Jun. 14, 2022
Allison Herren Lee, Acting Chair U.S. Securities and Exchange Commission 100 F Street NE Washington, D.C. 20549 Re: Public Statement: Public Input Welcomed on Climate Change Disclosures, Acting Chair Allison Herren Lee Dear Ms Herren Lee: The SEC is not the forum, nor was it ever equipped to be the forum, to make decisions about climate science. In fact it is quite obvious that this entire matter is purely a political maneuver to carry out a political agenda that has almost no basis in science, history or fact. As a former geologist I can assure the Commission that geology (in large part the science of studying the past effects of climate on the earth) strongly disagrees with the hypothesis that carbon dioxide, whether produced by humans or naturally, causes, or even has significant influence over, earth's climate. Ice core studies from both Greenland and Antarctica prove that carbon dioxide levels rise AFTER temperature rises, not before. This observation is supported by other geological findings in the areas of beryllium isotope analysis, oxygen isotope analysis, sedimentary analysis, and even laboratory research. This is of huge significance given that the currently popular hypothesis states exactly the opposite. That the IPCC promotes this unfounded hypothesis is the result of it very narrow and unscientific mandate: "to find the human causes of climate change" Of course they won't find any other 'cause' because that isn't their job! And the SEC should know this and therefore reject any and all biased information coming therefrom.). I would even go so far as declaring that this exceedingly narrow mandate borders on criminal given the widespread aura of 'authority' something coming from the UN has. The sad fact is that this faulty hypothesis is based entirely upon GIGO computer modeling and activist players on the world scene. Like the IPCC those computers only regurgitate what they are programmed to find -- and I remind the Commission that computer models, while they can be useful, are NOT observational science. They only reflect the bias of those who program them. Speaking of bias, in 2009 and again in 2011, someone surreptitiously made available a large number emails and correspondence -- later referred to as the "Climategate Email Dump" -- which outlined an underhanded scheme to provide disinformation and outright lies to the public and scholarly community regarding climate. In them it was acknowledged by some principal actors that the geological history refuted their hypothesis and therefore they had to made all of that scientific evidence "disappear". In addition one of those principals, Dr. Michael Mann, created a most unscientific "hockey stick graph" that not only has been completely refuted by observed science but he also was essentially proven to be a liar by a court in British Columbia, Canada when he refused to produce evidence in support of his claims. Why did he not do so? Because he knew that his "evidence" was fabricated and a complete farce and the Climategate emails proved he conspired to defraud the world about it. In addition there has been a concerted effort by the mainstream media, Big Tech, and even academia to censor those who disagree with the unproven AGW hypothesis. These actions should make the SEC very, very suspicious of, and avoid at all costs, attempts to include climate in any disclosures that come before it. Much has been made about the doubling of carbon dioxide in the atmosphere and how that will cause, if it hasn't already, a "climate emergency". This preposterous idea is self-serving special pleading and circular reasoning at its worst. What the public is not being informed about is that carbon dioxide absorbs radiation on a logarithmic scale and that almost all of whatever radiation/heat is already absorbed, and thus re-radiated, at 20 ppm! In fact you could add up ALL of the heat absorbed thereafter and it would not equal the amount absorbed at 20 ppm! Careful, OBSERVATIONAL studies of the infrared wavelengths of carbon dioxide conclusively prove that doubling the amount of carbon dioxide from its current 417 ppm to 800 ppm would add less than 0.5 degrees 1 2 3 4 5 6. What the public is also not being told about is that the earth is greening 1 2 as a result of increased carbon dioxide in the atmosphere - some 30% over the past 50 years or so! This, plus the widespread use of hydrocarbon-based fertilizers has caused crop production around the world to more than increase in quantity so as to be able to feed the entire world's population 1 2 . Clearly from these brief studies there is no such thing as a "climate emergency", indeed quite the opposite! Another specious claim that is made to the public is that extreme weather events are increasing. This is bogus in the extreme! Easily verifiable data and headlines from the past prove such claims to be utterly false -- that doesn't stop the media from repeating them but it certainly doesn't make them true just because they are repeated. Study after study after study has shown that hurricanes, tornadoes, floods, droughts and other such weather-related events are not increasing 1 2 3 4 . Geological studies also prove that earth has gone through ebbs and flows of climate-related events and that what we experience today are neither unique, nor more in number, nor worse in effect. The only thing that has really changed is that our media have taken to megaphoning any and all events to a blinkered public as if the current event is the "most unprecedented ev-a-a-ahhh!" I could go on and on but I'm sure the Commission has received an abundance of scientific reports demonstrating that it would be very, very suspect to require any company or corporation or business to file a "climate disclosure". Once again, THE ONLY reason to do so is not due diligence but pure and simply to accede to a political agenda which has nothing to do with science or the well-being of the economy or businesses. At the same time I am not very optimistic that the Commission will objectively look at the lack of scientific evidence supporting the climate activist agenda. I say this not with malice, but a deepening sense of gloom that science has been jettisoned in favor of a political agenda - which is then papered over with a thin veneer of pseudoscience, easily disprovable but adhered to nonetheless for the sake of political gain. I would hope otherwise. James Church, B.Sc., M.Div.