Apr. 25, 2022
Dear Secretary Vanessa Countryman, As the agency tasked with regulating U.S. markets, I applaud your efforts to provide the public and investors with standardized and comprehensive information on climate risks to corporations. Corporations are responsible for the vast majority of greenhouse gas emissions in the U.S. and should not be left to their own devices in terms of reporting and planning for the consequences of those emissions. Requiring the reporting of Scope 3 emissions, which represent the full life cycle of a company’s emissions from cradle to grave, will for the first time allow the public and investors to see a complete picture of climate impacts from the U.S. private sector. For example, according to an analysis of Proctor & Gamble’s 2018 Citizenship report, the company’s reported greenhouse gas emissions soar from 4.3 million metric tons to 215 million metric tons when Scope 3 emissions are included alongside Scope 1 and 2. Without full transparency and standardized reporting requirements, investors, businesses, and the public are not able to fully prepare for the risks that come with a changing climate. Thank you for considering the swift adoption of rules to help businesses and individuals make fully informed decisions and achieve transparent climate goals and targets. Kathleen Nawaz