Jul. 09, 2021
Gary Gensler, Chair
SEC Headquarters
100 F Street, NE
Washington, DC 20549
(202) 551-2100
chairmanoffice@sec.gov
Vanessa A. Countryman
Secretary, Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
rule-comments@sec.gov
Re: Public Input to the SEC: Climate Change Disclosures
Dear Chairman and Secretary:
E3G has submitted a response to a call for public input from the US
Securities and Exchange Commission (SEC) on climate change disclosures.
The call for public input on the SEC’s ongoing work on climate change
disclosure was a welcome opportunity to articulate the need for such
regulation and what it should include to drive comparable and consistent
climate change disclosure from companies. They additionally acknowledge
the significance of the Executive Order on Climate-Related Financial
Risk made by President Biden on May 20th, including its emphasis on
advancing “consistent, clear, intelligible, comparable, and accurate
disclosure of climate-related financial risk”.
In the response to the questions posed by the SEC, E3G recommends
several key areas for the SEC to require mandatory disclosure from
registrants on climate change.
The recommendations include the following:
Requiring registrants to disclose against the full 11
recommendations made the Taskforce for Climate-related Financial
Disclosures.
Mandating the disclosure of climate transition plans for net-zero
by 2050, as part of disclosure on material climate-related risks and
opportunities.
Requiring registrants to disclose Scope 1, 2 & 3 emissions on a
phased basis.
Requiring registrants to disclose whether climate scenarios have
informed their strategy and provide detail on these scenarios including
underlying assumptions and alignment with a 1.5°C trajectory.
Full submission:
https://9tj4025ol53byww26jdkao0x-wpengine.netdna-ssl.com/wp-content/uploads/E3G-Response-to-SEC-Call-for-Input-June-2021.pdf
Take the time to review these recommendations and give them the weight
they deserve.
Yours sincerely.
Robert E. Rutkowski
cc:
Legislative Correspondence Team
1705 Longworth House Office Building
Washington DC 20515