Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, All who manage investment accounts professionally or who personally invest in the stock market or have retirement plans that are in the market should have access to accurate, 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. The current practice of leaving it up to corporations to voluntarily choose what and how to report, and even whether or not they want to disclose their climate-related financial risks, makes it impossible for investors and other market participants to fully understand and compare the risks and opportunities associated with different investments. I support the Securities and Exchange Commission (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 believe we should require the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I urge the SEC to strengthen the final rule by requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all large registrants, and to include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. This proposal addresses a needed remedy to the current lack of necessary, comparable, voluntary climate risk disclosure. It will protect investors, encourage retirement savers to invest in the U.S. capital markets, and provide us all with the climate-related information we neef to accurately price climate risk and make well-informed investment decisions. Sincerely, Erica Silverman