By Todd Jones
The clean energy world is stuck in a fight over greenhouse gas (GHG) accounting. Advocates of annual renewable energy matching, hourly matching, and consequential accounting increasingly treat each approach as mutually exclusive—sometimes even accusing one another of greenwashing or deception.
But these approaches can coexist.
All three approaches provide useful information, can help accelerate decarbonization, and depend on credible renewable energy markets and contractual tracking instruments like renewable energy certificates (RECs).
The Three Camps
The debate centers on three main approaches:
- Annual market-based accounting (today’s dominant voluntary renewable energy market model), where electricity consumption is matched to renewable generation annually, across broad regional and national markets.
- Hourly and locational matching, which aligns electricity consumption and renewable generation hour by hour and with closer geographic alignment between load and generation, using hourly load and generation data.
- Consequential accounting, which estimates the broader emissions impact of purchased electricity using annual or hourly marginal emissions and system-level modeling, typically with broader geographic sourcing to maximize avoided emissions.
Each camp tends to frame its preferred method as the only credible path forward. But these approaches answer different questions and serve different purposes.
Annual Matching Is Credible Accounting
No grid-connected customer—whether using annual or hourly matching—physically receives electricity from a specific generator. Renewable energy claims are contractual claims enabled through instruments like RECs. Annual matching has long supported credible renewable energy markets, utility programs, corporate target-setting, and emissions reporting, in part because annual and monthly data have historically been more widely available, consistent, and reliable. Hourly matching can make contractual claims more precise by tightening the time window, but not more accurate in a physical sense.
Annual matching has worked precisely because it supports large, liquid, accessible markets that aggregate demand and finance large-scale renewable deployment. Broader regional and national markets can improve liquidity, lower costs, expand participation, and help drive clean energy deployment where it is most cost-effective or where avoided emissions impacts are greatest. A 100% clean grid is ultimately a system-wide outcome driven by broad market participation, large-scale investment, and continued clean energy deployment across the grid—not only by increasingly precise procurement by individual buyers.
Hourly and Locational Matching Can Add Value
Hourly and more geographically targeted matching can absolutely improve precision and sharpen market signals.
Particularly when paired with large new electricity loads—like data centers or hydrogen production—hourly and more local procurement can create targeted demand in scarce hours and constrained areas, incentivizing new clean energy generation, storage, and infrastructure investment where and when it is most needed. Under the right conditions, that can accelerate decarbonization and strengthen local grid impacts.
But this approach is not automatically superior in every context or right for all buyers and programs.
If they have hourly data (for electricity consumption and generation), customers should use it. Otherwise, customers should be able to use the monthly and annual data that they have, and they should avoid sacrificing data quality for precision. More localized procurement can also be a valuable option and policy preference in some circumstances, especially for large new loads.
Mandating hourly and local matching for everyone and under all circumstances risks making markets smaller, more expensive, and less inclusive. Smaller markets can reduce liquidity and demand aggregation, increase transaction costs and price volatility, and limit participation by buyers that help finance large-scale renewable deployment. Many buyers could be priced out entirely, reducing participation and slowing investment overall.
Hourly and more geographically targeted procurement approaches should expand the market-based system, not replace it.
Consequential Accounting Expands the Picture
Consequential accounting can provide important insights into how both consumption and purchased generation may affect overall grid emissions and where procurement decisions can have the greatest system impact. These are questions and insights that attributional accounting alone is not intended to capture, particularly when evaluating avoided emissions, market effects, or strategies for accelerating decarbonization.
Part of making consequential accounting useful and credible is distinguishing between fundamentally different consequential claims and metrics—primarily:
- Estimating avoided grid emissions, and
- Claiming emissions reductions beyond business-as-usual.
These are not interchangeable and require different levels of rigor, including different treatments of baselines, marginal emissions, and additionality.
Consequential metrics can complement existing accounting frameworks if claims remain transparent, clearly differentiated, and understandable to consumers and investors.
A Shared Market Foundation
Most importantly, all of these approaches rely on the same underlying market infrastructure: contractual tracking, exclusive claims to renewable generation and associated emissions attributes, and credible instruments like RECs to prevent double counting.
Neither hourly matching nor consequential accounting removes the need to track and verify renewable generation and allocate associated emissions impacts to customers. Both approaches still depend on the same contractual market infrastructure that enables credible renewable energy claims today.
RECs do more than support credible claims and prevent double counting. They also help aggregate demand and create a foundation on which more granular hourly and consequential approaches can continue to evolve.
Don’t Break What’s Working
The clean energy transition still needs vastly more demand.
Non-emitting sources currently account for only around 42% of U.S. electricity generation, and renewables make up roughly 25%. Restricting participation or invalidating existing clean energy procurement approaches will not accelerate decarbonization.
To continue scaling clean energy deployment, we need market structures that can support broad participation, sustained investment, and continued growth over time. Existing voluntary renewable energy markets are not standing in the way of progress—they have helped finance and deploy large amounts of clean generation across the grid. Their scale and flexibility have allowed clean energy development to expand first where it is most cost-effective, while also creating the foundation for increasingly sophisticated procurement and accounting approaches, including more granular hourly, locational, and consequential frameworks.
A Better Path Forward
This should not be a fight between annual matching, hourly matching, and consequential accounting. We agree on a lot, and we can have it all.
Annual matching remains credible and effective. Hourly and locational matching can provide additional precision and sharper market signals. Consequential accounting can offer complementary insights into broader system impacts.
Most importantly, clean energy advocates should stand together and not let ourselves be divided. We should defend renewable energy markets, expand participation, improve data and transparency over time, and continue innovating—without undermining the market structures that have already driven enormous clean energy growth.
What CRS is Doing
CRS is actively supporting all three approaches.
We continue to strengthen and grow today’s voluntary renewable energy market through programs like Green-e® Energy, which provides credibility, transparency, and protections against double counting. We also engage policymakers, regulators, voluntary standards bodies, buyers, and industry groups while supporting market education and research.
At the same time, CRS is helping build the infrastructure needed for hourly markets. That includes:
- New Green-e® certification options for time-based and time-matched products
- Several recent Clean Energy Accounting Project (CEAP) initiatives focusing on hourly accounting and procurement questions—including Accounting for Transacted Timestamped Information and Hourly Utility Product Design Options
- Clean Energy Tracking Collaborative’s (CETC) first technical working group on hourly certificate tracking system functionality
CRS is also supporting the development of consequential accounting frameworks and data standards through initiatives including:
- A GHG Protocol Scope 2 and Actions and Market Instruments (AMI) joint subgroup
- The Task Force for Corporate Action Transparency (TCAT) electricity workstream pilot
- The Energy Storage Solutions Consortium (ESSC)
Across all of this work, CRS is focused on identifying and recognizing individual impactful procurement strategies while defending the credibility and scalability of renewable energy markets overall.
Todd Jones is Head of Policy at CRS.