AHLA wants Climate Change Legislation to protect U.S. Hotel Investors

AHLA Letter to the Securities and Exchange Commission

The American Hotel and Lodging Association (AHLA) President & CEO Chip Rogers told SEC Chairman Gary Gensler that AHLA is committed to addressing climate change, and many AHLA members have been leading on the issue for years, but the SEC’s draft rule could have the opposite effect as intended.

“We believe that certain provisions of the Rule as drafted will discourage some registrants from continuing their forward-leaning practices and embracing climate-related initiatives,” Rogers said.

The Securities and Exchange Commission in March proposed rule changes that would require registrants to include certain climate-related disclosures in their registration statements and periodic reports, including information about climate-related risks that are reasonably likely to have a material impact on their business, results of operations, or financial condition, and certain climate-related financial statement metrics in a note to their audited financial statements.

The required information about climate-related risks also would include disclosure of a registrant’s greenhouse gas emissions, which have become a commonly used metric to assess a registrant’s exposure to such risks.

Chairman Gary Gensler
Securities and Exchange Commission 100 F Street, NE
Washington, DC 20549

Dear Chairman Gensler:

The American Hotel and Lodging Association (AHLA) appreciates the opportunity to comment on the U.S. Securities and Exchange Commission’s (SEC) proposed rule on The Enhancement and Standardization of Climate-Related Disclosure for Investors (the Rule).¹

Serving the hospitality industry for more than a century, AHLA is the sole national association representing all segments of the U.S. lodging industry, including hotel brands, owners, real estate investment trusts (REITs), franchisees, management companies, independent properties, bed & breakfasts, state hotel associations, and industry suppliers.

Headquartered in Washington, D.C., AHLA focuses on strategic advocacy, communications support, and workforce development programs for an industry that advances long-term career opportunities for employees, invests in local communities across the country and hosts more than one billion guests’ stays in American hotels every year.

AHLA proudly represents a dynamic hotel industry of nearly 61,000 properties that supports $1.1 trillion in U.S. sales and generates nearly $170 billion in taxes to local, state, and federal governments.

AHLA supports the SEC’s commitment to addressing the global threat of climate change and welcomes the growing interest from the investor community to better understand how U.S. businesses are impacted by climate change and the steps they are taking to reduce their greenhouse gas (GHG) emissions to mitigate climate-related risks.

We agree that consistent, comparable, and reliable data is needed to produce the most helpful and relevant information for investors. Indeed, many of our members have been leading on this issue for years.

A number of our members have, for example, set Science Based Targets pursuant to the Science-Based Targets Initiative (SBTi) and are reporting various relevant climate figures pursuant to other globally recognized frameworks such as the Carbon Disclosure Project (CDP), the Task Force on Climate-Related Financial Disclosures (TCFD), the Global Reporting Initiative (GRI), Sustainability Accounting Standards Board (SASB), and the Global ESG Benchmark for Real Assets (GRESB).

Our industry has also been proactive in finding an alignment of methodologies. Over a decade ago, a number of AHLA’s larger members contributed to the development of the Hotel Carbon Measurement Initiative (HCMI), which provides industry-specific guidance for preparing “per room night” and “per meeting” carbon footprint metrics for corporate and leisure customers.