Apr. 27, 2022
I would like to submit my comments to the SEC proposed rule S7-10-22 (Enhancement and Standardization of Climate-Related Disclosures for Investors). I am opposed to this rule for two basic reasons: Congress attempted to pass these rules but were unable so the SEC is attempting to circumvent Congress and public pressure on companies is already producing the same information SEC is trying to implement. The summary admits that Investors have been asking for similar information from the companies they are looking to invest in, and those companies have provided it. The summary states the existing disclosure requirements “do not adequately protect investors.”. The summary states companies “may not disclose certain information needed to understand their existing climate-related disclosures, …”. The summary also states “increasing calls by the public… regarding how climate change may affect their business and operations…” Investing is a risk and placing a government required environmental, social and governance (ESG) score on each publicly traded company is overreach and outside of this Agency’s authority. This commission admits the public is asking for and receiving this information already. There are existing laws that protect investors from fraudulent/misleading information. The Global Investor Statement that is referenced has the primary goal of net zero emissions – which means phasing out fossil fuels. New York Times published an article on March 2, 2021 titled “How Green Are Electric Vehicles?” In this article, it addresses possible solutions to the lithium-ion cells and their environmental costs and how some companies are planning on using them in other ways to minimize this impact. Companies are innovating due to public pressure and demand, not government requirements! The commission does not address public utilities that use carbon-based fuels or the total carbon footprint from raw materials to finished product. Congress attempted to pass these same regulations but was unable to and this authority must remain in congress, not SEC. Thank you Andrew Hoggan