Jun. 15, 2022
June 15, 2022 I write to express my concerns regarding the Securities and Exchange Commissions (SEC) proposed rule on Enhanced and Standardization of Climate-Related Disclosures for Investors. I have serious concerns regarding the SECs regulatory overreach, as well as the impact that this proposed rule will have on all industry. As such, I urge you to rescind the proposed rule. On March 21, 2022, the SEC issued a proposed rule that would require publicly traded companies (SEC registrants) to include financially immaterial climate change disclosures in their registration statements and periodic reports. Specifically, the proposed rule requires SEC registrants to disclose information about their direct greenhouse gas emissions (Scope 1), indirect emissions from purchased electricity or other forms of energy (Scope 2), and, if found to be material to investors, greenhouse gas emissions from all activities in its value chain (Scope 3). I cannot imagine the SEC has done its due diligence on the cost benefit analysis of such a rule and the magnitude of documentation and labor to comply with this proposed rule. In addition, this rule is promulgated on the speculation that greenhouse gas emissions have been solely responsible for naturally occurring weather-related phenomena. Even the Intergovernmental Panel on Climate Change (IPCC) has not nor cannot definitively prove, conclude nor state that such a cause-and-effect relationship exists between greenhouse gas emissions and naturally occurring weather-related events. For these reasons I urge you to rescind this ill-advised proposed rule.