April 14, 2022
There is a saying in northern England where theres muck, theres brass translated, where theres mess, theres money. My Company, Valkyrie Production and Abandonment, LLC, was created with the concept of extensive data analytics and artificial intelligence to capitalize on residual opportunities on end-of-life oil fields with extensive abandonment and environmental burden, abandoning redundant wells and facilities, and ultimately closing the door, and turning off the lights. Creating brass from muck, money from mess in fields that represent a burden to current owners and society at large.
This proposed rule could provide a common repository of data and information, benchmarked to a common format, that will allow innovative individuals and companies like us to identify opportunities. Consistent, comparable, and reliable disclosures on the material climate-related risks public companies face would not only serve their own investors and capital, but investors and capital looking to invest to innovate and develop new technologies to mitigate and monetize. Capitalizing on the challenges current players are facing, and turning it into a significant business opportunity, generating employment and wealth, and turning a negative impact on the financial system into a positive.
The procedural protocol for incumbents could be staged much like the NEPA obligations to action agencies. Issuers generate a Level-1 Climate Assessment Review (CAR), after which they might proceed to file a Finding Of No Significant Climate Impact (FONSCI), with appropriate supporting data. If CAR indicates otherwise, a Level-2 review is conducted, and a Climate Impact Statement (CIS) is issued, comprising a more extensive level of analysis and data presented. Periodicity of reviews would be predicated on the immediate risk of hazard levels identified, and risk modification from material changes, positive or negative, occurring in the fiscal year.
This exciting development is predicated on achieving the stated SEC goal - consistent, comparable, and reliable disclosures. Only in this way can innovators sort through the vast array of data and other filings to develop viable business plans and work with incumbents and society towards a win-win-win solution.