May. 09, 2022
To protect both investors and the overall economy in the face of worsening climate impacts and the transition to clean energy, the SEC should take climate-related financial risk seriously. That’s why I support the SEC’s proposal (87 FR 21334; File No: S7-10-22) to require public companies to make mandatory disclosures about their climate-related financial risks within annual SEC filings. I also support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I encourage the SEC to strengthen the rule by requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all large registrants. Ignoring Scope 3 would mean missing information on 75% of emissions, information that is material to investors. Additionally, as the market and economy transitions, impacts on people and communities need to be known. The rule should include disclosures around environmental justice, indigenous rights, a just transition for dislocated workers, and community-level impacts. Best regards,