Jun. 16, 2022
June 16, 2022 This proposal is an important step towards strengthening a disjointed system that is confusing to all involved, especially investors. This proposal would elicit meaningful, comparable disclosures that investors need to assess climate-related financial risks. In regards to some of the key questions, the following are some of my thoughts. For Q15 on page 75. I believe that there are many - for example plastics and other pollution, land use change and deforestation, environmental justice, community impacts, just transition for workers, Indigenous rights, and affected community outreach activities. It is important for registrants to disclose the role that carbon offsets or RECs will play in overall strategy to assess the credibility of these claims fraudulent claims are becoming more common already. Similarly, we as the public want to know how these claims affect the finances of a company. Beyond this, it is important for investors to know the quantitative affects. Expenditure metrics, as referenced on pg 144, transition plans, as referenced on pg 114, target reductions of GHG emissions and beyond, as referenced on pg 284, and Scope 3 emissions, as referenced on pg 184 should have required disclosure. Honestly, all goals and targets in regards to this project should be disclosed. Finally, location data for Scope 1, 2, and 3 emissions should be provided if feasible, as well as the risks associated with it. The timeline should be accelerated with limited disclosure for these Scopes, expanding into reasonable assurance required in the second year. Thank you for the work and consideration towards a more transparent, carbon neutral future. This is important for the health and longevity of our planet, and I am heartened to see regulations increase at a federal level.