Subject: S7-10-22: WebForm Comments from Suzanne Solensky
From: Suzanne Solensky
Affiliation:

Jun. 13, 2022



June 13, 2022

 I support the SEC's proposed rule S7-10-22, requiring publicly traded companies to disclose climate-related risks and their potential effects on business plans and strategies.  Many companies are already providing such information, in part because many shareholders and investors - including me - are asking for it and taking it into account when we make decisions about investments.  The SEC's rule, though, would encompass more companies and bring standardization to their reporting.

The need for such information is clear, because of the threat that climate change poses to our economy right now.  Individuals and households have already been affected by the rapidly changing climate, sometimes through extreme weather events that damage and even wipe out homes and small businesses, and many of us are assessing risks, planning how to adapt, and seeking to lower our carbon footprints.  Corporations must do the same, and investors rightly want to know how the companies we do business with and invest in are meeting the challenge.

By requiring consistent, comparable, and reliable information about how a registrant has addressed climate-related risks, the SEC's proposed rule will enable investors to better determine how to align our investments with our values.  But as companies gather the data, they may also scrutinize their operations for ways to lessen their contributions to climate change - and that would be welcome and economically sound.

I would support the proposed rule even more if it included disclosure of Scope 3 greenhouse gas emissions for all companies.  Although I am aware of the difficulty of quantifying emissions throughout the supply chain, Scope 3 emissions are potentially the biggest category for a business - and knowing how large they are and what a company is doing about them is key for investors.  Perhaps the proposed rule can be modified, either now or in the future, to fully include all emissions in reporting requirements.

Sincerely,
Suzanne Solensky