Energy Market Update

LevelTen Energy’s snapshot on U.S. and EU Power Purchasing Agreement (PPA) pricing is below. For more information on LevelTen please visit www.leveltenenergy.com.

Recent changes in climate reporting standards reveal an effort from working groups to standardize terminology, metrics, and reporting. However, these changes are being met with political resistance, most notably from a group of attorney generals who claim these organizations are exhibiting anticompetitive behavior. Concurrently, the EPA has challenged net-zero standards and emissions reporting with an effort to roll back the collection of emissions data.

• September 8, 2025: “ISO, Greenhouse Gas Protocol to Align on Carbon Accounting Rules”
  • The International Organization for Standardization (ISO) and the Greenhouse Gas Protocol (GHGP) are aiming to align their reporting frameworks for GHG emissions to enable governments and businesses to more easily disclose their emissions.
  • This move aims to mitigate fragmentation between GHG reporting standards globally and cut down on geographical differences between the playbooks, tools, and guidelines used.
  • Certain environmental groups are concerned that this harmonization in standards might mean weaker rules overall, so this will be a key area to track as guidelines are released.
• September 8, 2025: “Republican Attorneys General Accuse Net-Zero Standards Setters of Running Climate Cartel - WSJ”
  • In August 2025, twenty-three Republican Attorneys General wrote a letter claiming that the Science Based Targets Initiative (SBTi) and the Carbon Disclosure Project (CDP) were engaging in anticompetitive behavior, stating that net-zero goals harm U.S. agriculture, industry, and energy independence.
  • This letter follows a wave of anti-ESG legislation and investigations around antitrust laws, with over 480 bills proposed since 2021 that have targeted ESG investing and accused several other climate focused groups of collusion.
  • These actions have the potential to discourage companies from publishing emissions disclosures and have already sparked an exodus of firms from their respective net-zero alliances.
• September 12, 2025: “EPA to Stop Collecting Emissions Data From Polluters”
  • As of Friday, September 12, 2025, the Environmental Protection Agency (EPA) has “moved to stop requiring thousands of polluting facilities to report the amount of heat-trapping greenhouse gases that they release into the air” citing reduced compliance costs for businesses.
  • While certain emissions reporting requirements for oil and gas facilities will still be mandatory, these reporting requirements will be postponed until 2034.
  • Historically, groups such as local communities, private companies, and the United Nations have relied on EPA data to track and report emissions, so the EPA’s departure from emissions reporting could hinder the reporting abilities of these groups.
  • This proposal has not yet been finalized yet, but “after the E.P.A. proposal is published in the Federal Register, the E.P.A. will solicit public comments for 47 days [and then] the agency will finalize the proposal, likely within the next year.”

For questions on these items and more please reach out to SustainabilityTeam@Constellation.com and your inquiry will be directed to an inhouse expert.

From Voluntary Action to Global Compliance: The New Era of Corporate Greenhouse Gas Reporting

For decades, corporate greenhouse gas (GHG) emissions reporting was largely voluntary, motivated by investor pressure, brand reputation concerns, or participation in initiatives such as CDP (formerly the Carbon Disclosure Project). Early adopters were mostly found in high-profile industries like technology, retail, and finance, and reporting often served as a badge of climate leadership or sustainability ambition.

Today, however, emissions disclosure is rapidly becoming a legal requirement rather than a choice. An increasing number of jurisdictions—from the European Union to California—mandate emissions reporting by law. This shift is transforming emissions transparency into a core business function that goes far beyond voluntary pledges.

At the heart of emissions reporting lies transparency: quantifying a company’s climate impact across its operations (Scope 1), purchased energy (Scope 2), and entire value chain (Scope 3). Thousands of companies globally now report their emissions through CDP, following frameworks such as the Greenhouse Gas Protocol (GHGP), or by pursuing targets validated by organizations like the Science Based Targets initiative (SBTi).

In our earlier articles, we explored how Scope 2 emissions can be calculated using both location-based and market-based methods:

• The location-based method uses average regional grid emission factors (such as those published by the EPA’s eGRID in the U.S.) to reflect the carbon intensity of the electricity a company consumes.
• The market-based method allows companies to account for specific electricity purchases—like renewable energy certificates (RECs), power purchase agreements (PPAs), or emission-free energy certificates (EFECs)—aligning emissions reporting with procurement strategy.

These dual methods are increasingly important as businesses harmonize their reporting with emerging regulatory requirements.

Global Regulatory Momentum

Europe: The Corporate Sustainability Reporting Directive (CSRD) has transformed the emissions landscape. Starting in 2025, thousands of companies—including U.S. firms with EU operations—must disclose detailed emissions and broader sustainability data under the European Sustainability Reporting Standards (ESRS). These standards require Scope 3 disclosures, double materiality assessments, and provide clear guidance on energy sourcing and climate impacts, positioning Europe as the global leader in mandatory climate disclosure.

United States: California is setting the pace with Senate Bills 253 and 261, signed into law in 2023. These laws require large public and private companies doing business in California—regardless of headquarters location—to disclose Scope 1, 2, and 3 emissions as well as climate-related financial risks. The threshold includes companies with more than $1 billion in revenue, marking a significant move toward mandatory U.S. emissions reporting.

Meanwhile, a patchwork of regional rules is emerging across the U.S. From New York City’s Local Law 97 to Boston’s BERDO and state-level climate laws in Illinois, Washington, and Colorado, local and state mandates are establishing de facto national standards, particularly for real estate and energy-intensive sectors.

The New Business Imperative

The convergence of legal mandates, investor expectations, and increased climate risk has made emissions reporting a core element of business operations. It’s no longer sufficient to make climate pledges—regulators, customers, and stakeholders now demand hard data. For companies aiming to compete on a global stage, emissions transparency is no longer just a compliance exercise; it’s a license to operate and a key to maintaining credibility and competitiveness.

For questions on these items and more please reach out to SustainabilityTeam@Constellation.com and your inquiry will be directed to an inhouse expert.