Oct. 02, 2022
October 2, 2022 I like that it would create transparency and the ability to compare 'apples to apples on a company's risk exposure and greenhouse gas emissions to make the best decision for themselves. I think this makes complete sense and aligns with other requirements of filing with the SEC to provide investors with the information needed to make the best investment decision. I am particularly supportive of Scope 2, which will require a registrant would be required to disclose GHG emissions from upstream and downstream activities in its value chain. This approach provides more visibility into the full impact of business operations on the environment. However, I'd like to see some improvement or clarification around requirements for existing registrants. They should be held to the same standard as new registrants and given a certain period - maybe one year, to produce the report. There is also an opportunity to add clarification around Scope 2 - I think including a complete 'cradle-to-grave audit of the supply and, especially the transportation effects are critical to understanding the true impact of the business. This suggested approach could mirror that of the RCRA requirements for manifest reporting. I strongly believe that the 'transportation aspect should be required because transportation is the most significant contributor to greenhouse gas emissions.