Energy Use Accounting

1.0 Introduction

This Module (Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.) describes how energy-relatedto calculate emissions (The term used to describe greenhouse gas emissions mustto bethe calculatedatmosphere as a result of Project activities.) related to energy use for 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.)projects (An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.) as part of project 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).)) accounting. This Module applies to all CDR 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 projects and approaches.

2.0 Future versionsVersions

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 (An estimate of the emissions factorsintensity per unit of an activity.), temporal matching and power purchase agreements.

This Module will be reviewed at aleast minimum each year,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 the provision ofsupplying energy to CDR projects currentlyare representsstill an area of uncertaintyevolving. Isometric will continue to actively 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 regardingto assess the scientific rigor and operability of various energy emissions accounting frameworks for CDR projectsapproaches, and will actively work to drive consensus in the ecosystem between suppliers, buyers, and academics towards the most rigorous approaches possible. This ongoing assessment and consensus building exercise will include monitoring both hourlyincluding temporal matching and emissions matching as approaches for low-carbon power procurement, with respect to scientific rigour, operability, and alignment with emerging policy frameworks. Any future changes to the approach outlined in this Module will be conducted in consultation with a range of ecosystemstakeholders participantsand 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 introducingincreasing the mostrigor rigorous available requirements forof energy emissions accounting over timerequirements, and intendswill to phase-inintroduce more robust approaches atas thesoon earliestas timethey atare whichsupported by the evolving science allows, and at which time such approaches are proven to bedemonstrably operable under prevailing market conditions.

3.0 System boundariesBoundaries

The emissions associated with energy use must account for all operations that consume energyelectricity withinand thefuel as part of CDR project processes, through the usage of both electricity and fuel. Emissions associated with energyEnergy use for a Removal, [math: R],Use are written hereafter asdenoted [math: CO_2e_{Energy,R RP}].

Sources (Any process or activity that releases a greenhouse gas, an aerosol, or a precursor of a greenhouse gas into the atmosphere.) included in this Module’s scope are:

• Non-mobile machinery;
• Primary non-road/rail/air/maritime mobile sources are included within this boundary, 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 However,to the GHG Accounting Module v1.1 for the calculation guidelines for transportation (including road, rail, air and maritime mobile emission sources are excluded from the calculation of [math: CO_2e_{Energy,R}], as they are accounted for in [math: CO_2e_{Transportation,R}]. Refer to the Transportation Emissions Accounting Module for the calculation guidelines.

It should be noted that this Module relates to electricity) and fuelembodied consumptionemissions strictly(Life withincycle the project gate. EnergyGHG emissions associated with production of materials, transportation, and construction or other processes for goods or buildings.) accounting (including the production of products/ feedstocks (Raw material which is used as inputs for projectCO₂ operationsRemoval areor accountedGHG for separately within the scope of the Embodied Emissions Accounting ModuleReduction.)).

4.0 Calculation of CO₂e_Energy,RRP

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

[math: CO_2e_{Energy,RRP} = CO_2e_{Electricity,RRP} + CO_2e_{Fuel,RRP}]

(Equation 1)

Where:

• [math: CO_2e_{Energy,RRP}]: the total GHG emissions associated with energy consumption for a removalReporting Period, [math: RRP], in tonnes of CO2 equivalent (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.).
• [math: CO_2e_{Electricity,RRP}]: the total GHG emissions associated with electricity usage for a removalReporting Period, [math: RRP], in tonnes of CO₂e.
• [math: CO_2e_{Fuel,RRP}]: the total GHG emissions associated with fuel usage for a removalReporting Period, [math: RRP], in tonnes of CO₂e.

[math: CO_2e_{Electricity,RRP}] and [math: CO_2e_{Fuel,RRP}] 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.

4.1 Calculation approach

Equation (1) and the calculation approaches described in Sections 5-6 can also be followed for a batch, [math: n], or for a Reporting Period, [math: RP].

5.0 Calculation of CO₂e_{Electricity, RRP}

Electricity-relatedThis emissionsModule areprovides typicallyaccounting indirectrequirements emissionsfor associatedthe withfollowing generation and transmissiontypes of electricity:

• Behind-the-meter byprovision: anotherProjects entitymay establish generation “behind-the-meter”. Project Proponents (eThe organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.g) must follow the quantification requirements in Section 5.1.
• Grid-based anelectricity: electric utility)electricity which is used by the CDR process. All electricity-related emissions for electricity obtained from the grid (i.e. from an electric utility) shall be accounted for using average emissions intensities for theelectricity grid region withinto which The Project is located (see Section 5.2).

5.1 Definition of non-intensive and intensive facilities

The calculation approach in this Module distinguishes between intensive facilities, which use significant amounts of electricity, and non-intensive facilitiesconnected. IntensiveProjects facilities are defined as those which consume more than 200 GWh of electricity per year.

Intensive facilities are subject to more stringent energy accounting rules than non-intensive facilities. Non-intensive facilities shouldmust follow the calculationquantification approachrequirements in Section 5.2.

5.1 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 (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 both of the following 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:

• 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 ([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:

• 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 CO₂e_{Electricity, RRP} withWith gridGrid-basedBased electricityElectricity provisionProvision

TheEquation following calculation approach2 must be followed for emissions associated with provision of electricity from the grid:.

[math: CO_2e_{Electricity,\ RRP} = f_{grid} \sum_{i=1}^{N}E_i]

(Equation 2)

Where:

• [math: CO_2e_{Electricity,RP}]: the total GHG emissions associated with electricity usage for a Reporting Period, [math: RP], in tonnes of CO₂e.
• [math: 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.
• [math: E_i]: electricity usage in hour [math: i], in kWh.
• [math: N]: total number of calendar hours for removalReporting Period, [math: RRP].

IfProjects a CDR project relying on a non-intensive facility wishes tomay reduce their energyelectricity emissions through direct procurement of low-carbon power, they may use the calculation approach in(See Section 5.4.1. If a CDR project relying on an intensive facility wishes to reduce their energy emissions through direct procurement of low-carbon power, they may use the calculation approach in Section 5.4.2. Project Proponents will be responsible for providing sufficient documentation to submit these calculations, as set out in Section 5.3).

5.3 EligibilityCalculation criteriaof forCO₂e_{Electricity, low-carbonRP} powerWith procurementElectricity Environmental Attribute Certificate Procurement

A projectProject may wish to reduce its energy emissions through the procurement of low-carbon power. Project Proponents will be responsible for providing sufficient documentation to allow for the discounting of project energy usage through this mechanism.

Electricity consumptionEACs, is subdivided into consumption of ‘qualified’ and ‘non-qualified’where electricity:

• Qualified: electricity which is procured by contract purchase from low-carbonrenewable sources for the exclusive use of The Project. ForNote qualifiedthat electricityElectricity 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 specific generator types which have been procured, including any embodied emissions.

• Non-qualified: electricity whichgeneration is obtained fromfollowing the electricity grid to which The Project is connected. For non-qualified electricity, Project Proponents are required to use average grid emissions factorsrequirements for the[math: calculationf_p] ofset emissions - as describedout 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.

ItIn should be noted that Project Proponents may elect to establish power generation "behind-the-meter". Generators are considered to be behind-the-meter when the equipment is owned and operated by the Project Proponent, or when the equipment is (i) owned and operated by a third-party, (ii) directly connected to The Project, and (iii) does not contribute to transmission on the local electric grid. Under theseexceptional circumstances, theProjects electricityoperating usageintensive meteredfacilities may apply for a temporary exemption from the project operations ([math: E_i]) will correspondrequirement to theobtain differencea betweenPower thePurchase totalAgreement electricity(PPA). demandTo ofbe granted an exemption, The Project andProponent must demonstrate reasonable efforts to comply with the amountrequirements of electricitythis generated by behind-the-meter generators in each metering time period. GeneratorsModule, which are behind-the-meter do not need to satisfy the eligibility criteria established below for qualified electricity. Both embodied and operational emissions associated with behind-the-meter generators should be quantified and allocated to the net-CO2e calculation for each Reporting Period, [math: RP], following the same approach as for all other project equipment. Note that a connection of "behind-the-meter" generators to the grid will be permittedassessed by Isometric on a case-by-case basis. inTo instancesdemonstrate wherereasonable the connection is present to manage excess generation which cannot be reasonably stored or used on-site byefforts, The Project Proponent must provide:

• evidence of systematic outreach to potential PPA counterparties in the relevant grid region (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.), including a record of entities approached and the RFI or RFP issued specifying delivery region, start date, term, and volume requirements;
• documentation of responses received, including any formal rejections citing credit (A publicly visible uniquely identifiable Credit Certificate Issued by a Registry that gives the owner of the Credit the right to account for one net metric tonne of Verified CO₂e Removal or Reduction. In the case of this Standard, the net tonne of CO₂e Removal or Reduction comes from a Project Validated against a Certified Protocol.) or financial concerns, or terms offered that The Project Proponent was unable to accept, with an explanation for the refusal;
• The Project Proponent's current credit rating, or, where no formal rating exists, a statement from a financial institution or independent advisor regarding The Project Proponent's creditworthiness and capacity to enter into a long-term offtake (A contract in which a Buyer agrees to purchase a set Removal and/or Reduction at a set price.) agreement; and
• evidence that alternative procurement structures were explored (such as sleeved PPAs or aggregated purchasing arrangements), along with available credit enhancement mechanisms and government support programmes in the jurisdiction of project operations, with an explanation of why these were insufficient to secure a compliant arrangement.

Temporary exemptions are valid for five years. The total duration of temporary exemptions granted to a single Project must not exceed 15 years from the date of the initial exemption. Upon expiry, The Project must meet the intensive facility requirements against which it was validated. It is anticipated that fifteen years represent a time period over which project bankability will reach levels required for necessary procurement structures. Isometric will review the continued appropriateness of the 15-year timeframe in future Module revisions, informed by evidence from project delivery and developments in financing availability.

5.4.1 200 GWh Threshold

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

QualifiedTo 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 ofEligibility theCriteria followingEC1-EC5 eligibilityin criteriaTable 1.

Table 1: Eligibility Criteria for Electrcity EACs

In

5.34.2.1 Definition of gridGrid 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 (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 theThe 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 theThe projectProject lifetime, regardless of future updates to this Module.

5.4.3 Calculation of CO2eElectricity, R with procured low-carbon power

Projects whichthat procure low-carbonElectricity powerEACs to reduce their energy emissions should follow the calculation approach for [math: CO_2e_{Electricity,RRP}] 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-intensiveIntensive facilities

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

[math: CO_2e_{Electricity, RRP} = 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:

• [math: CO_2e_{Electricity,RP}]: the total GHG emissions associated with electricity usage for a Reporting Period, [math: RP], in tonnes of CO₂e.
• [math: 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.
• [math: E_i]: electricity usage in hour [math: i], in kWh.
• [math: N]: total number of calendar hours for Reporting Period, [math: RP].
• [math: G_p]: total amount of energy procured for removalReporting Period [math: RRP] by generator type [math: 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 removalReporting Period, [math: RRP].
• [math: f_p]: emissions factor for generation by generator type [math: p], in tonnes of CO₂e/kWh.

For non-intensive facilities, documentation proving the direct procurement of low-carbon power should be time-stamped within one12 yearmonths prior toof 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 Electricity 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:

[math: CO_2e_{Electricity, RRP} = 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:

• [math: CO_2e_{Electricity,RP}]: the total GHG emissions associated with electricity usage for a Reporting Period, [math: RP], in tonnes of CO₂e.
• [math: 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.
• [math: E_i]: electricity usage in hour [math: i], in kWh.
• [math: N]: total number of calendar hours for Reporting Period, [math: RP].
• [math: G_{p,i}]: amount of energy procured in hour [math: i] by generator type [math: p], in kWh. Note that in the calculation outlined above, the amount of procured energy in hour [math: i] may not exceed the amount of electricity consumption by The Project in hour [math: i].
• [math: f_p]: emissions factor for generation by generator type [math: 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 2B.

5.4.3.2.1 Exemptions to EC4: Hourly Matching

Under some operational circumstances, documentationit provingmay thenot directbe procurementfeasible ofto procure low-carbon power featuring hourly time stamps may not be available from any power provider 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 followingEC6 conditions areis met.

Table 2: EC6 Exemption to hourly matching

• Eligibility Criteria	Description	Documentation required
  EC6	The Project must have reached Final Investment Decision (FID) is reached before the year 2028; 2030.	Evidence that The Project reached FID and is atdue to commence construction before 2030, including documentation of the demonstrationFID scale, defined here as an annual gross removal rate of less than 100,000 tnCO2/yr. Note that subdivison 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; and Reasonable best efforts have been made to obtain documentation featuring hourly time stampsdate. This mustshould bedemonstrate evidenceda byfinal and irrevocable commitment to proceed with project construction prior to 2030. Examples of documentation include: • A formal signed record of the provisiondecision to Isometricproceed • atSigned theEngineering, pointProcurement ofand Construction contract • Evidence that project verificationfinancing ofhas bothbeen (i)secured

  This evidenceexemption ofreflects engagementIsometric's withassessment athat minimum of three independentlow-carbon power providers and/or vertically-integrated utilities in whose territory the Project operates, including evidenced correspondence confirming that these suppliers do not offer documentation featuring hourly time-stamps and evidence that power provision from these suppliers would otherwise satisfy the requirements established under EC3 and EC4 for qualified electricity, and (ii) a signed affidavit by the Project Proponent declaring that, to the best of their knowledge, procurement documentation featuring hourly time stamps is notunlikely currentlyto be widely available inat economically feasible terms before 2030. This position is aligned with the regionapproach 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 projectthe operationsModule 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. InUpon regionsexpiration whereof threethe eligibleobtained independentPPA, powerif providersthis and/oroccurs vertically-integratedat utilitiessuch ina whosetime territorythat this exemption has been revoked from this Module, then compliance with the hourly matching scheme described above will be mandatory. If The Project operateshas doan notexisting exist,PPA evidencein place at the time of engagementvalidation 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 allthe eligiblerules entitiesin musteffect at the time of execution. Such PPAs will be providedassessed 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 mustshould 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 2028, 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 (Equation 4) will be mandatory for all projects relying on an intensive facility. Isometric anticipates that this provision will expire in approximately the year 2028. 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 theThe 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.

5.4.3.2.12 IntensiveEmission facilities larger than demonstration scale

Projects withWhere an annualintensive grossfacility removal rate of more than 100,000 tnCO2/yr may also utilizeutilizes the provisionexemption outlineddescribed above, followingand follows the calculation approach described in Section 5.4.3.1 (Equation 3), low-carbon power procurement is not matched to consumption on an hourly basis. HoweverIn practice, the generation profile of procured low-carbon power may not correspond to the electricity consumption profile of The Project. For example, procured solar generation may occur during daytime hours while The Project consumes electricity during periods when that generation is unavailable. This introduces the potential for the emissions impact of electricity consumption by The Project to be underestimated.

To mitigate this risk, Project Proponents utilizing the exemption are encouraged to conduct an Emission Screen. The purpose 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 thisannual provisionmatching bydoes projectsnot withresult in a grossmaterial removal rateunderestimation of moreThe thanProject's 100electricity-related emissions.

The Emission Screen calculation may be conducted as set out in Equation 5,000 tnCO2/yror Equation 6 where generation data for procured power is furtheravailable subjector tocan anbe additional safeguard in the form of an "emissions screen"derived. Projects operationalizing this provision must demonstrate that the following criteria is satisfied by power procurement activities:

[math: \left( f_{grid} \sum_{i=1}^{N} f_{grid,i} \cdot E_i \right) - \left( \sum_p (f_\bar{f}_{grid} - f_p) \, G_p \right) \leq 0]

(Equation 5)

Where:

• [math: f_{grid,i}]: grid average emissions factor in hour [math: i], in tonnes of CO₂e/kWh. Details of requirements for acceptable emissions factors can be found in Section 5.5.
• [math: E_i]: The total amount of electricity The Project consumed in hour [math: i], in kWh.
• [math: N]: total number of calendar hours for Reporting Period, [math: 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.
• [math: f_p]: emissions factor for generation by generator type [math: p], in tonnes of CO₂e/kWh.
• [math: G_p]: total amount of energy procured for removal R by generator type p, in kWh.

[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:

• [math: f_{p,i}]: emissions factor for generation by generator type [math: p] in hour [math: i], in tonnes of CO₂e/kWh.
• [math: G_{p,i}]: amount of energy procured for removal R by generator type p in hour [math: i], in kWh.

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.

5.5 Acceptable emissionsEmissions factorsFactors - CO₂e_{Electricity, RRP}

[math: 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 Equations 2 and 3, and in the project electricity consumption term (left-hand side) of Equations 5 and 6. Hourly average emission factors must only be used in Equation 4 if low-carbon power features hourly time stamps, otherwise annual average emission factors must be used. In the procurement term (right-hand side) of Equations 5 and 6, hourly average emission factors must only be used in Equation 6, where hourly generation data for procured power is available or can be derived. Where hourly generation data is not available (Equation 5), annual average grid emission factors must be used in the procurement term.
• 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;
• 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; 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 (A measure of how much energy the emissions of 1 tonne of a GHG will absorb over a given period of time, relative to the emissions of 1 ton of CO₂.) (GWP) for the relevant GHG, based on the most recent volume of the IPCC Assessment Report (presently the Sixth Assessment Report).

[math: 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, theThe 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)³⁴, 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 [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 cycle emission factors include those utilized in the Argonne National Laboratory GREET Model4^2, California Air Resources Board modified GREET model (CA-GREET)5^3, Ecoinvent database6^4, US Federal Life Cycle Inventory database or LCA Commons7^5, 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).

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 (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.

5.6 Measurements - CO₂e_{Electricity, RRP}

The primary measurement considered in calculation of electricity emissions is:

• [math: E_i]: total amount of electricity used by The Project in hour [math: i].

Measurements must be made using a utility grade power meter, or an independent power meter installed by theThe 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 theThe Project net-CDR calculation. Meters must be calibrated initially and at regular intervals in accordance with manufacturer specifications to ensure accuracy.

5.7 Required recordsRecords and documentationDocumentation - CO₂e_{Electricity, RRP}

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 5.34.2), 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 theThe 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 theThe Project Proponent for a period of at least five years.

6.0 Calculation of CO₂e_{Fuel, RRP}

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 theThe projectProject gate.

The following calculation approach in Equation 7 must be followed for calculation of [math: CO_2e_{Fuel, RRP}]:.

[math: CO_2e_{Fuel, RRP} = \sum_{k=1}^K m_{fuel,k}f_{fuel,k}]

(Equation 67)

Where:

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

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 SectionTable 6.13 to be eligible for discounting against project heat usage.

Any activities specifically developed inside theThe projectProject 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 EmbodiedSection Emissions4.1 of the GHG Accounting Module v1.1.

6.1 Waste heat eligibility criteria

Waste heat must meet all of the followingcriteria criteriain Table 3 to be considered 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

6.2 AcceptableCalculation 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 factorsare 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 claims (e.g. under ICAO CORSIA⁵).

Isometric evaluates Fuel EAC programs, registries and methodologies against high-level 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

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 [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.

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, [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:

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

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)

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:

[math: m_{j} = D_{j} \times W_{j} \times \frac{f_{Transportation,j}}{f_{Fuel,Transportation,j}}]

(Equation 10)

• [math: D_j] = the distance traveled for the transportation journey, [math: 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, [math: j], from one location to another, in appropriate units e.g. tonnes.
• [math: 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.
• [math: 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 - CO₂e_{Fuel, RRP}

[math: 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. Where waste heat is used, the full life cycle emissions factor shall also include transmission and distribution (T&D) losses, where applicable; 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 Model4^2, California Air Resources Board modified GREET model (CA-GREET)5^3, Ecoinvent database6^4, US Federal Life Cycle Inventory database or LCA Commons7^5, 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 Combustion⁸⁶, US EPA AP-42⁹⁷, or US EPA MOVES Model¹⁰⁸ (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.

6.34 Measurements - CO₂e_{Fuel, RRP}

The primary measurement considered in calculation of fuel emissions is:

• [math: m_{fuel,k}]: total mass, volume, or heating value of fuel [math: k] used for a removalReporting Period, [math: RRP] in appropriate units e.g. kg, gal, ft³, therms etc.

6.45 Required recordsRecords and documentationDocumentation - CO₂e_{Fuel, RRP}

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 removalReporting Period, RRP, 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 theThe 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 acronymsAcronyms

Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.

The term used to describe greenhouse gas emissions to the atmosphere as a result of Project activities.

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.

An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.

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).

A collection of Removal or Reduction processes that have mechanisms in common.

An estimate of the emissions intensity per unit of an activity.

Any person or entity who can potentially affect or be affected by Isometric or an individual Project activity.

Any process or activity that releases a greenhouse gas, an aerosol, or a precursor of a greenhouse gas into the atmosphere.

Life cycle GHG emissions associated with production of materials, transportation, and construction or other processes for goods or buildings.

Raw material which is used for CO₂ Removal or GHG Reduction.

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.

The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.

GHG sources, sinks and reservoirs (SSRs) associated with the project boundary and included in the GHG Statement.

The increase in GHG emissions outside the geographic or temporal boundary of a project that results from that project's activities.

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.

A publicly visible uniquely identifiable Credit Certificate Issued by a Registry that gives the owner of the Credit the right to account for one net metric tonne of Verified CO₂e Removal or Reduction. In the case of this Standard, the net tonne of CO₂e Removal or Reduction comes from a Project Validated against a Certified Protocol.

A contract in which a Buyer agrees to purchase a set Removal and/or Reduction at a set price.

A process for evaluating and confirming the net Removals and Reductions for a Project, using data and information collected from the Project and assessing conformity with the criteria set forth in the Isometric Standard and the Protocol by which it is governed. Verification must be completed by an Isometric approved third-party (VVB).

The document that clearly outlines how a Project will generate rigorously quantifiable Additional high-quality Removals or Reductions.

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).

A measure of how much energy the emissions of 1 tonne of a GHG will absorb over a given period of time, relative to the emissions of 1 ton of CO₂.

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.

A United States Government agency that protects human health and the environment.

Sources, Sinks and Reservoirs

An evaluation of the likelihood that an intervention—for example, a CDR Project—causes a climate benefit above and beyond what would have happened in a no-intervention Baseline scenario.

9.0 Appendix 1A - companionCompanion documentationDocumentation

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 doesDoes the Module useUse averageAverage emissionsEmissions factorsFactors for gridGrid-basedBased electricityElectricity useUse?

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.

AMarginal emission factors represent the change in emissions resulting from a marginal generator is the specific generating unitchange in a grid region which will modify its output in response to changes inelectricity demand fromor userssupply ofon the grid. InMarginal manyemission gridfactors regions, even those with a high proportion of generation providedvary by renewables,time thehorizon marginaland generatorsscope willand ofteninclude be fossilShort-fuel based. Therun marginal emissions factor, specifically the Short-Run Marginal Emissions (SRME) rate,factors aimsand to quantify the emissions which result from an incremental increase in demand causing a realLong-time increase in output from a specificrun marginal generatoremission (LRME). TheIsometric 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 isacknowledges that marginal emissionsemission 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; 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 proxy for the change in emissions caused by decisions that affect longer-term generation capacity. As CDR projects typically involve long-term infrastructure investment and capacity implications, the application of SRME factors is methodologically unsuitable. Conversely, while LRME factors account for capacity changes, they currently lack standardized methodologies and rely on significant assumptions about the future regarding policy and market evolution.

The status quo at a policy level remains grid average emission factors; for example, the EU CRCF delegated act methodologies for permanent carbon removals reference Delegated Regulation (EU) 2023/1185³, 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 data and methodologiesonly for theirlimited calculation are not sufficient to permit confident real-world usagegeographies. 

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 2028. 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 2B - EnergyTagEnergytag's "Configurationconfiguration 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 theThe projectProject 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 theThe Project Proponent is the sole buyer of RECs/EACs produced by a generator.

11.0 Relevant worksWorks

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

U.S. Environmental Protection Agency. (2023, April 18). Understanding Global Warming Potentials | US EPA. Environmental Protection Agency. Retrieved June 14, 2023, from https://www.epa.gov/ghgemissions/understanding-global-warming-potentials