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United States securities and exchange commission logo
September 14, 2021
Brian L. Roberts
Chairman and Chief Executive Officer
Comcast Corporation
One Comcast Center
Philadelphia , PA 19103
Re: Comcast Corporation
Form 10-K for
Fiscal Year Ended December 31, 2020
File No. 001-32871
Dear Mr. Roberts:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
1. There have been
significant developments in federal and state legislation and regulation
and international
accords regarding climate change. Please tailor the general disclosure
you have about
environmental-related regulatory matters to identify material pending or
existing climate
change-related legislation, regulations, and international accords and
describe the impact to
your business, financial condition, and results of operations.
2. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
decreased demand
for goods or services that produce significant greenhouse gas
emissions or are
related to carbon-based energy sources, including energy use across
your network,
production studios and theme parks;
increased demand
for goods or services that result in lower emissions than competing
products or
services;
increased
competition to develop innovative new products or services that result in
lower emissions;
and
any anticipated
reputational risks resulting from operations, products, or services that
Brian L. Roberts
Comcast Corporation
September 14, 2021
Page 2
produce material greenhouse gas emissions.
3. You disclose that severe weather events such as hurricanes and
wildfires have impacted
your products, services and properties, and could lead to large
expenditures. In addition,
your CSR report outlines projects and initiatives you will undertake
to meet your goal of
becoming carbon neutral by 2035. Please revise your disclosure to
identify any material
past and/or future capital expenditures for climate-related projects.
If material, please
quantify these expenditures. In addition, discuss the significant
physical effects of climate
change on your operations and results, if material. This disclosure
may include the
following:
severity of weather from climate change, such as floods,
hurricanes, sea levels,
wildfires, and water availability and quality;
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have
affected or may affect your
major customers or suppliers; and
any weather-related impacts on the cost or availability of
insurance.
4. Disclose the material effects of transition risks related to climate
change that may affect
your business, financial condition, and results of operations, such as
policy and regulatory
changes that could impose operational and compliance burdens, market
trends that may
alter business opportunities, credit risks, or technological changes.
In this regard, we note
disclosure in your CSR report about your goal to become carbon neutral
by 2035 and steps
you plan to take to meet that goal.
5. Quantify any material increased compliance costs related to climate
change.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Mitchell Austin, Staff Attorney, at (202) 551-3574 or
Anna Abramson,
Staff Attorney, at (202) 551-4969 with any questions.
FirstName LastNameBrian L. Roberts Sincerely,
Comapany NameComcast Corporation
Division of
Corporation Finance
September 14, 2021 Page 2 Office of
Technology
FirstName LastName