Mar. 25, 2022
The proposed rule mentions Scope 3, but only requires Scope 3 “if material, or if the registrant has set a GHG emissions reduction target or goal that includes its Scope 3 emissions”. “If material” basically just leaves it up to the companies to decide if scope 3 emissions are “material” right? SEC should make Scope 3 reporting mandatory since scope 3 can make up to 80% of a company’s emissions. At the least make Scope 3 mandatory for meat and dairy companies. The top 5 meat and dairy companies combined emit more greenhouse gases than ExxonMobile, Shell, or BP. The condition of “if the registrant has set a GHG emissions reduction target or goal”, seems will only discourage companies from setting Scope 3 emissions targets in the first place to avoid reporting requirements. SEC should include a provision to prevent this. SEC should require asset and pension managers to disclose climate implications of the funds they offer to shareholders. The SEC should also require the federal Thrift Savings Plan to disclose the total climate impact of the holdings they manage to the general public as well as disclose to federal employees the climate impact of their individual account holdings. The TSP should also disclose the climate impact of the different fund options offered to federal employees.