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8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources http://slidepdf.com/reader/full/2-mar-2015-letter-to-us-senate-ctee-on-energy-natural-resources 1/22 Douglas A. Grandt PO Box 6603 Lincoln, NE 68506  (510) 432-1452 March 2, 2015  Senator Lisa Murkowski, Chairman Senate Committee on Energy and Natural Resources 709 Hart Senate Office Building Washington, D.C. 20510 Re: Oil Refining - Considering future eventualities versus the myopia of the present Dear Chairman Murkowski, The article “Investors ask oil companies to disclose refineries' risks from climate change” appeared in The Guardian on February 26. I found it very alarming to read the following: “[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that companies disclose climate change-related risks that might affect their bottom lines. But oil companies have largely ignored this guidance, which isn’t legally required. Of the companies studied in the report, only Phillips 66 has disclosed any physical climate risks in SEC filings, according to the report, which calls the Texas-based company’s disclosures “poor”. In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in the Earth’s climate, such as more severe or frequent weather conditions in the markets we serve or the areas where our assets reside, we could incur increased expenses, our operations could be materially impacted and demand for our products could fall.”   And in its most recent earnings statement, filed last week, the company said climate change posed a serious potential risk to its business. None of the companies provided information on how they will prepare for these risks. “Really in the end, the industry is damned if it does and damned if it doesn’t when it comes to climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’ carbon asset risk program. “If oil companies continue along the business-as-usual  path, they’ll either be hit by demand risk and the rise of clean energy, or by the massive physical impact of climate change, or perhaps both.”  [Lead analyst at the Center for Science and Democracy] Goldman’s report recommends that the SEC push companies to follow its guidelines for disclosing climate change risks.  An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced by the SEC: “companies can use the guidance to assess their own facts and circumstances on this issue and provide disclosure to the extent material to investors”. Congress has an obligation to compel the industry to behave in the national and public interest. Sincerely yours, Doug Grandt [email protected]

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Page 1: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

http://slidepdf.com/reader/full/2-mar-2015-letter-to-us-senate-ctee-on-energy-natural-resources 1/22

Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Lisa Murkowski, ChairmanSenate Committee on Energy and Natural Resources709 Hart Senate Office BuildingWashington, D.C. 20510

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Chairman Murkowski,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate change

posed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 2: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Lamar AlexanderSenate Committee on Energy and Natural Resources455 Dirksen Senate O!ce Building Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Alexander,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 3: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator John BarrassoSenate Committee on Energy and Natural Resources307 Dirksen Senate O!ce Building Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Barrasso,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 4: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Shelley CapitoSenate Committee on Energy and Natural Resources5 Russell Senate O!ce Building Courtyard Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Capito,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 5: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Bill CassidySenate Committee on Energy and Natural Resources703 Hart Senate O!ce Building Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Cassidy,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 6: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Steve DainesSenate Committee on Energy and Natural Resources1 Russell Senate O!ce Building Courtyard Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Daines,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 7: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Jeff FlakeSenate Committee on Energy and Natural ResourcesRussell Senate O!ce Building 368 Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Flake,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 8: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Cory GardinerSenate Committee on Energy and Natural ResourcesDirksen Senate O!ce Building SD-B40B Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Gardiner,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 9: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator John HoevenSenate Committee on Energy and Natural Resources338 Russell Senate O!ce Building Washington DC, 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Hoeven,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 10: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

8/9/2019 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Mike LeeSenate Committee on Energy and Natural Resources316 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Lee,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 11: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Rob PortmanSenate Committee on Energy and Natural Resources448 Russell Senate O!ce Building Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Portman,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 12: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator James E. RischSenate Committee on Energy and Natural Resources483 Russell Senate O!ce Building Washington, DC 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Risch,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Maria CantwellSenate Committee on Energy and Natural Resources511 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Cantwell,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 14: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Al FrankenSenate Committee on Energy and Natural Resources309 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Franken,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 15: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Martin HeinrichSenate Committee on Energy and Natural Resources702 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Heinrich,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 16: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Mazie HironoSenate Committee on Energy and Natural Resources330 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Hirono,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 17: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Joe ManchinSenate Committee on Energy and Natural Resources306 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Manchin,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 18: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Debbie StabenowSenate Committee on Energy and Natural Resources731 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Stabenow,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 19: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Elizabeth WarrenSenate Committee on Energy and Natural Resources317 Hart Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Warren,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 20: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Ron WydenSenate Committee on Energy and Natural Resources221 Dirksen Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Wyden,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

Page 21: 2 Mar 2015 Letter to US Senate Ctee on Energy & Natural Resources

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Douglas A. GrandtPO Box 6603

Lincoln, NE 68506  (510) 432-1452

March 2, 2015 

Senator Bernie SandersSenate Committee on Energy and Natural Resources332 Dirksen Senate O!ce Building Washington, D.C. 20510 

Re: Oil Refining - Considering future eventualities versus the myopia of the present

Dear Senator Sanders,

The article “Investors ask oil companies to disclose refineries' risks from climate change”appeared in The Guardian on February 26. I found it very alarming to read the following:

“[T]he US Securities and Exchange Commission in 2010 issued guidance suggesting that

companies disclose climate change-related risks that might affect their bottom lines. But oilcompanies have largely ignored this guidance, which isn’t legally required.

Of the companies studied in the report, only Phillips 66 has disclosed any physicalclimate risks in SEC filings, according to the report, which calls the Texas-basedcompany’s disclosures “poor”. 

In its 2014 filing, Phillips 66 stated: “To the extent there are significant changes in theEarth’s climate, such as more severe or frequent weather conditions in the markets weserve or the areas where our assets reside, we could incur increased expenses, ouroperations could be materially impacted and demand for our products could fall.”  

 And in its most recent earnings statement, filed last week, the company said climate changeposed a serious potential risk to its business.

None of the companies provided information on how they will prepare for these risks.

“Really in the end, the industry is damned if it does and damned if it doesn’t when it comesto climate change,” says Andrew Logan, director of sustainability advocate nonprofit Ceres’carbon asset risk program. “If oil companies continue along the business-as-usual

 path, they’ll either be hit by demand risk and the rise of clean energy, or by themassive physical impact of climate change, or perhaps both.”  

[Lead analyst at the Center for Science and Democracy] Goldman’s report recommendsthat the SEC push companies to follow its guidelines for disclosing climate change risks.

 An SEC spokesperson said the guidelines aren’t mandatory and aren’t actively enforced bythe SEC: “companies can use the guidance to assess their own facts and circumstances onthis issue and provide disclosure to the extent material to investors”.

Congress has an obligation to compel the industry to behave in the national and public interest.

Sincerely yours,

Doug Grandt

[email protected]

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