The U.S. Chamber's Climate Policy Engagement, February 2023

An InfluenceMap Briefing

February 2023

Executive Summary

InfluenceMap's ongoing research into the climate policy engagement of the U.S. Chamber of Commerce finds continued opposition to meaningful legislation and regulation introduced by the federal government. InfluenceMap analysis suggests a continuing trend of positive PR from the Chamber to create the impression of reform for climate-conscious investors and corporate members.

About InfluenceMap

InfluenceMap is a non-profit think tank providing objective and evidence-based analysis of how companies and financial institutions are impacting the climate and biodiversity crises. Our company profiles and other content are used extensively by a range of actors including investors, the media, NGOs, policymakers, and the corporate sector. InfluenceMap does not advocate or take positions on government policy. All our assessments are made against accepted benchmarks, such as the Intergovernmental Panel on Climate Change. Our content is open source and free to view and use (

In March 2022, InfluenceMap published a briefing highlighting the lack of material improvement from the U.S. Chamber of Commerce (the Chamber) in its climate policy engagement since 2017. Since last March, the Chamber has continued to oppose climate policy under the Biden administration, most notably the Inflation Reduction Act (IRA).  Recent negative engagement alongside limited positive positioning has resulted in negligible change in the Chamber’s performance: the group’s Organization Score remains an E-, marginally above the lowest InfluenceMap grade of F.

The US Chamber’s engagement mirrors the advocacy of fossil fuel interest groups such as the American Gas Association (E-) and American Petroleum institute (F). In fact, across six major federal climate policies introduced in 2022, the Chamber’s positions were the same as those of the American Petroleum Institute (API), the country’s predominant fossil fuel industry group. InfluenceMap captured 39 instances of policy engagement by the Chamber in 2022; of these, 64% were negative.

Many of the Chamber’s member companies show significantly more positive positions on climate policy, yet despite this glaring disconnect, the vast majority of Chamber members have failed to publicize their misalignment with the group on climate. Notably, not a single member of the Chamber publicly disavowed the group’s advocacy against the 2022 Inflation Reduction Act.

With a suite of new US climate regulations expected in 2023, it is critical that the corporate sector take steps to hold the Chamber accountable for its anti-climate advocacy. The chart below shows the divergence between the organization and its members on climate policy advocacy.

Recent Climate Policy Engagement by the Chamber

The Chamber’s climate policy engagement spans numerous policy areas, from oil and gas regulation to automotive emissions standards. Of the 39 evidence pieces captured in 2022, InfluenceMap scored 25 of them – nearly two thirds – negatively, indicating engagement that is largely at odds with IPCC guidance and opposed to Paris-aligned climate policy. InfluenceMap scores every evidence piece in our database on a 5-point scale of -2 to +2, signifying an assessment of strongly oppositional (-2), unsupportive (-1), mixed (0), supportive (1) or strongly supportive (2) engagement, benchmarked against Government Policy Based or Science Based Benchmarks. Click into the linked evidence below for more detail on how it was assessed).

A breakdown of evidence collected on the US Chamber’s positioning on climate policy in 2022

InfluenceMap captured nine instances of positive engagement by the Chamber in 2022.  Six related to high-level communications that did not refer to specific climate policy, while the other three related to legislation to phase down hydrofluorocarbons (HFCs). It appears that the Chamber has adopted a tactic of issuing high-level, nominally positive statements on climate-related issues at the same time that it offers detailed opposition to relevant items of legislation and regulation.

Of the 39 evidence pieces captured in 2022, InfluenceMap scored 25 of them – nearly two thirds – negatively, indicating engagement that is largely at odds with IPCC guidance and opposed to Paris-aligned climate policy.

One exception to this trend covers all three cases of “strong support” (to the far right of the graphic above) from the Chamber on the Kigali Amendment to phase down HFCs. Legislation to reduce HFC emissions appears to be one of the only areas of specific climate policy supported by the group.

One evidence piece from an August 2022 blog post offered top-line support for climate change science, while another from November 2022 supported the global methane pledge, a voluntary initiative to reduce global methane emissions. High-level support for methane emissions reduction contrasts with the Chamber’s opposition to actual methane regulation, as detailed below.

Two evidence pieces showed support for the electrification of transport – one in a May 2022 blog post, another in a joint letter from September 2022 supporting a waiver of Buy America requirements for EV chargers to facilitate EV infrastructure. The Chamber’s high-level support for transport decarbonization contrasts with its opposition to stringent transport regulation, including automotive GHG emissions standards, as overviewed below.

The remaining two instances of positive engagement are highlighted below:

DatePolicy AreaInfluenceMap AssessmentDetails and Link to Analysis on InfluenceMap's Website
December 2022Renewable Energy+1The Chamber submitted a joint statement with Business Europe to the US-EU Trade and technology council in December 2022 appearing to support accelerating the approval process for renewable technologies.
June 2022Energy Transition+1In a June 2022 letter to the House Committee on appropriations, the Chamber expressed support for the implementation of clean energy programs in the Bipartisan Infrastructure Bill.

Despite some positive messaging, the majority of the Chamber’s engagement appears to stand against climate policy progress. Examples from 2022 include:

DatePolicy AreaInfluenceMap AssessmentDetails and Link to Analysis on InfluenceMap's Website
December 2022Energy Transition0The Chamber submitted a joint statement alongside Business Europe to the US-EU Trade and technology council, where it supported investment into renewable and “other clean energy” projects, citing carbon reduction targets, but did not specify what it means by “clean energy,” the pace of uptake, or the need for specific policy.
November 2022Transport-2The Chamber filed an amicus brief to the California district court supporting a legal case against emissions regulations (introduced by the California South Coast Air Quality Management District) to encourage the purchase of zero-emission vehicles.
November 2022U.S LNG-1In a press release, the Chamber appeared to support long-term LNG production, suggesting that sourcing U.S. LNG to Europe is beneficial on the basis that it is cleaner than Russian oil.
October 2022Energy Transition-2The Chamber submitted joint comments to the Department of Energy opposing its energy efficiency proposal, a move toward electrification, to raise the ambition of energy conservation standards for gas furnaces.
September 2022Energy Mix0The Chamber’s Executive Vice President and Chief Policy Officer Neil Bradley released a statement permitting reform to facilitate all types of infrastructure, including oil and gas pipelines.
August 2022Inflation reduction Act-2The Chamber signed an August 2022 coalition letter to Congress firmly opposing the Inflation Reduction Act, citing issue with its corporate tax increases.
May 2022EPA HDV Standards-1The Chamber submitted comments in response to the EPA’s Clean Trucks Plan arguing against the degree of stringency proposed in the standards.
May 2022Transport & Energy-2In a blog post titled “An Effective Climate and Energy Security ‘Grand Bargain’ Is Within Reach,” Martin Durbin outlined seven "core elements" which would bridge climate and energy security, citing the crisis in Ukraine as justification for infrastructure and investments that will lock in unabated fossil gas.
April 2022Energy Mix-2Marty Durbin, Senior VP for Policy at the Chamber and head of its Global Energy Institute, said in a statement to the Washington Post that the Biden Administration’s decision to restore climate provisions under the National Environmental Policy Act (NEPA) – including consideration of “cumulative” impacts from GHG emissions – would result in “unnecessarily extensive and duplicative bureaucratic red tape.”
March 2022Energy Mix-2In a press release, the Chamber expressed its opinion that oil and gas are likely to remain the most-consumed sources of energy in the U.S. through at least 2050. This does not align with IPCC scenarios for 1.5 °C, which project oil at 16.22% globally by 2050 in high-overshoot pathways, and even less in low-overshoot pathways.
January 2022Methane regulations-2In a comment to the EPA, the Chamber contested the agency’s legal authority to regulate methane emissions from existing sources. More information on corporate engagement with the EPA’s November 2022 methane proposal is available on InfluenceMap’s US platform.

Misalignment Between the Chamber and its Members on Climate

While the Chamber’s climate advocacy remains largely negative, many of its member companies demonstrate significantly more positive engagement. As evident in the graphic below, the Chamber’s engagement mirrors that of its fossil fuel members – in some cases falling even lower. Despite being a cross-sector group, the Chamber does not seem to adopt the positions of its numerous, highly positive members from other sectors beyond oil and gas.

More information on US companies and their industry association links is available on the InfluenceMap US platform.

In fact, the Chamber’s score of E- is the same as the American Gas Association (E-) and only marginally higher than the American Petroleum Institute (F). Below is a table of six major federal climate policies (*and one additional transparency measure proposed by the SEC, assessed separately under InfluenceMap’s sustainable finance program) that were introduced in 2022. While not comprehensive of all climate-related action taken in 2022, these six policies represent specific items of legislation or regulation introduced by the federal government in 2022 to mitigate climate change as motivated by the country’s commitment to the Paris Agreement. They span multiple sectors and exclude non-binding targets and other related initiatives.

Notably, the Chamber’s position mirrors API’s on all six measures, except for one instance where InfluenceMap did not locate any evidence of engagement from API.

2022 Climate PolicyAPI PositionU.S. Chamber Position
Build Back Better ActOPPOSED

The API advocated against the Clean Electricity Performance Program and the methane fee in Build Back Better from 2021-22, including soliciting scores of state trade associations to cosign a joint letter against the methane fee before it was incorporated into the bill.


The US Chamber appeared to run an extensive campaign the Build Back Better Act, repeatedly opposing the bill on the basis of its corporate tax increases.

Inflation Reduction ActOPPOSED

The API strongly opposed the Inflation Reduction Act, joining multiple coalition letters against the bill, including one in August 2022 critiquing the methane fee in particular.


The Chamber appeared to run another extensive campaign against the Inflation Reduction Act. It joined an August 2022 coalition letter against the IRA and ran ads in two of Arizona’s largest papers in February 2022, pressuring state Senators to vote against the bill.

EPA Methane RegulationsOPPOSED

In comments to the EPA in February 2022, the API attempted to weaken multiple parts of the proposal, describing them as unnecessarily burdensome.


The Chamber submitted comments to the EPA in January 2022 critiquing the proposal and contesting the EPA’s legal authority to regulate methane emissions from existing sources.

EPA Clean Trucks PlanOPPOSED

The API submitted comments to the EPA in May 2022 cautioning against the Clean Trucks Plan and calling for a technology-neutral approach to transportation policy in the U.S. to transportation policy in the U.S.


The Chamber heavily criticized the Clean Trucks proposal in direct comments to the EPA in May 2022.

DoE Gas Boiler StandardsNo Recorded EngagementOPPOSED

The Chamber submitted joint comments in October 2022 opposing the Department of Energy’s proposal to raise the ambition of Energy Conservation Standards for Consumer Furnaces.

Revision to National Environmental Policy Act (NEPA)OPPOSED

API released a “10-in-2022 Plan” outlining ten policy recommendations for the U.S. federal government to support oil and gas production, which included limiting the NEPA review process in apparent contrast with the administration’s proposed changes.


The Chamber suggested that the Biden Administration’s decisions to restore climate provisions under NEPA would result in unnecessarily extensive and duplicative bureaucratic red tape.

*SEC Climate Disclosure RuleOPPOSED

In June 2022 comments to the SEC, the API opposed the rule, asserting that it would violate the First Amendment and face legal challenges.


In June 2022 comments to the SEC, the Chamber opposed the rule, asserting that it would violate the First Amendment and face legal challenges.

Companies are now facing growing scrutiny over their links to powerful industry groups that continue to block climate action in their name. Policymakers, investors, NGOs, and other actors are calling attention to the issue. Climate Action 100+ (CA100+), for example, is a voluntary initiative of 700 investors responsible for over $68 trillion in assets under management working to ensure the world's largest corporate greenhouse gas emitters take necessary action on climate change. Through CA100+ as well as various other investor initiatives, shareholders are requesting enhanced disclosures from companies on the topic of climate policy engagement and industry association membership.

Since 2021, InfluenceMap has detected an uptick of disclosures and other statements from Chamber members highlighting where they disagree with the group on climate and, in some cases, steps they are taking to evolve its positions. However, the vast majority of Chamber member companies have not publicly disclosed where they disagree with the group on climate.

Securities and Exchange Commission (SEC) Climate Disclosure Rule

The Chamber has, in its own words, been “at the forefront of fighting” the SEC’s proposed climate disclosure rule. In comments on the proposal in June 2022, the Chamber asserted that the proposal exceeded the SEC’s statutory authority and violated the First Amendment. In supplemental comments to the SEC in November 2022, the Chamber suggested that the major questions doctrine, a principle employed in the West Virginia v. EPA decision, “confirms the Commission’s lack of statutory authority.” The Chamber has suggested that the rule will be vulnerable to legal challenges if finalized in its current form.

Facing this opposition, the SEC is considering scaling back its climate disclosure rule. According to a Politico story from February 2023, “the top Wall Street regulator’s team has signaled that a primary concern is the wave of lawsuits that are expected to challenge the rule once it’s finalized.” An area of potential rollback is the rule’s mandate to disclose Scope 3 greenhouse gas emissions if material, or if the registrant has set a target or goal that includes Scope 3 emissions. The Chamber has opposed Scope 3 disclosure requirements in its comment letters and other public messaging.

In its opposition to the SEC rule and Scope 3 emissions disclosure requirements, the Chamber appears to be adopting the most negative positions of its members, and omitting the positions of members that fully or partially support the rule. Members that have expressed support for the rules, including its Scope 3 disclosure requirements, include United Airlines, Bank of America, Capital Group, UPS, and BP, to name a few. Members that have expressed opposition to Scope 3 requirements include Devon Energy, ConocoPhillips, Walmart, and ExxonMobil.

As of November 2022, over 55 companies globally have published audits of their industry association memberships. 22 US companies have produced these disclosures (18 of which are members of the Chamber). While none identified full misalignment with the Chamber on climate change policy, 5 of them – General Motors, ConocoPhillips, Delta, Dominion Energy, and Teck Resources – as well as EU-based Bayer, BHP, BP, Shell PLC, and Rio Tinto identified partial misalignment.

When it came to the Chamber and its opposition to the Inflation Reduction Act – the greatest attempt at emissions reductions in US history – not a single company publicly disavowed the group’s advocacy against the bill.

GM and Delta provided details on the steps they were taking to evolve the Chamber’s positions, while ConocoPhillips and Dominion did not. Teck Resources outlined general ‘Next Steps and Actions’ it would take towards trade associations it was misaligned and partially misaligned with but did not provide specific steps it would take for the Chamber.

In its review, General Motors stated that CEO Mary Barra meets frequently with the Chamber to push the group to support policies complementary to its vision for an all-EV future. During the debate over the Inflation Reduction Act, GM also distanced itself from the Business Roundtable, where its CEO Mary Barra chairs the Board, in supporting the bill.

Yet when it came to the Chamber and its opposition to the Inflation Reduction Act – the greatest attempt at emissions reductions in US history – not a single company publicly disavowed the group’s advocacy against the bill.

Impact on Climate Policy and Emissions Reductions

Shortly after assuming office, US President Biden announced a goal of reducing US emissions by 50-52% from 2005 levels by 2030. Rhodium Group and Energy Innovation analysis estimates that the Inflation Reduction Act will deliver reductions of 37 to 43% below 2005 levels toward this aim. While these projections mark a significant milestone for US climate policy, the US will need to scale and accelerate ambition to meet its target. 

In 2023, the administration will introduce a suite of new climate regulations, while also finalizing the ones it introduced these year. The US Chamber has opposed many of these types of policies in the past few years, from methane standards to automotive GHG standards, power sector rules, and more. Given the urgent need for emissions reductions in line with IPCC recommendations, it is critical that the Chamber not obstruct forthcoming policy ambition.

Addressing the anti-climate policy engagement of the Chamber and other obstructive industry groups may be the single most important step that US companies can take to support climate action in the new year.