Mar. 25, 2022
Dear Commissioners, I am writing in support of the draft rule that would require climate-related disclosures in filings by U.S. publicly listed companies. Since southern plantation owners started getting rich on cotton driving the industrial revolution, the USA and Europe have driven climate change with our economic system. With the discovery of oil, invention of cars, electrical gadgets with planned obsolescence, airplanes, weapons and modern warfare, we have come to a crisis threatening our planetary existence. In the 1800’s, people didn’t realize that CO2 was accumulating in the atmosphere, nor did most realize that their investments in slaves were inhumane, immoral and were going to lead to the civil war. Today, within this financial system dependent on economic growth, people still don’t realize what their investments are contributing to. In 2016, the SEC fined Monsanto $80 million for securities fraud. The investors were being doubly defrauded, by Monsanto’s financial manipulations and by the poisoning of the earth by Monsanto’s chemicals. Each of us has an accumulation of PCBs in our bodies. The SEC draft climate disclosure ruling has been applauded by Kristina Wyatt, former senior counsel at the SEC. She says: I think it does a very nice job of weaving climate through the entirety of a company's reporting process. Investors should not only have the right but the responsibility to know what our money is supporting. When we are not provided that information, we support policies that are literally killing us, have already contributed to the losses of livable environments for millions of climate refugees and to what is being called the 6th extinction of species. It is therefore vital that the requirement for a registrant to disclose separately its total scope 3 GHG emissions for the fiscal year if those emissions are material, or if it has GHG emissions reduction targets or goals that includes scope 3 emissions, should not be limited by the safe harbor clause nor should it be limited to disclosures that the registrant considers material. This would appear to give too much deference and discretion to the registrant on scope 3 emissions reporting, which, in some cases, forms the bulk of a company’s GHG emissions. Only by strict oversight and an objective test of what is considered material for scope 3 purposes, would it become possible for investors/us to gain access to the information we really need for making our investment decisions in our efforts to reduce the risk of dangerous climate change. A recent editorial from the WSJ, written in opposition to the draft ruling noted that “…carbon emissions aren’t relevant to the financial performance of most public companies”. This should be seen as reason for the ruling and not as opposition to it. Companies should be financially responsible for the damage their emissions cause. Those suffering the damages will become increasingly successful in litigation, as happened with the tobacco industry, the opioids epidemic, and “forever” chemicals. This is only right. And relative to the SEC ruling, will impact investors’ returns. Thank you,