Apr. 28, 2022
Requirements to report Scope 3 emissions are quite problematic. Emissions associated with the use of an electronic device or electrical appliance by downstream consumers are going to be very dependent upon the source of electricity, which may vary depending upon the time of day. These emissions are completely out of the regulated entity's control. As renewables grow in scope, the emissions in this example will in general decrease, but there is considerable uncertainty as to how quickly that transition will occur, and most predictions for the share of different modes of electrical power generation have proven wildly incorrect. The scope 3 emissions are also stated to include employee commuting. But, companies do not control where their employees live, how they travel to work, or by what modes of transport. These are largely personal choices of their employees. Upstream scope 3 emissions should be fair game, however, as these are nominally captured in Type III EPDs for a product.