September 23, 2021

Climate Change: What Do the Staff’s Comments Look Like So Far?

While it’s helpful to know what kind of climate comments the Staff says companies should expect to receive, it’s also good to have some insight into what comments the Staff’s provided to date. My colleague Lawrence Heim addressed that topic in this recent blog, and it turns out that those comments are pretty consistent with what the Staff is telling companies to expect.

Lawrence cites this Gibson Dunn alert that reviews these comments & provides advice on how to prepare for them, but he also adds the following additional thoughts:

The alert walks through recommendations to prepare for the possibility of a comment on this topic. I would add to those – validate the data and assumptions on which you relied in (a) quantifying your emissions and (b) making future reduction commitments. At a minimum, consider using an internal team of environmental and internal audit staff, augmented with other internal functions as needed. Alternatively, it may be worth considering engaging a qualified external climate emissions quantification and/or risk management expert.

John Jenkins