provider verification process. We have extracted this content and created this page for easier linkability and discoverability of information for those who are interested in our provider verification requirements. The full technical criteria document is available on the Climate Group’s website.

Important notes

Our verification criteria uses the wording “fossil-free energy” in place of the Climate Group’s “carbon-free electricity”. The two terms are interchangeable for the purpose of our verification process.

Section four: Recognised procurement types for carbon-free electricity

The 24/7 Carbon-Free Coalition categorises corporate procurement of CFE into five broad types. They differ in terms of the party being contracted with (directly with a generator 8 or through a more conventional contract with an electricity supplier), whether the procurement of energy and energy attributes is bundled or unbundled, and active versus passive procurement.

1. Self-generation from facilities owned by the company
2. Direct procurement (contracts with generators)
   • 2.1 Physical power purchase agreement (physical PPA)
   • 2.2 Financial power purchase agreement (financial/virtual PPA)
3. Contracts with electricity suppliers
   • 3.1 Project-specific supply contract with electricity supplier
   • 3.2 Retail supply contract with electricity supplier
4. Unbundled procurement of energy attribute certificates (EACs)
5. Passive procurement

1. Self-generation from facilities owned by the company

Corporate buyers can own their own projects. Projects might be on-site or off-site, on the grid, or entirely off-grid. Corporate buyers must retain energy attributes to claim use of CFE. This means corporate buyers can consume directly from their projects, retain the attributes, and claim use of CFE. It also means corporate buyers can sell energy to the grid, retain the attributes, and claim use of CFE (up to the volume that they purchase from the grid).

2. Direct procurement (contracts with generators)

Direct procurement describes procurement from, and contracting with, generators themselves. It includes two forms of power purchase agreements (PPAs).

2.1 Physical power purchase agreement (physical PPA)

A physical PPA is a contract between a corporate buyer and a generator for the supply of CFE. A physical PPA can characterise purchases from on-site projects owned by third parties, off-site projects to which there is a direct line or off-site grid-connected projects. A physical PPA typically uses a long-term contract.

Physical PPAs do not necessarily need to be bilateral between the corporate buyer and the generator. A bilateral PPA requires the corporate buyer to also take responsibility for the offtake of the power itself, including managing the moving and scheduling of the power to the corporate buyer’s load, or into the wholesale power market (if the project is grid-connected). The corporate buyer may need to be licensed to be able to do this. Alternatively, a trilateral PPA can involve an additional party which is responsible for the off-take of the power from the project. This third party is often an electricity supplier. A trilateral PPA may be advertised as a ‘retail PPA’, ‘sleeved PPA’, or a ‘third-party PPA’.

2.2 Financial power purchase agreement (financial/virtual PPA)

A financial PPA (often called a virtual PPA – VPPA) is a purely financial transaction in which a corporate buyer assumes market risk related to the sale of a generator’s electricity and receives energy attributes. This can be done through a contract for difference, where the generator exchanges the risk of selling the project’s generation to the wholesale market at a variable rate with a fixed-price cash flow agreed with the corporate buyer. The corporate buyer therefore offtakes market risk the generator would be exposed to by selling power at the fluctuating wholesale energy price, and in return is entitled to the energy attributes.

Because a financial PPA is only a financial instrument, the corporate buyer must still separately procure electricity for its operations. It is therefore a form of unbundled procurement. A financial PPA can serve as a hedge for fluctuating electricity costs, and some corporate buyers may realise a financial benefit from using them. A financial PPA typically uses a long-term contract.

3. Contracts with electricity suppliers

A contract with a supplier describes a conventional supply arrangement with an electricity supplier for the supply of CFE. Energy and energy attributes are bundled together in their delivery to the corporate buyer.

The 24/7 Carbon-Free Coalition recognises two types of contracts with electricity suppliers: project-specific, and retail. Appendix F contains guiding questions for corporate buyers needing to identify whether a particular supply must be characterised as project-specific or retail.

3.1 Project-specific supply contract with electricity supplier

A project-specific contract with a supplier describes an arrangement whereby the supplier procures from specified projects on behalf of the corporate buyer. Often, the supplier holds a power purchase agreement. The contract may be advertised as a ‘green tariff’, has complete transparency regarding the energy attributes in the supply (meaning the corporate buyer always knows exactly which specific projects they are purchasing from through their electricity supplier), and typically uses a longer contract length.

3.2 Retail supply contract with electricity supplier

A retail contract with a supplier describes an ‘off-the-shelf’ arrangement with an electricity supplier for the supply of CFE. The corporate buyer usually pays a per-kilowatt hour premium through an additional line item on their monthly electricity bill for the CFE. This contract may be advertised as a ‘green electricity product’, may have less transparency regarding the energy attributes in the supply, and typically uses a shorter contract length. The supplier may vary the projects from which energy attributes are sourced throughout the contract.

4. Unbundled procurement of energy attribute certificates (EACs)

Energy attribute certificates (EACs) can be purchased alone, separate from the underlying generation they are issued to, and separate from corporate buyers’ procurement of electricity for their operations.

Corporate buyers can purchase EACs 9 to pair with their consumption of purchased grid electricity. This permits a claim to having consumed electricity with the attributes conveyed by the EACs 10 . The EACs must be issued to generation located in the same market for electricity as the electricity supply being decarbonised by the corporate buyer 11 . A purchase of CFE generated in one market cannot be equated to its consumption in a different market.

EACs can be procured through short or long-term contracts, with varying degrees of project specificity. EACs are sometimes procured through brokers and trading platforms, making for transactions that are less complex than those in other procurement types.

Unbundled EACs can only ever present an additional cost on top of corporate buyers’ separate electricity purchases. This is a key point of distinction between long-term contracts for unbundled EACs and financial PPAs, which can sometimes realise a financial benefit.

5. Default delivered CFE from the grid, supported by EACs

This is the CFE in the electricity utility/supplier mix that has not been voluntarily procured by corporate buyers but is delivered by default. Corporate buyers can claim use of default delivered CFE if, and only if, an equivalent amount of EACs with hourly or sub-hourly granularity is retired by the utility/supplier. Corporate buyers wishing to claim use of this CFE must seek relevant information from their utility/supplier to justify their claims.

Default supplies can include CFE supplied under a compliance mandate. However, the existence alone of such a mandate is not justification for corporate buyers to claim use of CFE. Corporate buyers must verify how their utilities/suppliers are complying with the mandate. In the United States, Renewable Portfolio Standards (RPS) and Clean Electricity Standards (CES) require that a specified percentage of the electricity that utilities supply comes from renewable or low-carbon resources, and that utilities/suppliers retire EACs on behalf of their customers for that percentage. In some cases, these programs allow for alternative compliance routes, multipliers, and other mechanisms that do not deliver CFE to corporate buyers. Another example in Australia is the default supply of CFE by utilities/suppliers retiring Large-scale Generation Certificates (LGCs) under the Renewable Energy Target (RET). Again, corporate buyers must verify that their utilities/suppliers are retiring LGCs rather than using an alternative compliance route such as paying a shortfall charge. This procurement type is not applicable in most markets and corporate buyers wishing to use it must have evidence to support their claims.

For the avoidance of doubt, claims to default delivered CFE, supported by EACs, require an absence of voluntary procurement of CFE. Corporate buyers can only claim default delivered CFE where they have a contract for a supplier’s default supply. If a corporate buyer consumes 100 MWh, 60 MWh of which is supplied through a contract for CFE, and 40 MWh of which is supplied through a default supply, the corporate buyer can only claim the default delivered CFE, supported by EACs, present in the 40 MWh conveyed by the default supply.

It is essential that claims to use of default delivered CFE remain unique and exclusive. Some markets place RPS/CES-type compliance mandates on utilities but allow those utilities to also sell that CFE to voluntary corporate buyers actively procuring it (for example, through the Green Premium contracts available in the Republic of Korea). Therefore, the CFE procured by utilities to meet their compliance mandate is not present in a default supply. Claims to default delivered CFE cannot be made using compliance mandates on utilities as a justification in these instances.

Appendix A: Credible claims to use of carbon-free electricity

A claim to use of carbon-free electricity (CFE) must be unique and exclusive. Corporate buyers must be able to demonstrate that they have such claims. This means securing property rights to CFE attributes. Energy attribute certificates are recommended as the best method for tracking and establishing ownership of energy attributes. However, it is possible for a contract alone to perform the same tracking function as EACs and ensure no other entity may claim use of the same CFE.

The following seven principles more completely define the features of a credible claim to use of CFE:

• Credible generation and charging data;
• Attribute aggregation;
• Exclusive ownership (no double counting) of attributes;
• Exclusive claims (no double claiming) on attributes;
• Geographic market limitations of claims ;
• Temporal limitations of claims; and
• Demonstration of CFE usage in storage charging.

These points are expanded upon below.

1. Credible generation and charging data

Accurate generation data (as well as charging data, in the case of storage) is critical as the basis for any CFE usage claims. Static data (e.g., fuel type, location, date of first operation, etc.) should be third-party verified, a common practice of attribute tracking systems. Dynamic data (quantity of generation or charging) is best when metered using a “revenue-grade meter” and independently used as the basis for determining the quantity of attributes and certificate issuance.

Companies should avoid making claims where static data cannot be verified by third parties and/or generation or charging data is not metered.

2. Attribute aggregation

A CFE usage claim is not supported by any individual attribute, but rather by all attributes that define the generation being claimed. Therefore, making a credible CFE usage claim requires ownership of all environmental and social attributes associated with the generation that can be owned, and that none of these attributes have been sold off, transferred, or claimed elsewhere.

The conditions of attribute aggregation vary by country and legal/regulatory framework for the electricity sector. Where a single multi-attribute instrument, such as a U.S. REC exists, assurance of all relevant attribute aggregation is simplified. If separate instruments have already been created for different attributes of power generation (e.g., carbon attributes), attribute aggregation can be achieved by bringing these instruments together – by demonstrating ownership and retirement of all instruments that make up a CFE usage claim. Where there is not an existing market for CFE, or where electricity is not typically differentiated, attribute aggregation may require engagement with local electricity suppliers. Companies should also take account of the in-country policy context of the generation (existing practices, policies, and legal frameworks that determine how electricity and CFE is or can be transacted in different markets).

Where certain attributes (e.g. GHG emissions), cannot be owned or are equivalent to zero due to policy (e.g. the effect of a GHG cap-and-trade program on the avoided grid emissions attribute), and where attributes are not sold off separately, a CFE usage claim may nevertheless be possible, provided that the CFE purchaser owns all other generation attributes and that the remaining owned attributes are sufficient to define use of the resource according to market development, consumer expectation, and stakeholder feedback.

Companies should disclose any attributes that are not included in the instrument or transaction. In addition, different standards and certifications (e.g., Green-e) may have different or additional requirements for a “fully aggregated” instrument or group of instruments. Companies should also abide by any local laws and regulations pertaining to claims (e.g., the U.S. Federal Trade Commission’s “Green Guides” in the U.S.).

3. Exclusive ownership

Exclusive ownership of CFE attributes consists of legal enforceability, tracking (exclusive issuance, trading, and retirement), and exclusive sales and delivery.

3.1 Property rights

Legally enforceable contractual instruments must include “property rights” to environmental attributes of generation – that is, there must be a legally enforceable contract in place to back the exchange of attributes as property rights. Legal enforceability does not necessarily require governmental programs or legislation to create or recognise a market or energy attribute certificate, only that the mechanism for definition and conveyance/transfer of the attributes (e.g., contract, energy attribute certificate in a tracking system, etc.) is legally enforceable.

3.2 Tracking

Claims must be substantiated by attributes that have been reliably tracked from a generator to a consumer. Where attributes are transacted without energy attribute certificates, the transfer of attributes must be clearly articulated in a legally enforceable contract or series of contracts that link the generator to the end user, and claims must be based on the permanent end-use ownership or final use of those attributes, which also must be specified in a contract. Where energy attribute certificates are used, the certificates must be reliably tracked. This, again, can be done using contracts. However, the most sophisticated mechanism for tracking energy attribute certificates is an electronic attribute “tracking system”, in which certificates are electronically serialised and issued to generators with accounts on the system, tracked between account holders in the system where they are traded, and ultimately permanently retired or cancelled electronically by the entity making the claim or on behalf of an end-user making a claim. Attribute tracking systems provide exclusive issuance, trading, and retirement of attributes to markets for CFE to support credible claims. Where tracking systems exist, transactions outside of the tracking system are usually limited to special cases (e.g., where participation in the tracking system is too costly for very small generation units).

While tracking systems have developed independently of each other in different jurisdictions around the globe, there are a few elements that all credible tracking systems compatible with 24/7 CFE usage claims have in common. These include:

Standardised certificate information: Compatible tracking systems issue certificates in MWh, and include the same basic information on each certificate:

• Resource/Fuel Type (e.g., wind, solar, etc.)
• Serial ID
• Generator ID
• Generator Name
• Generator Location
• Generator Commercial Operating Date
• Vintage (time of generation, hourly or sub-hourly granularity)
• Issuance Date

The EnergyTag Granular Certificate Scheme Standard contains guidelines for implementation of a temporally granular certificate scheme compatible with these technical criteria. 

Certificates are issued for all CFE generated by registered generators: Certificates are issued to the CFE generator. Some tracking systems require that certificates be issued for all production that is put onto the grid by registered generators. In others, such as those in Europe, registered generators have the right to request certificates issuance for selected production, in which case the attributes associated with production that is not issued certificates are allocated to the residual mix. In both cases, no energy attribute certificates from registered generators should be traded outside of the tracking system, in order to avoid potential double counting.

Defined geographical footprint: To prevent double registration and issuance of certificates, tracking systems must be clear on the geographic boundaries within which generators have access to the tracking system, and ensure, through cooperation with other tracking systems, that generation facilities register in only one tracking system for certificate issuance.

Independence and transparency: Independence and transparency of tracking systems help to maintain the integrity of the attribute market. Best practices include:

• The tracking system operator does not act as a market player trading, selling or redeeming certificates;
• Tracking systems should have transparent and non-discriminatory issuance criteria and operating rules;
• Tracking system operators should follow defined procedures to identify and prevent conflicts of interest;
• The tracking system should provide access to regulators and system auditors and allow for independent consumer claim verifications. To the extent possible, full disclosure of unit attributes and status should be made public;
• Frequent independent third-party audit of the tracking system should be conducted by a credible and competent organization, verifying the factual static and dynamic data contained within the tracking system, and preferably made public;
• The system should be open and accessible to new participants.

3.3 Claims made using temporally non-granular attributes

Some tracking systems may not support EACs containing vintage data at sufficient temporal granularity to enable credible claims to use of CFE (see Appendix A Section 6: Vintage limitations). Such EACs may be used to support credible claims to use of CFE if and only if the following conditions are met:

• EACs are verifiably paired with hourly or sub-hourly granularity metering data sharing the same generator ID;
• The proportion of a generator’s metered hourly or sub-hourly output claimed by the corporate buyer in each hour during an EAC issuance period is equal to the proportion of total EACs issued by the generator in the same EAC issuance period that have been procured and retired by the same corporate buyer; and
• The generator transfers the corporate buyer the exclusive right to make the above granular claims based on its metered output and the proportion of EACs transferred, as clearly articulated in a legally enforceable contract.

The above criteria enforce the principle of ‘shape preservation,’ such that procurement of a temporally non-granular EAC allows a corporate buyer to claim exclusive ownership of a fixed percentage of a project’s temporally granular metered output during the period covered by the EAC’s reported vintage. For example, if a corporate buyer procures EACs representing 50% of the output of a CFE project over a month-long period, it may claim exclusive ownership of exactly 50% of the metered output of the project during each hour in the same month.

4. Exclusive claims

To the extent that tracking systems prevent double issuance and other forms of double counting, tracking systems alone will not necessarily ensure exclusive claims, i.e., that there are no other claims being made on either the attributes (including emissions) or electricity as CFE. Where energy attribute certificates can be sold separately from electricity, the electricity buyer does not have an exclusive CFE use claim unless they own and retire the certificates, and likewise the certificate buyer does not have an exclusive usage claim where the electricity is also being claimed/reported as CFE or individual attributes are being claimed/transacted in another way. This requires that all CFE instruments or instruments representing individual generation attributes (e.g., carbon offsets issued for CFE energy generation) have been retired by or on behalf of the same entity and that there are no other usage claims being made on the generation or attributes, for example, by the electricity supplier to meet a CFE delivery target or in marketing that CFE is being delivered to customers.

5. Geographic market boundaries

The 24/7 Carbon-Free Coalition recognises claims to use of CFE if and only if the generating facility and the point of consumption are part of the same interconnected electricity system.  Where this condition is met, attributes (and certificates) must furthermore be sourced and purchased from within the same defined geographic region that constitutes a “market” for the purpose of transacting and claiming attributes, or must be otherwise demonstrated as deliverable to the location where they are claimed. Ideally a “market boundary” would be clearly defined on the basis of physical network characteristics, but in general it refers to an area which is internally well-connected by a synchronous electric grid and within which power can be reasonably assumed to be physically deliverable from one internal point to another.

Geographic boundaries between internally well-connected grid regions are often, but not always, correlated with energy market, regulatory or national boundaries. In general, geographically tighter market boundaries increase the credibility of claims to physical use of CFE, while more relaxed market boundaries reduce barriers to procurement of diverse carbonfree resources and reduce administrative burdens.

Appendix B contains definitions of market boundaries that 24/7 Carbon-Free Coalition partners must observe, as well as descriptions of alternative pathways to demonstrating deliverability. Beyond these basic requirements for claims to use of CFE, the 24/7 Carbon-Free Coalition expects partners to pursue and, if possible, demonstrate maximal deliverability of claimed CFE via contractual arrangements and analysis of current and future grid congestion and expansion.

6. Vintage limitations

To make a credible CFE usage claim, the vintage of the attributes (and certificates) – that is, when the generation occurred – must fall within the same hour as the electricity consumption to which they are applied. Both attributes and electricity consumption may be metered at subhourly granularity and may be aggregated on an hourly basis in this case.

7. Demonstration of CFE usage in storage charging

To make a credible CFE usage claim using electricity discharged from a storage facility, a corporate buyer must credibly demonstrate that the electricity was originally sourced from a carbon-free generator. The 24/7 Carbon-Free Coalition allows this condition to be met through procurement of EACs or similar contractual instruments from storage facilities following the EnergyTag Granular Certificate Scheme Standard “First In First Out” allocation method or a similar CFE tracking and allocation approach. Any CFE tracking and allocation approach used to justify claims to use of stored CFE must meet the following criteria:

• The storage operator must provide storage facility charge and discharge (or net charge/discharge) records at hourly or sub-hourly granularity;
• Attributes associated with distinct units of energy consumed by a storage facility must be assigned to distinct units of energy held in storage at the same facility, and all attributes held in storage must be tracked alongside the energy to which they are assigned until discharged;
• Any electricity discharged from the storage facility must draw down the oldest CFE attribute held in storage at the time of discharge;
• Storage losses must be allocated in equal proportion to energy from all sources, and each final EAC or similar contractual instrument issued in association with storage discharge must reflect an amount of energy inclusive of such losses; and
• A storage facility may not hold attributes representing more energy than its estimated state of charge at any point in time.

Alternatively, a corporate buyer may claim storage discharge as CFE by demonstrating that the storage facility was charged exclusively using CFE during the same reporting period. To do so, hourly charging data from the storage facility for each hour in the reporting period must be matched with EACs or similar contractual instruments procured and retired by the corporate buyer or storage facility, and representing an identical or greater amount of CFE generation in those same hours.

CFE used to charge storage is subject to the same principles for credible claims to use as CFE that is directly consumed by the participant. Attributes used by a corporate buyer to support claims of CFE storage charging must be cancelled and may not also be used to support claims to direct use of the same CFE.

Appendix B: Market boundaries

1. What are markets for carbon-free electricity?

Claims to use of CFE must be based on generation occurring in both the same interconnected electricity system and the same market for CFE in which its use is claimed, or on demonstration of CFE deliverability across market boundaries.

A market for CFE refers to an area in which:

• A single well-interconnected electric grid enables high levels of physical deliverability of power between internal points;
• The laws and regulatory framework governing the electricity sector are consistent between the areas of production and consumption; and
• Utilities and suppliers recognise each other’s energy attributes and account for them in their trade of energy and energy attributes.

While market boundaries are described geographically for convenience, they are defined fundamentally on the basis of electricity system topology. The 24/7 Carbon-Free Coalition holds that an electricity generating or consuming facility is located within the same geographic market boundary as its first point of interconnection to a meshed transmission network, which may not necessarily be the same as the market boundary within which the facility itself is physically located.

2. Markets for CFE recognised by the 24/7 Carbon-Free Coalition

2.1 Geographic market boundaries

The 24/7 Carbon-Free Coalition recognises the following as distinct geographic markets for 24/7 CFE:

• Bidding zones in electricity markets that employ a zonal pricing structure, including:
  • Australia’s National Electricity Market;
  • The electricity market operated by Brazil’s Chamber of Electric Energy Commercialization; and
  • The electricity market operated the European Network of Transmission System Operators for Electricity (ENTSO-E).
• Government-defined grid regions used for electricity sector regulation or emissions reporting in large countries that do not employ zonal electricity pricing, including:
  • For Canada, provincial and territorial electricity grids defined by the Canada Electricity Regulator;
  • For mainland China, the territories of the Inner Mongolia Power Company, the six branches of the State Grid Corporation of China, and the China Southern Power Grid; and
  • For the United States, grid regions defined by the US federal government for verification of CFE consumption by hydrogen producers.

For all other countries and territories, country-level boundaries apply.

2.2 Recognition of CFE imports across geographic market boundaries

Campaign partners may also make claims to use of CFE imported into a relevant geographic market boundary if the CFE is generated within a geographic market boundary that is physically interconnected via some transmission pathway to the geographic market boundary where it is claimed, and either of the following conditions are met:

1. The corporate buyer demonstrates the existence of exclusive rights allocating to itself or its energy provider the transmission capacity necessary to deliver power bundled with associated energy attributes from the point of generation to the point of consumption. These rights may be allocated via regulatory practice, contracts, or market instruments, and must be recognized by the transmission operators of all markets through which power is delivered. Energy attribute tracking systems and standards used to support claims must also be mutually compatible and recognized within all markets through which power is delivered. Delivery of power and attributes must be demonstrated on an hourly or more frequent basis with no direct counterbalancing reverse transactions.
2. In cases where hourly nodal or zonal electricity prices are published in both markets and the exporting market is topologically adjacent to the importing market, the corporate buyer demonstrates that the average price at the point of consumption is less than 1.05 times the average price at the point of generation in the hour for which a claim is made.

2.3 Market boundary updates and grandfathering

The 24/7 Carbon-Free Coalition recognises that geographic market boundaries are a necessary but imperfect proxy for physical deliverability of CFE and that boundaries must be defined subjectively following multiple criteria and informed by the best information available at the time. The 24/7 Carbon-Free Coalition therefore commits to continually reevaluating market boundary and cross-boundary deliverability definitions in response to new analysis, emerging global standards and best practices, and ongoing changes to the physical and regulatory structure of electricity systems. To minimise uncertainty for 24/7 Carbon-Free Coalition campaign partners, all CFE procured via self-ownership or long-term contracts will be considered deliverable in perpetuity to within whatever market boundaries it was assigned at the time it was first included in a campaign partner’s 24/7 CFE reporting, provided that this grandfathering is also compatible with Greenhouse Gas Protocol scope 2 emissions reporting guidance.

Appendix D: Markets where EACs are in common use

In the following markets, the 24/7 Carbon-Free Coalition requires CFE procurement to include EAC cancellation (see Section Five for details of exempted procurement). Corporate buyers may prefer to use a system shown to be in common use in the market, but are not required to choose a specific system.

An EAC system is considered by the 24/7 Carbon-Free Coalition to be in common use in a market once at least ten companies have made renewable electricity or CFE use claims in the market using the system and have had their market-based scope 2 inventory total verified by a third party. This list is derived from nearly 2,200 companies reporting on their renewable electricity purchasing and GHG inventory verification to CDP in 2023. This list should not be interpreted as endorsement of particular EAC systems or as proof that the systems are without flaws, but solely as recognition that they are in common use.

Markets where EACs are in common use

Note on Republic of Korea:
The Korean REC is issued to renewable electricity generation using multipliers to incentivize different technologies. Corporate buyers are issued a Confirmation of Renewable Energy Use (CREU) document that removes these multipliers. PPAs in Korea do not include a Korean REC but do include a CREU.

Markets where EACs are not in common use

Where EACs are not yet in common use, the 24/7 Carbon-Free Coalition still recommends that partners use them as a matter of best practice.

24/7 Carbon-Free Coalition companies may also consider the list of countries where I-RECs are issued for a more up-to-date idea of where EACs exist than what 2023 CDP data show.