Jun. 13, 2022
June 13, 2022 I strongly disagree with the proposal S7-10-22-The Enhancement and Standardization of Climate-Related Disclosures based on the following: 1. This is clearly a thinly vailed attempt to further radical climate activism. 2. Unfortunately the SEC is a partisan organization. The current SEC Commissioners are majority democrat. The chair is Gary Gensler who is a progressive climate worrier pushing a variety of progressive policies. Much of the progressive agenda that has taken hold in the democratic party doesn't line up with a majority of the American population and in many cases is not supported within the democratic party itself. 3. The SEC was created by congress after the 1929 stock market crash. Congress has not given the SEC any authority over climate policy. In comparing large and impactful regulatory laws enacted fairly recently, congress passed Sarbanes-Oxley and Dodd-Frank to address company failures and failures related to the 2008 financial crisis. The SEC enforces these laws. It would be similarly wise to implement any regulatory requirements related to the impact of climate change through congress. In that way it would be a democratic process rather than partisan activism. 4. The SEC does not have the technical expertise to define and/or evaluate climate science or accuracy of climate models. 5. Climate experts currently disagree on the impact of climate change. How can significant regulatory burdens be enacted when the science and impact of climate change is not well defined or agreed to among climate experts. 6. The US should endeavor to stimulate production of energy sources that result in energy independence. Increased regulatory burdens are costly and an impediment to producing energy sources. The proposal will result in reduced investment in oil and gas industries when we really need to increase these investments. 7. Renewable energy is not at a scale to replace fossil fuels. 8. Consistent and reliable sources of energy are mandatory to ensure the safety and national security of the US. 9. The US needs to be energy independent... again My 2 cents: Much of the energy and hysteria around this topic is driven by information/disinformation related to climate. The current administration has commissioned a climate envoy to advocate for action across the globe to address climate change. That's a good thing. But the basic message is that the US and rest of the world needs to do enough in 2020-2030 to be able to achieve net-zero by 2050, that's 8 years. The implication is that if we don't achieve the 8-year goal, then the 2050 goal is not achievable and we get what? mass food shortages, mass demographic displacement, pestilence, conflict, mayhem, etc. etc. etc. That sounds a lot like a used car salesman, \"what can I do to get you into this climate change today\". This is alarmist messaging. Alarmist messaging is not leadership. Actually, I believe this type of alarmist messaging is harmful and raises to the level of disinformation. Unfortunately, in this world of social media making alarmist claims can raise emotions and hysteria to a fever pitch and open opportunities for people to be exploited for political purposes. One other problem with the current administrations narratives and messaging around climate change is that dots don't connect. Big, BIG dots. We have our climate envoy flying around in a private plane trying to promote climate justice. His family owns a charter plane business. World leaders fly around for global meetings lamenting climate change. Domestically politicians fly all around, people think other people are important if they fly around for their job, people say climate change is a big threat then they drive away in their SUV, a family of two with no children that drives electric cars and have solar generate more than 100% of their electricity and owns a heat pump does not derive any benefit for their reduced greenhouse gas emissions over a family of 8 people with 6 gas cars and conspicuously consumes and throws away tons of trash. Where are leadership proposals that can address these examples and many, many other types of \"do as I say not as I do\" examples. So, I believe proposals like S7-10-22 are misguided and are actually counterproductive. I strongly support actionable proposals that can address climate change and effect changes in attitudes and behavior that contribute to reducing energy use. Since currently we get something like 80% of our energy from non-renewable, hydrocarbon-based sources, a reduction in energy use will have a direct impact on reducing climate change. One huge example we can learn from is the covid pandemic. The resulting lock downs resulted in people not driving, flying, taking train trips, commuting, office buildings did not need to be heated due to remote work, supply chain capacity was not needed due to the reduction of product needed to be moved around the world, etc. The list can go on and on. If you recall the impact on the energy market, oil futures actually went negative and storage capacity around the world was insufficient to store oil. This clearly indicates that the need for energy is demand based. Take away the demand and it's clear that the world does not need the amount of en ergy produced and consumed. Now it's true that the world cannot operate in a lock down mode. But it is also empirically obvious that we need fewer people consuming fossil fuels and for the current population that exists, we need them to use less. The government can and should be a valid source that can drive policies that have an impact on demand at a personal, community, county, state, country level. A couple of examples would be: 1. A yearly individual consumption tax. For example, how much electricity is used, how much heating oil or natural gas is used, how many miles are driven in a gas car, how many plane trips are taken, etc. Maybe some way to track product consumption, e.g., a family with 3 kids buys a lot of products that are produced in other countries and moved via a supply chain to the point of consumption (obviously this requires significantly more greenhouse emissions than a family with no kids-just an illustrative example). The list can go on but the idea is to relate the environmental cost of consumption to the source of that consumption. It's common understanding that, at least in the US, consumers drive the economy. A consumption tax would place the cost at the responsible level (the individual) and drive attitudes and behaviors that would either reduce greenhouse gas emissions and/or provide funds to help reduce these in other areas. 2. A yearly individual consumption credit. People and families are climate change factories. PEOPLE ARE THE SOURCE OF DEMAND THAT DRIVES CLIMATE CHANGE. Companies produce products and utilities generate energy to meet this demand. Individuals and families that make conscious choices to reduce their impact on the environment and reduce climate change should be rewarded. 3. Elimination of the child tax credit. When you get down to the bottom line, people (humans) are the cause of climate change. The government should not incent people that choose to add to population growth and associate a cost if people choose to do so. 4. A corollary to the above, creation of a yearly \"no child or no population growth\" tax credit. The government should incent people who choose not to add to population growth. 5. Somehow create a cost for cities and counties that choose to grow irresponsibly. For example, I live in a rural area that is in the process of approving development of 2K+ homes. This would be on 500+ acres of existing orchards. So the result would be eliminating orchards that actually reduce carbon in the environment with homes and the associated demand for water and electricity, cement/asphalt heating the environment, traffic contributing the air pollution, etc. How can this make sense given the critical impacts of climate change being pushed by the current administration. So, to sum up the above, the government should enact policies and procedures that associate a cost to climate change are associate that cost to individuals in proportion to their impact on climate change. A good example is the steps that the Biden administration has taken to drive up gas prices. They are clearly trying to financially influence folks in the US to move in the direction of electric vehicles. This dovetails with the push for auto makers to phase out gas powered cars. This may have the desired effect but seem punitive. A better approach would be to: - Expand oil and gas exploration and production - Achieve energy independence in the US again - Influence individual attitudes and behaviors via tax policy. Back to the gas example, paying $8.00/gal is not so different than paying $2-4/gal and being taxed on usage but seems more palatable as folks would understand that the additional cost would be going to address climate change not enrich oil companies. - Influence cities, counties, states to grow responsibly and consider climate change in general plans. If you made it this far, thanks for reading this.