IPAA was among 33 trade and industry associations led by the Western Energy Alliance in writing to the Securities and Exchange Commission to “respectfully request that SEC provide a substantial comment period for the climate change disclosure rule given the size, scope, complexity, and ramifications of the rule. The 39 days allotted for comment since the proposed rule was published in the Federal Register are woefully inadequate for the magnitude of this rule, which runs to 506 pages, contains 1,068 footnotes, references 194 dense academic and governmental reports, imposes a $10.235 billion cost on society, and seeks answers to 196 discrete questions. The public requires ample time to consider all the materials SEC has laid out in this rule in order to thoughtfully and thoroughly respond. Likewise, SEC has a statutory obligation to provide the public with a meaningful opportunity to comment. Thirty-nine days does not constitute a meaningful opportunity when there are so many wide- ranging economic and financial impacts from this rule.”
The associations on the letter represent thousands of upstream, midstream, downstream, and service companies in the oil and natural gas industry across the entire country.