Apr. 25, 2022
comment for S7-10-22: Greenhouse Gas (GHG) emissions are already regulated under the EPA under the Clean Air Act. Should a publicly traded company’s GHG emissions trigger EPA permitting, then a federal major source permit showing their potential to emit GHG emissions and actual reported emissions would be readily/publicly available. Requiring all publicly traded companies to disclose their GHG emissions through the SEC is outside the SECs jurisdiction to regulate. Instead, why can’t the SEC require companies applicable to the EPA’s GHG permitting and reporting to provide copies of their permitting status and compliance with EPA’s GHG regulations? This proposed rule with respect to the proposed GHG emissions disclosures misses its goal in transparency of environmental risk disclosure. Quantifying GHG emissions is already under the EPA’s jurisdiction for sources applicable to GHG emission permitting and reporting. A more cost-effective approach for all parties would be to request whether or not a publicly traded company is applicable to GHG emissions permitting and reporting, and whether there are any fines or proof of non-compliance needing to be disclosed. Thank you for considering these comments.