May. 05, 2022
May 5, 2022
Sirs,
I fully support the US Securities and Exchange Commissions proposed rule No. 33-11042, called The Enhancement and Standardization of Climate-Related Disclosures for Investors proposed rule. The three requirements of 33-11042 that are non-negotiable are:
All businesses, foreign and domestic, traded on any American stock exchange must comply to disclose the answers required by 33-11042, without delays or exceptions, within the documents those businesses initially or annually report to the SEC
Disclosing how any identified climate-related risks have been affected or are likely to affect the businesss strategy, its business model, and outlook on a short-, medium- and long-term basis
Disclosing what are a business's direct greenhouse gas emissions (Scope 1) and its indirect emissions from purchased electricity and other forms of energy (Scope 2), separately disclosed, expressed both by disaggregated constituent greenhouse gases and in the aggregate, and in absolute terms, not including offsets, and in terms of intensity (per unit of economic value or production).
I am grateful for the SEC employees that composed each of 33-11042s requirements and I admire the managers of the SEC for their courage and concern for the safety of all of us that are affected by the intentional neglect that corporate and limited liability entities practice to enrich shareholders at the expense of others. Please allow me to explain how proposed rule 33-11042 is incomplete.
Destructive lethal climate change has resulted from our forefathers practice of capitalism. Individual human beings do not have the capability to dig and extract fossil fuels, embedded in the earth, at the massive scale that has caused anthropomorphic climate change. It has been capitalism that has coordinated the organization of business activities necessary for the mass extraction, production, international distribution and use of fossil fuels, steel and cement that has overloaded Earth's atmosphere with waste products of those favored industries. The waste products of these three business activities have and are continuing to diminish our children's chances of survival of the consequences of the changes occurring now in earth's atmosphere. Remember, according the EPA, greenhouse gases accumulate to trap heat within our atmosphere for as long as a thousand years, hour by hour, day and night.1
Adopting Proposed rule no. 33-11042 will lay the groundwork for the changes to capitalism that are necessary to reform its predatory practices and mitigate its toxic byproducts. Investors, both institutional and private, could use their financial leverage to pressure companies to commit to the decarbonization of their investments if given the information that 33-11042 would require of businesses provide to stock market investors.
I ask that the SEC require all applicants to reveal their past expenditures, since 1980, to alter or form governments', State and national, as well as the public's perception about climate change. These profit motivated campaigns of deception and greenwashing are every bit as lethal as the carbon dioxide equivalents generated during those periods that corporations withheld scientific data, financed the creation and distribution of disinformation that intentionally interfered with the public's absorption of science-based climate change information.
I ask that the SEC require of all applicants to disclose their amount of Scope 3 emissions as determined from an accredited third party, non-profit environmental organization for compliance of 33-11042.
I ask that enforcement must include prohibitive fines on the executives and board members for non-compliance with SEC No. 33-11042, and the violators stock and bonds immediately be yanked off all US exchanges as well as liability exposure to violators from investors' court actions.
As radical as the punishment I recommend for violation of proposed rule 33-11042 is, the growing destruction resulting from current accumulation of greenhouse gases in earths atmosphere will be survivable only if capitalism is changed to be harnessed to reverse its parasitical damage to life sustaining resources and atmospheric functions that nurtured humanity's advance to a science-based, circumspect civilization.
Keep up the good work and thanks for your time and attention.
Jeffrey Silva
1 Overview of Greenhouse Gases, 5 May 2022, https://www.epa.gov/ghgemissions/overview-greenhouse-gases .