Jun. 15, 2022
June 15, 2022 I feel this is an important and thoughtful proposal that would elicit meaningful, comparable disclosures that investors need to assess climate-related financial risks, but requires strengthening in a few areas. Scope 3 (value chain) GHG emissions are only required if they are material as determined by the issuer, or if they have set a public Scope 3 emissions target. This should be made mandatory for all large registrants with reasonable assurance (Question 98). There is also a safe harbor from liability with no sunset that should be excluded in the final rule. Per the proposal, Scope 3 disclosures will be judged to not be fraudulent unless it is shown that such statement was made or reaffirmed without reasonable basis or was disclosed other than in good faith (Pg. 489). The proposal should incorporate more disclosures around environmental justice, just transition for dislocated workers, and community-level impacts.