Jun. 16, 2022
I am a citizen in Denver gravely concerned about climate change. I see the effects every day - toxic air, burned forests, drought stricken landscapes and too little water for agricultural users. As an investor, I believe that investors want—and need—more standardized info about companies’ climate-related financial risks, their contributions to climate change, and their plans for remaining solvent in a low-carbon economy. This SEC effort is about investor protection, fair and efficient capital markets, and capital formation. It is the SEC’s job to make sure this information is freely available to all investors and the public, not just large financial institutions with vast resources. Already, this is an important and thoughtful proposal that would elicit meaningful, comparable disclosures that investors need to assess climate-related financial risks. I would like to share just a few suggestions to strengthen it: Scope 3 (value chain) GHG emissions are only required if they are “material” as determined by the issuer, or if they have set a public Scope 3 emissions target. This should be made mandatory for all large registrants with reasonable assurance (Question 98). There is also a safe harbor from liability with no sunset that should be excluded in the final rule. Per the proposal, Scope 3 disclosures will be judged to not be fraudulent unless “it is shown that such statement was made or reaffirmed without reasonable basis or was disclosed other than in good faith” (Pg. 489). The proposal should incorporate more disclosures around environmental justice, just transition for dislocated workers, and community-level impacts (Question 15) Thank you, Mandana Nakhai