Jun. 01, 2022
June 1, 2022 I am commenting to show support for The Enhancement and Standardization of Climate-Related Disclosures for Investors. Furthermore, I am advocating for the recommendation of hourly accounting for Scope 2 emissions using Granular Certificates proposed by the EnergyTag initiative. Adhering to hourly accounting with granular certificates (as opposed to RECs) will ensure a faster transition to 24/7 carbon-free energy on our grids for at least two key reasons: 1) It will enable transparency into leverage points for grid decarbonization (when and where are the shortfalls? When and where is the demand?) 2) It will encourage power purchase agreements between large energy consumers and carbon-free energy suppliers that can be tracked to show full 24/7 CFE coverage per customer. With enough demand, we will begin to see new CFE projects come online. Please consider recommending 24/7 CFE accounting for Scope 2 emissions through granular certificates (GC's). (Secondly, in the future, (though it may not be the purview of the SEC) it may be interesting if the ISOs were required to submit similar reports annually detailing progress towards full grid decarbonization.)