NATSO urged the Securities and Exchange Commission (SEC) to develop policies that make energy technologies with more desirable emission characteristics cost-competitive with other sources of energy.
NATSO was joined by SIGMA in filing comments in response to the SEC’s Proposed Rule requiring public companies to disclose the risks from climate change that are reasonably likely to have material impacts on their businesses or financial condition.
[Review NATSO’s SEC Comments Here]
The SEC Proposal needs to be refined to avoid unnecessarily burdensome, and in some cases counter-productive, obligations on public and private companies.
“A narrowly tailored reporting requirement that focuses on Scope 1 and Scope 2 emissions, calculated in a manner that is consistent with other reporting regimes, some of which are already required under previously released SEC requirements, would both encourage companies to assess and reduce their carbon footprint and allow investors to assess companies’ financial exposure to climate change,” the associations wrote.
The SEC in March issued a 510-page proposal expressing concern that existing disclosures are uneven and inadequate and that greater consistency, comparability, and reliability is needed.
Public companies are currently required to tell investors about climate risk if they think the risk is "material." Approximately 33 percent of public companies made some type of climate disclosure in 2019 and 2020, according to the SEC. While some companies conduct scenario analyses, or have in place transition plans. The new rule would require disclosures to enable investors to understand those climate risk management tools as well and the proposal requires all public companies to make this type of disclosure.
Scope 1 Emissions -- Public companies must report any direct GHG emissions produced by sources controlled or owned by the company, including vehicles.
Scope 2 Emissions -- Public companies must also disclose indirect GHG emissions generated by a company's energy consumption, expressed both by disaggregated constituent GHG emissions and in the aggregate. Scope 2 emissions typically result from the purchase of electricity, fuel, or other forms of energy.
Scope 3 Emissions -- Indirect emissions produced by upstream and downstream activities in a company's value chain must be disclosed if "material" to the company or if the public company has set a GHG reduction target or goal that includes these emissions. The rule doesn't require companies to establish climate-related goals, but if they do, they would have to disclose Scope 3 Emissions.
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