May. 26, 2022
Dear Secretary Vanessa Countryman, Every businessman knows you can't control what you don't measure. That's why people trying to solve climate disruption need transparency, and people getting a free ride want to avoid it. But climate is going to do all of us in, if we don't get our act together. Climate risk disclosue rules proposed by the Securities and Exchange Commission will serve to protect investors and promote a market environment worthy of the public’s trust. In fact, a national survey conducted by CERES and JUST Citizen shows 85% of Americans want large companies to publicly disclose climate related risks. If enacted, these rules will protect investors, promote innovation and transparency, and prepare the U.S. economy for a rapidly changing climate. In particular, including Scope 3 emissions will give investors a more complete picture of climate-related risks and total emissions from public companies, allowing regulators and lawmakers to make smarter decisions that benefit businesses and the environment. As we face increasingly frequent storms, heat waves, and sea-level rise, Virginia communities and businesses are eager to meet legislative mandates for a clean energy economy, but to do so requires transparency, consistency, and credible figures, especially from our investor-owned energy utilities. The systematic reporting required by the proposed rule will give state regulators, investors, and utility customers a vital tool to assess how Virginia’s energy monopolies are responding to climate change. Douglas Hendren