The National Waste & Recycling Association (NWRA), Arlington, Virginia, submitted comments to the United States Security and Exchange Commission (SEC) regarding its proposed rule on improving and standardizing climate-related information for investors.
The NWRA supports the intent of the proposed rule, but notes that certain circumstances could arise if not addressed.
“The NWRA and its member companies support us and believe that we are playing a vital role in the transition to a low carbon economy,” said NWRA President and CEO Darrell Smith. “Not only are we doing our part to reduce greenhouse gas (GHG) emissions from our operations, but we also provide products and services that help our customers meet 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 matter.
Among its concerns with the proposed rule, the NWRA indicates that there is no accepted method for measuring GHG emissions from Scope 1 landfills as included in the proposed rule. The NWRA recommended that the SEC provide a safe harbor for landfill operators from liability as the methodology and measurement of fugitive landfill gases continue to evolve. This is partly because of the complex calculations currently involved in estimating landfill gas emissions, which, if reported too early, could yield “significantly different results than those otherwise estimated,” 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 separately from the Form 10-K filing or to disclose data for a given year on the Form 10-K. for the following year..
The NWRA also indicates that disclosing board members with climate expertise could impact board governance structures, and initial compliance dates may not allow sufficient time to collection, analysis and disclosure of GHG data.
Further, the NWRA asserts that any proposed SEC rules that are “requirements inconsistent with widely accepted frameworks, namely the standards published by the GHG Protocol and the recommendations of 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.