In the utility sector, “infrastructure” usually refers to things you can touch, poles and wires, substations, or pipelines. These tangible assets receive the greatest amount of capital and are rightly front and center in discussions about decarbonization, reliability, and cost.
However, beneath the visible buildout is another class of infrastructure that is just as critical to the energy transition yet far less developed: an invisible framework that accounts for, validates, and translates decarbonization for markets.
the steel and concrete that make up the physical infrastructure that powers our lives, this digital infrastructure plays a critical role in powering our economy and keeping us warm in the winter. Digital systems such as registries, market rules, data standards, verification protocols, software platforms, settlement systems, and governance frameworks enable energy markets to function. Together, this invisible web forms the accounting and coordination layer of decarbonization markets. Without it, renewable energy deployment may still occur, but clean energy claims, incentives, and investments break down.
This is the infrastructure that makes decarbonization legible and the means by which tech giants Microsoft can confidently reach their carbon-negative goals. Microsoft contracted 40 gigawatts (GW) of new renewable energy across 26 countries and worked with more than 95 utilities and developers on more than 400 contracts to hit its target of matching its total annual global electricity consumption with renewable sources.
Such large-scale achievements in renewable energy require investors, governments, and physical infrastructure owners to adapt to how they fund, construct, and maintain the physical as well as the invisible infrastructure. By applying a systems thinking approach focused on growth, which is what a modern technology-focused economy demands, ambitious decarbonization goals can become a reality.
Decarbonization is a Systems Problem, Not an Asset Problem
Utilities understand systems better than most industries. Power plants are useless without transmission, and transmission does not function without interconnection rules and standards. The reliability of our grid does not rely on a single asset, but on a system of generators, transmission lines, and coordinated rules and regulations.
Decarbonization operates under the same logic, yet the industry treats it as a physical infrastructure problem rather than a systems problem. A renewable generator or low-carbon molecule producer does not reduce emissions on their own. Impact, and just as importantly, value, requires a trusted system that measures, attributes, and verifies claims. However, because these systems do not resemble traditional infrastructure, they are often seen as secondary and not structural.
Failure of Systems Thinking
For decarbonization markets to function, the answer is not always just more clean megawatts and molecules—although this is a good thing. As energy and environmental attributes move through more complex value changes (i.e., from electron to molecule and into more complex molecules), a functional decarbonization market requires trust, standardization, and accountability. Invisible infrastructure, registries, data standards, etc., provides the trust, standardization, and accountability. However, they become an administrative afterthought without a systems thinking approach.
This is exactly the landscape we encounter today. Accounting standards lag physical deployment, market signals fragment, and we see a proliferation of competing standards and approaches, causing market confusion. This leads to regulatory intervention that is reactive rather than proactive. The result is a paradox familiar to the utility industry: more assets, more spending, higher costs, and less clarity.
Energy attribute certificate (EAC) registries illustrate this dynamic clearly. They exist to prevent double-counting and preserve market integrity. But registries only function within a broader system of definitions, verification, and governance. Without alignment across that system, registries become contested rather than authoritative. The failure of carbon markets to scale is a great example of this problem.
Why This Matters Now
Early clean energy markets tolerated ambiguity, and voluntary markets accepted imperfect accounting because reputational and financial exposure was limited. However, that tolerance no longer exists as these claims draw scrutiny not only from regulators but also from across the political spectrum.
Today, utilities, corporates, and governments are using environmental claims to justify rate recovery, compliance strategies, and capital allocation involving billions of dollars. Investors and regulators increasingly (as they should) scrutinize those claims. Weak infrastructure at the accounting layer now creates material financial risk. When accounting systems are unclear, utilities bear uncertainty even when physical assets perform as expected.
Reframing Invisible Infrastructure as Core Infrastructure
The energy transition does not suffer from a lack of capital, ambition, or engineering capability. It suffers from a mismatch between physical and invisible infrastructure and a lack of systems design thinking.
Treating invisible infrastructure similarly to how society treats physical infrastructure changes the approach. It invites long-term investment, durable governance, and coordination across stakeholders before fragmentation sets in. It aligns incentives between utilities, regulators and markets rather than forcing alignment after disputes arise. Decarbonization markets—especially environmental attribute certificate markets—fit this description precisely. Their success depends less on any single asset than on the integrity of the systems that bind them.
Regional Transmission Organizations (RTOs) are a great example of how invisible infrastructure can thrive when treated physical infrastructure. The energy markets RTOs run are invisible; however, as renewable penetrations increased across North America, RTOs adjusted their markets to accommodate the new market dynamic. This led to real-time dispatch optimization, congestion pricing, and attempts to reform the interconnection queue, leading the invisible infrastructure to support a physical grid reformation.
The European Union Emission Trading System (EU ETS) is another great example of an invisible system that succeeded because of its treatment as a physical, regulatory, and financial system. The EU ETS system scaled, leading to a 51% decline in emissions from stationary installations from 2005-2024, because it treated emissions as a tradable physical asset with strict standardized measurement, reporting, and verification requirements. This allowed markets to respond and provide for the reductions seen today.
Google’s recent announcement on its renewable energy infrastructure plans for a data center in Pine Island, Minnesota, further emphasizes how invisible infrastructure can unify multiple stakeholders. The wind power, solar, and battery storage Google intends to deploy to power its Minnesota data center will be owned by the local utility, Xcel. Google intends to pay a premium for the power, a result of a new tariff created to protect consumers from infrastructure costs while still allowing new clean energy deployments in the state. Behind this significant development towards renewable energy powering future technologies is the work between corporates, utilities, and local governments.
Making Systems Thinking and Invisible Infrastructure Visible
Utilities already operate within some of the most complex systems in the economy. It is not a stretch to apply that same discipline to the invisible infrastructure that supports their transition. In fact, it is a natural extension of how the sector already manages reliability, markets, and compliance. The invisible infrastructure of the energy transition will never be as visible as transmission towers or power plants. But without it, the system cannot function at scale.
The challenge is not building more assets. It is designing, implementing, and supporting the invisible infrastructure that allows those assets to work together as a system. If we continue to ignore the importance of investments in things data standards and EAC registries—the connective tissue that turn physical infrastructure into measurable, governable, and investible outcomes—we put the whole energy transition at risk.
About the Author
Benjamin Gerber is a former energy regulatory lawyer and the CEO ofCleanCounts, North America’s most expansive clean energy registry and a trusted gateway to environmental markets. As a national nonprofit organization, CleanCounts empowers participants across the energy ecosystem to track, trade, and validate clean energy production and consumption with confidence and transparency.
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Renewableenergyworld.com
