Apr. 06, 2022
Dear Chair Gary Gensler, As our government's chief financial regulator, I know 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. I am a molecular biologist, specializing on arthropods and recently ranked among the top 2% of the world's scientists regardless of specialty. As an expert in my field, I know the impact that global climate change is having on insect populations. 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. On a personal level, I investigate the corporations with which I do business and avoid investing in a buying from those with poor environmental records. My research has found that we are in a rapidly deteriorating situation with our climate, and we are on a path for making the world uninhabitable for humans. 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. Felicito Guerrero