Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, People with a retirement plan, like a 401K, an IRA, or a pension, should be ensured that the professionals managing their investment have standardized information about public companies’ vulnerability to climate change, their current greenhouse gas (GHG) emissions, and their plans to manage climate risks and make good on their public climate commitments. This information needs to be able to be compared between companies, so that the fund managers can make informed decisions for their investors. Currently companies can volunteer what to report and how they want to report it. They can choose not to disclose their climate-related financial risks, making it impossible for investors and other market participants to fully understand and compare the risks and opportunities associated with different investments. This is why I support the SEC’s recent proposal (87 FR 21334; File No: S7-10-22) to require public companies to make standardized, mandatory disclosures about their climate-related financial risks within annual SEC filings. I support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I strongly encourage the SEC to strengthen the final rule by requiring all large registrants to disclose Scope 3 GHG emissions (such as product and supply chain emissions), and to include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. This proposal is a vital step towards fixing a broken system of inadequate, non-standardized, voluntary climate risk disclosure. It will protect investors, encourage workers looking to invest their retirement funds to invest in U.S. capital markets, and it will provide investors and their fund managers with the climate-related information they need to accurately price climate risk and make well-informed investment decisions. Sincerely, Sandy Blakeney