June 15, 2022

NBAA has urged the Securities and Exchange Commission (SEC) to be cognizant of the complexities of business aviation and recognize the industry’s commitment to sustainability when considering a proposed rulemaking to mandate that companies subject to SEC reporting requirements disclose the environmental impact of their operations.

In a lengthy and complex proposed rulemaking, the SEC requested comments on plans to require companies to include certain climate-related disclosures in their registration statements and periodic reports. Among other criteria, the proposed rulemaking includes a provision to report total direct Scope 1 greenhouse gas (GHG) emissions. The Scope 1 reporting would represent the reporting company’s total direct emissions, and would not be broken down by specific emissions sources.

Find out more about the SEC’s proposed rulemaking: The Enhancement and Standardization of Climate-Related Disclosures for Investors.

In a letter to the SEC, NBAA noted business aviation’s vocal support for sustainability programs, as well as the technological advances that help reduce aviation’s environmental footprint. NBAA also underscored the industry’s pledge to achieve net-zero carbon dioxide emissions by 2050.

NBAA’s letter emphasized the importance of sustainable aviation fuel, as well as the work conducted by the association and its partners in the Business Aviation Coalition for Sustainable Aviation Fuel to educate airports, operators and policymakers on the significance of this vital drop-in fuel in reducing aviation GHG.

NBAA stressed the need for the SEC to appreciate that its rule, in its current form, would add a significant and potentially costly burden to the many companies that rely on business aviation to support their operations.

The association also recommended several measures – including extended phase-in periods – that would help American businesses successfully develop the many new processes this new rule would require while ensuring that they comply with their environmental obligations.

“Aviation is widely considered one of the most challenging sectors of transportation to decarbonize, yet our community, through technological gains and sustainability commitments, is rapidly progressing towards net-zero,” said Scott O’Brien, NBAA’s senior director, public policy and advocacy. “We look forward to working with the SEC to ensure the proposed rule addresses the unique concerns of our industry and provides opportunities for educating the business aviation community about compliance best practices.”

Read NBAA’s letter to the SEC. (PDF)