Energy Use Accounting v1.3

1.0

Introduction

This Module describes how to calculate emissions related to energy use for Carbon Dioxide Removal (CDR) projects as part of project greenhouse gas (GHG) accounting. This Module applies to all CDR pathways, ensuring a consistently rigorous standard in how energy-related emissions are quantified and reported between different projects and approaches.

2.0

Future versions

This Module was developed based on the current state of the art, 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 increases, for example regarding emission factors 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 and the scientific community to assess the rigor and operability of accounting approaches, including hourly temporal matching and emissions matching. Any future changes to the approach outlined in this Module will be conducted in consultation with a range of ecosystem participants 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 requirements, and will introduce more robust approaches as soon as they are supported by the evolving science and demonstrably operable under prevailing market conditions.

3.0

System boundaries

The emissions associated with energy use must account for all operations that consume electricity and fuel as part of CDR project processes. Emissions associated with Energy Use are denoted $CO_2e_{Energy, RP}$ .

Sources included in this Module’s scope are:

Non-mobile machinery;
Primary non-road/rail/air/maritime mobile sources, such as fork trucks and loaders used for material handling, and small personal transport modes used to move staff around project sites; and
Fuels combusted to provide heat, steam, startup energy, or to power eligible mobile sources.

Refer to the GHG Accounting Module v1.0 for the calculation guidelines for transportation (including road, rail, air and maritime mobile emission sources) and embodied emissions accounting (including the production of products/ feedstocks).

Refer to the GHG Accounting Module for calculation guidelines.

4.0

Calculation of CO|2|e|Energy,RP

Calculation of CO₂e_Energy,RP

Emissions associated with energy usage include the use of both electricity and fuel. The following calculation approach must be followed for the calculation of $CO_2e_{Energy,RP}$ :

 $CO_2e_{Energy,RP} = CO_2e_{Electricity,RP} + CO_2e_{Fuel,RP}$

(Equation 1)

Where:

$CO_2e_{Energy,RP}$ : the total GHG emissions associated with energy consumption for a Reporting Period, $RP$ , in tonnes of CO₂ equivalent (CO₂e).
$CO_2e_{Electricity,RP}$ : the total GHG emissions associated with electricity usage for a Reporting Period, $RP$ , in tonnes of CO₂e.
$CO_2e_{Fuel,RP}$ : the total GHG emissions associated with fuel usage for a Reporting Period, $RP$ , in tonnes of CO₂e.

$CO_2e_{Electricity,RP}$ and $CO_2e_{Fuel,RP}$ 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.

5.0

Calculation of CO|2|e|Electricity, RP

Calculation of CO₂e_{Electricity, RP}

This Module provides accounting requirements for the following types of electricity:

Behind-the-meter provision: Projects may establish generation “behind-the-meter”. Project Proponents must follow the quantification requirements in Section 5.1.
Grid-based electricity: electricity which is obtained from the electricity grid to which The Project is connected. Projects must follow the quantification requirements in Section 5.2.
Electricity Environmental Attribute Certificates (EACs): electricity procured by contract purchase from renewable power sources for the exclusive use of the Project. The Project Proponent must must meet Eligibility Criteria in Section 5.4.2 and follow calculation requirements in Section 5.4.3. This Module distinguishes between intensive and non-intensive facilities to align accounting requirements for projects using Electricity EACs with the scale of electricity use (See Section 5.4).

5.1

Calculation of CO|2|e|Electricity, RP| with behind-the-meter electricity provision

Calculation of CO₂e_{Electricity, RP} with behind-the-meter electricity provision

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. 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 $f_p$ in Section 5.5 and proportionally allocated to the Project.

Projects utilizing electricity from generators that meet both of the following criteria must also account for Energy Leakage:

Generator was in operation for more than 36 months before The Project was initiated; and
The generator supplies electricity to the local electricity grid.

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 ( $f_{grid}$ ).

Project electricity demand may be supplied entirely by behind-the-meter generation or partially supplied. The accounting requirements for each are set out below:

Full Supply: No additional electricity emissions accounting is required beyond the life cycle emissions of the generator and Energy Leakage (if applicable) described above.
Partial Supply: When demand is partially supplied, the remaining electricity requirement must be quantified in accordance with Section 5.3 and Section 5.4. For the purpose of these calculations, the facility’s net grid import is equal to the total electricity demand minus the behind-the-meter generation supplied to the Project.

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.

5.2

Calculation of CO|2|e|Electricity, RP| with grid-based electricity provision

Calculation of CO₂e_{Electricity, RP} with grid-based electricity provision

Equation 2 must be followed for emissions associated with provision of electricity from the grid.

 $CO_2e_{Electricity,\ RP} = f_{grid} \sum_{i=1}^{N}E_i$

(Equation 2)

Where:

$CO_2e_{Electricity,RP}$ : the total GHG emissions associated with electricity usage for a Reporting Period, $RP$ , in tonnes of CO₂e.
$f_{grid}$ : grid average emissions factor, in tonnes of CO₂e/kWh. Details of requirements for acceptable emissions factors can be found in Section 5.5.
$E_i$ : electricity usage in hour $i$ , in kWh.
$N$ : total number of calendar hours for Reporting Period, $RP$ .

Projects may reduce electricity emissions through procurement of low-carbon power (See Section 5.4).

5.3

Calculation of CO|2|e|Electricity, RP| with Electricity Environmental Attribute Certificate procurement

Calculation of CO₂e_{Electricity, RP} with Electricity Environmental Attribute Certificate procurement

A Project may wish to reduce its energy emissions through the procurement of Electricity EACs, where electricity which 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 $f_p$ set out in Section 5.5. Furthermore, Eligibility Criteria in Table 1 must be complied with.

5.4

Definition of non-intensive and intensive facilities

Intensive facilities are defined as those which consume more than 200 GWh of electricity per year (See Section 5.1.1).

Intensive and non-intensive facilities are subject to different electricity emission accounting rule when procuring Electricity EACs:

Non-intensive facilities should follow the non-intensive Eligibility Criteria in Section 5.4.2 and the calculation approach in Section 5.4.2.1.
Intensive facilities should follow the intensive Eligibility Criteria in Section 5.4.2 and the calculation approach in Section 5.4.2.2.

In exceptional circumstances, projects with intensive facilities may apply for temporary exemptions from certain requirements (e.g., where required procurement structures are not feasible). In these instances, projects must demonstrate a reasonable effort to comply with the relevant requirements. Reasonable effort will be assessed based on the intent of the requirements set out in Section 5.4.2. Temporary exemptions are provided at the discretion of Isometric and are considered on a case-by-case basis. Temporary exemptions are valid for one year and may be applied for annually for a maximum of five years. Following this period, Projects must meet the intensive facility requirements against which they were validated, or subsequent updates to the same requirements.

5.4.1

200 GWh threshold

An intensive facility is defined as a facility which consumes more than 200 GWh of electricity per year.

To provide operational flexibility, a 25% buffer on the 200GWh threshold is applied. A facility validated as non-intensive will enter a ‘monitored state’ if its annual electricity consumption over one calendar year is 200-250 GWh. Upon entering the monitored state, Isometric will issue a formal notice to the Project Proponent describing the potential reclassification and the need to prepare to comply with the intensive facility rules.

A facility in the monitored state will be reclassified as an intensive facility if its annual electricity consumption remains between 200 GWh and 250 GWh for three consecutive calendar years. This grace period is intended to allow sufficient time for operators to secure a PPA or make other necessary operational adjustments. Once a facility is reclassified as intensive, it must comply with all accounting rules for intensive facilities in all subsequent reporting periods.

If a facility's electricity consumption exceeds 250 GWh over the course of one calendar year, it will be reclassified as an intensive facility starting the following calendar year.

5.4.2

Eligibility criteria for Electricity Environmental Attribute Certificates

Electricity EACs must meet all Eligibility Criteria EC1-EC5 in Table 1.

Table 1: Eligibility Criteria for Electrcity EACs

Criteria	Description	Documentation required (non-intensive facilities)	Documentation required (intensive facilities)
EC1	Contract Purchase The electricity utilized is obtained via contract purchase. It should be noted that "sleeved" contract purchases, where a third party (such as a utility provider) procures low-carbon electricity supply on behalf of the Project Proponent, is allowable provided that all EACs for verification are under sole ownership of the Project Proponent at the point of verification.	Documentation of EAC purchase, including copy of contract and EAC retirement certificates.	Copy of Power Purchase Agreement (PPA), or other direct long-term offtake agreement, which identifies: Physical source and type of electricity generation; Location and grid region of generating facility; Date of commissioning of electricity source; and Date of PPA or offtake agreement.
EC2	Exclusive Issuance The Project must obtain and retire all EACs tied to the electricity it is claiming, and provide adequate evidence that this has been done—except where some of those EACs must be transferred to the project’s load-serving entity (LSE) to comply with a jurisdictional clean electricity standard (CES) or similar government policy. If a CES (or similar policy) requires the LSE to retire EACs for a specified share of the Project’s total electricity use, the Project may transfer that required amount of EACs to the LSE and still count the associated electricity as qualifying under this Module. However, the transferred amount must not exceed the increase in the LSE’s legally required EAC retirements that is attributable to the Project’s electricity consumption.	Documentation of EAC retirement certificates. Documentation must also be provided of any relevant CES requirements and applicability to the project energy usage.	Documentation of EAC retirement certificates. Documentation must also be provided of any relevant CES requirements and applicability to the project energy usage.
EC3	Additional The generating facility from which the claimed electricity is sourced entered service no more than 36 months before The Project was initiated. Note that the expansion of existing assets to increase power generation capacity (e.g. "repower" projects), where the expansion occurred no more than 36 months before The project entered service, is eligible as qualified power under this Module. In this case, only capacity at the contracted generating site which entered service no more than 36 months before The Project is eligible, with older existing capacity being ineligible. The use of existing assets which entered service more than 36 months before The Project are permitted in cases where the asset is considered "stranded" and would otherwise be entirely or partially non-operational in the absence of contract purchase by The Project.	Evidence that the generating facilities identified in the EACs entered service no more than 36 months before The Project was initiated.	One of the following: Provide a PPA associated with “existing assets”, and evidence that the generating facilities identified in the PPA entered service no more than 36 months before The Project was initiated; or Provide a PPA associated with "existing assets" and evidence that the generating facilities identified in the PPA would otherwise be entirely or partially non-operational in the absence of contract purchase by The Project. In this case, the volume of power procured by The Project from such generators may not exceed the volume by which the generating assets were under-utilized in the absence of contract purchase by The Project; or Provide a PPA associated with “new-to-earth” assets.
EC4	Physically Deliverable The electricity must be physically deliverable to The Project. Electricity is considered to be physically deliverable to The Project if either of the following conditions are met: The Project is directly connected to the generating facility; or Both The Project and the generating facility are located within the same grid region. See Section 5.3.1 for acceptable grid region definitions.	Provide the location of the generating facilities identified in the submitted RECs/EACs, and documentation from government or grid operators to justify that the generators are located within the same grid region as The Project.	One of the following: Provide an indirect PPA, specifying the location of the generating facilities identified in the submitted PPA, and documentation from government or grid operators to justify that the generators are located within the same grid region as The Project; or Provide a direct PPA.
EC5	Temporal Matching If the facility is classified as a non-intensive facility (see Section 5.1), the electricity must be generated no more than 12 months prior to the point of consumption by The Project. If The Project is classified as an intensive facility (see Section 5.1), wherever possible, the electricity must be generated in the same hour for which it is claimed. Under specific conditions it will be permitted for projects classified as an intensive facility to use electricity which was generated no more than 12 months prior to the point of consumption by The Project. In cases where documented market constraints are in place, non-intensive facilities may use electricity which was generated no more than 18 months prior to the point of consumption by The Project.	Provide documentation of power procurement proving that generation of the claimed electricity occurred no more than 12 months prior to the point of consumption by The Project. Where documented regional market constraints prevent a non-intensive facility from meeting the 12-month requirement, the following is permitted: The REC vintage is no more than 18 months prior to the point of consumption; and The Project Proponent provides sufficient evidence at verification demonstrating that compliance with the 12-month requirement was not feasible as a result of market constraints.	One of the following: Provide documentation of power procurement featuring timestamps with hourly granularity; or Provide all of the following (See Section 5.4.2.2.1 for further details): Documentation of power procurement proving that generation of the claimed electricity ocurred no more than 12 months prior to the point of consumption by The Project; Evidence that project reached Final Investment Decision (FID) before the year 2030; Evidence that The Project is demonstration scale, defined here as gross annual removals by The Project of less than 100,000 tonnes CO₂/year. Projects larger than demonstration scale must undertake an emission screen (See Section 5.4.2.2.2); and Evidence that reasonable best efforts have been made to obtain documentation featuring hourly time stamps and demonstration of either technical or economic infeasibility.

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.

5.4.2.1

Definition of grid regions

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 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 will retain this certification for the duration of the project lifetime, regardless of future updates to this Module.

5.4.3

Calculation Approach

Projects that procure Electricity EACs to reduce their energy emissions should follow the calculation approach for $CO_2e_{Electricity,RP}$ 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.

5.4.3.1

Non-intensive facilities

The following calculation approach must be used for non-intensive facilities:

 $CO_2e_{Electricity, RP} = f_{grid} \left[ \left( \sum_{i=1}^{N}E_i \right) - \left( \sum_p G_p \right) \right] + \sum_p f_p G_p$

(Equation 3)

Where:

$CO_2e_{Electricity,RP}$ : the total GHG emissions associated with electricity usage for a Reporting Period, $RP$ , in tonnes of CO₂e.
$f_{grid}$ : grid average emissions factor, in tonnes of CO₂e/kWh. Details of requirements for acceptable emissions factors can be found in Section 5.5.
$E_i$ : electricity usage in hour $i$ , in kWh.
$N$ : total number of calendar hours for Reporting Period, $RP$ .
$G_p$ : total amount of energy procured for Reporting Period $RP$ by generator type $p$ , in kWh. Note that in the calculation outlined above, the amount of procured electricity may not exceed the amount of electricity consumption by The Project for the Reporting Period, $RP$ .
$f_p$ : emissions factor for generation by generator type $p$ , in tonnes of CO₂e/kWh.

For non-intensive facilities, documentation proving the direct procurement of low-carbon power should be time-stamped within 12 months prior to 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. In such instances, Projects must follow the calculation details in Equation 4. It is not permissable for projects to combine Electrcity EACs featuring timestamps with hourly granularity and annual granularity within the same reporting period.

5.4.3.2

Intensive facilities

The following calculation approach must be used for intensive facilities:

 $CO_2e_{Electricity, RP} = f_{grid} \sum_{i=1}^N \left( E_i - \sum_p G_{p,i} \right) + \sum_p \left( f_p \sum_{i=1}^N G_{p,i} \right)$

(Equation 4)

Where:

$CO_2e_{Electricity,RP}$ : the total GHG emissions associated with electricity usage for a Reporting Period, $RP$ , in tonnes of CO₂e.
$f_{grid}$ : grid average emissions factor, in tonnes of CO₂e/kWh. Details of requirements for acceptable emissions factors can be found in Section 5.5.
$E_i$ : electricity usage in hour $i$ , in kWh.
$N$ : total number of calendar hours for Reporting Period, $RP$ .
$G_{p,i}$ : amount of energy procured in hour $i$ by generator type $p$ , in kWh. Note that in the calculation outlined above, the amount of procured energy in hour $i$ may not exceed the amount of electricity consumption by The Project in hour $i$ .
$f_p$ : emissions factor for generation by generator type $p$ , in tonnes of CO₂e/kWh.

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 2.

5.4.3.2.1

Exemptions to EC4: Hourly matching

Under some operational circumstances, it may not be technically or economically feasible to obtain documentation proving the direct procurement of 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 that all of the following conditions are met:

Project Final Investment Decision (FID) is reached before the year 2030;
The Project is at the demonstration scale, defined here as an annual gross removal rate of less than 100,000 tCO₂/yr. Note that subdivision of projects into several smaller projects is explicitly prohibited, and compliance with this requirement will be verified on a case-by-case basis at the point of project verification. If the Project is larger than demonstration scale, they must demonstrate that they have undertaken an emission screen test (See Section 5.4.3.2.2); and
Reasonable best efforts have been made to obtain documentation featuring hourly time stamps. This must be evidenced by the provision of the folowing at Project Validation. Project must demonstrate either technical or economic infeasibility:
- Technical infeasibility: Project Proponents may claim technical infeasibility only if they show no hourly-matched supply is available in the relevant grid region. Projects must provide the following:
  - i) Project Proponents must submit evidence of outreach to a comprehensive list of potential suppliers in that region. Evidence of outreach must demonstrate that a Request for Information/Proposal (RFI/RFP) for hourly-matched supply was circulated to (a) all licensed utilities/retail suppliers from the relevant regulator’s register; and (b) any independent generators/aggregators with ≥10 MW operating contracted listed on the relevant regulator’s register. The RFI or RFP must specify at minimum: delivery region, start date/ term and volume/ profile requirements. Outreach may also be completed by market intermediaries, provided that the scope of market intermediaries outreach is in line with the above.
  - ii) Project Proponents must submit a copy of the RFI/RFP, the distribution list (including the scope of reach if using a market intermediary), timestamps for circulation, a register summarising all responses and a statement of the outcome.
  - iii) A claim of infeasibility is supported only if no conforming offers are received.
- Economic infeasibility: Project Proponents may claim economic infeasibility only if they show that hourly-matched supply is available in the relevant grid region, but is priced disproportionately high. “Disproportionately high” means the lowest normalized all-in price for an hourly-matched, bundled renewable PPA (conveying environmental attributes) is ≥20% above the lowest normalized all-in price for an annual-matched, bundled renewable PPA for the same procurement. Projects must provide the following:
  - i) Project Proponents must follow i) and ii) in the section above.
  - ii) In addition, Project Proponents must provide a normalization workbook showing calculations of normalized all-in price for each offer received. This must demonstrate that the lowest normalized hourly-matched price is ≥20% above the lowest normalized annual-matched price.

It should be noted that all energy intensive projects must procure low-carbon power according to an hourly matching scheme (i.e. Equation 4) whenever possible, as this represents the most credible approach towards accurate characterization of the emissions associated with the provision of electricity to CDR projects. Isometric anticipates that by approximately the year 2030, contracting structures featuring hourly time stamps to facilitate hourly matching of low-carbon power procurement to project electricity demand will be widely available as a consequence of incoming regulations in various jurisdictions (e.g. the US DOE 45V tax credit for the production of low-carbon hydrogen, EU CRCF, etc.). At such a time that contracts featuring hourly time stamps are widely available in the energy market, the exception for energy intensive facilities described above will be revoked and compliance with the hourly matching scheme will be mandatory for all projects relying on an intensive facility. Isometric anticipates that this provision will expire in approximately the year 2030, however, this date will remain under constant review. It should be noted that projects which commence operations using the exception described above will be permitted to utilize the exception 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 provision has been revoked from this Module, then compliance with the hourly matching scheme described above will be mandatory.

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.

5.4.3.2.2

Intensive facilities larger than demonstration scale

Projects with an annual gross removal rate of more than 100,000 tonnes CO₂/yr may also utilize the provision outlined above, following the calculation approach described in Section 5.4.3.1 (Equation 3). However, use of this provision by projects with a gross removal rate of more than 100,000 tCO₂/yr is further subject to an additional safeguard in the form of an emissions screen.

The objective of the emissions screen is to ensure that the Project's procurement of renewable electricity neutralizes the emissions impact it would have otherwise had on the local electricity grid. The emissions screen is passed if the total avoided emissions attributed to the procured renewable energy are greater than or equal to the emissions that would have resulted from consuming an equivalent amount of electricity from the grid.

Projects utilizing the emissions screen must demonstrate that the criteria in Equation 5 is satisfied by power procurement activities.

 $\left( f_{grid} \sum_{i=1}^{N} E_i \right) - \left( \sum_p (f_{grid} - f_p)G_p \right) \leq 0$

(Equation 5)

$f_{grid}$ : grid average emissions factor, in tonnes of CO₂e/kWh. Details of requirements for acceptable emissions factors can be found in Section 5.5.
$E_i$ : electricity usage in hour $i$ , in kWh.
$N$ : total number of calendar hours for Reporting Period, $RP$ . Note that in some cases, satisfying this criteria may require that a larger amount of RECs/EACs are retired than the amount claimed for discounting project energy usage according to Equation 3.
$f_p$ : emissions factor for generation by generator type $p$ , in tonnes of CO₂e/kWh.
$G_p$ : total amount of energy procured for Reporting Period $RP$ by generator type $p$ , in kWh.

In some scenarios, compliance with the emissions screen may require that the project procures and retires a volume of qualified electricity that exceeds the project’s electricity consumption for the reporting period. The volume of qualified energy that is procured that exceeds the project’s electricity consumption is defined as the overprocured volume. The overprocured volume must comply with eligibility requirements for non-intensive facilities. Required overprocurement is capped such that total energy procurement costs do not increase by more than 20% above the Project’s baseline energy procurement cost for the reporting period.

5.5

Acceptable emissions factors - CO|2|e|Electricity, RP

Acceptable emissions factors - CO₂e_{Electricity, RP}

$f_{grid}$ - emissions factors used must:

Be technology-specific to the mix of electricity generation methods in the connected electric grid;
Wherever available, represent hourly average emission factors when used in: Equation 2; and Equation 3 and 4 if low-carbon power features hourly time stamps.
Wherever available, be reported on a residual-mix basis, meaning that any generators within a grid region which are subject to contract purchase (e.g. through RECs/PPAs) are excluded from the average emissions calculation. Project Proponents must declare whether such data is available in the region of operation, and utilize such data wherever possible. Where residual mix factors are not available, national grid average factors are considered acceptable.
Be reported on a consumption basis, meaning that all net physical energy imports/exports across the grid boundary should be reflected;
Account for the full life cycle emissions associated with electricity generation, including direct emissions from power generation, transmission and distribution losses, and upstream life cycle emissions associated with extraction, refining and transportation of primary fuels (i.e. from cradle-to-gate);
Be for the specific region (nation, state, locality) where the electricity consumption is occurring, with the most granular or site-specific data source preferred;
Be for the most recent published year. Wherever possible, the utilized emissions factors must correspond to those most recently published by the relevant authority in the region of project operations; and
Account for total GHG emissions as CO₂e. Separate emissions factors for each GHG may be utilized, and the calculated emissions should be converted to CO₂e using the 100-yr Global Warming Potential (GWP) for the relevant GHG, based on the most recent volume of the IPCC Assessment Report (presently the Sixth Assessment Report).

$f_p$ - emissions factors used must:

Be technology-specific to the method of electricity generation;
Account for all embodied emissions associated with the establishment of procured generators by amortizing on a per unit electricity generation basis. If embodied emissions are not included within the used emissions factor, then they must be calculated separately and allocated to The Project on a proportional basis relative to the usage of the generating asset over its anticipated lifetime and generation capacity;
Account for the full life cycle emissions associated with electricity generation and include direct emissions from power generation (i.e. fuel combustion), upstream emissions associated with fuel production, equipment manufacture, and equipment decommissioning and disposal at a minimum;
Account for any necessary derating factors associated with energy loss during transmission between the generating facility and The Project. Where derating factors are not applied in the utilized emissions factors, the Project Proponent must additionally account for these. For example, derating factors for transmission losses may be estimated using the approach of Sadovskaia et al. (2019)³, or any other suitably justified method; and
Account for total GHG emissions as CO₂e. Separate emissions factors for each GHG may be utilized, and the calculated emissions should be converted to CO₂e using the 100-yr Global Warming Potential (GWP) for the relevant GHG, based on the most recent volume of the IPCC Assessment Report (presently the Sixth Assessment Report).

Regional or subnational location-based grid average emissions factors must be used where available for the calculation of $f_{grid}$ . 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 cycle emission factors include those utilized in the Argonne National Laboratory GREET Model⁴, California Air Resources Board modified GREET model (CA-GREET)⁵, Ecoinvent database⁶, US Federal Life Cycle Inventory database or LCA Commons⁷, and similar databases used in common life cycle assessment (LCA) practices or tools (such as OpenLCA, SimaPro, or GaBi).

Emission factors may 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. Power generation emission factors based on fuel combustion from sources such as EIA or US EPA (i.e., AP-42) may also be utilized if the additional upstream and downstream life cycle considerations are addressed.

5.6

Measurements - CO|2|e|Electricity, RP

Measurements - CO₂e_{Electricity, RP}

The primary measurement considered in calculation of electricity emissions is:

$E_i$ : total amount of electricity used by The Project in hour $i$ .

Measurements must be made using a utility grade power meter, or an independent power meter installed by the Project Proponent, with hourly reporting frequency at minimum. Preference is for meters with an accuracy of better than 2% of reading for total electricity consumption, as reported in units of kWh. However, 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. Meters must be calibrated initially and at regular intervals in accordance with manufacturer specifications to ensure accuracy.

5.7

Required records and documentation - CO|2|e|Electricity, RP

Required records and documentation - CO₂e_{Electricity, RP}

Electricity usage must be monitored for all operations within the gate at each location of utilization relevant to project operation. The Project Proponent must maintain records of any electricity use for any operation or support system within the gate of a removal that consumes electricity. This is in addition to documentation listed in Section 5.4.2), if applicable to The Project.

Allowable electricity records include, but are not limited to:

On-site electricity meter readings (i.e. utility electric meter), whether owned by the site owner or by the electric utility, either electronic or manually logged; or
Independent power meter readings for metering equipment installed by the Project Proponent to measure power consumption of the process.

If other equipment or processes not related to the removal 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, or by other justifiable allocation methods which must be reviewed and accepted during third party verification.

All records of electricity usage, including meter specification and calibration records, must be maintained by the Project Proponent for a period of at least five years.

6.0

Calculation of CO|2|e|Fuel, RP

Calculation of CO₂e_{Fuel, RP}

Process emissions may result from combustion of fuels to provide thermal energy to support equipment startup and operations, 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 6 must be followed for calculation of $CO_2e_{Fuel, RP}$ .

 $CO_2e_{Fuel, RP} = \sum_{k=1}^K m_{fuel,k}f_{fuel,k}$

(Equation 6)

Where:

$CO_2e_{Fuel, RP}$ : total GHG emissions resulting from fuel combustion for a Reporting Period, $RP$ , in tonnes of CO₂e.
$m_{fuel,k}$ : total mass, volume, or heating value of fuel $k$ used for a Reporting Period, $RP$ in appropriate units e.g. kg, gal, ft³, therms etc.
$f_{fuel,k}$ : emissions factor for fuel $k$ in tonnes of CO₂e/unit.
$K$ : total number of distinct fuels, $k$ , used for a Reporting Period, $RP$ .

Project Proponents 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.

6.1

Waste heat eligibility criteria

Project Proponents may consider the use of waste heat to reduce the emissions associated with fuel usage of a project. Waste heat sources do not require accounting of GHG emissions associated with production of the utilized thermal energy. Waste heat utilization must meet the criteria described in Table 2 to be eligible for discounting against project heat usage.

Any activities specifically developed inside the project gate to handle and utilize waste heat must be accounted for in the life cycle analysis. These potentially include, but are not limited to:

Waste heat distribution systems, including pumps, piping, or other equipment;
Waste heat upgrading processes, such as heat pumps, booster pumps, other other equipment; and
Waste heat conversion processes, such as heat-to-power technologies (e.g. organic Rankine cycle generators).

Equipment and energy usage associated with waste heat utilization must be accounted for in accordance with the requirements of this Module and the Embodied Emissions Accounting Module.

Refer to Embodied Emissions Accounting Module for the calculation guidelines.

Waste heat must meet all of the criteria in Table 2 to be considered exempt from GHG emissions accounting:

Table 2: Eligibility Criteria for Waste heat

Criteria	Description	Documentation required
EC6	The waste heat is “unavoidable waste heat”, requiring that the delivered thermal energy cannot: Be recovered inside the same process or project where it is produced i.e. they are operationally independent; Be reduced through the use of more efficient equipment or other energy efficiency measures; Be feasibly supplied to another co-located non-CDR industrial process with a thermal energy deficiency which could utilize the waste heat; Be the intended output of a process, such as in a combined heat and power facility; and Result in an increase in the rate of production of the process from which the heat is sourced.	Affidavit from waste heat supplier, confirming that there was no feasible alternative non-CDR end-use for the waste heat; that the provided waste heat is unavoidable; and that supplying waste heat to the project will not result in an increase in the production rate of the process from which the heat is sourced.
EC7	The heat-generating process is financially viable without revenue from the CDR project. If the facility producing the waste heat is owned by the Project Proponent, the facility or process that generates the waste heat must be financially viable without revenue from the CDR project. If heat is sourced from a third-party provider, one of the following must be true: The end-user does not pay for the heat, or only pays for the costs associated with its delivery (e.g., pipeline construction, pump operation); or The end-user pays for the heat, but the facility or process that generates the waste heat is financially viable without revenue from the CDR project.	If the waste heat source is owned by the Project Proponent, provide financial evidence demonstrating that the facility supplying the waste heat is viable without the CDR project. This evidence must clearly show that the continued operation of the heat-generating process does not rely on revenue or cost savings from the CDR project. If the waste heat is sourced from a third party provider: If the end-user does not pay for the heat, provide the contract for waste heat provision, which indicates: contract dates; contracted heat source, location, and amount; and a cost structure for the contract purchase price. The cost structure may be a breakdown of contract price by heat provider, or may be an estimate of the waste heat delivery costs based on the specific contract, equipment, and heat source. If the end-user pays for the waste heat, provide: purchase records between Project Proponent and waste heat supplier demonstrating price paid, amount, buyer, seller and date. Furthermore, provide either: Financial evidence demonstrating that the facility generating the waste heat remains viable without revenue from selling waste heat to the CDR project; or An affidavit from the waste heat generating facility that demonstrates that the facility or process is financially viable without payments from the CDR project for waste heat and would continue to operate in the absence of payments from the CDR project for waste heat.

6.2

Calculation of CO|2|e|Fuel, RP| with Fuel Environmental Attribute Certificate procurement

Calculation of CO₂e_{Fuel, RP} with Fuel Environmental Attribute Certificate procurement

6.2.1

Fuel Environmental Attribute Certificate Eligibility Criteria

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 ﬁnance the use of low-carbon fuels 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 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 claims (e.g. under ICAO CORSIA⁸).

Isometric evaluates Fuel EAC programs, registries and methodologies against high-level integrity and issuance and claiming principles that are aligned with ICAO’s CORSIA⁸ 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 3.

Table 3: Fuel EAC Eligibility Criteria

Criteria	Description	Documentation required
EC8	EACs must be purchased and retired by the Project Proponent in a volume equivalent to the volume of fuel substitution claimed.	Documentation of EAC retirement certificates. Volume of fuel represented by the EACs must be equivalent to the volume of fuel substitution claimed. Purchased EACs must specify: Feedstock and production process for the low-carbon fuel; The location of low-carbon fuel production facility; and GHG emissions associated with low-carbon fuel production in an appropriate and usable set of units.
EC9	EACs must be verified in accordance with an acceptable regulatory or voluntary methodology which appropriately considers: GHG emission associated with low-carbon fuel production Exclusive issuance of the attribute for the activity that occurred Traceable chain-of-custody Sustainability of Feedstock sourcing	Provide proof of verification of the EAC associated with low-carbon fuel production according to an acceptable methodology. Acceptable methodologies include: Aviation: ISCC CORSIA and RSB CORSIA Road and marine: ISCC EU and RSB EU RED Other voluntary low carbon fuel certification programmes will be accepted by Isometric at the point of project verification on a case-by-case basis. Isometric reserves the right to disallow EACs generated from specific feedstocks or to require adjustments to the low-carbon fuel carbon intensity to align with Isometric's GHG Accounting principles, if deemed appropriate.
EC10	Production and use of low-carbon fuels represented by EACs must be demonstrably additional.	Provide either of the following: Proof that the production facility associated with the low-carbon fuels represented in the EAC entered into service no more than 36 months before initiation of The Project. Note that the expansion of existing assets to increase fuel production capacity, where the expansion occurred no more than 36 months before The project entered service, is eligible under this Module. In this case, only capacity at the contracted production site which entered service no more than 36 months before The Project is eligible, with older existing capacity being ineligible. The use of existing assets which entered service more than 36 months before The Project are permitted in cases where the asset is considered "stranded" and would otherwise be entirely or partially non-operational in the absence of contract purchase by The Project; or Proof that revenue from EAC purchase by The Project is required for financial viability of production facility operations. For example, this could be satisfied by providing: Production site financials demonstrating that EAC purchases are required to yield financial viability; or A signed affidavit from the fuel producer stating that EAC purchases are required to yield financial viability. And the following: Proof that production and use of the low carbon fuel meets regulatory additionality, meaning that either: Production, sale, or use is not influenced by any government policy, mandate, or incentive, demonstrated with a signed affidavit from the fuel producer declaring that the production, sale, and use of the specified fuel volume was not subject to or influenced by any government mandate, financial incentive, or policy support scheme; or If the fuel has benefited from a government incentive (e.g., a tax credit), but it has not been used to meet a renewable fuel volume - or emissions target-based regulatory compliance obligation, provide a signed attestation of non-compliance use or national registry cancellation records confirming the specific batch ID was not claimed against a government target.
EC11	The chain of ownership of all EACs, from generation to retirement, is recorded in a suitable registry, or other suitable record keeping system. The registry or record keeping system must be secure and must ensure exclusive issuance of the attribute itself and transparent public disclosure of issuances, transfers, redemptions, and retirements.	Provide proof that EAC ownership, transfer, and retirement is managed by a registry aligned with the principles established in the Book and Claim Communities "Best Practices for Book and Claim Systems in Heavy Transport" and "CORSIA Emissions Unit Eligibility Criteria". Where suitable registries have not yet been established, Project Proponents must maintain high quality record keeping to ensure traceability of ownership of the EACs, and to support validation of verification of the fuel supply chain in accordance with the relevant methodology (see EC2). Record keeping must comply with Book and Claim Communities "Best Practices for Book and Claim Systems in Heavy Transport" (Principle 3) and "CORSIA Emissions Unit Eligibility Criteria". Where EACs are used off-registry, Project Proponents must provide a signed affidavit stating that the claimed EACs will not be sold or otherwise used by any third party, or by the Project Proponent, in any other context.
EC12 (not applicable to SAF)	Demonstration that alternative low-carbon alternatives were not accessible, for example due to activities being early-stage solutions that are not yet commercially viable, or due to availability being constrained.	Provide a statement that summarizes alternative decarbonization options considered by the project in relation to project fuel usage and the reasons they were not accessible. Reasons could be either because of: Technical feasibility: demonstrate that alternatives do not exist, or their availability in the region is low. Economic feasibility: demonstrate that low carbon alternatives are too costly, and would compromise the financial viability of the project. The statement must include a plan for future decarbonization of activities. Examples of low-carbon alternatives include: Reducing number of trips or transport distances; Switching to less carbon intensive modes of transportation, for example rail instead of road; Switching to electric, hybrid or hydrogen fueled transport alternatives; and Purchasing low-carbon fuel for use in combustion engines.

6.2.2

Calculation Approach

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 $F_{Fuel}$ 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.

6.2.2.1

Calculation of fuel emissions using Fuel Environmental Attribute Certificates

When using EACs to substitute for some, or all, of project fuel usage and calculating transportation emissions using the energy usage method, $CO₂e_{Fuel}$ , must be calculated in accordance with Equation 7.

$CO_2e_{Fuel,RP} = \sum_j \left[ f_{Fuel} \times \left( m_{j} - m_{EAC,RP} \frac{ED_{EAC,RP}}{ED_{Fuel,RP}} \right) + \left( f_{EAC,RP} \times m_{EAC,RP} \right) \right]$

(Equation 7)

Where:

$m_{j}$ = the quantity of fuel consumed, $j$ , in appropriate units, e.g. litres.
$m_{EAC,RP}$ = the quantity of fuel represented in EACs used for a Reporting Period, $RP$ , in appropriate units e.g. liters.
$f_{EAC,RP}$ = emissions factor of low-carbon fuel represented in EACs used for a Reporting Period, $RP$ , in appropriate units e.g. tonnes of CO₂e/liter.
$ED_{EAC,RP}$ = energy density of low-carbon fuel represented in EACs used for a Reporting Period, $RP$ , in appropriate units e.g. MJ/liter.
$ED_{Fuel,RP}$ = energy density of fuel consumed a Reporting Period, $RP$ , in appropriate units e.g. MJ/liter.

Note, in Equation 7, the term $CO₂e_{Fuel}$ is analogous to the term $CO₂e_{Transportation}$ 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 7, at maximum, an amount of EACs may be used for a Reporting Period, RP, such that:

$\left( m_{j} - m_{EAC,RP} \frac{ED_{EAC,RP}}{ED_{Fuel,RP}} \right) \geq 0$

(Equation 8)

6.2.2.2

Calculation of transportation emissions using Fuel Environmental Attribute Certificates with the distance-based method

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:

$m_{j} = D_{j} \times W_{j} \times \frac{f_{Transportation,j}}{f_{Fuel,Transportation,j}}$

(Equation 9)

$D_j$ = the distance traveled for the transportation journey, $j$ , from one location to another, in appropriate units e.g. km.
W_j = the mass of material transported as part of the transportation journey, $j$ , from one location to another, in appropriate units e.g. tonnes.
$f_{Transportation,j}$ = the weight- and distance -base d emission factor for transportation for a specific vehicle type , or infrastructure asset where available, provided in appropriate units e.g. tonnes of CO2e/tonne-km.
$f_{Fuel,Transportation,j}$ = emission factor of fuel assumed to be used for journey j, in appropriate units e.g. tonnes of CO2e/liter. Assumption of fuel type used for journey j as a basis for this calculation must be based either (i) on information provided to the Project Proponent by the transport provider, or (ii) by prevailing fuel type used for the transport mode for journey j in the region of project ope rations, where the most granular or regionally-speciﬁc data possible is preferable.

6.3

Acceptable emissions factors - CO|2|e|Fuel, RP

Acceptable emissions factors - CO₂e_{Fuel, RP}

$f_{fuel,k}$ - emissions factors used must:

Be selected based on the specific fuel type being used and the type of combustion process;
Be for the specific region (nation, state, locality) where the fuel consumption is occurring, with the most granular or site-specific data source preferred;
Account for the full life cycle emissions (well-to-wheel) associated with fuel combustion and include direct emissions from fuel combustion, as well as upstream emissions associated with fuel production and equipment manufacture, and downstream emissions associated with equipment decommissioning and disposal, at a minimum; and
Account for total GHG emissions as CO₂e. Separate emissions factors for each GHG may be utilized and calculated emissions converted to CO₂e using the 100-yr Global Warming Potential (GWP) for the relevant GHG, based on the most recent volume of the IPCC Assessment Report (presently the Sixth Assessment Report).

Acceptable emission factors include those utilized in the Argonne National Laboratory GREET Model⁴, California Air Resources Board modified GREET model (CA-GREET)⁵, Ecoinvent database⁶, US Federal Life Cycle Inventory database or LCA Commons⁷, 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 Combustion⁹, US EPA AP-42¹⁰, or US EPA MOVES Model¹¹ (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.

6.4

Measurements - CO|2|e|Fuel, RP

Measurements - CO₂e_{Fuel, RP}

The primary measurement considered in calculation of fuel emissions is:

$m_{fuel,k}$ : total mass, volume, or heating value of fuel $k$ used for a Reporting Period, $RP$ in appropriate units e.g. kg, gal, ft³, therms etc.

6.5

Required records and documentation - CO|2|e|Fuel, RP

Required records and documentation - CO₂e_{Fuel, RP}

Fuel usage must be monitored for all operations within the gate at each location of their utilization relevant to project operation. The Project Proponent must maintain records of any fuel use for any operation or support system within the gate of a removal process that consumes fuel.

Allowable fuel records include, but are not limited to:

On-site fuel meter readings (e.g. natural gas utility meter, fuel flow meters), either electronic or manually logged; or
Weight of fuel container readings, either electronic or manually logged; or
Monthly utility bills, if they indicate total fuel consumption for the month by the process, and/or a justifiable allocation procedure is used to determine fuel consumption by the process; or
Fuel usage for handling equipment may also be determined by any of the above methods, or, if necessary, by documentation of total time of use of each equipment item for a Reporting Period, RP, and calculation of the fuel consumption based on manufacturer fuel consumption ratings. Data obtained from equipment manufacturer on-board-diagnostics or on board data systems is also acceptable.

If other equipment or processes not related to the removal 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, or by other justifiable allocation methods which must be reviewed and accepted during third party verification.

Meters must be calibrated initially and at regular intervals in accordance with manufacturer specifications to ensure accuracy. All records of fuel usage, including meter specification and calibration records, must be maintained by the Project Proponent for a period of at least five years.

7.0

Acknowledgements

Isometric would like to thank following contributors to this Module:

Tim Hansen (350 Solutions).
Wilson Ricks (Princeton University)

8.0

Definitions and acronyms

Greenhouse Gas (GHG)Those gaseous constituents of the atmosphere, both natural and anthropogenic (human-caused), that absorb and emit radiation at specific wavelengths within the spectrum of terrestrial radiation emitted by the Earth’s surface, by the atmosphere itself, and by clouds. This property causes the greenhouse effect, whereby heat is trapped in Earth’s atmosphere (CDR Primer, 2022).
Life Cycle Analysis (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.
ModuleIndependent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.
PathwayA collection of Removal processes that have mechanisms in common.
ProjectAn activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals.

9.0

Appendix 1 - companion documentation

This appendix is a companion to the Isometric Energy Use Accounting Module V1.2, 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.

9.1

Why does the Module use average emissions factors for grid-based electricity use?

The emissions accounting approach adopted in this Module for electricity consumption from the grid requires the use of generation-weighted grid-average emissions factors. An alternative approach supported by some published studies relies on the use of marginal grid emissions factors when accounting for emissions from electricity consumption from the grid.

A marginal generator is the specific generating unit in a grid region which will modify its output in response to changes in demand from users of the grid. In many grid regions, even those with a high proportion of generation provided by renewables, the marginal generators will often be fossil-fuel based. The marginal emissions factor, specifically the Short-Run Marginal Emissions (SRME) rate, aims to quantify the emissions which result from an incremental increase in demand causing a real-time increase in output from a specific marginal generator. The motivation behind marginal emissions accounting in this context is to embed within the calculations that incremental demand, like that from a CDR project, is likely to be met by flexible fossil-fuel based power generation in many real-world settings - which can result in significant emissions and a reduction of the net carbon removal achieved by a project. In many cases, the SRME will be substantially larger than the corresponding grid average emissions factor.

However, Isometric’s present view is that marginal emissions factors are not appropriate for emissions accounting of electricity usage in this context. Firstly, the marginal generator is fundamentally unobservable in practice. In real-world grids, there are a large number of fluctuating sources of demand at any given time, and complex grid dispatch models respond to these fluctuations in demand by ramping up/down several independent generators simultaneously. Under these conditions, the definition of the SRME provided above is invalid and loses practical meaning from the perspective of establishing a causal relationship between a CDR project and a specific marginal generator.

Secondly, marginal emissions rates are determined by modeling approaches, which can be categorized as either (i) statistical models applied to historical data to analyze the relationship between demand and emissions, or (ii) economic dispatch models to estimate a merit order based on marginal generation cost (dispatching lowest cost first). There is no clear consensus in the published literature as to which modeling approach is favorable, and the models used are fundamentally unable to be validated because the marginal generator cannot be observed in practice. Therefore, there is no clear mechanism by which any model for the marginal emissions factor can be validated as achieving the intended goal in real-world scenarios. This combination of factors does not satisfy Isometrics standards for the use of modeling approaches in emissions accounting. As per Section 2.5.5.3 of the Isometric Standard; “Models must be [...] shown to be reliable via [...] testing or correlation with empirical data”. In contrast, grid-average emissions factors can be readily validated as achieving their intended objective by using empirical data and real-world measurements. This means that grid-average emissions factors are inherently more reliable, based on currently available data and science.

Therefore, while marginal emissions rates appear to be the most conceptually aligned approach with a consequential emissions accounting framework for CDR projects, currently available data and methodologies for their calculation are not sufficient to permit confident real-world usage. Isometric will continue to monitor developments in the scientific literature, as well as data availability in the energy market, and will make future amendments to this Module as needed.

9.2

How does the Module approach procurement of low-carbon electricity for energy intensive projects?

For energy intensive projects, defined as having an annual electricity consumption of more than 200 GWh, the Module requires that any procured power is matched to project demand on an hourly basis (i.e. “hourly matching”). Following consultation with experts in the carbon removal ecosystem, Isometric believes that such an approach is the only effective means by which to embed the impact of generator intermittency within the emissions accounting scheme for widely-used low-carbon generator types (e.g. solar, wind).

In practice, implementation of hourly matching requires two conditions to be satisfied by the prevailing energy market:

Renewable Energy Certificates (RECs) or Energy Attribute Certificates (EACs) proving procurement of power featuring hourly generation timestamps must be available; and
Digital infrastructure in the energy market must exist to facilitate liquid trading of hourly RECs/EACs to match the varied operational requirements of carbon removal suppliers.

At present, it is generally the case that neither of these conditions are satisfied by real-world regional energy markets. Isometric anticipates substantial developments in energy markets towards these goals over the next several years. However, in the interim while these market developments take place, an alternative emissions accounting approach is required. To ensure that early stage projects can secure financing, emissions accounting requirements which are operable in the real-world are necessary. This is an essential component of ensuring that the CDR industry can scale effectively over the coming years to drive down cost and energy consumption of key carbon removal technologies.

Therefore, Isometric is introducing an operational on-ramp for carbon removal suppliers operating energy intensive projects. The on-ramp will allow an exemption for energy intensive projects to use a conventional volumetric matching approach (i.e. “annual matching”), rather than being required to conduct hourly matching. This on-ramp will be accessible to suppliers initiating projects in the period until 2030. Isometric will be reviewing the conditions of the energy market on, at least, an annual basis to determine if the continued use of the exemption is necessary - if the wider energy market develops the required infrastructure faster than we anticipate, then Isometric’s timeline for a full transition to hourly matching will be accelerated. The exemption will only be available to removal projects which meet the following two criteria (i) the gross removal capacity of the project is less than 100,000 tnCO₂/yr, and (ii) a burden of proof is satisfied to demonstrate that implementation of hourly matching is not possible in the region of project operations. Full details of the burden of proof and other details relating to the exemption can be found in the Module main text.

As outlined above, the exemption for energy intensive projects to use volumetric matching in place of hourly matching is expected to increase uncertainty on the number of credits which should be generated for a removal activity. Prior to the release of this Module, Isometric has conducted extensive modeling activities to quantify how the volumetric matching exemption could impact the number of generated removal credits. As inputs, the modeling exercise used:

Regional electricity generation and carbon intensity data from the NREL Cambium model for a range of typical grid regions; and
Representative performance data and electricity demand profiles for carbon removal technologies.

This data was used to estimate the impact on calculated energy emissions in a range of scenarios for both hourly matching and volumetric matching based frameworks. We have concluded based on the outcomes of this exercise that the impact on the accuracy of the net carbon removal calculation when allowing volumetric matching is small enough in magnitude that use of the exemption is permissible in the near-term for projects operating at small scales. It is important to note that the limited use of the exemption with respect to project deployment date and size are key pillars towards ensuring the responsible application of carbon accounting rules in the context of energy intensive carbon removal.

As outlined in Section 5.4.2.1 of this Module, the use of the exemption is also permitted for projects with a gross removal of more than 100,000 tnCO₂/yr - subject to the application of an “emissions screen” (see Equation 5). The emissions screen provides an additional guardrail to protect against significant uncertainties in the context of large energy intensive projects. The formulation of the emissions screen criteria requires that large projects procure a sufficient amount of power to fully abate all emissions which would have occurred had the project procured all electricity directly from the grid. We note that this will always result in a project at least procuring a sufficient volume of power to match the measured demand by the project, and will in some cases require the project to procure an excess of power to ensure that the full amount of equivalent grid-based emissions are fully addressed.

While permissible for near-term use, Isometric intends to phase out the use of this exemption at the earliest possible date. Isometric will actively support market advancements in collaboration with carbon removal suppliers, buyers, and academics to ensure that the necessary market structures are both rigorous, and implemented as soon as possible, to enable a full transition to the application of an hourly matching approach for all energy intensive removal projects.

10.0

Appendix 2 - EnergyTag's "Configuration 3"

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 RECs/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 RECs/EACs purchased from that generator. Under this approach, RECs/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 RECs/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 RECs/EACs produced by a generator.

11.0

Relevant works

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

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Contributors

Emma Marsland

Jasmin Kazazi

Michael Shell

Contents

Introduction

Future versions

System boundaries

Calculation of CO2eEnergy,RP

Calculation of CO2eElectricity, RP

Calculation of CO2eElectricity, RP with behind-the-meter electricity provision

Calculation of CO2eElectricity, RP with grid-based electricity provision

Calculation of CO2eElectricity, RP with Electricity Environmental Attribute Certificate procurement

Definition of non-intensive and intensive facilities

200 GWh threshold

Eligibility criteria for Electricity Environmental Attribute Certificates

Definition of grid regions

Calculation Approach

Non-intensive facilities

Intensive facilities

Exemptions to EC4: Hourly matching

Intensive facilities larger than demonstration scale

Acceptable emissions factors - CO2eElectricity, RP

Measurements - CO2eElectricity, RP

Required records and documentation - CO2eElectricity, RP

Calculation of CO2eFuel, RP

Waste heat eligibility criteria

Calculation of CO2eFuel, RP with Fuel Environmental Attribute Certificate procurement

Fuel Environmental Attribute Certificate Eligibility Criteria

Calculation Approach

Calculation of fuel emissions using Fuel Environmental Attribute Certificates

Calculation of transportation emissions using Fuel Environmental Attribute Certificates with the distance-based method

Acceptable emissions factors - CO2eFuel, RP

Measurements - CO2eFuel, RP

Required records and documentation - CO2eFuel, RP

Acknowledgements

Definitions and acronyms

Appendix 1 - companion documentation

Why does the Module use average emissions factors for grid-based electricity use?

How does the Module approach procurement of low-carbon electricity for energy intensive projects?

Appendix 2 - EnergyTag's "Configuration 3"

Relevant works

Footnotes

Contributors

Changelog

Calculation of CO₂e_Energy,RP

Calculation of CO₂e_{Electricity, RP}

Calculation of CO₂e_{Electricity, RP} with behind-the-meter electricity provision

Calculation of CO₂e_{Electricity, RP} with grid-based electricity provision

Calculation of CO₂e_{Electricity, RP} with Electricity Environmental Attribute Certificate procurement

Acceptable emissions factors - CO₂e_{Electricity, RP}

Measurements - CO₂e_{Electricity, RP}

Required records and documentation - CO₂e_{Electricity, RP}

Calculation of CO₂e_{Fuel, RP}

Calculation of CO₂e_{Fuel, RP} with Fuel Environmental Attribute Certificate procurement

Acceptable emissions factors - CO₂e_{Fuel, RP}

Measurements - CO₂e_{Fuel, RP}

Required records and documentation - CO₂e_{Fuel, RP}