Apr. 01, 2022
Dear Chair Gary Gensler, I strongly encourage passage of your agency’s new rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (S7-10-22). As an expert in coastal zone and flood risk management, I’m extremely concerned about the greenhouse gas emissions increases that are worsening climate impacts to any built infrastructure near a stream, river, lake, coastline, forest, or mountain. Increasing floods, fires, landslides, droughts all a significant risk to our financial systems which depend on the ability to classify and quantify risk. The significant financial and human losses that are accruing due to climate change are quite literally undermining all of our safety net systems, including reinsurance, mortgages, and fundamental built infrastructure. 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. Please protect our financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible. Sincerely, Dr. Michael Parke