March 25, 2022
I support the proposed rule and the emphasis on reporting Scope 1 and 2 emissions, in addition to material Scope 3 categories and climate-related risks and opportunities in line with the TCFD recommendations. This would allow me to effectively evaluate a company's climate initiatives and policies. Most of my clients have been measuring and reporting Scope 1 and 2 emissions and climate-related risks and opportunities for years in their ESG reports and reporting to CDP, but not all report Scope 3 emissions, not all perform scenario analysis, not all receive third-party assurance, and few report this information in their financial statements. I therefore support the phase-in period over the next 2-3 years to give companies the opportunity to review and adopt these requirements effectively. I would encourage the SEC to create a central repository for these reports and to make it easy to compare these climate data across companies. Lastly, I support mandating Scope 3 disclosures, but also allowing a safe harbor due to the current difficulty of accurately measuring these emissions.