SSV Advocacy Update: SEC 10ks, BARC, Seamless Transit & More
This is the busy season for legislation and rulemaking. Here’s a review of what SSV has been up to on a number of fronts. Here are excerpts from our letters.
The Securities and Exchange Commision
Subject: Proposed Rule [Release No. 33-11402; File No. S7-10-22]: Enhancement and Standardization of Climate-Related Disclosures for Investors – SUPPORT
We would like to express our support for the Enhancement and Standardization of Climate-Related Disclosures for Investors.
The proposed rule is well within the SEC’s mission to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. Requiring publicly traded firms to enhance disclosures about climate risks and impacts is totally consistent with existing requirements to fully disclose other material risks.
Climate risks and impacts are material to investment decisions.
Uniformity of emissions reporting and other climate change disclosure protects investors by requiring actual risks to be disclosed in a standardized manner.
Industry-specific metrics: To help investors compare climate risks and impacts for public companies in the same industries, there should be standard reporting frameworks by industry, which various independent groups (TCFD, SASB, etc.) have proposed and are endorsed by hundreds of companies and investors globally.
Scope 1 and Scope 2 emission reporting should be detailed enough to distinguish a company’s actual emissions from net emissions resulting from carbon credits and offsets. Additionally, reporting on a company’s total emissions should include supporting detail showing emissions by major processes (i.e., mineral extraction, distribution, manufacturing), particularly for vertically integrated companies.
Regular updates: SEC Climate Reporting Rules, particularly around Scope 3 emissions, should continue to evolve as transparency and standardization for Scope 1 & 2 reporting and other metrics improve.
Bay Area Regional Collaborative (BARC)
Subject: Attn: Draft Shared Work Plan
We would like to express our strong support for BARC’s Shared Work Plan in service of September’s Joint Resolution to Address Climate Change.
If we are to meet the myriad challenges of a drastically changing climate, we must do it together. It will take an abundance of villages, united in a region. The Shared Work Plan’s goal of strategically aligning regional planning and regulatory initiatives is a necessary step towards accelerating implementation of effective strategies.
Many Sustainable Silicon Valley programs and initiatives dovetail with BARC Work Plan focus areas. Some examples: our recently completed cloud-based, AI-powered intelligent Transit Signal Priority (iTSP) pilot demonstrated significantly reduced intersection delays and overall route travel time; we have long championed water reuse and are working to smooth satellite facility permitting and interconnection; our Regenerative Communities project is currently analyzing a portfolio of large commercial development projects through a multi-factor sustainable lens; we’ve been advocating for seamless transit through our ongoing support for Senate Bill 917; and we’ve been promoting the valuation of multi-benefits through strategic and budgetary approaches to urban cooling through our work with the Smart Surfaces Coalition.
The California Legislature
Senate Committee on Transportation
Subject: SB 917 Seamless Transit Transformation Act– SUPPORT
We would like to express our support for SB 917 and greater coordination and integration across Bay Area transit agencies.
While there have been some improvements of late (Caltrain synchs with BART in Millbrae!) no one would be hard pressed to argue that the Bay Area’s twenty-seven operators sing from the same songbook. The public transit rider experience needs integrated fares, a unified map, a sensible transfer system and overall, a Connected Network Plan.
Of course, as always, the current ‘system’ impacts lower income citizens, with fewer options, the most. A thriving Bay Area requires robust public transit that works for all, it needs to be much more than the sum of its parts. This known problem must become a strength. We need a seamless solution now.
Senate Energy, Utilities and Communications Committee
Subject: SB 1469 Water corporations: demand elasticity – SUPPORT
We would like to express our support for SB 1469, the decoupling of water rates and sales volume and the promise of aligning water efficiency incentives through performance-based standards.
For Californians to adapt to our changing climate, water efficiency needs to be central to our way of life. This demands good governance and regulation as much as it requires stable infrastructure, process innovation and sensible supply management.
We face another grim drought year overlayed with lagging levels of residential water savings. The Climate Emergency (Water Scarcity Division) is no less real if it slowmoving. It is incumbent on the Public Utility Commission to achieve the twin goals of wise water use and fair pricing. The public good demands creative, well-designed decoupling mechanisms that deliver tangible usage reductions, applying relevant aspects of its energy-side program experience to water rate cases. SB 1469 is a strong step in the right direction.
Senate Energy, Utilities and Communications Committee
Subject: SB 1112 (Becker) Tariffed On-Bill (TOB) Investment Enablement– SUPPORT
We would like to express our support for SB 1112 and the Energy Commission’s active involvement and support for low-cost capital for climate-beneficial building “decarbonization upgrades” through Tariffed On-Bill (TOB) investment programs.
Utility TOB programs have proven to be scalable investment model for the acceleration of energy and water efficiency across the country. Ratepayers make needed upgrades to their homes, and the tariff remains attached to the meter. SB 1112 aids the TOB process through county recording, landlord disclosure and state agency funding and financing direction. California utilities do not currently offer TOB programs; it is high time they kept “pace” with progressive counterparts across the country.
Other bills we’ve taken support positions, signing on to joint letters:
· SB 1230…EV Incentive Program Unification
· SB 1482…Building standards: electric vehicle charging infrastructure
· SB 778…Buy Clean California Act: Environmental Product Declarations: concrete