We have written about how the world classes energy as “green” lots and lots of times on this website, and the end of this month is the deadline for being able to respond to a really important consultation run by GHG Protocol, a standards body that will shape how literally trillions will be spent on green energy in the next 10 years. We’re feverishly working on our response, and if you care about green energy meaning something we think you should respond too. In this post we’re sharing some resources we’ve found useful, and they key dates you need to put in your calendar.
Put it in your calendar now – the deadline for responding to the GHG Protocol consultation on Scope 2 guidance is *31st January 2026*
We’re putting the most important bit at the front of this post, before giving all the helpful context like what the GHG Protocol is, what Scope 2 means, and where to look for help in responding to the GHG Protocol’s public consultation.
Also, to respond to the consultation you can’t just send someone an email – you need to slog through a long multistep form of questions pasting them in, so you’ll need to put some time aside for that too – assume 30 mins to be safe.
Ok, with that out of the way, let’s run through what this is about, where to get help, so you feel confident responding.
Why does this matter, really?
We have written at length about this, and also responded to early consultations ourselves, but the short version is that right now, the way people class energy as “clean” or “green” or “carbon free” or even “fossil free” has some absolutely colossal issues that might have seemed a good idea at the time in 2015, but in 2025, they incentivise some of the worst behaviour by huge companies, and in general count energy as clean using approaches that are wildly at odds with how most people expect buying clean energy to work.
Almost every significant law in the world around corporate reporting, energy or organisational transparency references the GHG Protocol’s guidance, so final decisions here will have far reaching implications.
Ok, this sounds pretty important. Where should I start?
We have written at length about the issues in an earlier consultation about what is wrong with the current Scope 2 guidance – essentially how energy is classed as ‘green’. In our recent post, No Fossil Fuels in Our Tech Stacks, we’ve laid out where we stand on the issue. Here’s what we said:
To counter that, we join leading scientists and advocates calling for green energy claims that meet the following criteria:
- Every hour of usage in a data center is matched with 100% renewable energy that is generated locally and additive to the local grid.
- All claims about energy generation and consumption must be publicly accessible and independently verifiable.
- Decarbonization goals are set and met with binding interim targets.
- Carbon offsets are rejected.
- Communities are empowered to participate meaningfully in decisions about energy generation and consumption
Turning these into specific answers to the 180+ questions in the public consultation is a bit of work, which is why we and so many others are hustling to get a response together.
However, there’s good news – first of all, you don’t need to answer all the questions in the survey (phew), and there are various groups who have been sharing their own work to help inform how you might answer them.
Cribsheets and cram sessions
When it comes to translating this into something that directly responds to the questions from the GHG Protocol consultation, we’ve found the GHGP Scope 2 guidebook from EnergyTag, on their catchily named “Scope True” website really helpful.
In addition, they’re even running a cram session webinar on Jan 21st you can join, where you can get a good summary of the changes and some pointers.
Elsewhere, the National Resources Defence Council have also written about the process waaay back in 2024 in their post The Once in a Generation Chance to Fix Corporate Emissions Reporting.
Tedious and important at the same time
We get it – responding do consultations is rarely fun, and can feel thankless, but in this specific case the stakes are very high.
The responses to this consultation are likely to decide if it’s possible to build a 2 GW gas fired power station to power your AI like Meta is doing, and say you’re running on renewable power, or for companies to claim the ‘ greenness’ for clean power paid by tax payer’s money as their own, instead of actually having to get new fossil free energy generation built for real.
This is a chance to get the rules right around counting energy as green, and the last chance was ten years ago.
We’re not sure when the next one will come up, so while it’s here, why not take it?
Helpful links
The GHG Protocol’s official consultation page
The actual submission form to use
Our earlier post responding to how the Scope 2 rules are now, and need to be updated
Energy Tag’s cram session on Jan 21st
Energy Tag’s Scope true website and their guidebook
The National Resource Defence Council (NRDC) on the important of these changes
