Burgess COMMENTARY

Peter Burgess

Public Exposure Draft Standards – Resource Transformation Thank you for your interest in SASB’s Standards. Below are the Public Exposure Draft Sustainability Accounting Standards. Standards Introduction Black-line

This 7-page document provides context and guidance on the use and structure of standards below. Reading this document prior to reading the standards below is recommended.

Resource Transformation

Comment Instructions:

The set of proposed sustainability accounting standards for the Resource Transformation sector will be available for public review from October 8, 2014, to January 6, 2015.

SASB welcomes comments from the public. Those providing comments should keep in mind that the proposed disclosure standards are intended to be integrated in standard filings of publicly traded companies, such as the Form 10-K. As such, they reflect auditable information that is likely to be material to investors and can be disclosed in a cost-effective manner.

The industries in this sector are:
Chemicals
Aerospace & Defense
Electrical & Electronic Equipment
Industrial Machinery & Goods
Containers & Packaging

Please provide comments in the form of a letter on official letterhead, submitted by email to: rt_comments@sasb.org. We strongly encourage participants to provide comments on company/organization or individual letterhead signed by the authorized representative.

SASB recommends that letters include the following for each comment:
Industry Standard (e.g., Restaurants)
Disclosure Topic (e.g., Energy & Water Management)
Accounting metric code (e.g., SV0203-01)
Line of disclosure, where relevant (e.g., .02) Comment:

Specifically, SASB would like comments to address the following:

Disclosure Topics
Identify any disclosure topics in the Standards that may not be material to a reasonable investor, including an explanation. Suggest any disclosure topics not included in the Standards that may be material to a reasonable investor, including evidence supporting your assertion.

Accounting Metrics
Provide comments to correct, improve, or add to accounting metrics in the standards.
Suggest additional or alternate accounting metrics to measure performance with respect to a disclosure topic.

Cost Effectiveness
How costly would it be for companies to collect, analyze, and report information required for the proposed accounting metrics?
Do you anticipate this cost to be a barrier to reporting, adoption, or usage of the proposed accounting metrics?
What aspects of reporting, if any, would you foresee being most costly for reporting organizations?