May. 27, 2022
Dear Chair Gary Gensler, I am writing to support proposal S7-10-22, requiring companies to disclose audited greenhouse gas emissions in much the same way they are required to disclose audited financials. I strongly feel that the SEC should approve this proposal. Requiring disclosure of climate-related risks, and metrics reflecting those risks, is a timely and much needed step. Climate-related risks have reached historic and catastrophic levels. Voluntary guidance is inadequate. Existing disclosures do not adequately protect investors and shareholders who want to monitor the extent to which a company's behavior is consistent with its public statements. The current disclosures make it difficult for investors and shareholders to make investment or voting decisions aligned with their risk tolerances or ESG concerns. Many companies publish sustainability reports but few include emissions data in their SEC filings. Consistent, comparable and reliable disclosures on material climate-related risks will serve both investors and capital markets. I support requiring reporting of Scopes 1, 2, and 3 emissions, with a safe harbor from liability for reporting on Scope 3 emissions for one year. Its important that companies be held more responsive to shareholders. Sincerely, Paul McHugh 2601 Kenzie Ter Minneapolis, MN 55418-4229