Revised SBTi Net Zero Standard: Second draft released, allowing for multiple paths to emissions reductions

Board Member, Global Sustainability Standards Board (GSSB)
GHG Protocol Technical Working Group (TWG) Members
Zeroboard Research Institute Director Tomoo Machiba

Josephalisa Michelle

In the previous Insight , we explained the status of the revision of the GHG Protocol and reported that a public consultation on the calculation and disclosure method for Scope 2 emissions (electricity, heat, and steam supplied by others) was running until December 19th. Subsequently, the Science Based Targets Initiative ( SBTi ), which supports companies in Settings short- and long-term greenhouse gas (GHG) reduction targets and managing their progress based on the Protocol, published the second draft of the second edition of its Corporate Net Zero Standard on November 6th, and conducted a public consultation until December 13th. This article explains the key points of the draft.

In general, the new standards incorporate feedback from companies about the effectiveness of the current standards, and although they still do not allow for offset emission amount with carbon credits, they allow for a variety of paths and indicators toward net zero that are feasible for high-emitting sectors, companies with complex supply chains, and growing start-ups.

What is SBTi?

SBTi is a joint initiative *1) established in 2015 by WWF, CDPs , World Resources Institute (WRI), and the United Nations Global Compact. To achieve the Paris Agreement goal of limiting the rise in global average temperature to 1.5°C, the initiative supports companies in Settings "science-based targets" that define how much and by when they must reduce their GHG emission amount . Companies that are deemed to comply with SBTi standards are given SBT certification, and to date, nearly 12,000 companies worldwide have been certified, including over 2,000 Japanese companies, beginning with Sony in October 2015 *2) .

Current net-zero standard

To encourage a long-term decarbonization transition toward net zero by 2050, the first version of the SBTi Corporate Net Zero Standard was published in October 2021, and has since been gradually updated to version 1.3. The standard defines corporate net zero as follows:

• Eliminate Scope 1, 2 and 3 emission amount or reduce them to residual emission amount levels consistent with achieving net-zero emissions at a global or sector level on a qualified 1.5°C trajectory.
• emission amount emission amount into the atmosphere at the time of the net-zero target and thereafter.

In order to translate this into concrete goals, the following four elements have been defined *3) .

The most recent year for which data is available (since 2015) is recommended as the base year, and reduction targets should be set within 5 to 10 years from the time of application. Settings targets for Scope 1 and 2 is mandatory, and if Scope 3 emission amount account for 40% or more of total emission amount, Settings a Scope 3 target is also mandatory. Scope 1 and 2 targets should be set at a minimum annual reduction of 4.2% to keep global warming to within 1.5°C, and Scope 3 targets should be Settings at a minimum annual reduction of 2.5% to keep global warming to within 2°C (Small and medium-sized enterprises *4) are only required to calculate Scope 3 targets; setting a target is optional). Scope 1 and 2 targets must account for at least 95% of total emission amount, and Scope 3 targets must account for at least 67%.

To be consistent with the 1.5°C level, a 90% reduction across Scope 1, 2, and 3 emissions is required by 2050. If separate sector-specific documents have been prepared, follow the emissions reduction pathways in those documents. The base years for short-term and long-term targets must match. Scope 3 targets must be calculated at 90% or more.

Even if a long-term goal achieves a 90% or greater reduction in Scope 1, 2, and 3 emission amount, some remaining emission amount must be offset by removing carbon from the atmosphere and permanently storing it. While carbon removal credits are permitted as a neutralization method, they cannot be counted toward the emission reductions required to achieve the short- and long-term goals.

It is recommended that companies undertake activity outside their value chains that lead to emission avoidance or reduction through renewable energy investments and energy-efficient products, as well as activity and investments in new technologies that remove and store GHGs from the atmosphere (purchasing REDD+ credits, CCS, and investments in DAC technologies) to help increase the likelihood that global society will stay within the 1.5°C carbon budget. However, this does not replace the obligation for companies to reduce emission amount from their own value chains.

To date, more than 2,200 companies worldwide have been certified as net-zero based on this standard, including 92 companies in Japan (as of November 2025) *5) .

Key Elements of the Revised Standards

Based on the experience gained from applying the first version of the Corporate Net Zero Standard over the past three years, the SBTi Secretariat states that it is implementing a major revision to "make climate science more accessible and actionable, enabling more companies to set ambitious science-based targets and achieve measurable progress." The first draft of the second version of the Corporate Net Zero Standard was published in March 2025, and approximately 860 comments were submitted, as well as a pilot test. Based on this, the second draft has been Create and comments are currently being solicited for finalization. The Secretariat states that "a simpler, more rational, and more innovative approach has been adopted, taking into account the realities of various sectors and regions in implementing decarbonization." Below, we provide an overview of the second version, taking into account the changes from the first draft *6) .

A) General requirements

• Standard application level : Instead of large and small companies, companies are divided into two levels , "Category A" and "Category B," taking into account the circumstances of each country. Category B companies must meet two or more of the following criteria: fewer than 250 employees, annual sales of less than $50 million/euro, balance sheet of less than $25 million/euro, and Scope ₁ and 2 emission amount totaling less than 10,000 tCO2e. Low- and middle-income countries are provided with more lenient standards.
• Overall goal : Companies must Settings an "ambition" to transition their operations and value chains in line with the goal of achieving net zero by 2050 at the latest (Category B is optional). The word "commitment" that was in the first draft has been removed, and the question now simply asks about each company's overall intention.
• Transition plan : Companies will be required to publish a transition plan that supports their targets and commitment to net zero within 12 months of initial validation (Category B is optional). The first draft considered both mandatory and recommended levels, but the second draft made it mandatory.
• Sector criteria : Follow sector-specific criteria where applicable and required. If 5% or more of your revenue comes from financial services , apply the Financial Institution Criteria *7) to your Scope 3 Category 15 targets.
• Third-party assurance : The numerical values ​​used in Settings targets are assured (at a minimum, limited assurance ) by a third party, and the results are made public (optional for Category B).

B) Goal base

• Base year : The base year for setting emissions reduction targets has been changed from 2015, which was the most recent year for which data is available, to the most recent year for which comprehensive data is available .
• Short-term goals : The short-term reduction goals that were set at the time of application for 5-10 years have been unified to 5 years . At the time of initial certification, companies can also Settings shorter-term goals to suit their own business and reporting cycle.
• Mid-term goals : We are seeking comments on whether to recommend or require mid-term goals covering the 10 years from initial certification.
• Long-term goal : The provision to Settings it by 2050 or earlier remains unchanged.
• Target Renewal : To receive renewal validation , it is recommended that you submit your next target as early as possible, starting 24 months before the deadline for your current short-term or mid-term target. Submission of your next target more than 12 months after the target deadline is not permitted.

C) Scope 1 (direct emissions from company-owned or controlled operations)

• Target scope : Currently, the target is the combined target for Scope 1 and 2, but to prevent the practice of offsetting Scope 1 emissions by using Environmental Attribute Certificates (EACs) such as renewable energy certificates in Scope 2, individual targets will be Settings for each scope . Emission reduction targets for forests, land, and agriculture (FLAG) will be set separately.
• Scope of inclusion : From 95% or more of combined Scope 1 and 2 emission amount to covering 100% of Scope 1 emission amount .
• Target Settings methodology : In addition to the existing "linear contraction approach," which aims to achieve a linear reduction in emissions from the base year to the net-zero target year, and the "sectoral decarbonization approach" (SDA) provided for specific sectors, two New approaches are proposed. The "carbon budget maintenance contraction approach" that was included in the first draft has been deleted (Figure).
  • "Alignment-based target approach" : For low emission amount companies, start-ups that find it difficult to reduce their Total emissions as they grow, and companies that provide climate solutions, the proportion of low-carbon options in air conditioning, hot water supply, transportation, etc. will be increased linearly in accordance with reference pathways based on the International Energy Agency (IEA) 2050 Net Zero Scenario (Table A.1 in Annex A) (Table 1) .
  • "Asset Decarbonization Planning Approach" : For capital-intensive, high-emission Industry such as steel that renew assets in a fixed cycle, we offer an approach that Settings a carbon budget using a linear contraction approach or sectoral decarbonization pathways, develops plans to reduce, replace, and phase out assets in line with this, and Settings five-year milestones.
• Target adjustment : Once progress is verified, the following targets can be adjusted in the methodology design according to progress. The option to utilize carbon removal credits, which was in the first draft, has been removed.

Figure: Version 2 allows for a variety of Scope 1 target Settings methods
(The current ① and ② will be joined by ③ and the consistency goal approach. ④, which was in the first draft, will be deleted.)

Table 1: Examples of Scope 1 Alignment Targets

Source: SBTi*9) Zeroboard Create from Annex A, Table A.1

D) Scope 2 (electricity, heat, steam, and cooling provided by others)

• Calculation basis : It is optional to use either the location-based or market-based GHG Protocol for Settings reduction targets. The requirement to Settings targets based on location, which was in the first draft, has been removed.
• Short-term goal : Separate targets for electricity and heat, steam, and cooling. Cover 100% of emission amount from electricity, but consider limited exclusions (for markets where low-carbon electricity is not available and EAC is not available). Allow exclusion of heat, steam, and cooling if it is less than 5% of location-based emission amount. Disclose excluded emission amount and percentage of electricity consumption, and which markets they apply to.
• Long-term goal : 100% coverage of electricity and heat, steam and cooling (Category B is optional).
• Target Settings methodology : See Table A.1 in Annex A (Table 2) .
  • Electricity: Alignment-based target to linearly increase the share of low-carbon electricity purchased or matched by EAC to 100% by 2040. Optionally, additional location-based or market-based electricity emission amount targets can be Settings.
  • Heat, steam, and cooling: Settings at location-based or market-based emission amount .

Table 2: Scope 2 target Settings criteria

Source: SBTi *9) Zeroboard Create from Annex A, Table A.1

• Power procurement conditions :
  • Definition: Low-carbon electricity (0.024 kgCO ₂ /kWh or less) , not zero-carbon, and allows for the use of biomass and natural gas-fired power plants with CCS (with a CO ₂ capture rate of 95% or more) that can be proven sustainable.
  • Availability: Low-carbon electricity and EAC must be generated within the same physical availability area as the consumption . The definition of the area follows the "24/7 Carbon-Free Coalition Standards" *10) .
  • Temporal matching: Companies with a total annual consumption of 10 GWh (10 million kWh) or more in a single region will be required to gradually implement hourly matched electricity procurement (50% in 2030, 75% in 2040, 90% in 2050). Businesses with an annual consumption of 100 MWh (100,000 kWh) or less may be exempt.
  • Operation period: Low-carbon attributes are only available to power generation facilities that have been in operation or have had their output increased within the past 10 years . *11) Consideration is being given to shortening this period to within five years by 2035.
  • Integrity: The EAC will clearly demonstrate its exclusive use and meet the Scope 2 quality requirements of the GHG Protocol, following the relevant integrity principles outlined in Annex E.

E) Scope 3 (indirect emissions from value chain activity)

• Scope : For short-term targets, Category A is mandatory , Category B is optional. The restriction disappears only if Scope 3 emission amount account for 40% or more of total emission amount. All long-term targets are optional.
• Target Settings scope : Short-term targets are Settings for categories that account for more than 5% of Total emissions . Priority emission sources are required to Settings focused reduction targets (the requirement for high-emitting activity that account for more than 1% of Total emissions , or 10,000 _tCO2 e, which was in the first draft, has been deleted). Long-term targets cover 100% of Scope 3 emission amount.
  • Priority sources: Materials production, transport and traffic, primary commodity production, fossil fuel and electricity-based products. Examples are given in Annex 1, Table A.2.
  • Possible exclusions: Very small businesses (fewer than 10 employees and annual sales or balance sheets of 2 million euros or less), purchases of second-hand goods, upstream emissions from purchased fuel and electricity already included in Scope 1 and 2, means of transportation without a contract or other reason, transportation where the company has no influence over fuel or route, employee commuting, upstream leased assets over which the company has no control over business operations, downstream emissions from intermediate products whose end use is unknown, processing of sold products where the company has no contractual relationship with the processor, and franchises that are independently operated under license and over which the company has no control over facility management. Exclusions and their justification must be disclosed.
• Target- Settings methodology : While the long-term goal is to reduce absolute emissions, in the short term , alignment-based targets have been adopted to increase feasibility, and a variety of options have been provided for the target- Settings methodology by category (the supplier engagement target that was mandatory in the first draft has been removed). The intervention levels, which were divided into direct reduction and indirect reduction in the first draft, have been reorganized so that Scope 3 reduction efforts will be carried out at four levels : activity, business partner, activity pool, and sector .
  • It is essential to Settings an ambition for the entire Scope 3, such as "by what year will we reduce Total emissions by what percentage?"
  • Targets that can be Settings across categories: Average emission intensity of activity ( _tCO2 e/t), quantity/value, percentage of trading partners, or percentage of trading partners using low-carbon Energy, aiming to achieve progress consistent with the five-year benchmarks shown in Table A.3 of Annex 1 (Table 3) .
  • Categories 1 and 2 (raw materials and capital goods): For priority products that account for 5% or more of total Scope 3 Total emissions and are listed in Table A.2 of Annex 1, 95% or more of the average emission intensity or purchase volume must be aligned to a five-year benchmark, or 95% or more of purchases must be from suppliers *12) that are aligned to SBTs. If the requirement extends to Tier 1 and below, Tier 1 suppliers must cascade similar requirements to their upstream tiers through contracts or Code of Conduct. For other products, the rate of aligned suppliers or the alignment of suppliers' low-carbon Energy consumption rates to the benchmark must be met.
  • Categories 4, 6, 9 (Transportation): 95% or more of average Emission intensity or traffic volume is aligned to the benchmark, and 95% or more of traffic volume from suppliers aligned to SBTs. If this extends to Tier 1 and below, Tier 1 suppliers cascade similar requirements to upstream tiers through contracts or Code of Conduct. Alternatively, align the increase in the proportion of zero-emission vehicles in traffic volume to the benchmark (or IEA Net Zero Scenario, ICCT transport route).
    
    Table 3: Examples of Scope 3 Alignment Targets

Source: SBTi *9) Extracted from Annex A, Table A.3 and Create by Zeroboard

• Categories 5 and 8 (operational waste, upstream leased assets): The proportion of procurement volume from suppliers aligned with SBTs is aligned with the benchmark, or the supplier's low-carbon Energy consumption rate is aligned with the benchmark.
• Categories 11 and 13 (Use of sold products, downstream leased assets): For sales of fossil fuels, Service related to the Manufacturing and sale of fossil fuels, products that use fossil fuels, and products that emit GHGs during their use, a linear reduction to zero revenue by 2050 or a reduction in sales, while plans are in place to achieve 100% sales of net-zero aligned products in 2050. For post-sales emissions from electrical appliances, the proportion of revenue from customers aligned to SBTs will be aligned to a benchmark, and revenue or sales from products with the highest level of Energy efficiency (e.g., EU Energy Label A) will be linearly increased to 95% or more by 2040, or customers' low-carbon Energy consumption rates will be aligned to a benchmark.
• Category 12 (End of Sale): Linearly increase the percentage of revenue or units sold that undergo verified circular end-of-sale processing (Cradle to Cradle, ISO 59040, WRAP Circular Living Standards) to at least 95% by 2050.
• Categories 10, 14 (Sales Processing, Franchises): Percentage of revenue from customers, downstream processors, or franchises that are aligned to Science Based Targets or processor/franchise low-carbon Energy consumption benchmarks.
• activity Pools : When it is difficult to track individual emission sources, it is possible to aim for performance alignment within "activity pools" (Category B is optional). activity pools include 1) land-based supply sheds (areas where biomaterials are collected), 2) transport operations categories (groups of the same transport mode, route, cargo, or trade line), 3) factory sheds (factories Manufacturing similar goods within a region), and 4) Energy sheds (grids or sub-grids where renewable energy interventions are linked to consumption). Alignment can be achieved by aligning the Emission intensity of activity pools to a benchmark, or by purchasing unbundled Energy and product EACs produced within the pool, or by increasing the number of SBT-certified suppliers within the pool.
• Sector level : Where sufficient procurement of net-zero aligned goods and Service is not possible, purchasing unbundled Energy and product EACs can support the deployment of low-carbon alternatives at the sector level and achieve quantitative alignment (optional for Category B).

F) Awareness and responsibility for ongoing emissions

• Evaluation system: Even if companies make every effort to achieve net zero, they will be required to recognize and take responsibility for their continued emissions up to 2050 in order to achieve a 1.5°C increase. The current standards will be neutralized and the BVCM will be restructured, and a new voluntary participation system will be established to evaluate efforts at the following two levels.
  • Certified: Support activity that have already reduced emissions (post-facto) by an amount equivalent to at least 1% of ongoing Scope 1, 2, and 3 emissions over the short-term target period, or use the amount equivalent to at least 1% of that reduction, with a carbon price (recommended to be at least $20 per tCO2e), to finance eligible climate actions (mitigation, adaptation, research and development, loss and damage).
  • Leaders: Place a carbon price of at least $80 per tCO2e on 100% of ongoing emission amount(Category B: Scope 1 and 2 only), with at least 40% of the funds supporting ex-post mitigation activity and the remainder supporting eligible climate actions.
• Supported emissions: Reductions achieved through support cannot be counted towards Scope 3 targets.
• Credit utilization: Carbon credit purchases can be used for support activity, as long as there is no double counting and they are not resold for other purposes.
• Long-term response: Accountability for continued emissions will be mandatory from 2035 onwards (optional for Category B). Specific requirements and levels will be considered when formulating the third edition of the Net Zero Standard.
• Neutralize: Neutralize all remaining Scope 1, 2 and 3 emission amount through carbon removal in the net-zero target year and beyond.
  • Removal method: Over 41% of residual emission amount will be stored for long-term storage (e.g., CCS), the rest for short-term storage (e.g., forests)
  • Scope 1: Removal of residual Scope 1 emissions must be performed in-house.
  • Scope 3: Remove any remaining Scope 3 emissions yourself or in collaboration with value chain partners. Evidence of removal by other companies can be used. Double counting is not permitted.

G) When the second edition will come into effect

• Second edition publication : The second edition is scheduled to be completed and published in 2026, reflecting the results of this consultation. Use of the second edition is encouraged from the publication date.
• Transition to the second edition : Full implementation from January 1, 2028.
• Expiration date of Version 1.3 : May be used for Settings new targets until the end of 2027 together with the "Short-term Standards" (Version 5.3) *13) .
• Existing targets : Companies that have already Settings targets under the current standards can use the current standards until that target year.

Points for Japanese companies to consider

The second edition significantly clarifies provisions that were vague in the current standards, while the second draft reflects opinions on the first draft and, with momentum toward decarbonization stagnating, gives the impression of being in a form that companies can implement in concrete terms.

While aligning with the current sustainability information disclosure standards (IFRS S, SSBJ, GRI, CSRD/ESRS) by mandating the formulation and publication of transition plans, the SBTi also provides four different methods for Settings Scope 1 targets, taking into account the non-linear transition paths advocated by Japan in its Energy transition under the GX policy and transition finance, making it easier for high-emitting sectors and emerging companies to participate in the SBTi.

The elimination of location-based target Settings for Scope 2 eliminates one hurdle for Japanese companies, simplifying the target to achieve 100% low-carbon electricity by 2040. The possibility of including biomass and natural gas-fired power plants with CCS as low-carbon electricity sources has expanded procurement scope. Meanwhile, as in the discussions regarding the revision of the GHG Protocol , procurement of low-carbon electricity through power purchase agreements (PPAs) and energy agreements (EACs) requires supply availability conditions and time matching. The current definition of supply areas divides Japan into 10 power regions, inevitably affecting renewable energy procurement. Furthermore, while time matching will be applied in conjunction with the GHG Protocol and will be limited to large-scale consumers from 2030, supply area restrictions will become applicable earlier, starting with the publication of the second edition. Furthermore, instead of the standard supply Service(SSS) concept *14 introduced by the GHG Protocol, a 10-year limit has been imposed on the operating life of low-carbon power plants. This is shorter than the 15-year limit set by RE100, and it is important to note that this will be shortened to five years by 2035.

While short-term targets are now mandatory for all Category A companies under Scope 3, they are only applicable to categories that account for more than 5% of Total emissions, and various exemptions, such as employee commuting, are included. These provisions are more lenient than those in the revised GHG Protocol. A variety of alignment targets are presented for each category, and requiring suppliers to Settings SBTs remains an option, making it easier to link them to specific decarbonization activity. Furthermore, even if tracking individual emission sources is difficult, this can be substituted by improving performance within activity pools or at the sector level, reducing the headache of figuring out how to reduce emissions throughout the value chain. However, the extent to which SBT-aligned sourcing, effective Energy and product EACs, and circular products become widespread will determine future outcomes.

The newly established voluntary assessment system for continuing emissions is intended to further accelerate investment in technologies and projects related to carbon absorption and storage. Demand is expected to expand as carbon credits, which still cannot be used to offset a company's own emission amount , will now be assessed as contributions outside the value chain. The avoided emissions contributions of products and Service that Japanese companies have promoted as BVCMs could also be circulated if they could be converted into credits. Meanwhile, the second draft does not mention mass balance-based green certificates, which attribute the emissions reduction effect to part of the product, or the use of synthetic fuels, hydrogen, and ammonia, and it appears that, under the current circumstances, it will be difficult to include them in target Settings and implementation.

The subtle discrepancies with the discussions on revising the GHG Protocol are also a cause for concern. The Protocol is about calculation methodology, while SBTi has different roles in Settings and achieving targets, so the fact that the two regulations differ is not necessarily a problem. However, the gap between the scope of Scope 3 calculation disclosure and target Settings, as well as the differences in the inclusion and exclusion regulations for things like employee commuting, could result in double Create for companies, so reconciliation between the two is required.

*1) It is now one of the commitments to join the We Mean Business Coalition.

*2) WWF Japan, "What is the Science Based Targets Initiative (SBTi)?", March 28, 2023 https://www.wwf.or.jp/activities/basicinfo/409.html 

*3)Science Based Targets Initiative (SBTi), SBTi Corporate Net-Zero Standard, Version 1.3, September 2025. https://sciencebasedtargets.org/net-zero Ministry of the Environment, "SBTi Corporate Net Zero Standards (Version 1.0) Provisional Translation"https://www.env.go.jp/earth/ondanka/supply_chain/gvc/files/tools/Net-Zero-Standard_v1.0_jp.pdf 

*4) For the definition of small and medium-sized enterprises under the current standards, please refer to our column "What is SBT Certification (Science Based Targets)? Introducing how to obtain it, its benefits, and the certification system."https://www.zeroboard.jp/column/5748

*5) WWF Japan, as above

*6)SBTi, SBTi Corporate Net-Zero Standard, Version 2.0, Draft for Second Public Consultation, November 2025. https://sciencebasedtargets.org/consultations/cnzs-v2-second-consultation; SBTi, What’s Next for Net-Zero: An updated draft of the Corporate Net-Zero Standard V2, 6 November 2025. https://sciencebasedtargets.org/blog/whats-next-for-net-zero-an-updated-draft-of-the-corporate-net-zero-standard-v2; SBTi, Corporate Net-Zero Standard (CNZS) V2, Public Consultation #2, Key Updates and Areas Under Consultation, November 2025. https://files.sciencebasedtargets.org/production/files/2nd-Consultation-Draft-CNZS-V2-_-Detailed-Explanatory-Guide.pdf

*7)SBTi, Financial Institutions Net-Zero Standard, version 1.0, July 2025. https://files.sciencebasedtargets.org/production/files/Financial-Institutions-Net-Zero-Standard.pdf　

*8)SBTi, Deep Dive: Evolving approaches to address Scope 1 emissions, November 2025. https://files.sciencebasedtargets.org/production/files/Deep-dive-Evolving-approaches-to-address-scope-1-emissions.pdf　

*9)SBTi, SBTi Corporate Net-Zero Standard, Version 2.0, Draft for Second Public Consultation. 

*10)The Climate Group 24/7 Carbon-Free Coalition, 24/7 Carbon-Free Electricity Technical Criteria and Appendices, version 1.0.1, 26 August 2025. https://www.theclimategroup.org/247-technical-guidance 

*11) Exceptions apply to projects that require operation or capacity expansion within 15 years in accordance with Section 5.3.2 of the 24/7 Carbon-free Coalition Standards in Section 5 of the RE100. The Climate Group and CDPs, RE100 Technical Criteria, version 5.0 , 24 March 2025. https://www.there100.org/sites/re100/files/2025-04/RE100%20technical%20criteria%20%2B%20appendices%20%2815%20April%202025%29.pdf; The Climate Group 24/7 Carbon-Free Coalition, Same as above

*12) SBT certification through third-party verification by business partners is recommended but not required.

*13)It would be unfair for a specific organization to monopolize 100% of publicly supported renewable energy sources, and so claims would only be allowed up to an average percentage. If this approach were to be adopted, it would likely become difficult to utilize FIT non-fossil certificates and other such schemes.