Subject: S7-10-22: WebForm Comments from James Kalfas
From: James Kalfas
Affiliation:

May. 11, 2022

 ***May 11, 2022

 As an engineer and an investor concerned with the financial stability of my investments and the stability of the economy as a whole, I believe it is ABSOLUTELY IMPERATIVE for S7-10-22 to be enacted as soon as possible.

I work in the heavy manufacturing industry, supplying Pharmaceuticals and Research facilities. It is inevitable that every single customer and vendor with whom I interact is developing a plan for improving sustainability, both as a genuine effort and also as a way of encouraging potential investors and customers.  One of the chief complaints I encounter is a lack of standards for comparing ourselves to possible alternative vendors, and thus an inability to distinguish ourselves to our potential customers. This rule would help greatly to provide exactly the point of comparison we need to draw a distinction between ourselves and our competitors, and also to hold both ourselves and our competitors to account when it comes to advertised initiatives.

From the perspective of an investor, I'm relatively young. I will still be working in 2050 when most climate impacts are expected to be in full swing, and I cannot afford the uncertainty in my investments both for personal and retirement purposes that unclear climate standards create. I need to know when I'm investing that the companies I'm buying into aren't going to simply boost profits until they collapse due to unsustainable practices.

This rule is the absolute least that can be done to clarify the basic state of our climate efforts in industry, and it must be enacted without delay.
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