Clean Air Task Force and Green Strategies File Comments on SEC Climate Disclosure Rule
June 21, 2022
Clean Air Task Force (CATF) and Green Strategies are pleased to offer comments on the SEC’s proposed rule on climate-related financial disclosures.
CATF and Green Strategies fully support the Commission in this effort to adopt required climate disclosures. We offer suggestions on ways the Commission can strengthen the Rules to better achieve their purpose.
Our main suggestions are as follows:
- The Commission should not require registrants to only disclose Scope 2 greenhouse gas emissions calculated through the Greenhouse Gas Protocol. Scope 2 reporting under the Protocol as it is currently written does not fully convey the extent to which a registrant is reliant upon fossil fuel-generated electricity. We urge the Commission to require the disclosure of additional information to more fully capture the risks related to a registrant’s reliance on fossil generation.
- The Greenhouse Gas Protocol also falls short in capturing the actual decarbonization impact of a registrant’s electricity procurement decisions – that is, the extent to which actual GHG emissions were decreased. Commission should require modest additional disclosures that provide more information on the carbon impact of a registrant’s electricity purchases.
We have included the complete version of our comments as submitted to the Securities and Exchange Commission below. We applaud the SEC for its robust consideration of the climate disclosure rule as it will be a necessary and transformative decision for both for the climate and financial risk management.
CATF and Green Strategies - SEC Comments
Update 6/23/22 – Comments have now been uploaded by the SEC. Please view here.
