Response to the GHG Protocol consultation on Scope 2 guidance

SolarPower Europe supports a gradual, voluntary transition toward hourly matching, based on solid regional impact assessments that prove long-term benefits such as reduced system-wide emissions, industrial decarbonisation, and a stronger PPA market. 

SolarPower Europe advocates for pragmatic approaches to locational granularity, rejecting rigid zonal pricing boundaries that could disadvantage certain EU Member States and acknowledging the difficulties of tracing electricity flows across Europe’s coupled electricity markets. At the same time, SolarPower Europe supports the introduction of stronger deliverability criteria that take into account actual interconnection capacity and grid constraints. In this context, it recommends considering wider deliverability boundaries in highly interconnected regions in order to preserve the value of cross-border PPAs, and calls for a consistent treatment of deliverability across energy vectors.

Finally, SolarPower Europe supports a Legacy Clause at asset-level to ensure existing renewable contracts and investments remain valid, protecting investor confidence and preventing disruption to Europe’s renewable energy expansion.