Public Comments on the SEC Climate Disclosure Proposed Rule
The Securities and Exchange Commission (SEC) is proposing rule changes regarding the reporting of climate-related risk to include GHG emissions throughout a company’s value chain. The proposed rule would:
“[R]equire a registrant to disclose information about its direct greenhouse gas (GHG) emissions (Scope 1) and indirect emissions from purchased electricity or other forms of energy (Scope 2). In addition, a registrant would be required to disclose GHG emissions from upstream and downstream activities in its value chain (Scope 3), if material or if the registrant has set a GHG emissions target or goal that includes Scope 3 emissions.” – SEC Press Release, March 21, 2022.
Over the past two decades, GHGMI has educated GHG practitioners and developed training on corporate GHG accounting. In our research program, our team engages to raise awareness and develop evidence-based documentation of the key issues relating to corporate GHG accounting, including the market-based method for accounting scope 2 emissions using renewable energy credits (RECs), which is grossly misused and breaks with environmental accounting principles (see the Green Power FAQ). The findings of our research, and the broader scientific community, are included in the course content that we teach to our learners.
GHGMI’s comments – submitted to the SEC – draw upon existing scientific literature and our ongoing research efforts to inform the proposed rule.
GHGMI shares these comments to foster conversation and highlight key issues that exist in the GHG Protocol’s corporate accounting standards and how they are applied. We welcome respectful engagement on our submitted comments.