Apr. 02, 2022
Dear Chair Gary Gensler, Your agency, as our government's chief financial regulator, is responsible for ensuring public companies provide investors’ with the information they need to help protect their investments. Given the increasing financial impacts mounting climate change is imposing, passage of your agency’s new rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (S7-10-22) is critical. Doing anything less would be to disregard your mandate. As an expert in my field, I’m more than concerned and increasingly moreso about how heat-trapping emissions and rapidly worsening climate and biosphere impacts are significantly increasing risk across many areas of human society—including to most aspects of our life constraining financial, economic and environmental systems. I ask and advocate for the Commission to adopt a strong, comprehensive rule without delay. It is important that the final rule 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. Rapid adoption, implementation, and enforcement of a strong rule will help businesses meet the growing demands of international capital markets. It will helpfully ensure investors have consistent and comparable data, which is essential for investors to make fully informed decisions and hold corporations accountable for their climate impacts, their plans to mitigate those impacts, and their progress in achieving climate-related goals and targets. Please protect our financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible. Sincerely, Mr. Jim McMillan