March 23, 2022
To whom it may concern
I am writing in regards to S7-10-22
The Enhancement and Standardization of Climate-Related Disclosures for Investors
I strongly urge the creation of a very transparent system for reporting scope 1, 2, and 3 emissions, and even more strongly urge scope 3 emissions be made publicly searchable for each corporation. As an investor, it is critical to make an informed decision, otherwise, the funds we invest may encourage, and rapidly escalate, the current trend towards a disastrous rise in average global temperature. This in turn, as you know, will negatively effect global economic exchange, as well as our immediate quality of daily life and the lives of our grandchildren and so on.
Obviously, the worst polluting corporations are not likely to voluntarily offer a reliable and accurate documentation of Scope 3 emissions. As we have seen in L.A. California, where long-distance visibility is significantly improved since the 1980's due to emissions regulations, regulation does work (personal communication with numerous longterm LA residents).
One option would be to tax corporations a certain percentage directly related to their emissions (scope 1, 2, and 3). If a company reduces emissions, they get a tax break in proportion to their reduction. If a large company can reduce emissions by 15%, then they will lower 15% less. Alternately, the tax could be based on emissions so a large polluter's emissions would be measured against a standard minimum baseline allowable emissions and taxed accordingly. If they are 20% above the allowable baseline, they pay 20% more than a company meeting the minimum baseline requirement. This money then would be used to fund programs agressively reducing emissions through 1. creation or investing in renewable energy, 2. searching out the largest sources of emissions and strictly reducing/regulating/improving them.
This % could be based on a set percentage. Say a corporation owes this year, if I'm not mistaken, 21%. Perhaps they could be allowed to only pay 16% if their emissions are lower than the minimum required baseline. In a scenario where taxable income is 15 million a 5% savings would be $750,000.
If the government can't afford to lose that much tax revenue, one alternative could be to simply raise the taxes. So a company that is above the baseline minimum emissions scope 1, 2, OR 3, by 5% with year end reporting of 15 million would lower 26% instead of 21%. Their additional $750, 000 would go into government funding to reduce emissions. Strict accountability would be required within the government to ensure this money goes exclusively towards solutions to climate change and emissions reduction.
In summary, there are many ways to leverage accountability from corporations with large emissions and investors demand accountability. We want to know Scope 3 emissions for the corporation (accurately reported) before deciding to invest. The funding for the reduction of emissions can be both an asset to corporations and can come from their own assets if the right structure is put in place.
Thank you,
Robin Bliss-Wagner