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

Apr. 01, 2022



Dear Chair Gary Gensler,

     I am writing as a physician and public health advocate, to make you aware that because you are  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. Please realize that the 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 a physician and public health advocate, I am  extremely concerned about how heat-trapping emissions and rapidly worsening climate impacts pose a significant risk across many areas of human society and include our financial and economic systems.
     At this time, I urge the Commission to please adopt a strong, comprehensive rule without delay. In particular, I recommend  that 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.
     I strongly support these disclosures  because the proposed rule would increase transparency by requiring corporations to report how much heat-trapping emissions their businesses produce, how climate impacts might affect their businesses, and how they plan to meet their global warming emissions targets and transition to cleaner sources of energy. The rule would allow investors of all sizes to make smart and informed decisions in the face of systemic climate risk.
     At this time, I thank you for your consideration of my letter and my recommendations.  It is crucial to understand that swift adoption, implementation, and enforcement of this 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.

Sincerely,
Jean Marie Naples, MD-Ph.D.


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

Sincerely,
Dr. Jean Naples
Suffern, NY 10901