April 23, 2022
My name is David Beatson and I am currently a senior at the University of Colorado Boulder. I am studying Business Analytics and will be graduating in May of this year. I will be starting my career at KPMG, a firm which will be directly impacted by the adoption of the SEC Climate Disclosure Rule. While I will be a consultant, not an auditor, I will be working with many people and companies who will need to comply with this rule.
Personally, I am hugely in favor of this rule. While I believe that personal action regarding climate change is important, I believe that major corporations are truly the ones at fault for the climate crisis we find ourselves in. By forcing major companies to disclose climate-related risks that could have a material impact on their business, I believe that consumers will be able to make more informed decisions and that businesses will be forced to act in a more sustainable way.
One component of the potential rule that I worry about is the disclosure of Scope 3 emissions. Due to the complexity of Scope 3 emissions, I believe that companies will likely try to push the SEC to not require the disclosure of Scope 3 emissions. Considering the potentially huge amount of a company's emissions that can be categorized under Scope 3, I believe that many companies may seek to \"push\" their Scope 1 or Scope 2 emissions into Scope 3 to create a false image of climate friendliness. While I am in support of the short-term liability protection for Scope 3 emissions, I believe that there should be no extensions on this and that there should be a plan for smaller companies to be required to report their Scope 3 emissions as well. Overall, I believe that there needs to be a particularly heavy emphasis placed on Scope 3 emissions. Considering that many companies will likely not want to report their Scope 3 emissions and or will want to minimize the effects that they have on the company, I believe that strict enforcement of the new climate rule must be used.