Jun. 17, 2022
The Enhancement and Standardization of Climate-Related Disclosures for Investors AGENCY: Securities and Exchange Commission I object in the strongest possible terms to the rules proposed herein. These rules are drafted by bankers for the exclusive benefit of bankers. I became aware of the ESG movement after reading about Carbon Disclosure Project (CDP) in the context of WalMart and their involvement in the Global Roundtable for Sustainable Beef (GRSB), a top-down technocratic effort to assume control over all beef production and the lands and resources associated therewith. I came across a very telling, 2010 article in the Harvard Business Review entitled The Most Powerful Green NGO You Never Heard OF, https://hbr.org/2010/10/the-most-powerful-green-ngo I urge you to read same. The control mechanism used by CDP and other similar organizations (such as CERES) is most closely analogous to the Struggle Sessions forced upon society by the failed communist regimes in the Soviet Union and Maoist China. There, subjects were called upon to voluntarily disclose perceived indiscretions. Those failing to disclose such were publicly punished as an example to others. Subsequently, those disclosures were used selectively to indict previously cooperative individuals who later resisted the tyranny. The quote "Show me the man and I'll show you the crime" is famously attributed to Joseph Stalin, voicing approval of the efficiency of the Struggle Sessions. But CDP, CERES (and now the SEC proposes to similarly) exercise power differently but the blueprint is pure Struggle Session. By aggregating trillions of dollars of assets under investment, these organizations force companies to disclose their alleged carbon sins. Initially, those that willingly disclose will be rewarded by having investment money directed their way. Those that fail to disclose will find themselves deprived of investment capital. Favored companies will be object of preferential capitalization that will provide prosperity and growth through merger and acquisition until a cartel of only a handful of companies is constructed by Big Finance at the choke point within the supply chain of every service and commodity. This puts the financiers in a position to dictate all terms of production. Any subsequent transgressions by companies are punishable by jerking the funding. As a case study, the purpose of GRSB had nothing to do with making beef production better. It had to do with financiers, with the help of their surrogates in the United Nations and the World Wildlife Fund, (all of whom very publicly hope to change global diets away from animal agriculture) forcing an unmanageable command and control technocracy upon producers, raising their cost structure and driving them out of business. It cannot be ignored the SEC has proposed here nearly 500 pages of mind numbing regulation and has essentially deprived the public of meaningful comment by only allowing a very short comment period. Why the rush? A sympathetic media has kept these rules all but secret from the public. Plainly, the SEC plans to ram these rules through without providing so much as a shred of proof of their necessity or prospective benefit. Inclusion of requirements to disclose "Scope 3" emissions will outsource enforcement of these endless requirements to corporations. The last two years or so have revealed federal law enforcement agencies to be little more than a protection racket run by secret police given cover by a compliant and similarly controlled media. Even the casual observer will know corporations that fail to find favor with those in power will be dealt with selectively. The rules are bereft of any indication just exactly what it is about Gary Ginsler or being another Goldman Sachs insider that transforms him or his staff into experts on climate science. As I said, these rules are proposed by bankers for the exclusive benefit of bankers. That CERES, CDP and World Wildlife Fund are foremost cheerleaders of this effort tells the world this is no more than a naked power grab. With every fiber of my being, I and those within my sphere of influence will not cooperate with this dystopian fascism.