Jun. 17, 2022
June 17, 2022 Dear Commissioner Allison Herren Lee, I am writing in response to your request for public feedback regarding climate change information and questions about whether current disclosures adequately inform investors. I am a practicing Earth Scientist of over 40 years with multiple geological science degrees. I have been strongly involved in the study of the earth's paleoclimate throughout my career. Additionally, I have held and hold leadership positions in companies very large to small and several geoscience societies. I am very concerned with the SEC developing rules to try and have companies assess the climate impact of their businesses. Some of my concerns are as follows: 1) There are no acceptable models or theories for a business to make this assessment. Current computer models focusing on man made CO2 as a primary cause of the current mild increase in observed minimum temperatures have all consistently been incorrect by large margins. Importantly, their performance has not improved over several decades of effort. Dr. Steven Koonan's recent book "Unsettled" makes this case very clearly. My work and that of many other top scientists confirms these findings and indicate the fundamental algorithms are incorrect. 2) The observed climate changes are primarily of natural origin associated with complex cycles of variations in Earth orbit and tilt around the Sun. Solar irradiance dominates our constantly changing climate and consistently best explain the variations through both geological and historical time periods. I know of no time in Earth history where the climate has not been changing. 3) There is no scientific consensus on how to assess man's small impact on these processes. Statements by the media and others that there is such a consensus are fabrications that have been fully discredited by serious scientists. Numerous surveys and studies indicate that only some 20-30% of earth scientists and meteorologists believe man made CO2 is a primary cause of observed warming. 4) In light of no credible scientific model to make such assessments, the process will become inherently political with undefined legal liabilities that will inhibit investment in the United States. 5) In an era of understaffed companies with numerous supply shortages and bottlenecks, this will be another massive regulatory burden that will further inhibit productivity and supply. This reduction in supply, particularly in the energy sector, will result in additional inflationary pressure. 6) American companies already lead the world in reduction of carbon footprint and these regulations will further offshore projects to regions of the world with terrible environmental standards. China and India are adding coal fired power plants at a rate that dwarfs all the reductions that can be made in the United States. As a result, wealth and jobs will exit the United States with no discernable impact on our climate. This is a completely punitive and anti American concept. Respectfully submitted, Ernest LaFlure Tyler, Texas