The history of solution providers and avoided emissions/ climate handprint in 35 steps
- The first group tend to be dominated by classical CSR managers with focus on PR/reporting that often use offsetting to reach reporting targets, they cherry-pick a few solutions and use a “climate snapshot” that just focus on current solution to be able to communicate a net-zero target.
- The second group focus on strategic planning and business model innovation to deliver what society needs and focus on providing society with sustainable solutions. This group use avoided emissions as a strategic tool to guide product development and business model development to ensure that they have a strategic role to play in a society that need a just transition towards 1.5 °C globally sustainable future here 11 billion people can live flourishing lives. Around start-ups an ecosystem is emerging where incubators, investors (angel/VC), and start-ups are working together and move beyond individual companies to clusters.
We’d love feedback!
August 2002
WWF
Aim
To highlight the opportunities and challenges of digitalisation and the need for leadership with focus on impact in society through indirect and systemic effects.
Highlighted the disruptive and transformative nature of digitalisation and the opportunities as well as challenges that this provides. Presented by WWF and partners at the 2002 World Summit on Sustainable Development in Johannesburg with a call for ICT companies to become solution providers and other stakeholders to use digitalisation as an opportunity to transform in a sustainable direction.
July 2003
GRI
Aim
Help companies report and understand direct, indirect, and systemic effects.
A table was introduced that presented a range of direct, indirect, and systemic effects resulting from the provision and use of telecommunications products and services.
May 2006
WWF/ ETNO
Aim
Help ICT companies approach the need for reduced emissions in society as an opportunity for new business offerings.
New technologies and knowledge can ensure that sustainable resource use and economic development is not only possible but mutually supportive. By approaching the challenges from a new perspective, problems can turn into opportunities.
April 2007
WWF/ IKEA
Aim
To develop a business case from “Carbon Neutral” to “Climate Positive” with assessment of avoided emissions.
Identifying the key areas where IKEA can have a positive impact in society and link sales to positive impacts in society. The official strategy was launched 2012.
February 2008
WWF/ HP
Aim
This report presents ten strategic Information and Communication Technology (ICT or IT, hereafter written only as IT) solutions that can help accelerate the reduction of CO₂ emissions.
This paper is based on WWF’s work with IT/ICT, particularly a joint initiative with HP where the key objective is to identify the first billion tonnes of CO₂ reductions through the use of IT. The paper is also a contribution to the collaboration between WWF and the World Economic Forum.
April 2008
WWF/ China Renewable Energy Industry Association (CREIA), China Wind Energy Association
Aim
The report provides an assessment of Baoding’s potential to contribute to global CO₂ emissions reductions by becoming a world leading producer and exporter of renewable energy goods.
China is the factory of the world providing us with a large variety of products at an affordable price. Lowering prices on renewable energy and energy efficiency products is also a key issue in our battle to mitigate climate change. Baoding is recognized by the Chinese Government as a first and only industrial base for development of China’s new energy sector. The world needs a dramatic increase in renewable energy if we are to be able to secure a sustainable energy supply for the global economy and avoid dangerous climate change. Baoding is therefore a key to global sustainable development.
May 2008
WWF/ HP
Aim
The Sustainable Innovation Zone, SIZ, is an internal HP web portal engaging employees to share ideas on ICT applications that can help reduce CO₂ emissions. Rather than focusing on how HP can reduce its own environmental impact, the SIZ focuses on how HP can help customers reduce their carbon footprint by using HP solutions. The SIZ promotes ICT applications that significantly reduce CO₂ emissions, the use of resources and improve service quality.
June 2008
GeSI
Aim
A major study identifying the significant contribution the ICT industry can make to creating a low-carbon economy.
The report predicts that the emissions from the ICT sector will represent an estimated 3% of total global emissions by 2020 but that ICT will enable others to achieve significant emissions reductions, helping other industries and consumers avoid an estimated 7.8 gigatonnes of CO2e emissions by 2020. That is 15% of predicted total global emissions – or five times ICT’s own footprint. Additionally, applying ICT solutions to sectors such as energy, buildings, transport and commerce can save up to €600 billion and create 15 million green jobs globally by the year 2020.
September 2008
Innovest/ WWF
Aim
Fund management companies have started to develop innovative new solutions that not only promote greenhouse gas emissions reductions but also provide new business opportunities.
The severity of the climate change challenge requires even more action from the investment community in the near future. This is where SWFs can step in and take a leadership role to move the investment community in the right direction.
November 2008
Gartner/ WWF
Aim
To provide a framework to assess low-carbon leadership.
The difference in how companies approach the need for a low-carbon economy is creating a new corporate landscape where new winners and losers will emerge and where ICT customers must learn to navigate. This is an assessment of 24 of the industry's world-leading providers and an analysis of where the ICT industry is today in relation to its maturity in mitigating environmental risks and exploiting the opportunities that the need for reduced carbon emissions will create.
November 2008
World Economic Forum (WEF)
Aim
Seven contributions of ICT to mitigating climate change are laid out in this paper and can be grouped into the following three logical categories:
- Infrastructure innovation
- Behavioural change & green enablement
- Energy efficiency of ICT products and solutions
Whilst significant opportunity exists for ICT products and services to enable climate change mitigation, the opportunity is far from realising its potential. With climate change now being one of the top issues at global, intergovernmental level, a unified, clear message on the role of ICT is urgently required. This message needs to be delivered outside of the ICT sector. Otherwise, uninformed legislation and investment decisions would probably only focus on ICTs direct climate change impact and thereby limit both the overall positive impact of ICT, as well as reduce the total green technology market opportunity for the ICT sector.
A unified and clear message would allow the ICT sector to establish itself as a leading contributor that sees reduction of CO2 as a driver for innovation and profit. It would also allow the sector to claim a leadership role as a winner in a low carbon economy.
November 2008
WWF/ IKEA/ HP
Aim
Both IKEA and HP noted that no stakeholder, i.e. NGO, media, investors, policy maker, think tank, had asked them for their positive impact before the collaboration with WWF and its climate innovation initiative.
During the BSR conference in New York a workshop. It was a really interesting event and both Tomas Bergmark, Head of Social & Environmental Affairs, IKEA/ Olle Blidholm, Development Manager, Social & Environmental Affairs, IKEA Olle from IKEA and Pierre Delforge, Worldwide Energy and Climate Programme Manager, HP made presentations that more people should see as they clearly showed that some companies already provide positive climate contributions and can do much more with the right incentive. Pankaj from WRI did a really interesting presentation about the next generation of reporting guidelines. With an introduction of secondary effects (that would include the consequences during the use phase, e.g. reduced traveling using laptops) a fantastic opportunity would exist for to assess the climate impact of products and services during the use phase (and not just the emissions associated with the use phase). He also made it clear that avoided emissions are outside the risk scope for the GHG protocol, one is part of a climate risk agenda the other could be seen as a climate opportunity agenda.
June 2009
WWF/ IKEA/ HP
Aim
The analyses in this report are the result of a 5-month workstream that took place between February and June 2009 as a part of the Biosolutions initiative, a joint project between WWF and Novozymes, which aims at exploring and establishing biotechnology solutions for both climate and industrial policies.
The hypothesis and vision underpinning this project is that sustainable biotechnology solutions, applied in the industrial sector, can provide a critical contribution in the transition from current, unsustainable, economic practices to more sustainable economic systems, which are able to meet human needs without destroying the natural ecosystems that support life (including human life) on our planet.
September 2009
WWF
Aim
A methodology to identify and quantify the positive climate impact in society from start-ups.
WWF’s innovation programme, Climate Solver aims to highlight innovative technologies that provide immediate and practical solutions to climate change. The Climate Solver Awards honour climate-smart entrepreneurs and businesses from China, India and the Nordic countries.
June 2010
UN Global Compact/ WWF
Aim
The Low-Carbon Leaders Project encourages the rapid development of transformative low-carbon solutions and provides a Web 2.0 platform for communication and exchange of ideas. The project will seek government support for an accelerated uptake of solutions. It will also develop tools and methodologiesto identify, calculate and report on solutions that helpsociety reduce emissions.
Incremental improvements in existing systems are insufficient measures in the battle against climate change. Many initiatives are well-intended, often in response to government policies, but these small changes will seldom contribute to the creation of a zero carbon society at the speed and scale that is necessary. There is even a risk that such incremental improvements might further lock society into a high-carbon infrastructure, making necessary reductions difficult or even impossible to achieve. Fortunately a growing number of companies with transformative solutions now view the creation of a low-carbon economy as a business opportunity rather than as a threat. These solutions deserve attention.
October 2010
UN Global Compact/ WWF
Aim
This paper provides a brief overview of the possibilities for calculating and reporting a company’s positive contributions to societal emissions reductions.
Over the last few years, discussions and strategies have shifted from an exclusive focus on big emitters and the need to reduce emissions by improving existing systems, to also focus on providers of low-carbon solutions and transformative change whereby services are provided in totally new ways (such as modal shifts and dematerialization). As a consequence the need for new reporting that can capture contributions from companies that provide solutions has emerged. The terminology is still under development, and the concepts are working names that have been used in the discussion related to the GHG-protocol and other systems for calculating emission reductions: Total emissions approach: A focus on the total impact, both positive and negative Climate Positive: A company that helps reduce more emissions in society than it emits over the whole value chain, Scope 1-3 Low-carbon market opportunities: The emissions that a company can contribute to reducing in society through the use of the products/ services and that are outside Scope 1-3
October 2010
GeSI/BCG
Aim
A practical and consistent Methodology, Tool and roadmap for assessing ICT’s capacity to enable the transition to a low-carbon economy.
This methodology uses an LCA approach to guide the assessment of changes to the BAU system resulting from adoption of an ICT solution (the BAU, or business-as-usual, system refers to the components in the existing manual, mechanical or physical processes that are impacted by the implementation of the ICT solution). As this methodology was developed to assess the capacity of ICT implementation to reduce the carbon footprint of other sectors, it focuses on quantifying CO2e (carbon dioxide equivalent) emissions. It does not assess other important environmental impact categories such as acidification, eutrophication, or land use, although the methodology could potentially be adapted in the future to consider these impacts.
April 2012
WWF
Aim
Simple calculation tool to estimate potential avoided GHG emissions and increased energy access for climate innovations globally.
December 2012
GeSI/BCG
Aim
GeSI's SMARTer2020 report demonstrates how the increased use of information and communication technology (ICT) could cut the projected 2020 global greenhouse gas (GHG) emissions.
This new research study identifies 16% more savings than was calculated in an earlier study conducted four years ago. The SMARTer2020 report evaluates GHG abatement potential from ICT-enabled solutions ranging across six sectors of the economy: power, transportation, manufacturing, consumer and service, agriculture, and buildings. Emission reductions come from virtualisation initiatives such as cloud computing and video conferencing, and also, through efficiency gains such as optimisation of variable-speed motors in manufacturing, smart livestock management to reduce methane emissions, and 32 other ICT-enabled solutions identified in the study.
June 2013
BT
Aim
As part of low-carbon technology value chains various chemical industry productsaid the reduction of greenhouse gas (GHG) emissions compared to conventional products or compared to the market average. Under the terminology of the Greenhouse Gas Protocol international accounting tool, emission reductions of thiskind are termed “avoided emissions”.
BT Net Good’s 3:1 goal is based on the premise that BT is directly responsible for emissions resulting from its own operations (for example network, offices, commercial fleet and company cars) but also bears responsibility for emissions at both ends of its value chain: in its supply chain (producing the products and services it buys) and from its products and services when used by BT customers.
October 2013
WBCSD/ICCA
Aim
As part of low-carbon technology value chains various chemical industry products aid the reduction of greenhouse gas (GHG) emissions compared to conventional products or compared to the market average. Under the terminology of the Greenhouse Gas Protocol international accounting tool, emission reductions of this kind are termed “avoided emissions”.
This document provides guidelines for calculating avoided GHG emissions enabled by chemical products, by comparing two solutions with the same user benefit. It also gives guidance on how to communicate the results.
February 2014
EPA
Aim
A tool to evaluate county-level (US) emissions impacts resulting from energy efficiency and renewable energy programs.
AVERT is a free tool with a simple user interface designed to meet the needs of state air quality planners and other interested stakeholders. Non-experts can use AVERT to evaluate county, state and regional emissions displaced at fossil-fueled power plants by EE/ RE policies and programs.
June 2015
GeSI/ Accenture
Aim
Since 2008, the Global e-Sustainability Initiative has been researching the role Information and Communications Technology (ICT) can play in cutting global CO2e emissions and promoting a more sustainable society. This is our third report in that effort and it is based on detailed modelling that, for the first time, also quantifies the far-reaching social and economic benefits of ICT.
As ICT has become faster, cheaper and more accessible globally, this report highlights its potential to generate powerful environmental, economic and social benefits beyond what we envisioned as recently as two years ago. The findings show an ICT-enabled world that is cleaner, healthier and more prosperous, with greater opportunities for individuals everywhere.
June 2016
Impact Forecast
Aim
Making impact assessments available for early-stage impact companies so organizations can allocate their resources to the most promising sustainable innovations.
Our scalable impact services make impact expertise accessible, by leveraging self-assessment with lean expertise when and where needed. And with webinars and workshops we can help a dozen projects a day to forecast their climate impact.
December 2017
Prime
Aim
There is a gap in the marketplace for tools that can inform investors about the potential for their investments to mitigate future emissions. In an attempt to help fill this gap, PRIME partnered with NYSERDA, New York State’s energy innovation agency, to develop a methodology for assessing the potential climate impact of early-stage ventures.
This report:
- Highlights the need for actionable climate impact tools for early-stage investors, and introduces Emissions Reduction Potential as the metric required for early-stage investors to make better informed investment decisions based on the potential climate impact of a new venture;
- Defines a methodology for down selection – a process for narrowing from many companies to a smaller subset of potential investment targets – based on potential climate impact; and
- Develops a methodology for estimating the Emissions Reduction Potential of a new venture.
January 2018
VTT/LUT
Aim
For many companies and organizations the day-to-day challenge of reducing their environmental footprint – using resources more efficiently and minimizing emissions and waste – is already business as usual. Some, though, have gone beyond this and are developing products, services and technologies that also reduce the environmental impacts of their customers. The need to calculate and communicate these positive environmental benefits is clear, yet there has been a lack of effective methods of achieving this.
A life cycle assessment in its current form does not assess positive environmental impacts. Some industries, individual companies, and initiatives have introduced handprints to communicate the environmental benefits of their actions. Yet these approaches differ in their principles making accountability difficult. Moreover, the wider the scope is (including environmental, social, and economic aspects), the more challenging the quantification becomes. VTT Technical Research Centre of Finland Ltd and LUT University have developed an approach for quantifying the environmental handprint based on standardized methods.
March 2018
METI
Aim
The Ministry of Economy, Trade and Industry (METI) launched the “Long-term Global Warming Countermeasures Platform” in 2016, toward the reduction of Greenhouse Gas (GHG) emissions on a long-term basis beyond 2030, by bringing together experts from the government, industries, and academia. Compiling the report in April, 2017, METI’s report stipulates “three arrows” which are game changers as countermeasures against global warming: “International contributions”, “Global value chain reductions by industries and companies” and “Innovation”. In order to reduce global GHG emissions further, it is important for industries to take drastic steps to contribute to reducing GHG emissions through the dissemination of environmentally-friendly goods or services.
Quantifying and clarifying contributions to global GHG reductions provides motivation for success, so “visualization” of contributions to reducing emissions of GHGs is important. As one effort towards this goal, Japanese industries have applied a system called “pledge and review” – in which companies pledge their own GHG reduction targets, implementing actual measures to achieve the targets, reviewing the measures and taking advanced global warming countermeasures- and the system has contributed to reductions of GHG emissions. “Contribution through law-carbon goods or services” and “international contributions” have already been included in and are now regarded as one of the important pillars in the Japan Business Federation’s “Commitment to a Low-Carbon Society”. Some industries in Japan are taking initiatives to quantify their reductions of GHG emissions, called avoided emissions.
June 2018
Carbone4
Aim
An offsetting and reporting focused initiative that also include avoided emissions as part of the strategy.
Aiming to offer an alternative to the simplistic claims of "carbon neutrality" and "offsetting" often used by companies, Net Zero Initiative proposes a unique framework for private sector action in favor of the only carbon neutrality objective making sense: that of the planet and of the national territories.
November 2018
Keidaren
Aim
The Concept Book explains the idea and significance of avoided emissions through the GVC. In the second half, it also introduces case studies of various industries and companies “visualizing” the avoided emissions achieved through a variety of products and services.
In order to promote efforts to avoid emissions through the GVC, it is important to “visualize” the amount of CO2 emissions avoided by companies and other various actors. By “visualizing” avoided emissions, companies can acknowledge the strengths of their products and services in a concrete manner. Furthermore, identifying these realities, they will be able to implement more effective climate change measures. What is important is that actors do not engage in “visualizing” avoided emissions for the purpose of claiming or fighting over credit for their contributions. The point is that each actor objectively evaluates the scale of environmental impact and potential avoided emissions based on the social characteristics of their business and quantifies avoided emissions through the value chain. This is in agreement with the spirit of voluntary approaches to be taken by various actors, as called for in the Paris Agreement. These efforts will further encourage cooperation among various concerned parties as well as stakeholder dialogue.
September 2019
GeSI/ Deloitte
Aim
This report identifies and quantifies the ways in which digital technologies, both established and cutting edge, are capable of delivering transformative impact against each of the 17 UN Sustainable Development Goals (SDGs).
The report draws on input from academics, key international NGOs and over 500 use cases – also provides specific recommendations and actions for all who are committed to taking on the 2030 Agenda and helping move the world onto a sustainable path.
November 2019
Mission Innovation NCI
Aim
Framework to assess avoided emissions.
- The Three-Step Solution Framework for Net-Zero Compatible Innovations (TSF) is the introductory framework, providing the context and background for the Net-Zero Compatible Solution Initiative. It describes how stakeholders can move from a reduction only perspective, to also include a solution perspective. It discusses the need to move beyond reductions in existing structures to sustainable system solutions.
- The Avoided Emissions Framework (AEF) is at the core of the initiative and provides guidance for how avoided emissions can be assessed. The objective is to develop a draft framework that is capable of classifying and then ranking companies/ solutions, based on their positive climate impact, through their supply of low carbon products and services.
- The 1.5°C Compatibility Pathfinder Framework (CPF) was developed in response to the IPCCs 1.5°C special report. It provides guidance for how innovations can be assessed to increase the probability for 1.5°C compatibility and especially whether they support an innovation driven low-energy demand pathway or focus mainly on supply-side measures.
January 2020
Exponential Roadmap Initiative
Aim
A handbook for CEOs, board members, managers and employees who want to prepare for the fastest economic transition in history – and help drive it. It is developed for companies and organisations of all sizes that want to align with the 1.5°C ambition through concrete action. It contains solid guidelines for setting climate targets and strategies, planning, taking action and disclosing results.
This guide focuses on four pillars that need to be addressed in a company’s climate strategy to align with the 1.5°C ambition.
Pillar 3 focuses on the company’s impact in society through the use of its products and services. It shifts the focus from only reducing the footprint to also providing solutions. Such a shiftrequires the alignment of the company’s vision, strategy, value proposition, and customer offerings with the 1.5°C ambition.
April 2020
Prime/ RHO Impact
Aim
Despite the importance of guiding investments to early-stage ventures with large potential climate impact, early-stage investors lacked a common lexicon to discuss the potential climate impacts of early-stage companies. Prior to CRANE, there has not been a standard methodology for assessing the potential climate impact of a new ventures and the technologies, solutions, or business models they bring to market.
Estimating emissions reduction potential is difficult, and doing it across hundreds of technologies is ambitious. We hope our users will view CRANE output reports as a helpful starting place for considering climate impact in their own diligence, reporting and conversations. Note that CRANE does not precisely forecast the future, but rather provides an estimate for future emissions reduction potential.
October 2021
Mission Innovation/ LEAD/ Swedish Scaleups
Aim
Introducing the PICU framework for incubators.
The purpose of this report is to present the PICU framework and the potential for incubators to play a key role in the urgent work to deliver the deep and fast emission reductions needed to avoid dangerous climate change. PICU is a framework with four steps to help incubators, identify start-ups with significant (P)otential, strengthen sustainability (I)deas, support (C)lustering, and enable accelerated (U)ptake of the solutions from the start-ups.
November 2021
Mission Innovation NCI
Aim
Framework to assess 1.5 °C Business Model Compatibility.
Identifying 1.5°C compatible innovations in the 4th industrial revolution that can deliver what is needed to allow 11 billion people to live flourishing lives.
January 2022
Panasonic
Aim
The GREEN IMPACT aims for a reduction impact of “around 1% (approximately 300 million tons)” of current total global CO2 emissions by 2050.
Panasonic is targeting all aspects of its businesses to reduce CO2 emissions, with three distinct areas of impact:
- OWN IMPACT/SCOPE 1-3 (the emission reduction impact in the company's own value chain)
- CONTRIBUTION IMPACT/ AVOIDED EMISSIONS (the emission reduction contribution impact on society of existing businesses)
- FUTURE IMPACT/ FUTURE AVOIDED EMISSIONS (the emission reduction contribution impact on society of new businesses and technologies).
May 2022
Tesla
Aim
Current ESG evaluation methodologies are fundamentally flawed. To achieve acutely-needed change, ESG needs to evolve to measure real-world Impact [avoided emissions].
Many ESG ratings evaluate: “Does this ESG issue impact the profitability of the company?” We need a system that evaluates: “Does the growth of this company have a positive impact on the world?”
This evolution of ESG needs to be championed by institutional investors, rating agencies, public companies and the general public. As the world needs to strive for a substantial positive impact, we won’t be referring to ESG in this report. Instead, we’ll talk about Impact.
August 2022
Mission Innovation, UNFCCC Global Innovation Hub, Global Covenant of Mayors and ICLEI
Aim
When the cities are not only reducing – or avoiding – their own emissions, but with focus on needs and utilizing opportunities provided by the 4th industrial revolution they help the rest of the world through export of 1.5°C solutions for a future with 11 billion citizens living flourishing lives.
The “Expanded Innovation Agenda for Cities” initiative is a part of the UNFCCC Innovation Hub and will be implemented in collaboration with Mission Innovation, the Global Covenant of Mayors for Climate & Energy, ICLEI, and other partners. The initiative aims at promoting the development and deployment and rapid uptake of transformative 1.5°C compatible solutions, including technology, policy, financial instruments, cooperation, and business models. Cities are relevant in multiple roles including, providers, enablers, implementers, and exporters of 1.5°C compatible climate innovations.
March 2023
World Business Council for Sustainable Development (WBCSD) and the Net Zero Initiative (NZI)
Aim
New avoided emissions guidance provides companies with a credible way to assess the decarbonizing impact of their solutions.
The five key areas to making credible avoided emissions claims covered in this guidance include:
- Defining avoided emissions
- Leveraging avoided emissions
- Ensuring the contribution is legitimate
- Assessing avoided emissions
- Reporting avoided emissions
March 2023
Mission Innovation/RISE
Aim
A four-step, purpose driven, climate impact assessment to assess the full climate impact from a company beyond product substitution.
This tool presents a four-step purpose driven climate impact assessment to assess the full climate impact from a company. Such an approach is important for three reasons. First, it broadens the focus beyond the product a company provides to also include the system delivering relevant impact, as well as the way a company delivers on human needs and how it changes structures and values in society. In this way the assessment provides a unique insight into how the company support, or undermine, a 1.5 °C global sustainable future. Current assessments that focus on companies reducing their own emissions can provide relevant insight, but also limit the focus to one where the best a company can do is to reduce emissions from current operations to zero, rather than developing globally sustainable system that support a future where 11 billion can live flourishing lives.
Second, it provides an opportunity to better understand purpose driven companies with business models based on the goal of improving society in a sustainable way. It can also help companies become purpose driven by highlighting how it can use the need for sustainable solutions that deliver on human needs as a driver for innovation.
Third, it can help stakeholders such as incubators, investors, and regions/cities to support globally sustainable solutions and support purpose driven companies.
April 2023
G7 Climate, Energy and Environment Ministers’ Communiqué in Sapporo
Aim
To facilitate innovation and scale-up investment in clean goods and services, which are key for realizing the necessary emissions reductions and achieving our climate goals.
In recognizing the potential value of avoided emissions, we acknowledge that this:
- is an additional perspective to encourage companies’ positive action towards net zero society. Avoided emissions should not lead to discouraging companies to accelerate reducing their own SCOPE1-3 emissions.
- is expected to be used as an additional perspective to promote/facilitate/provide recognition of the diffusion of clean goods and services needed globally to reach net-zero. Furthermore, it can also be used as a key metric to support decision-making within a company to prioritize and scale the deployment of solutions in markets with the greatest decarbonisation potential.
- is not designed to exclude small medium enterprises (SMEs) or start-ups, while ensuring robust criteria and measurement standard for claiming avoided emissions. Any proposed avoided emissions criteria and measurement standard will be expected to develop with consideration of minimizing disproportionate impacts to small businesses