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REQUEST FOR COMMENT ON DISCLOSURE OF CLIMATE-RELATED MATTERS
Canadian Securities Administrators are requesting comment on Proposed National Instrument 51-107 Disclosure of Climate-related Matters. Closing date for comments is Jan. 17, 2022.

MISSION
According to the Mission Statement of the Canadian Securities Administrators:
“The mission of CSA members is threefold: to protect investors from unfair, improper or fraudulent practices; to foster fair and efficient capital markets; and to reduce risks to the market’s integrity and to investor confidence in the markets.”

MATERIAL CHANGE
Canadian Securities Administrators are requesting comment on Proposed National Instrument 51-107 Disclosure of Climate-related Matters. Closing date for comments is Jan. 17, 2022.

Before offering comment, it is prudent to consider if there has been any material change in our understanding of climate change or the impact of climate policies in the interim, since the final report of the Task Force on Climate Related Disclosures, issued in 2017.

This review and commentary is offered in the spirit of National Instrument 51-102 Continuous Disclosure Obligations and will review material changes in the business and evidence about climate change and human influence which will have a significant effect on the market price and value of climate-related industries.

National Instrument 51-102 Continuous Disclosure Obligations
“material change” means (a) a change in the business, operations or capital of the reporting issuer that would reasonably be expected to have a significant effect on the market price or value of any of the securities of the reporting issuer; or (b) a decision to implement a change referred to in paragraph (a) made by the board of directors or other persons acting in a similar capacity or by senior management of the reporting issuer who believe that confirmation of the decision by the board of directors or any other persons acting in a similar capacity is probable;

CHANGE IN THE BUSINESS CASE
According to the Bank of Canada report “Using Scenario Analysis to Assess Climate Transition Risk (2022)” released on Jan 14, 2022, the scenarios are based on an earlier work of the Bank of Canada from 2020.

Unfortunately, these assumptions have been shown by Bjorn Lomborg to be wrong. Even if all countries met their Paris Agreement targets, there would be an immeasurable reduction in warming, the costs would be $1 to 2 trillion dollars per year for no change in climate and no assurance that there would not be extreme weather events as these are integral to climate and not driven by carbon dioxide emissions or global warming.

Dr. Lomborg’s research reveals:
• The climate impact of all Paris INDC promises is minuscule: if we measure the impact of every nation fulfilling every promise by 2030, the total temperature reduction will be 0.048°C (0.086°F) by 2100.

• Even if we assume that these promises would be extended for another 70 years, there is still little impact: if every nation fulfills every promise by 2030 and continues to fulfill these promises faithfully until the end of the century, and there is no ‘CO₂ leakage’ to non-committed nations, the entirety of the Paris promises will reduce temperature rises by just 0.17°C (0.306°F) by 2100.

 US climate policies, in the most optimistic circumstances, fully achieved and adhered to throughout the century, will reduce global temperatures by 0.031°C (0.057°F) by 2100.

• EU climate policies, in the most optimistic circumstances, fully achieved and adhered to throughout the century, will reduce global temperatures by 0.053°C (0.096°F) by 2100.

• China climate policies, in the most optimistic circumstances, fully achieved and adhered to throughout the century, will reduce global temperatures by 0.048°C (0.086°F) by 2100.

• The rest of the world’s climate policies, in the most optimistic circumstances, fully achieved and adhered to throughout the century, will reduce global temperatures by 0.036°C (0.064°F) by 2100.

This suggests that the public, industry, and investors are being greenwashed and fraudulently misled on proposed climate change risk analysis and related regulatory measures. This would be contrary to fundamental securities law and greenwashing regulations of the Competition Bureau.

Follow best practices by making sure that your claims:
• are truthful and aren’t misleading;
• are specific: be precise about the environmental benefits of your product;
• are substantiated and verifiable: claims must be tested and all tests must be adequate and proper;
• do not result in misinterpretations;
• do not exaggerate the environmental benefits of your product; and
• do not imply that your product is endorsed by a third-party organization if it isn’t; and,
If you’re unsure whether a claim will mislead or misrepresent, then don’t make the claim!

Read the full report:

via Friends of Science Calgary

JANUARY 17, 2022