AGA-EEI Joint Comments on SEC Climate-Related Financial Disclosures Proposed Rule Filed June 17, 2022

AGA-EEI Joint Comments on SEC Climate-Related Financial Disclosures Proposed Rule Filed June 17, 2022

The American Gas Association (AGA) and EEI are leaders in voluntary ESG reporting and pioneered the first-of-its-kind, sector-wide, EEI-AGA ESG Reporting Template more than six years ago. We recognize and support SEC's ongoing efforts to enhance and standardize climate-related disclosures to investors and offer constructive suggestions for improving the draft rule, including adjusting the disclosure, audit and attestation requirements in the rule to bring down compliance costs and to improve the final rule.

In our comments, we encouraged the Commission to ensure that the incremental disclosures produce benefits that outweigh the costs and avoid causing investor confusion by requiring the disclosure of overwhelmingly voluminous, immaterial information. The timing for the first reports is also critical. We encouraged the Commission to delay the effective date until two fiscal years after publication of the final rule to give companies enough time to implement the systems needed to gather the required data. We also noted that the final rule also should require only prospective disclosures, since companies cannot have the requisite systems in place until after they know what the rule will require. With these changes and others suggested in our joint comments, the new disclosure requirements could better balance the costs to utility customers with the benefits of providing investors with more reliable, comparable, and useful information for making informed investment decisions