Feb. 20, 2023
February 20, 2023 Thank you for the opportunity to provide comments on the proposed rules. Overall, I am in support of the key elements in the disclosure approach as climate change is a critical conversation and climate-related reporting is a direct path to communication. There are, however, a few details that I suggest some alteration to. Include Boundaries on the Type of Emissions Required to Report Under Scope 3 Emissions reported under Scopes 1 and 2 have a near direct line of sight by the business. These direct and indirect emissions may be reported with a higher level of confidence bordering guarantee by the report. Suffice to say, most reporting agencies have grown comfortable attesting to their Scope 1 and Scope 2 emissions. Emissions to be reported under Scope 3 are too broad, undefined, and based on varying measurements. The framework for Scope 3 disclosure has not yet matured to the level of consistency and accuracy on par with what the SEC requires. The Commission should reconsider including Scope 3 reporting requirements or, at a minimum, include specific guidance on which emissions to disclose. The 1% Threshold for Disclosure is Immaterial Currently, most utilities use the FERC Uniform System of Accounts which does not provide the level required to identify a 1% variance. Nor have they been expected to identify variances at this minute level. Additionally, 1% applied across varying line items may range from what may seem significant for large spend items, in the tens of millions of dollars, to seemingly insignificant for lower cost spend in the thousands of dollars both of each, when applying a 1% threshold variance may, or in most cases, may not reach the level of materiality currently seen on financial filings. The 1% threshold should be replaced with the traditional materiality threshold. Reporting Duplication by Parents and Subsidiaries As proposed, the rule would require that a parent and each subsidiary provide the rule information, attestation, and footnote. Meaning, the parents information would also be included in that of the subsidiaries resulting in duplicate reporting. To avoid duplicate reporting, consolidated subsidiaries of a parent, where the parent disclosure includes the subsidiaries, should exempt from the rule.