From: Bevis Longstreth
Sent: May 29, 2016
To: rule-comments@sec.gov
Subject: File No. S7-06-16

Ladies and Gentlemen: 
This letter is directed at Releases No. 33-10064 and No. 34-77599, requesting comment on all aspects of Regulation S-K (the “S-K Release”).  The request includes with specificity and length  questions of sustainability, as that broad label may be applied to an issuer’s results and prospects, past, present and future.  These questions are of special significance today, given global recognition of the looming threat of climate change to life as we know it, including the life of issuers subject to the securities laws.
               In an Interpretative Release, dated February 8, 2010, the Commission gave guidance regarding disclosure related to climate change.  At the time, this effort was commendable.  However, it has been widely ignored by issuers and the Commission alike, reducing what should be mandatory disclosure concerning material effects of climate change on issuers to a voluntary system providing mostly boiler-plated platitudes that fail usefully to inform investors.
               The Sustainability Accounting Standards Board (the “SASB”) has submitted an important comment on the S-K Release.  I write in support of its comments, and rather than try to put them into my own words, simply incorporate them herein by reference.  Issues of sustainability can be, and often are, highly material to investor choice.  The SASB has developed sustainability standards for use as a way for issuers to comply with the disclosure requirements of the securities laws. It is the preferred way.  These standards are very well crafted to capture only what’s material to investors.  The Commission should incorporate them into the S-K and endorse with enthusiasm their use by issuers to meet the disclosure requirements of the securities laws.  

                                                                           Very truly yours,

                                                                           Bevis Longstreth
                                                                           Commissioner, 1981-84