The University of New Hampshire (UNH) published its first carbon footprint in 2001. In 2007, UNH joined hundreds of other higher education institutions in voluntarily committing to regularly updating and publicly reporting that footprint in their journey toward carbon neutrality. Nearly two decades later, large publicly traded companies in the US will be required to do the same, thanks to last week’s adoption of the first-ever national climate disclosure rule by the U.S. Securities and Exchange Commission (SEC). The rule, which passed 3-2 on March 6th, 2024, will mark the first time that large, publicly traded companies will be legally required to publicly disclose their greenhouse gas emissions and other climate risk factors.
This is welcome news to the UNH SIMAP team and to the many leading organizations and individuals who have already seen the benefits of tracking and reducing their greenhouse gas emissions.
Through our carbon footprint tool SIMAP and professional and student training programs, we have had the privilege to support thousands of organizations in their carbon accounting and reporting work, and these organizations have paved the way for effective, standardized methods and tools through years of “learning by doing.” Voluntary leadership and collaboration, across sectors and organizations and years, have brought us to this exciting moment which represents a long-awaited shift to broader societal reckoning with climate risk and opportunity—financial and otherwise.
However, notably missing from the rule is a requirement to disclose indirect “scope 3” emissions. These value chain emissions are further removed from an organization compared to scope 1 and 2, but provide important information about the upstream and downstream effects of a company’s operations. The original draft of the SEC’s climate disclosure rule included scope 3 emissions when they were considered “material.” However, this scope 3 requirement generated major backlash in the public comment period, largely by companies concerned about that scope 3 reporting would be too onerous.
Although it is challenging to calculate an organization’s complete scope 3 emissions, it is important: Scope 3 sources typically make up well over 50% of an organization’s complete carbon footprint. If we do not include scope 3 sources, we do not have the full picture and are not considering all the leverage points at our disposal to meet the urgency and scale that global climate change presents. This makes the scope 3 gap in the SEC rule significant. The good news is that many organizations have been reporting these emissions voluntarily for years, and will continue to push the work forward. Likewise, technology is rapidly reducing the barriers to quality scope 3 reporting, and a great deal of entrepreneurial innovation and investment is currently focused on this problem.
Perhaps more concerning in the disclosure rule is the use of the word “material” for describing the requirement for organizations to publicly report their scope 1 emissions. The original draft of the SEC rule had a blanket requirement to completely report all scope 1 and scope 2 emissions. Requiring only “material” scope 1 and 2 emissions (with materiality subjectively determined by prospective reporters themselves) provides a large loophole for companies that do not wish to report.
In spite of these two disappointing features of the final rule, it is still a major step forward in climate action. Release of its draft two years ago has already prompted many more companies to begin to explore their climate risk and carbon footprint.
Last week’s final adoption of the rule, which has both emissions disclosure mandates and a requirement to report a broad range of climate risk information, will continue to accelerate this trend (likely litigation notwithstanding). The resulting growth of the data set around company greenhouse gas emissions will give us a better sense of how we are doing at tackling climate change. The additional disclosures will also provide a valuable data set that can be used to calculate more accurate emissions factors and even to improve the accuracy of others’ greenhouse gas inventories.
This rule from the SEC follows recent climate disclosure rules for companies in Europe and California. Both go much further than the SEC’s, requiring large companies to disclose both their direct AND indirect emissions (i.e., all scope 1, 2, and 3 emissions). These European and Californian rules—slated to go into effect in 2025 and 2026 respectively—will likely have major ripple effects since they apply not just to businesses headquartered in their respective borders, but to any companies doing business there that also have revenue greater than specific thresholds (e.g., $1 billion for California). As companies doing business in California and Europe work to comply with those more sweeping rules, it will likely have ripple effects for SEC—and other—reporting as well.
As we often say in climate reporting, “You can’t manage what you don’t measure,” and all of these climate disclosure rules will allow for more informed climate action strategies to help us tackle the climate crisis. The challenge now will be to rapidly train the experts and analysts who can make this expanded carbon reporting a reality.
Last December, LinkedIn’s Global Green Skills 2022 report noted “If we’re to deliver real change, we have to think about green roles and green skills.” This report was widely touted for calling attention to the large discrepancy between the number of workers needed versus those available with the necessary knowledge and skills to lead organizations in measuring and managing their emissions.
At UNH, we are doing our part to close that gap with programs like the Climate Action Clinic and Carbon Footprinting Certificate, with our own exploration of our scope 3 footprint, and with our continued support of SIMAP itself. We are excited to continue to have a “front row seat” when it comes to climate leadership and action—and hopeful that the next two decades will be even more impactful and inspiring than the past two.
Jenn Andrews and Dr. Allison (Alley) Leach are co-developers of SIMAP, the campus carbon and nitrogen footprint tool hosted by the UNH Sustainability Institute and co-instructors for the Climate Action Clinic and PD&T Carbon Footprinting Certificate.
Jenn is a Project Director at the UNH Sustainability Institute where for more than ten years she has led a range of sustainability programs, including UNH’s sustainability reporting to AASHE STARS and the Climate Commitment, its SIMAP initiative, the Sustainability Fellows, and the Climate Action Clinic programs. Before coming to UNHSI, Jenn spent 13 years at the nonprofit Clean Air-Cool Planet, promoting and supporting practical climate solutions for colleges and universities as well as municipalities and businesses. During her tenure there she helped to launch, oversee and continually develop the Campus Carbon Calculator, to the point where it has become an indispensable carbon management and sustainability tool for hundreds of colleges and universities nationwide.
Alley is the SIMAP Program Manager with the UNH Sustainability Institute. In addition to leading research and development for SIMAP, Alley teaches two training programs on carbon accounting: A professional training called the Carbon Footprinting Certificate through UNH PD&T and an undergraduate course called the Climate Action Clinic. Alley is also an active member of the international nitrogen research community and regularly gives talks on her nitrogen footprint research and food footprint label research. Prior to arriving at UNH, Allison was a researcher and graduate student at the University of Virginia where she developed the first-ever university level nitrogen footprint model. She holds a B.S. and M.S. in Environmental Sciences from the University of Virginia and a Ph.D. in Natural Resources and Environmental Studies from the University of New Hampshire. Her dissertation was titled "The Nitrogen Challenge: Footprints Tools and On-Farm Solutions."
