Subject: S7-17-22: WebForm Comments from Wei Li and Yulin Zhu
From: Wei Li and Yulin Zhu
Affiliation: Chair, Department of Accounting in Kent State University and Phd Candidate in accounting, Kent State University

Jun. 17, 2022

The investment community is pushing public companies to disclose their long-term commitments to address the climate changes, such as achieving net-zero carbon emissions by 2040 as signatories of the Climate Pledge.

However, our survey among 74 accounting-related employees in US companies (of which 74% are at the middle and upper levels of management) indicates that only 26% of them perceive such a long-term goal to be a realistic goal for corporations. Thus, while top management of US companies may have voluntarily chosen to disclose the long-term goals in their climate disclosures to please the investment community, our survey results indicate a concern about the achievability of long-term goals from internal participants.

Thus, should the investment community and employees care more about the disclosures on corporates short-term goals for carbon emissions, of which the progress can be monitored easily?

In addition, to ensure consistency and comparability among firms, they should use the same metrics to measure emissions over their short-term goal.