CRES Submits Comments to SEC on Overreaching Climate Disclosure Rule and Risks to American Companies

WASHINGTON, June 14, 2022 Citizens for Responsible Energy Solutions (CRES) submitted comments today urging the U.S. Securities and Exchange Commission (SEC) to revisit the proposed rule on climate-related disclosures.

“CRES has long supported voluntary corporate greenhouse gas disclosures and voluntary commitments that address climate change,” wrote Heather Reams, president of CRES. “Consistent with this view, we have a number of concerns about the proposed rule in terms of the SEC’s authority, as well as the scope, cost, and unanticipated carbon leakage issues associated with the proposal.”

“The SEC should seek an approach that achieves consensus on the Commission and will ultimately provide businesses more certainty, not less, on their climate-related disclosures,” Reams continued. “An effective energy strategy will enhance our national security, reduce global emissions, provide American investors with reliable information, and assure that American companies are not disadvantaged in the global marketplace.”

Such an approach, as detailed in CRES Forum’s recent white paper — “Disclosure or Climate Policy? The SEC’s Role in the Climate Debate”—which was also submitted to the SEC, would include the following:

  • Updating existing guidance before promulgating a new rule – The SEC needs to adequately explain how the current regulations and legal protections for investors do not, or could not with updated guidance, provide reasonable investors with adequate information to inform investment strategy.
  • Better inter-agency coordination – The SEC should defer to the Environmental Protection Agency (EPA) to improve the utility of existing data for investors instead of creating a new duplicative GHG reporting disclosure framework that increases the reporting burden for companies.
  • Acknowledging the low-quality and high-cost nature of Scope 3 data – The SEC should provide a more robust and adequate cost-benefit analysis of the entire rule with particular focus on Scope 3 emissions given their incredibly high costs in both compliance and potential for increased liability.
  • Evaluating carbon leakage – To the extent it must evaluate issues outside its jurisdiction and expertise, the SEC should explain how mandates on publicly traded companies will in fact accomplish their goal of addressing climate-related risk given the global issue of carbon leakage.

Click HERE to read the full letter.

As part of CRES Forum’s white paper series — “Understanding the Facts”—registration is open for a briefing on the white paper “U.S. Plastics Manufacturing Offers Opportunities for Global Emissions Reductionism” this Thursday, June 16 at CRES Forum’s headquarters (1201 Pennsylvania NW, Washington, D.C.). The policy program will begin at 3:00 PM ET and a networking reception will follow. Journalists and attendees can register HERE.


Citizens for Responsible Energy Solutions (CRES) engages Republican policymakers and the public about responsible, conservative solutions to address our nation’s energy, economic, and environmental security while increasing America’s competitive edge. For more information, visit

Scroll to Top