Subject: Comment on Proposed Rule S7-10-22: Enhancement and Standardization of Climate-Related Disclosures for Investors
From: Lisa Hecht
Affiliation:

Apr. 01, 2022



Dear Chair Gary Gensler,

As our government's chief financial regulator, your agency is responsible for ensuring public companies respond to investors’ need for information that helps them protect their investments. Passage of your agency’s new rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (S7-10-22) is a critical step in fulfilling your mandate.

As an engineer who has tracked the science of global warming since 1975, reduced my own carbon footprint by 75% and adjusted my portfolio to reduce both fossil fuels and their risks, I’m extremely concerned about how heat-trapping emissions and rapidly worsening climate impacts pose a significant risk across many areas of human society—including to our financial and economic systems. I urge the Commission to adopt a strong, comprehensive rule without delay. In particular, the final rule should mandate and standardize disclosure by publicly listed companies of ALL heat-trapping emissions associated with corporate operations, products, and supply chains, as Scope 3 emissions can account for 80-90 percent of companies’ total emissions in some sectors.

Swift adoption, implementation, and enforcement of a strong rule will help businesses meet the demands of international capital markets and ensure investors have consistent and comparable data to make fully informed decisions and hold corporations accountable for their impact on the climate, their plans to mitigate those impacts, and their progress in achieving climate-related goals and targets.

The most powerful tool we have for addressing climate change and protecting their lives and livelihoods of Americans is what we value as reflected in our economy. That needs to express and incorporate the risks associated with fossil fuel extraction and use.

Please protect our financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible.

Sincerely,
Ms. Lisa Hecht
Boise, ID 83716