The National Waste & Recycling Association (NWRA), Arlington, Virginia, has submitted comments to the U.S. Security and Exchange Commission (SEC) regarding its proposed rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors.
The NWRA supports the intent of the proposed rule but noted certain circumstances could arise if left unaddressed.
“NWRA and its member companies are supportive and believe we play a critical role in the transition to a low-carbon economy,” NWRA President and CEO Darrell Smith says. “We are not only doing our part to reduce greenhouse gas (GHG) emissions from our operations, but we also provide products and services that help our customers achieve their GHG reduction goals. We appreciate the opportunity to provide comments on the proposed rule and look forward to engaging with the SEC on this issue.”
Among its concerns with the proposed rule, NWRA says that there is not an accepted method to measure Scope 1 landfill GHG emissions as included in the proposed rule. NWRA recommended that SEC provide a safe harbor to landfill operators from liability as the methodology and measurement of fugitive landfill gases continue to evolve. Part of the reason for this is the complex calculations currently involved in estimating landfill gas emissions, which—if reported too early—could yield “significantly different results than the results estimated otherwise,” Smith writes in the June 17 comments submitted to the SEC.
As such, the NWRA recommends that the SEC allow certain companies to report their climate-related disclosures later in the year separate from the Form10-K filing or to disclose data for a given year on the Form 10-K for the following year.
NWRA also says that disclosing board members with climate expertise could impact board governance structures, and initial compliance dates may not allow enough time for collection, analysis, and disclosure of GHG data.
In addition, the NWRA says any proposed SEC rules that are “requirements that are inconsistent with widely accepted frameworks, namely the standards published by the GHG Protocol and recommendations by the Task Force on Climate-Related Financial Disclosures, would be unnecessarily burdensome and counterproductive to the standardization of GHG reporting requirements that is necessary for investor confidence.”