Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, As a retired teacher I feel it is important for investment managers to have access to standardized, comparable 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. Allowing companies to voluntarily choose what and how they want 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 am writing to tell you of my support for 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 support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms and strongly encourage 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 is important to encourage prospective retirement savers to invest in the U.S. capital markets, and provide market participants with needed climate-related information for making investments. Sincerely, Diana Rogers Dia Rogers