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[Ed. note: No blog will be published Monday as our office will be closed in observance of Juneteenth. Some history – President Abraham Lincoln issued the Emancipation Proclamation on January 1, 1863, but it wasn’t until June 19, 1865 that approximately 2,000 Union troops arrived in Galveston, Texas, announcing that the more than 250,000 enslaved Africans there were free. Today, the holiday stands for African Americans’ liberation, resilience and excellence. It’s a day to celebrate the freedom and strength of a community that has fought and overcome years of exploitation. Historically, this holiday was largely unknown by many Americans and only became a federal holiday in 2021.]

In advance of the long weekend, today’s blog is a short one and borrows from First, earlier this week SEC published its Spring 2023 Reg Flex Agenda, which reflects the targeted timeframe for planned rulemaking. Generally, it looks like the most significant, unfinished rulemaking previously targeted for April has been pushed out to October – the Climate Change Disclosure. As we always caution – “Of course, these dates are aspirational and signify general timeframes versus precise dates. The Reg Flex Agenda can give insight into current (or, at least, as of April 10th) priorities of the Chair, but it isn’t a definitive guide for anyone trying to predict SEC rulemaking for purposes of specific board agendas, budget and workflow.”

Second, Meredith wrote about a recent “quantitative analysis of the SEC’s climate and ESG-focused comment letters issued from July 1, 2021 to March 31, 2023. The article categorizes the comments according to the nine topics identified by the SEC in its sample letter plus one additional topic – ‘greenwashing’ – and considered the qualities of the reporting entities who received these letters to identify key characteristics.” She points out that:

“… while the SEC has continued to focus on the issue of greenwashing, most of the SEC comment letters concerning the climate change topics identified in the Sample Letter were issued either in September 2021 (when the Sample Letter was published) or in a second burst of activity from May–September 2022 – the SEC does not appear to have inquired about those topics since November 2022. Finally, it is also noteworthy that the reporting entities receiving a comment letter aligned with the topics identified in the Sample Letter were concentrated in the Energy & Transport or Manufacturing sectors – about two-thirds of the total.

…  it appears that the reporting entities that received questions corresponding to the topics identified in the Sample Letter were usually asked about a majority of those topics, and that Physical Effects, Capital Expenditures, Indirect Consequences, Compliance Costs, and Carbon Offsets were the most frequent climate change topics that were the subject of inquiry.”

This is expected to change in the future: “the SEC’s comment letter focus with respect to climate change will eventually shift to the mandatory climate rules, if and when adopted.”

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile