The SEC’s climate proposal is not grounded in sound science

By Andy May

On March 22, 2022, the SEC released a new rule for public comment that would require public companies to report the climate-related impact of their businesses. Since it has been well established in multiple IPCC reports that the human impact on climate has never been observed, only modeled, this seems unnecessary. The climate models, used by the IPCC and NOAA to “compute” the human impact on climate have already been invalidated by Dr. Ross McKitrick and Dr. John Christy in their well-known 2020 Earth and Space Science peer-reviewed paper.

As you might imagine I had quite a lot more to say about this foolish rule that forces companies to make up costs that have an imaginary effect on an imaginary modeled climate future. You can find it in my Washington Examiner op-ed, here.

To read the full uncut Author’s version of the op-ed, see here.

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Nicholas McGinley
April 10, 2022 10:23 am

Logically speaking, repeating a lie over and over again can never make it become the truth, no matter how many times it is said, no matter who says it, no matter how earnestly they intone the lie, and no matter how seldom anyone calls out the lie for what it is.

And yet, as we can all plainly see, this particular lie, or more properly stated this particular pile of interconnected lies, was swallowed hook, line, and sinker by a huge number of people the moment it was first conceived and uttered. And over time, an increasingly huge number of individuals have come under the thrall of this steaming pile of stink, such that a sizable percentage of the population of the world are not even aware that there is any good reason to doubt the veracity of any of it.

Given that all of the above is by now old news, it is still jaw dropping and gob smacking that ideas that have zero basis in objective truth have gained so much traction in the minds of so many of the very powerful and the very influential.

I am reminded of a quote from a great movie, paraphrased here:
“It’s the damn money!
It’s just beyond everything.
What does it mean?
What is it leading to?
If you’d have told me twenty years ago,
I just flat out wouldn’t have believed you.
Who would do such a thing?
How do you defend against it?”

Different topic in the movie, but it fairly succinctly describes the feeling I get from all of this.

Reply to  Nicholas McGinley
April 10, 2022 12:05 pm

Correct Nicholas – every word our governments uttered about Catastrophic Human-Made Global Warming (“CAGW”, aka “Climate Change”) was a lie, repeated over and over by their “bought” media to program an ignorant populace. Now our world is becoming colder starting ~Feb2020, as we predicted in an article published on 1Sept2002. The climate scammers knew that even the most obtuse person would soon realize he’s not boiling, he’s freezing – and their scam would be over.
That is why their second big scam, the Covid-19 lockdowns and vaccines, was hatched in 2020. We now know that the lockdowns were costly, harmful and ineffective and the vaccines were costly, toxic and ineffective. Still, our authorities are pushing these toxic vaccines on younger and younger children. Genocide.
The next diversion is the war in Ukraine, intended to divert the attention of those attracted to shiny objects away from the costly, harmful Covid lockdown and vaccine disasters. Scholars of Russia and the FSU say that NATO deliberately provoked this conflict by blatant breaches of the Budapest Memorandum (1994) – the Agreement that Belarus, Ukraine and Kazakstan would stay neutral and stay out of NATO. The good people of Ukraine are mere collateral damage.
We are being played on a global scale, and most people are way too stupid to realize it.
This whole false narrative was never about global warming, or Covid-19, or Ukraine – it IS about totalitarian control of your country, you and your family by “scoundrels and imbeciles” like Biden, Trudeau, Johnson, Macron, Merkel and many other world leaders, who are themselves under the control of world criminals like Klaus Schwab of the WEF and his fellow-travellers. Most people are stupid and have been scammed for decades by the Global Warming fraud, in a now-cooling world. They have no scientific competence, and believe any lie that is repeated often enough.
A few of us recognized the CAGW / Climate Change scam as a lie decades ago. I knew the Global Warming narrative was a bold lie in 1985, based on my education in the Earth Sciences. I studied the subject for 17 years and my co-authors and I published those conclusions in 2002. I would not change a word of our 2002 predictions, which remain 100% correct.
Told you so, 20 years ago.
“The ability to correctly predict is the best objective measure of scientific and technical competence.”

What’s happening now? More global cooling – the latest from Cap Allon at
April 8, 2022 Cap Allon
Also, Solar Cycle 25 is progressing similarly to the historically weak SC24: Grand Solar Minimum expected by SC26 (so the early 2030s).
April 7, 2022 Cap Allon
The IPCC is pushing ‘the agenda’ harder than I’ve seen before: “The planet is on course for a 3.2C rise … an increase that would render much of the world uninhabitable … [and there must be] rapid, deep and immediate cuts [in GHG emissions].”
Excerpt from the Electroverse post of April 7, 2022:
I wrote recently that I am concerned about grain shortages – and now the genocidal IPCC says food systems have to go “low-carbon”. That should solve their alleged overpopulation problem – especially in the developing world. Nuremberg 2.0
The totalitarian scammers are not done – they continue to repeat their blatant lies, and gullible people keep believing them. This will end very badly.

Gordon A. Dressler
April 10, 2022 11:23 am

Well, in turn, I call on the SEC itself to report the climate-related impact of their operations, including staging hearings and issuing rules.

In The Real World
Reply to  Gordon A. Dressler
April 11, 2022 6:18 am

It is quite possible that the SEC are doing this as a way to sneak in another Green Carbon tax

In the UK , it has been law for some years that all large businesses , [ with x 100 workers , with x £million turnover ,] have to register their energy use with the government .
Then , under the EMISSIONS TRADING SCHEME , they have to buy carbon credits to offset their fossil fuel use .

From the start of last year the unit price of these Carbon Credits went up by very large amounts .
This is a very sneaky tax , as most of the media will not mention , [ or possibly understand ] it .
The only mention has been the effect on the steel industry .
But it has more than doubled the cost of electricity generation , made the price of fuel , [ for road use or others ], go up by a large amount , and increased the cost of flying .

So it is possible the US government is trying to do the same thing with one of the most hidden stealth taxes that have yet been devised .

Rud Istvan
April 10, 2022 11:24 am

Been a long time since I studied securities law in law school, and never practiced it. So rusty. But if memory serves, climate risks are outside the SEC charter (Securities Exchange Act of 1934). Two separate reasons. One, vague when securities stuff is supposed to be mostly clear cut. Second, no risk in relevant time frames of just a few years; after then, everything is just unactionable speculation.
Doubt this proposed SEC rule will withstand court challenge.

Janice Moore
Reply to  Rud Istvan
April 10, 2022 1:53 pm

This article explains how the SEC in promulgating this rule:

1) does NOT have statutory authority to do so (Sec. IV of article),

2) has failed to satisfy the long-settled requirement that information to be disclosed be “material” (to investors) (Sec. II), and

3) harms the economy (Sec. VI).

“We Are Not the Securities and Environment Commission …,”
Hester M. Peirce, Commissioner, SEC
March 21, 2022

Janice Moore
Reply to  Andy May
April 10, 2022 3:53 pm

Yes, indeed. Good for you, Commissioner Peirce!

TRUMP 2024 — for data driven policy, free markets, and prices which reflect material facts.

And, thank YOU, Mr. May, for another of your world class, fact-filled, articles (op-ed, here) promoting truth and, therefore, freedom.

Robert Cherba
April 10, 2022 11:45 am

It’s not climate risks that should worry anyone, it’s the political and regulatory risks associated with responding to a faux “climate crisis.” Those risks are substantial as long as politicians and their administration are as brain dead as “let’s go Brandon’s” are.

Reply to  Robert Cherba
April 10, 2022 1:35 pm

In fact the rule calls for reporting the “risks to the firm of the energy transition”. Start with frequent protracted blackouts and price spikes.

Ironically the SEC proposal actually mentions in passing the significant potential for transition induced economic chaos. In an incredible footnote they point out that the transition could wreck the economy, saying this:

“(There are) risks associated with a transition towards a low-carbon economy, particularly if the transition is disorderly, which could have a destabilizing effect on the global financial system.“

Every firm should report this risk.

See my

Reply to  David Wojick
April 10, 2022 2:55 pm

The risk to my business from energy transition disorder is very high, but we’re a privately held company, so we don’t get to report.

Excellent op-ed Mr. May.

Ron Long
April 10, 2022 11:56 am

It is hard to imagine a Chairman of the Board submitting an outside expenditure recommendation to the Board of Directors, wherein the outside expenditure has nothing to do with the corporate business, and instead is basically an extortion by the government. The potential for stockholder law suits is very high in this scenario, which would be a counter to the Greenies buying a few shares and disrupting shareholder meetings. What a mess.

April 10, 2022 12:07 pm

Neither is any of the crap coming out of CDC or NIH.

Frank from NoVA
April 10, 2022 12:34 pm

‘The climate models, used by the IPCC and NOAA to “compute” the human impact on climate have already been invalidated by Dr. Ross McKitrick and Dr. John Christy…’

Just the tip of the iceberg.

Tom Gasloli
April 10, 2022 12:45 pm

Big Corp has more than enough money & legal staff to fight this if they choose. But it is unlikely they will fight it. They prefer to use “climate change” as an excuse for more government subsidies & regulations that will disadvantaged their competitors.

The grifting is why the “climate change” fraud has gone on as long as it has.

D. J. Hawkins
Reply to  Tom Gasloli
April 11, 2022 7:40 am

Not only that, but as Hester M. Peirce points out in her statement, CEO’s can deflect criticism of their financial failures by pointing to how well their “energy transition” is going. Bob and weave, bob and weave…

Chris Nisbet
April 10, 2022 12:46 pm

Where does the burden of proof lie? The company making the report?
If a company reports that the climate-related risks are nil, how could anybody prove them wrong?
Are companies obliged to calculate risks based upon things like model predictions and somebody else’s estimation of how damaging CO2 is?

Pat from kerbob
Reply to  Andy May
April 10, 2022 7:29 pm

It has meant less severe weather, by every measure.
That is the entire point.

If a company wants they can state that all the available real data shows AWG is not only not catastrophic it is beneficial.

And you don’t even have to pretend you believe CO2 controls temp or not.
Just game the bloody system and quote peer reviewed science like this:

4 Eyes
Reply to  Chris Nisbet
April 12, 2022 9:45 pm

Chris, you have hit the nail on the head. The only thing that could be done after saying your company’s risk is nil is for the SEC / govt to declare that you are wrong because they will not accept Nil as an answer because every risk estimation has already been assumed to be greater than zero. This whole SEC requirement is glaring proof that CC is all about centralized govt control i.e. it is totally political

April 10, 2022 1:29 pm

The plan could bite them:

By far the biggest risk is from stupid climate policy not climate change. Companies should say that.

Bruce Cobb
April 10, 2022 1:29 pm

But, it is firmly grounded in libtarded politics, pseudoscience, and weapons-grade virtue signaling.
Does that count?

Andy Pattullo
April 10, 2022 1:35 pm

Based on evidence to date and the inevitable life-giving CO2 emissions attendant on consuming fossil fuels using reasonable means to avoid real pollutants such as sulphur and nitrous oxides and particulates, companies should be able to up-value their stock and their business activities based on the science as long as they show they are avoiding the environmental detriments of high resource and land consuming wind and solar energy which are net drains on society in general and on the natural environment. So sure, let’s have a rule to declare but let’s base the declaration on science not superstition.

High Treason
April 10, 2022 1:47 pm

In the childhood tale, Chicken Little, it was the WISE king that put an end to the nonsense. The WISE king went back to the source (base scientific evidence) to show the scare was based on nonsense.
Alas, our “kings” today are corrupt, and use the “crisis” for nefarious purposes. There is no shortage of tyrants throughout history that exploit any concocted crisis to grab more power.
It is up to us to get people to question the narrative to break out of the spell of propaganda and brainwashing.

April 10, 2022 1:48 pm

The top ten administrators at the SEC need to be fired and banned from ever holding a government job for life.

Danley Wolfe
Reply to  Bob
April 10, 2022 2:16 pm

Ranting, not a realistic scenario !

Reply to  Danley Wolfe
April 10, 2022 7:12 pm

Whether it could happen or not, it should happen. It is past time to hold administrators responsible.

Danley Wolfe
April 10, 2022 2:18 pm

Great piece, well thought out and beyond criticism or refutation. We need more thoughtful responses and position papers like this and the rant rant ranting blog entries are not helpful.

Ireneusz Palmowski
April 10, 2022 2:20 pm

If the Atlantic hurricane season becomes more severe during La Niña, will it be man-made?comment imagecomment image

April 10, 2022 2:32 pm

I have a quick and easy solution for all the companies affected. Start with the temperature rise as forecast by any model of your/SEC choice, let’s say it’s 2C per decade, (something really scary).

Since the global change can be assumed to be a function of the money/profit expended by your activities I propose that you can allocate a proportion of the change based on your companies dollar turnover for the year. To find your share of the global value, divide your value by the sum of the world’s GDP total. If using realistic numbers, your proportion will be something like 1 divided by some really, really huge number.

Multiply the 2C/decade value by your companies proportional contribution to work out how much your company is adding in the modeled temperature world.

Since your estimate of the world’s GDP cannot be more accurate than 4 decimal places, (at a stretch), you should report your contribution, rounded to the nearest 0.001C per year.

Here is a, (simple), worked example. Tesla sold 930,000 cars last year, let’s say at $30,000 cost. So turnover = $27.9B. Divide this by $93.86T to get the proportion = 0.000297.

So the annual model temperature rise, attributed to Tesla is 2/10 x 0.000297 = 0.000059C.
Round down as noted. Answer = 0.

Done for another year. And for anyone who runs a company with a similar turnover, the answer should be obvious.

David S
April 10, 2022 3:42 pm

I still maintain that the fossil fuel companies need to resolve this by giving the greens exactly what they want. Shut off all fossil fuels until the government begs them to turn it back on. This should be done in the winter when the effect of no heating would be felt. Here is what would happen: 48% of US homes are heated by natural gas another 9 % by other fossil fuels.Without heat people will start freezing to death. Cars will not run. People won’t be able to get to work or to the grocery store. Trucks will not be able to delivery food to the grocery store. So people will begin to starve. Planes won’t fly. 60% of electricity in the US is produced by fossil fuels. That will be gone. In other words real disasters will start happening almost immediately as opposed to unreal disasters that will happen (actually not happen) in the future from climate change. Just my guess but I suspect the voters will quickly give the green politicians the boot. The fossil fuel industry must make it clear that the consequences are the fault of government’s idiotic policies and not the fossil fuel industry.
I don’t want to inflict such misery on the American people. But sometimes a little taste of reality is necessary for clear thinking.

Reply to  David S
April 10, 2022 10:13 pm

The lawsuits and criminal charges would destroy everything.

Reply to  David S
April 11, 2022 4:29 am

The problem is that politicians are elected for a fixed period, like 4 or 5 years. So there will be a delay before they can be pitched out.

David S
Reply to  Disputin
April 11, 2022 9:21 am

Representatives are elected every two years. And 1/3 of Senators are up for re-election every two years. The next election is this November so we could take control of the House and Senate by next January when they are sworn in. (Assuming we have honest elections)

Joe Born
April 10, 2022 5:53 pm

Well done.

April 10, 2022 7:41 pm

The SEC would never use “sir” as it is gender specific they would use person 🙂

Philip Mulholland
Reply to  LdB
April 10, 2022 9:42 pm

In Wolf Hall the Duke of Norfolk called Thomas Cromwell a “person”.

Walter Sobchak
April 10, 2022 7:59 pm

I am very happy to be retired from my former trade of corporate lawyer. One of my tasks was preparing my clients annual SEC filings.

My clients were small public companies. One of them was a chain of 20 to 30 sitdown restaurants in the “casual dinning” sector (not fast food not white table cloth). They probably could have disclosed how much natural gas and how much electricity they purchased every year, but telling you what their emissions were?

Good lord, they were chefs not engineers. But the idea of disclosing: “GHG emissions from … downstream activities in its value chain” is downright funny.

“We estimate that the food consumed in our restaurants produced 100,000 pounds of poopoo and 100,000 gallons of peepee. Additionally we sold 50,000 servings of bean chili that produced 10,000 cubic feet of intestinal gas containing 70% methane which is a very potent GHG.

Our government is being run by lunatics. It is not a good feeling while the Russians are brandishing nuclear weapons while they murder innocent civilians.

Reply to  Walter Sobchak
April 11, 2022 3:17 am

No kidding, Ukrainians are killing innocent civilians too 🙁

April 10, 2022 8:47 pm

You might want to say what or who you are talking about!
Nobody knows what the SEC is ….
It’s the Securities and Exchange Commission…for god sake …all businesses will have to comply.
This is just another reason that Trump, not Biden should be in office !!!!

william Johnston
April 11, 2022 8:02 am

If the SEC can use computer models as the basis for the rules, then can’t the companies also use computer models to quantify the emissions???? GIGO!

Shemp Hawking
April 10, 2022 9:04 pm

If you have to run A/C in the summer, remove leaves in the fall, shovel snow in the winter, and deal with rain showers in the spring, your business has been impacted. Notify the SEC at once.

April 10, 2022 9:08 pm

I wish the companies affected by the SEC’s intended new rule would actually point how exactly, really their emissions will impact the environment.

Zero point zero zero zero zero

April 10, 2022 9:46 pm

Since the people behind those requirements are also behind requirements that make many business’ futures more problematic, the businesses actually have something real to factor into their statements. It is like the torturer preparing his victim’s psyche with vivid descriptions in order to be able to inflict the maximum pain with the least effort.

April 10, 2022 11:09 pm



“…You might think business stars like Warren Buffett have some idea of how to run an insurance company. But climate experts keep trying to explain that the focus insurers have on observational evidence is leading to insurers underestimating the risk of climate disasters.

As far as I know Buffet’s views on climate change have not changed significantly since 2015, I could not find a mention of climate change in his 2016, 2017, 2018 or 2019 letters.
For some reason the fact insurers like Buffett don’t think their businesses are in danger really seems to upset climate alarmists.”

That is certainoy correct. They are so upset they’re willing to make complete fools out of themselves.
Climate Change Experts Explain to Insurers They Don’t Understand Risk

April 11, 2022 1:06 am

Major threat to business from climate impacts:

Climate changers in cahoots with the medical profession want to reduce biz by 70% while all other weather related threats pale into insignificance-

On average, resource use needs to decline by at least 70 percent to reach the sustainable range.

The US And EU Have Unsustainably Plundered Natural Resources For Decades, Study Shows (

Paul MacLeod
April 11, 2022 7:04 am

Too many of the elites creating policy in the G-whatever countries are filled with self-righteousness and a highly exalted sense of their own worth, to wit: responding to a question about her recent budget on CBC’s “The House” on Saturday April 9, Canada’s Minister of Finance and Deputy Prime Minister arrogantly stated: “we know we need to bring our emissions down really, really sharply by 2030 and by 2050 in order to save the planet.”(my emphasis). 
This is our problem. We keep electing these characters who are so into their cult they believe they can “save the planet” by sending us all back into the dark ages – except, of course, they take real good care of themselves. What fools Canadian voters are.

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