CRS Comments on the draft Advanced and Indirect Mitigation Platform Electricity Annex

CRS welcomes the AIM Electricity Annex and supports its goal of providing electricity-specific guidance for Scope 3 interventions, while recommending targeted revisions to improve clarity, consistency, and guardrails. The comments ask AIM to strengthen electricity-sector direction on additionality; clearly define key regional terms such as “market boundary” and “electricity sourcing or use region” in line with GHG Protocol Scope 2 and RE100 concepts; and state explicitly whether a single intervention can be reported under both the substitution and consequential methods to avoid double counting.

CRS supports allowing limited MWh-to-tCO₂e conversions only for estimating and sizing interventions—not for claims—and urges a clear hierarchy for geographic specificity, favoring the most precise upstream electricity location data available. CRS also recommends broadening and consistently applying the definition of eligible electricity interventions, tightening equivalence rules so sizing methods are not mixed and rely on consistent emissions factors, clarifying how market boundaries should function over time in Scope 3 contexts, and ensuring regional boundaries are used only when justified by evidence and data limitations, not convenience.