This Modulemodule (Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.) describes how to calculate emissions (The term used to describe greenhouse gasenergy-related emissions tomust thebe atmospherecalculated asin a resultcarbon of Project activities.) related to energy use forremoval Carbon Dioxide Removal (CDR) (Activities that remove carbon dioxide (CO₂) from the atmosphere and store it in products or geological, terrestrial, and oceanic Reservoirs. CDR includes the enhancement of biological or geochemical sinks and direct air capture (DAC) and storage, but excludes natural CO₂ uptake not directly caused by human intervention.)projectsproject (An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.) asso partthat they can be subtracted in the net CO2e (The amount of CO₂ emissions that would cause the same integrated radiative forcing or temperature change, over a given time horizon, as an emitted amount of GHG or a mixture of GHGs. One common metric of CO₂e is the 100-year Global Warming Potential.)removal (The term used to represent the CO₂ taken out of the atmosphere as a result of a CDR process.) calculation. Furthermore, this module applies to all carbon removal pathways (A collection of Removal or Reduction processes that have mechanisms in common.), ensuring a consistently rigorous standard in how energy-related emissions are quantified and reported between different carbon removal projects and approaches.
[math: CO_2e_{Energy\ R}] must account for all operations and support systems that consume energy within the removal process, for example through electricity or fuel, as specified in Section 3 of this module. These operations and support systems are denoted as [math: k].
Primarily non-road/rail/air/maritime mobile sources are included within this boundary, such as fork trucks and loaders used for material handling. However road, rail, air and martime mobile emission sources are excluded from [math: k], such as electric or diesel vehicles, as they are accounted for in [math: CO_2e_{Transportation,\ R}].
Refer to Transportation Emissions Accounting Module for the calculation guidelines.
Where possible, project greenhouse gasproponents (The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.) should account for emission impacts of electricity usage based on the same grid regions (A geographically precise and internally well-connected energy distribution and use area representing a subsection or the entirety of a synchronized electricity grid. The assignment of a project to a grid region should be based on the location of the project’s point of interconnection within the topology of the electricity system, rather than the physical location of the project itself.) (well-connected energy distribution and use areas) as endorsed by national governments. For facilities within projects that consume large quantities of electricity, known as intensive facilities, accounting for the consequential (The analysis of specific Uncertainties, hazards and scenarios inherent in complex systems such as the natural and engineered environment, aiming to describe how systems-level environmentally relevant flows will change in response to possible decisions.) emission impacts of electricity usage may also be required. More details on when this is applicable can be found in Section 3.2.1.
Emissions associated with energy usage include the following potential emissions sources,
[math: CO_2e_{Energy,\ R} = CO_2e_{Electricity,\ R} + CO_2e_{Fuel,\ R}]
(Equation 1)
Where:
This Module was developed based on the current state of the artminimum, publicly available science regarding energy emissions accounting. This Module will be updated in future versions as the underlying science evolves and the availability of high-quality data and documentation in the energy market increasesCO2, for example regarding emission factors (An estimate of the emissions intensity per unit of an activity.), temporal matching and power purchase agreements.
This Module will be reviewed at least annually when substantial changes of data availability in the energy market occur, or when there are substantial advances in understanding of scientific concepts relevant to emissions accounting for energy usage.
Isometric recognizes that best practices for supplying energy to CDR projects are still evolving. Isometric will continue to engage with stakeholders (Any person or entity who can potentially affect or be affected by Isometric or an individual Project activity.) and the scientific community to assess the rigor and operability of accounting approaches, including temporal matching and emissions matching. Any future changes to the approach outlined in this Module will be conducted in consultation with a range of stakeholders and the scientific community to ensure a robust transition to the best available approaches, while maintaining operational integrity for existing projects which are continuing to be established under an evolving governance landscape.
Isometric is committed to progressively increasing the rigor of energy emissions accounting requirementsCH4, and will introduce more robust approaches as soon as they are supported by the evolving science and demonstrably operable under prevailing market conditions.
TheN2O emissions) associated with energy use must accountconsumption for alla operationsremoval, that[math: consumeR], in tonnes;
[math: withCO_2e_{Electricity,\ EnergyR}] Use are denotedand [math: CO_2e_{EnergyFuel,\ R}] must account for operations and support systems that consume electricity or fuel within a removal, denoted as [math: k]. This may be calculated on an individual or combined basis (e.g., for an individual piece of equipment, a sub-process, and/or a Project) as long as all operations and support systems, [math: k], are accounted for.
Equation (1) and the calculation approaches in Section 3 can also be followed for a batch, [math: n], or for a reporting period, [math: RP].
Electricity-related emissions typically are indirect emissions associated with generation and transmission of electricity by another entity (electric utility) which is used by the process.
The calculation approach in this module distinguishes between the types of electricity consuming facilities used for a removal, [math: R], within a project. [math: CO_2e_{Electricity,\ R}] is calculated from the sum of electricity usage across facilities for a given removal, [math: R].
SourcesThe (Anytwo processcategories orof activityprojects thatrelevant releasesto athis greenhousecalculation gasapproach are intensive projects, anwhich aerosolhave the potential for significant amounts of electricity utilization, orand anon-intensive precursorprojects. A facility is considered to be non-intensive for the purposes of a greenhouseproject gasif intoit uses less than 10 GWh and where the atmosphereestimated electricity use per ton of CO2 sequestration is less than 50 kWh.) includedFacilities inthat thisuse Module’sgreater scopethan 10 GWh of electricity or where estimated electricity use per ton of CO2 sequestration is greater than 50 kWh are: classified as intensive facilities.
Any machinery;
The following calculation approach must be followed for non-intensive facilities:
[math: CO_2e_{Electricity,\ R} =\sum_{1}^{N}kwh_{k}\cdot EF_{Elect,\ r}]
(Equation 2)
Where:
If a project relying on a non-intensive facility wishes to reduce their energy emissions through the purchase of qualifying electricity then they may use Equations 3 and small4 personalreplacing transport[math: modesEF_G] with [math: EF_{Elect,\ r}]. Project proponents will be responsible for collecting sufficient documentation to submit these calculations.
For intensive facilities a consequential accounting approach is adopted (see Appendix 1 for further information), which is designed to be conservative (Purposefully erring on the side of caution under conditions of Uncertainty by choosing input parameter values that will result in a lower net CO₂ Removal or GHG Reduction than if using the median input values. This is done to increase the likelihood that a given Removal or Reduction calculation is an underestimation rather than an overestimation.) such that it avoids overestimating the net carbon removal of a project. Emission impacts resulting from both the consumption of grid electricity and the direct procurement of power from individual generators are considered as part of this approach.
Facilities that source electricity from within jurisdictions that have implemented sufficiently rigorous GHG cap-and-trade programs shall assume a consequential emissions rate of zero for all electricity consumption within these jurisdictions. See Appendix 2 for further information on this exemption. Currently the European Union (EU) Emissions Trading Scheme is the only cap-and-trade jurisdiction approved as sufficiently rigorous under this Module.
For facilities not subject to the above exemption total emissions for a removal, [math: R], are calculated as the sum of the hourly emissions, [math: CO_2e_{Electricity,\ L}], over all hours of electricity consumption within that removal:
[math: CO_2e_{Electricity,\ R} = \sum CO_2e_{Electricity,\ L}]
(Equation 3)
Where:
[math: CO_2e_{Electricity,\ L}] is calculated as follows:
[math: CO_2e_{Electricity,\ L} = max \bigg(0,kwh_{L} - \sum_{p}G_{p}\cdot m_{p}\bigg) \cdot EF_G + \sum_{p} \frac {G_{p}\cdot EF_{p}}{m_{p}}]
(Equation 4)
Where:
Refer Short-run marginal emissions rates reflect the emissions associated with real-time changes in output from specific marginal generators in response to the GHGhypothetical Accountingchange Modulein v1demand.1 They do not reflect the potential for a persistent change in demand to incentivize entry of new generating facilities into the calculationelectricity guidelinessystem (i.e., structural change). Multiple methodologies for transportationcalculating (includingshort-run roadmarginal emissions rates from available grid data exist, railbut all aim to quantify the same impact. Short-run marginal emissions rates are provided directly at hourly or sub-hourly resolution by some grid operators, air and maritimein mobileother emissioncases sourcesthey are calculated and made available by third-party vendors. Some grid operators also provide temporally granular data on ‘fuels on the margin,’ from which project proponents may calculate marginal emissions rates using average fuel-specific emissions factors from the grid region in question.) (emissions associated with real-time changes in output from specific marginal generators in response to the hypothetical change in demand) of the local electricity grid at the project’s point of interconnection, and;
Electricity consumption may be subdivided into consumption of 'Qualified' electricity and 'non-Qualified' electricity:
Refer to the GHG Accounting Module for calculation guidelines.
Emissions associated with energy usage include theelectricity use of both electricity and fuel. The following calculation approach must be followed for the calculation of [math: CO_2e_{Energy,RP}]:
[math: CO_2e_{Energy,RP} = CO_2e_{Electricity,RP} + CO_2e_{Fuel,RP}]
(Equation 1)
Where:
[math: CO_2e_{Electricity,RP}] and [math: CO_2e_{Fuel,RP}] must account for all operations and support systems that consume electricity or fuel within the CDR process. This may be calculated on an individual or combined basis, provided that all operations within the process are accounted for.
This Module provides accounting requirements for the following types of electricity:
To connected.be Projects must follow the quantification requirements in Section 5.2.
Project Proponents may elect to establish power generation "behind-the-meter". Behind-the-meter electricity provision refers to generation that supplies electricity directly to The Project without passing through the local transmission grid. This may occur either via a direct physical connection or because the CDR process is integrated into the electricity generation process itself. Behind-the-meter generators may be owned and operated by The Project Proponent or by a third party. Additionally, they may be existing assets, or assets built at the same time as the CDR project.
Life cycle emissions associated with electricity produced by behind-the-meter generators and used by The Project must be quantified. If the electricity produced by the generator is used solely by The Project, the generator must be fully considered as part of The Project's system boundary (GHG sources, sinks and reservoirs (SSRs) associated with the project boundary and included in the GHG Statement.). If the electricity supply produced by the generator is delivered to the grid or other facilities as well as The Project, emissions associated with electricity provision to The Project must be quantified in line with the requirements for [math: f_p] in Section 5.5 and proportionally allocated to The Project.
Projects utilizing electricity from generators that meet bothall of the following eligibility criteria must also account for Energy leakage (The increase in GHG emissions outside the geographic or temporal boundary of a project that results from that project's activities.) if the following are true:
Energy leakage represents the indirect greenhouse gas emissions arising when a Project consumes electricity that would otherwise have been supplied to the grid, or when a Project creates a parasitic load that reduces the net electricity supplied to the grid. Energy leakage is quantified by determining the total reduction in electricity supplied to the grid resulting from the CDR process and multiplying this by the average grid intensity factor ([math: f_{grid}]).
Project electricity demand may be supplied entirely by behind-the-meter generation or partially supplied. The accounting requirements for each are set out below:
For the determination of a facility as intensive or non-intensive, the facility's relevant electricity consumption is equal to the total electricity demand minus the behind-the-meter generation supplied to The Project. Consequently, electricity supplied by behind-the-meter generation is excluded from the consumption total used to determine if the 200 GWh threshold is met.
Equation 2 must be followed for emissions associated with provision of electricity from the grid.
[math: CO_2e_{Electricity,\ RP} = f_{grid} \sum_{i=1}^{N}E_i]
(Equation 2)
Where:
Projects may reduce electricity emissions through procurement of low-carbon power (See Section 5.4).
A Project may wish to reduce its energy emissions through the procurement of Electricity EACs, where electricity is procured by contract purchase from renewable sources for the exclusive use of The Project. Note that Electricity EACs are known by different names depending on the jurisdiction, including Renewable Energy Certificates (RECs) and Guarantees of Origin (GOOs). In this Module, the term Electricity EAC is used as an umbrella term covering all such instruments.
To use Electricity EACs, Project Proponents are required to account for emissions associated with the electricity generation following the requirements for [math: f_p] set out in Section 5.5. Furthermore,
Eligibility Criteria
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EC1 |
The electricity utilized is |
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EC2 |
The Project
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If the Project has an annual energy |
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The generating facility from which the claimed electricity is sourced entered service no more than |
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If the Project has an annual energy use of greater than10 GWh, and the generating facility |
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In cases where documented market constraints are in place, non-intensive facilities or intensive facilties that are permitted to use electricity which was generated no more than 12 months prior to the point of consumption by The Project, may use electricity which was generated no more than 18 months prior to the point of consumption by The Project, if the following is evidenced:
In addition to the Eligibility Criteria in Table 1, EACs from bioenergy production will be subject to review by Isometric on a case-by-case basis to account for biomass sourcing and GHG accounting considerations.
Acceptable grid region definitions should be utilized in-line with those defined by a local regulatory authority. For projects operating in the United States, Project Proponents should use the definitions of grid regions established in the Department of Energy National Transmission Needs Study1 (i.e. the definition adopted in the United States 45V tax credit for production of clean hydrogen), or definitions of grid regions corresponding to Independent System Operator (ISO) regions. Projects operating in the United States should provide a brief justification in the PDD (The document that clearly outlines how a Project will generate rigorously quantifiable Additional high-quality Removals or Reductions.) for the choice of grid region definition with respect to the deliverability of procured power. We note that The Project Proponent must adopt a consistent definition of grid regions in the United States for all projects registered with Isometric operating within the United States, whenever technically feasible. For projects operating in the European Union, Project Proponents should use the European Network of Transmission System Operators (ENTSO) definitions of grid regions (referred to as "power regions"). Projects operating within all other global regions will agree with Isometric, at the point of submission of the PDD, appropriate grid region boundaries to use for the purposes of applying the requirements established in this Module. It should be noted that the definition of a grid region within this Module may change over time as regional frameworks and definitions develop further. However, generators which are certified as deliverable to a Project at the point of initial project validation (A systematic and independent process for evaluating the reasonableness of the assumptions, limitations and methods that support a Project and assessing whether the Project conforms to the criteria set forth in the Isometric Standard and the Protocol by which the Project is governed. Validation must be completed by an Isometric approved third-party (VVB).) will retain this certification for the duration of The Project lifetime, regardless of future updates to this Module.
Projects that procure Electricity EACs to reduce their energy emissions should follow the calculation approach for [math: CO_2e_{Electricity,RP}] described in this Section. Non-intensive facilities should follow the approach described in Section 5.4.3.1. Intensive facilities should follow the approach described in Section 5.4.3.2.
The following calculation approach must be used for non-intensive facilities:
[math: CO_2e_{Electricity, RP} = f_{grid} \left[ \left( \sum_{i=1}^{N}E_i \right) - \left( \sum_p G_p \right) \right] + \sum_p f_p G_p]
(Equation 3)
Where:
For non-intensive facilities, documentation proving the direct procurement of low-carbon power should be time-stamped within 12 months of the point of consumption by The Project. In some regions power procurement market dynamics can pose challenges to Projects in meeting the 12 month limit. Where documented regional market constraints prevent a non-intensive facility from meeting the 12-month requirement, EAC vintages of up to 18 months prior to the point of consumption are allowable. Project Proponent's must provide sufficient evidence at verification demonstrating that compliance with the 12-month requirement was not feasible as a result of market constraints.
Projects with non-intensive facilities may choose to procure Electricity EACs featuring timestamps with hourly granularity.
The electricity must followbe physically deliverable to the calculation detailsproject in Equationthe 4.same Ithour for which it is notclaimed. permissableElectricity for projectsis to combinebe Electricityconsidered EACsphysically featuringdeliverable timestampsif withany hourlyof granularitythe following conditions are met:
[math: CO_2e_{Electricity, RP} = f_{grid} \sum_{i=1}^N \left( E_i - \sum_p G_{p,i} \right) + \sum_p \left( f_p \sum_{i=1}^N G_{p,i} \right)]
(Equation 4)
Where:
For intensive facilities, documentation proving the direct procurement of low-carbon power should be time-stamped with an hourly time granularity and accordingly matched to project energy usage on an hourly basis. Project Proponents must obtain documentation time-stamped with an hourly time granularity when available in the region of operation. We note that as an alternative approach, Project Proponents are permitted to operationalize Configuration 3 of the EnergyTag Granular Certificate Scheme Standard2. Further details of this approach, and limitations to it's application in the context of this Module, are provided in Appendix B.
Under some operational circumstances, it may not be feasible to procure low-carbon power featuring hourly time stamps in the region of project operations. In this case, intensive facilities may follow the calculation approach described in Section 5.4.3.1 (Equation 3), provided the EC6 is met.
Table 2: EC6 Exemption to hourly matching
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This exemption reflects Isometric's assessment that low-carbon power procurement featuring hourly time stamps is unlikely to be widely available at economically feasible terms before 2030. This position is aligned with the approach adopted by the the EU CRCF delegated act methodologies for permanent carbon removals reference Delegated Regulation (EU) 2023/11843. Isometric will monitor market developments as part of the Module update process and will adjust these requirements as necessary.
Projects that utilize the exemption described above will be permitted to utilize the exemption for the full duration of the obtained PPA, regardless of any future updates to this Module. Upon expiration of the obtained PPA, if this occurs at such a time that this exemption has been revoked from this Module, then compliance with the hourly matching scheme described above will be mandatory. If The Project has an existing PPA in place at the time of validation that was negotiated under a prior version of this Module, The Project Proponent must provide a copy of the final signed and executed PPA and demonstrate that it was negotiated in accordance with the rules in effect at the time of execution. Such PPAs will be assessed against the version of this Module that was in force at the time the PPA was signed.
It should be noted that all energy intensive projects should procure low-carbon power according to an hourly matching schemeregions (i.e., Equationthose 4sharing a direct transmission connection) whenever possible, asat thisleast representsone of which publishes locational marginal electricity prices (LMPs), and the mostaverage credibleLMP approachat towardsthe accurateproject's characterizationpoint of interconnection is less than 10% greater than the average LMP at the generator’s point of interconnection over the hour in question. If one of the emissionstwo associatedgrid withregions does not publish LMPs, then the provisionLMP at the intertie location between the two regions (or the average of electricityLMPs toat CDRall projects.intertie Atlocations suchif multiple exist) may be used as a timesubstitute thatfor contractsthe featuringLMP hourlyat timethe stampspoint areof widelyinterconnection availablefor whichever electricity generator is located in the energynon-publishing marketregion.
In all cases, the exceptionProject must provide:
In cases where the hourly matching scheme will be mandatory for all projects relying on an intensive facility.
Information regarding the low-carbon power procurement approach used by The Project Proponent will be transparently reported in the public PDD, which will be available for download from the registry page associated with each credited removal.
Where an intensive facility utilizes the exemption described above and follows the calculation approach described in Section 5.4.3.1 (Equation 3), low-carbon power procurement is not matcheddirectly toconnected consumption on an hourly basis. In practice,‘behind the generation profile of procured low-carbon power may not correspondmeter’ to the electricitygenerating consumption profile of The Project. For examplefacility, procured solar generation may occur during daytime hours while Thethe Project consumesmust electricityprovide:
In cases where the Project seeks to establish deliverability between two adjacent grid regions, the Project must provide:
To mitigate this risk, Project Proponents utilizing the exemption are encouraged to conduct an Emission Screen. The purposeone of the Emission Screen is to verify that The Project's procurement of low-carbon power is sufficient to neutralize the emissions impact it would have otherwise had on the local electricity grid. Specifically, the Emission Screen is passed if the total avoided emissions attributed to the procured low-carbon power are greater than or equal to the emissions that would have resulted from consuming an equivalent amount of electricity from the grid. While the Emission Screen is not mandatory for projects, conducting it provides an additional layer of assurance that the use of annual matching does not result in a material underestimation of The Project's electricity-related emissions.
The Emission Screen calculation may be conducted as set out in Equation 5, or Equation 6 where generation data for procured power is available or can be derived.
[math: \left( \sum_{i=1}^{N} f_{grid,i} \cdot E_i \right) - \left( \sum_p (\bar{f}_{grid} - f_p) \, G_p \right) \leq 0]
(Equation 5)
Where:
[math: \left( \sum_{i=1}^{N} f_{grid,i} \cdot E_i \right) - \left( \sum_p \sum_{i=1}^{N} (f_{grid,i} - f_{p,i}) \, G_{p,i} \right) \leq 0]
(Equation 6)
Where:
Alternative approaches may be implemented (for example using marginal and hourly emission factors) to demonstrate that The Project's low-carbon power procurement sufficiently mitigates the emissions impact of its electricity consumption.
Whether an intensive Project implements the Emission Screen, or not, must be transparently reported in the PDD.
[math:Emission f_{grid}]factors -(An estimate of the emissions factorsintensity per unit of an activity.) used must:
[math: f_p] - emissions factors used must:
Regional or subnational location-based grid average emissions factors must be used where available for the calculation of [math: f_{grid}]. These must represent net physical energy imports and exports across the grid boundary and all electricity production occurring in a defined grid distribution region that approximates a geographically precise energy distribution and use area.
Applicable life cycleAcceptable emission factors include those utilized in the Argonne National Laboratory GREET Model^21, California Air Resources Board modified GREET model (CA-GREET)^32, Ecoinvent database^43, US Federal Life Cycle Inventory database or LCA Commons^54, and similar databases used in common life cycle assessment (LCA (An analysis of the balance of positive and negative emissions associated with a certain process, which includes all of the flows of CO₂ and other GHGs, along with other environmental or social impacts of concern.)) practices or tools (such as OpenLCA, SimaPro, or GaBi (LCA for Experts) ).
EmissionOther emission factors may also be used that do not incorporate the full life cycle emissions associated with power generation if these additional life cycle emissions are accounted for separately. For example, real-time carbon intensity factors5 may also be utilized, provided they are time-aligned with operations and account for CO2, CH4, and N2O. Power generation emission factors based on fuel combustion from sources such as EIA or US EPA (A United States Government agency that protects human health and the environment.) (i.e., AP-42) may also be utilized if the additional upstream and downstream life cycle considerations are addressed. A combination of such emission factor sources may also be used, such as real-time or daily CO2 data plus EPA or EIA CH4 and N2O factors.
Project proponents may estimate the short-run marginal emissions (SRME) rate, [math: EF_G], associated with consumption of grid electricity at a project’s point of interconnection, using hourly SRME data provided by a grid operator, government, or third-party provider, wherever such data is available.
Emission rates must:
If a project is located in a grid region for which no hourly-resolution SRME data is available from any provider, or if the project proponent opts not to use such data, the project proponent should assign a proxy (A measurement which correlates with but is not a direct measurement of the variable of interest.) marginal emission rate to all net electricity consumption from the grid.
Emission rates must not:
For every generating facility, [math: p], the value of [math: G_{p}] (see Section 3.2.3) in a given hour must be equivalent to the average metered A/C power output of the Project in that hour. If the facility is co-located ‘behind-the-meter’ with the Project, the value of [math: m_{p}] should be equal to 1. If the generating facility is not co-located with the Project, the value of [math: m_{p}] should be revised to 0.95, in order to account for transmission losses6.
ThePrimary primary measurementmeasurements considered in calculation of electricity emissions isare:
Measurements must be made using a utility grade power meter, or an independent power meter installed by The Project Proponent,metering with hourly reporting frequencyat ata minimum. PreferenceMeters ismust for meters withhave an accuracy of better than 2% of reading for total electricityenergy consumption, as reported in units of kWhkwh. However,
Any meters with accuracy of worse than 2% of reading for total electricity consumption are acceptable provided that the accuracy of the meter is reported and an appropriate discount is applied to The Project net-CDR calculation. Metersused must be calibrated initially and at regular intervals in accordance with manufacturer specifications to ensure accuracy.
Electricity usage must be monitored for all operations within the gate at each location of their utilization relevant to project operation. The Projectproject Proponentproponent must maintain records of any electricity use for any operation or support system, [math: k], within the gate of a removal, [math: R]'s, process, that consumes electricity. This is in addition to documentation listed in Section 53.2.4.2), if applicable to Thea Projectproject.
If other equipment or processes not related to the removal, [math: R]’s, process are included in meter readings or utility bills, electricity usage may be allocated to such processes based on sub-metering data, equipment maximum electricity consumption ratings and operating hours for each sub-system and percentage of total maximum electricity consumption accounted for by the meter or utility bill, or by other justifiable allocation methods which must be reviewed and accepted during third party verification.
All records of electricity usage, including meter specificationspecifications and calibration records, must be maintained by Thethe Projectproject Proponentproponent for a period of at least five years.
Process emissions may result from combustion of fuels to provide thermal energy to support equipment startup and operations,operation or to supply steam or other thermal energy sources for operations, or to power primary non-road/rail/air/maritime mobile sources. Fuels for the provision of heat to The Project can be supplied from outside sources, or may be produced as a result of activities within The Project gate.
The calculation approach in Equation 7 must be followed for calculation of [math: CO_2e_{Fuel, RP}].
[math: CO_2e_{Fuel,\RPR} =\sum_{k=1}^K{k} m_{fuelFuel,\ k}f_\cdot\ EF_{fuel,kFuel}]
(Equation 75)
Where:
Project ProponentsOperations may consider the use of waste heat to reduce emissions associated with heat provision for a project. Waste heat utilization must meet the criteria described in Section 6.1 to be eligible for discounting against project heat usage.
Project Proponents may consider procurement of Fuel EACs to reduce emissions associated with the use of liquid fuels. Fuel EACs must meet Eligibility Criteria set out in Section 6.2.1 and must follow the calculation procedures outlined in Section 6.2.2.
Project Proponents may consider the use of waste heat topotentially reduce the emissions associated with fuelenergy usage of a projectprocess. WasteA true waste heat sourcessource dodoes not require accounting of GHG emissions associated with the production and delivery of the utilizedwaste thermalheat energyto the project gate. Waste heat utilization must meet the criteria described in TableSection 3.3.1 to be eligibleconsidered for discounting against projectwaste heat usage.
Any activities specifically developed inside Thethe Projectproject gate to handle and utilize the waste heat, however, must be accounted for in the life cycle analysis. These potentially include, but are not limited to:
Equipment and energy usage associated with waste heat utilization must be accounted for in accordance with the requirements of this Modulemodule and the SectionEmbodied 4.1Emissions of the GHG Accounting Module v1.1module.
Refer to SectionEmbodied 4.1 of the GHGEmissions Accounting Module for the calculation guidelines.
Waste heat utilization must meet all of the following criteria in Table 3 to be considered true waste heat, and be exempt from GHG emissions accounting. For projects using heat that do not meet these criteria, emissions associated with the heat production shall be considered in the LCA, including leakage emissions as appropriate.
Table 3: Eligibility Criteria for Waste heat
Eligibility Criteria |
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Under this Module, Projects are permitted to use Fuel EACs for low-carbon liquid fuels to substitute for some, or all, of project fuel usage is permitted. Fuel EACs are an instrument which Project Proponents can purchase to financethrough the use of low-carbonmore fuelsefficient by a third party in situations where the third party would otherwise have used conventional fuel. The net effect of the Fuel EAC purchase attempts to yield the same outcome as if The Project Proponent had used low-carbon fuel within their own supply chain. Fuel EACs can offer additional flexibility to Projects where constraints may limit availability of low-carbon fuels in the region of project operations. In the context of this Module “low-carbon fuels” refers to alternative liquid fuels with a lower carbon intensity than a conventional equivalent, for example biodiesel as a substitute for conventional diesel.
Fuel EACs may only be used to discount Related project emissions. Related emissions are indirect emissions from SSRs (Sources, Sinks and Reservoirs) not controlled by The Project Proponent (typically occurring upstream or downstream of the project site). Fuel EACs transfer the environmental attribute of low-carbon fuel, but do not change the physical fuel combusted as a Controlled emission (i.e., direct emissions equivalent to Scope 1). This restriction preserves quantification integrity and avoids double claiming for organisational claimsequipment (e.g. under ICAO CORSIA5).
Isometric evaluates Fuel EAC programs, registries and methodologies against
high-levelefficiency integrity and issuance and claiming principles that are aligned with ICAO’s CORSIA5 framework. Methodologies and registries that are considered acceptable under this Module are those that meet CORSIA-aligned requirements. Best practices for Fuel EACs are still evolving and therefore Isometric will continue to engage with stakeholders and the scientific community to assess the rigor and operability of Fuel EAC Eligibility Criteria and accounting approaches.
EACs used to substitute for project fuel usage must meet all of the eligibility criteria in Table 4.
Table 4: Fuel EAC Eligibility Criteria
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When using EACs to substitute for some, or all, of project fuel usage, the calculation approach described in the following subsections must be followed for the calculation of [math: F_{Fuel}] emissions.
Projects that intend to use EACs for transportation fuel usage and are applying the energy based emission quantification method as in Section 4.2.1 of the GHG Accounting Module) should follow the calculation approach described in Section 6.2.2.1 when using EACs.
Project that intend to use EACs for transportation fuel usage and are applying the distance-based emissions quantification method as in Section 4.2.2 of the GHG Accounting Module should follow the calculation approach described in Section 6.2.2.2 when using EACs.
When using EACs to substitute for some, or all, of project fuel usage and calculating transportation emissions using the energy usage method, [math: CO_2e_{Fuel}], must be calculated in accordance with Equation 8.
[math: CO_2e_{Fuel,RP} = \sum_j \left[ f_{Fuel} \times \left( m_{j} - m_{EAC,RP} \frac{ED_{EAC,RP}}{ED_{Fuel,RP}} \right) + \left( f_{EAC,RP} \times m_{EAC,RP} \right) \right]]
(Equation 8)
Where:
Note, in Equation 8, the term [math: CO_2e_{Fuel}] is analogous to the term [math: CO_2e_{Transportation}] when quantifying transportation emissions using the energy based emission quantification method as in Section 4.2.1 of the GHG Accounting Module.
When applying Equation 8, at maximum, an amount of EACs may be used for a Reporting Period, RP, such that:
[math: \left( m_{j} - m_{EAC,RP} \frac{ED_{EAC,RP}}{ED_{Fuel,RP}} \right) \geq 0]
(Equation 9)
Transportation emissions may be calculated using the Distance-Based Method, as set out in Section 4.2.2 of the GHG Accounting Module. When using EACs to substitute for some, or all, of transportation fuel usage and calculating transportation emissions using the distance-based method, the amount of fuel required for each transportation journey, j, must be calculated as:
[math: m_{j} = D_{j} \times W_{j} \times \frac{f_{Transportation,j}}{f_{Fuel,Transportation,j}}]
(Equation 10)
[math: f_{fuel,k}] - emissionsEmission factors used must:
Acceptable emission factors include those utilized in the Argonne National Laboratory GREET Model^21, California Air Resources Board modified GREET model (CA-GREET)^32, Ecoinvent database^43, US Federal Life Cycle Inventory database or LCA Commons^54, and similar databases used in common LCA practices or tools (such as OpenLCA, SimaPro, or GaBi (LCA for Experts) ).
Other emission factors may also be used that do not incorporate the full life cycle emissions associated with fuel combustion if the additional life cycle emissions are accounted for separately. For example, data sources such as the US EPA - Direct Emissions from Stationary Combustion67, US EPA AP-4278, or US EPA MOVES Model89 (mobile sources) may be utilized as long as additional factors for full life cycle emissions are included in analyses.
Note that heat supply to projects from sources other than fuel combustion is allowable under this Module (e.g. geothermal steam). In these cases, bespoke emissions factors are likely necessary on a case-by-case basis, as emissions from such sources can vary significantly by site. Therefore, the exact emissions allocation procedure will be reviewed and agreed by Isometric at the point of project verification.
ThePrimary primary measurementmeasurements considered in calculation of fuel emissions isare:
Fuel usage must be monitored for all operations within the gate at each location of their utilization relevant to project operation. The Projectproject Proponentproponent must maintain records of any fuel use for any operation or support system, [math: k], within the gate of a removal [math: R]'s process, that consumes fuel.
If other equipment or processes not related to the removal [math: R]'s process are included in meter readings or utility bills, fuel usage may be allocated to such processes based on sub-metering data, equipment maximum fuel consumption ratings and operating hours for each sub-system and percentage of total maximum fuel consumption accounted for by the meter or utility bill, or by other justifiable allocation methods which must be reviewed and accepted during third party verification.
MetersAny meters used must be calibrated initially and at regular intervals in accordance with manufacturer specifications to ensure accuracy. All records of fuel usage, including meter specificationspecifications and calibration records, must be maintained by Thethe Projectproject Proponentproponent for a period of at least five years.
Isometric would like to thank following contributors to this Modulemodule:
Isometric would like to thank following reviewers of this module:
This appendix is a companionconditions to the Energy Use Accounting Module, providing supporting information regarding the rationale and factors considered when determining the requirements of the Module. This appendix should be read in conjunction with the Module and is provided as guidance. Should there be any discrepancy or inconsistency between this appendix and the Module itself, the requirements of the Module will prevail.
The emissions accounting approach adopted in this Module for electricity consumption from the grid requires the use of grid-average emissions factors. An alternative approach supported by some published studies relies on the use of marginal emissions factors when accounting for emissions from electricity consumption from the grid.
Marginal emission factors represent the change in emissions resulting from a marginal change in electricity demand or supply on the grid. Marginal emission factors vary by time horizon and scope and include Short-run marginal emissions (SRME) factors and Long-run marginal emission (LRME). Isometric acknowledges that marginal emission factors are the most conceptually aligned approach with a consequential emissions accounting framework for CDR projects; however, the implementation of marginal emission factors (SRME, LRME, or both) has not reached a consensus in CDR project accounting.
Brander et al. (2025)9 caution that SRME factors, which are the most commonly available marginal metrics, should not be used as a proxyreference scenario for comparison.
The accounting approach outlined in Section 3.2.3 implicitly assumes that all non-differentiated grid electricity generated to supply a Project’s needs comes from existing marginal generators, which in today’s electricity systems are generally fossil-fired. This method on its own is likely to overestimate the long-run marginal emissions impact of a plant’s electricity consumption, as it is possible if not likely that new low-carbon generators would eventually be deployed to meet some portion of this demand.
Because the consequential impact of a Project's electricity consumption on decisions to deploy new low-carbon generators cannot be observed empirically, the approach endorsed in Section 3.2.4 requires that a Project procure power directly from new low-carbon generators in order to be credited with consumption of their electricity. It further requires procured electricity to be generated in the same hourly period for which it is claimed, and to be physically deliverable to the Project during this period. These conditions align the electricity market and emissions impacts of both grid-based generators and those that are co-located with the Project.
While recent research has demonstrated that procurement of carbon-free electricity subject to these constraints can typically mitigate the consequential emissions impact of a Project’s electricity consumption during the hours for which such claims are made, there are still conditions under which this mitigation can be imperfect 1011. If low-carbon energy deployment is constrained temporarily by manufacturing, permitting, or installation bottlenecks, or permanently by geographic limitations, there can be carbon opportunity costs associated with the procurement of these resources to serve new electricity demand rather than to displace existing fossil-fired electricity generation. While this module establishes guardrails intended to mitigate such outcomes, it should be acknowledged that these carbon opportunity costs are fundamentally unobservable and cannot be eliminated with certainty. Project developers should take steps to qualitatively assess current and potential future bottlenecks to clean electricity development in their target markets, and should aim to deploy projects in locations where such constraints are minimized.
Binding government-imposed caps on GHG emissions prevent individual electricity consumers from driving system-level changes in emissions, and thereby obviate the need for project-level accounting of consequential emission impacts.
In a jurisdiction subject to a robust GHG cap-and-trade policy that is not oversupplied with emissions allowances, any increases in emissions causedfrom a project’s electricity consumption are required to be offset by decisionsreductions that(Lowering affectfuture longer-termGHG generationreleases capacityfrom a specific entity.) in emissions elsewhere in the economy. As CDR projects typically involve long-term infrastructure investment and capacity implicationsTherefore, the applicationconsequential emissions impact of SRMEa project’s electricity consumption should be assumed to be 0, if the project is located in an approved jurisdiction with a GHG cap-and-trade policy recognized under this Protocol as sufficiently robust.
Factors that characterize a robust cap-and-trade policy include:
The status quo at a policy level remains grid average emission factors; for example,Currently the EU CRCFEmissions delegatedTrading act methodologies for permanent carbon removals reference Delegated Regulation (EU) 2023/11853Scheme, under which the most broadly accessible default is a country or bidding-zone-level average emission factor. Furthermore, data availability for marginal emission factors is limited at a global scale, particularly for LRME factors, where dedicated public data sources are currently available only for limited geographies.
Isometric will continue to monitor developments incovers the scientific27 literature,EU member nations as well as dataIceland, availability in the energy marketNorway, and willLiechtenstein, makeis futurethe amendmentsonly tocap-and-trade jurisdiction approved as sufficiently rigorous under this Module as neededProtocol.
The EnergyTag Granular Certificate Scheme Standard (Version 2)2, published March 2024, establishes guidence ("Configuration 3"), which can be operationalized in the absence of the availability of documentation proving the procurement of low-carbon power for provision to The Project time stamped with an hourly granularity, which can emulate the same outcomes as hourly time matching under limited circumstances.
The basis of this approach is that where the EACs produced by a generator are not explicitly time stamped with hourly granularity, generation side metering of electricity production with hourly measurement frequency can be used to map a time stamp onto the EACs purchased from that generator. Under this approach, EACs produced by the generator are allocated time stamps corresponding to particular hours in proportion to the observed generating output from the generator in each hour of interest.
We note that the currently published guidence by EnergyTag in Version 2 of the Granular Certificate Scheme Standard does not provide protections against duplicate claims to generation at a partricular time under contractual purchasing structures where two (or more) buyers receive EACs generated by a single generator. Therefore, at this time, operationalization of Configuration 3 for emulation of hourly time matching will only be permitted under the Module in circumstances where The Project Proponent is the sole buyer of EACs produced by a generator.
EcoInvent. (2013). Overview and methodology Data quality guideline for the ecoinvent database version 3. https://ecoinvent.org/wp-content/uploads/2020/10/dataqualityguideline_ecoinvent_3_20130506_.pdf
Intergovernmental Panel on Climate Change (IPCC). (2023). IPCC Sixth Assessment Report. https://www.ipcc.ch/assessment-report/ar6/
International Organization for Standardization. (2006). ISO 14040:2006 Environmental management — Life cycle assessment — Principles and framework. https://www.iso.org/standard/37456.html
International Organization for Standardization. (2006). ISO 14044:2006 Environmental management — Life cycle assessment — Requirements and guidelines. https://www.iso.org/standard/38498.html
International Organization for Standardization. (2008). Evaluation of measurement data — Guide to the expression of uncertainty in measurement (ISO JGCM GUM). https://www.iso.org/sites/JCGM/GUM/JCGM100/C045315e-html/C045315e.html?csnumber=50461
International Organization for Standardization. (2011). ISO 14066:2011 Greenhouse gases — Competence requirements for greenhouse gas vion teams and verification teams. https://www.iso.org/standard/43277.html
International Organization for Standardization. (2017). ISO 21930:2017 Sustainability in buildings and civil engineering works — Core rules for environmental product declarations of construction products and services. https://www.iso.org/standard/61694.html
International Organization for Standardization. (2017). ISO/IEC 17025:2017 General requirements for the competence of testing and calibration laboratories. https://www.iso.org/standard/66912.html
International Organization for Standardization. (2019). ISO 14064-2:2019. Greenhouse Gases - Part 2: Specification With Guidance At The Project Level For Quantification, Monitoring And Reporting Of Greenhouse Gas Emission Reductions Or Removal Enhancements. ISO. https://www.iso.org/standard/66454.html
International Organization for Standardization. (2019). ISO 14064-3:2019. Greenhouse gases — Part 3: Specification with guidance for the verification and validation of greenhouse gas statements. ISO. https://www.iso.org/standard/66455.html
Isometric. (n.d.). Isometric — Glossary: Defining the terms that appear regularly in our work. Isometric. https://isometric.com/glossary
Matthews, J.B.R. (Ed.). (2018). IPCC, 2018: Annex I: Glossary [Matthews, J.B.R. (ed.)]. In: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of... Cambridge University Press. https://doi.org/10.1017/9781009157940.008
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