Is the GHG Protocol including “enabled emissions” in Scope 3 in future?


I found this when I sitting down to read Killian Daly’s recent update on the Energy Tag blog about how the GHG Protocol is changing how organisations report the greenness of electricity and it seemed interesting enough to jot some notes here for others, as I hadn’t seen it coming at all. The next version of the GHG Protocol looks like it might include reporting on what we might call “enabled” or “facilitated emissions”. This could very easily cover the use of AI for oil and gas exploration.

What are enabled emissions and why does this matter?

You can think of enabled emissions as the kind of emissions that come about as result of services provided by organisations that by themselves don’t cause that much in the way of emissions directly – but instead enable, or facilitate activity that can be cause lots of emissions themselves.

A good example might be the use of AI services to help drill for oil and gas. The AI services themselves might be super efficient and well coded, and run on very green energy, but if they’re helping a massive oil company drill for more oil and gas more effectively, then they’re facilitating the burning of a whole bunch of oil and gas.

To use the overly simple but still kinda useful two by two from another post, they’re stuff in the bottom right of this diagram below:

These enabled emissions can be massive – one AI contract with a big oil firm back in 2019 was estimated to have the same carbon footprint as all of Facebook.

A chart showing the comparative emissions figures from a blog post in my day job.

You don’t need to take my word for it though. Here’s a nice 5 minute video from someone who worked on these projects at Microsoft, talking about what he refers to as enabled emissions.

Anyway, the video is worth a watch:

From enabled emissions to facilitated emissions

Out of curiosity, after reading Killian’s piece, I saw a link referring to all the presentations and meeting minutes being shared publicly as the GHG Protocol goes through its reform process, and in the Scope 3 working group (i.e. the ’emissions in your supply chain’ one), I found out that there was a new class of emissions in Scope 3 called “facilitated emissions”, being proposed, that looks like it could have been designed to capture stuff activity like this use of AI for oil and gas exploration. I had no idea this was on the cards at all!

Here’s the key text from the proposal:

“A facilitated activity is a third-party activity, product, or emitting source that:

(a) is enabled, initiated, or influenced by a reporting company’s services, products, and/or infrastructure,

(b) where the reporting company does not own or directly operate the facilitated activity at any point in its lifecycle and

(c) from which the reporting company generates transactionally recorded economic value.

Some scope 3 categories currently require the inclusion of activities that may reflect a facilitated activity; these activities shall be itemized using the activity where they are itemized.”

Here’s the image of slide 33 from the public deck below.

Notes on Category 16 (facilitated emissions)
The following is draft proposed language for a Category 16 (optional) for facilitated activities (to be considered June 5th *):
• Definition: A facilitated activity is a third-party activity, product, or emitting source that: (a) is enabled, initiated, or influenced by a
reporting company’s services, products, and/or infrastructure, (b) where the reporting company does not own or directly operate the
facilitated activity at any point in its lifecycle and (c) from which the reporting company generates transactionally recorded economic
value. Some scope 3 categories currently require the inclusion of activities that may reflect a facilitated activity; these activities shall be
itemized using the activity where they are itemized.
• Classification: Any facilitated activity that does not satisfy a scope 1, scope 2, or scope 3, category 1 through 15, minimum or
optional boundary shall be classified as scope 3, category 16.
• Optionality: A company may account for and report emissions associated with a facilitated activity (excluding a facilitated activity
within the minimum boundary of scope 3 categories 1 through 15). A company should account for and report emissions associated
with a facilitated activity that is required by an industry- or sector-specific standard, guidance, framework, and/or legislation.
• Boundary guidance: If reported, a company should include the life cycle emissions of a facilitated activity (including the associated
scope 1, scope 2, and both upstream and downstream scope 3 emissions) (collectively, the “facilitated emissions”).
• Calculation method: If reported, a company should account for all (100%) of the scope 1, scope 2, and up/downstream scope 3
emissions.
• Disaggregation: If reported, companies shall disaggregate reported category 16 emissions by facilitated activity type (refer to Table
16.1).
The specific slide that caught my attention from the Scope 3 working group

It’s pretty wordy and tedious, granted, but that doens’t mean it’s not important.

Will this be included in Scope 3 in future? When is it being decided?

I’m not sure – if meeting notes are anything to go by, it’ll be discussed tomorrow, and now I’m extremely interested in seeing where this goes.

If you know any more about this, hit me up.


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