Sep. 28, 2022
September 28, 2022 I like that this rule would provide a standardized approach to climate-related disclosures to the investor on the topics of climate control efforts and greenhouse gas emissions that would allow them to make more informed decisions regarding risks. Now, more than ever, investors are evaluating companies climate-change efforts for financial risks and moral standing. What this rule may mean for the future beyond the SEC: (1) If approved, the streamlined approach and transparency of reporting greenhouse gases may provide for advancements in technology that can reduce the amount of greenhouse gases produced in various industries. (2) Greenhouse gas reporting may also lead to the adoption of greenhouse gases as a criteria pollutant in the Clean Air Act (CAA). This adoption would set limits on greenhouse gas production. Although regulating companies to provide greenhouse gas emissions annually provides streamlined data to the investor as an additional evaluation tool to analyze investment risks, this requirement seems to be an overreach of authority. The SEC is responsible for protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation requiring companies to provide emission reports falls outside the scope of SECs responsibility. The SEC should allow for the EPA to regulate greenhouse gas emission reporting via the CAA. If greenhouse gas emissions are to be shared with investors, why not let companies furnish emission reports to investors rather than file emissions reports with the SEC? Additionally, this requirement would require companies to bear the cost of monitoring and testing for greenhouse gas emissions. Ultimately, this cost would fall on investors. Since 2010, the SEC has required companies to disclose climate change related information. Instead of regulating the requirement of greenhouse gas emissions reporting, why not streamline the way climate change related information is provided to the SEC? Any streamlined approach to seeing uniform data would help the investor take calculated risks.