May. 22, 2022
Dear Chair Gary Gensler, I am writing to urge passage of your agency’s new rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (S7-10-22). It is a critical step in fulfilling your mandate as our government's chief financial regulator, and for ensuring public companies disclose such information so that investors and pension managers can protect their investments. I am extremely concerned about how heat-trapping emissions and rapidly worsening climate impacts pose a significant risk (particularly, as a physician, I worry about the increased spread of infectious diseases and pathogenic organisms). These risks threaten many areas of human society – including to our financial and economic systems. It is imperative that such risks be acknowledged and disclosed by publicly traded corporations. I urge the Commission to adopt a strong, comprehensive rule without delay. Specifically, the final rule should mandate and standardize disclosure by publicly listed companies of ALL heat-trapping emissions associated with corporate operations, products, and supply chains, as Scope 3 emissions can account for 80-90 percent of companies’ total emissions in some sectors. Swift adoption, implementation, and enforcement of a strong rule will help businesses meet the demands of international capital markets and ensure investors have consistent and comparable data to make fully informed decisions and hold corporations accountable for their impact on the climate, their plans to mitigate those impacts, and their progress in achieving climate-related goals and targets. Please protect our financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible. Sincerely, Dr. Richard Bradus