Jun. 17, 2022
My complete comment is attached as well as one referenced attachment. Excerpt: Re: Securities and Exchange Commission (“SEC,” “Commission”), The Enhancement and Standardization of Climate Related Disclosures for Investors, 87 FR 21334, April 11, 2022, https://www.govinfo.gov/content/pkg/FR-2022-0411/pdf/2022-06342.pdf. The SEC’s proposed rule is an ill-disguised, back-door attempt to implement the “Green New Deal” that has been rejected by Congress. Congress passed the Securities and Exchange Acts of 1933 and 1934 to implement a disclosure-based regime that facilitates investment decision-making by companies to determine what is material to investors, not the SEC. Congress has NOT given the SEC authority over climate policies or regulations. The SEC (or banking regulators) does not have the technical expertise to evaluate climate science, false claims made by alarmists or the accuracy of climate “models”. The SEC is not competent to assess the accuracy of disclosures regarding the supposed “risks” of climate change. The National Academies of Sciences, Engineering, and Medicine in its 2017 Report “Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide” oppose using the so-called Integrated Assessment Models (DICE, PAGE, FUND) for policy analysis. The only model that can be used that has been vetted under the Information Quality Act (signed into law by President Clinton) is the Model for the Assessment of Greenhouse Gas Induced Climate Change (MAGICC). (Note: the MAGICC model was developed by Dr. Tom Wigley because he didn’t trust the Global Climate Models used for the IPCC…this includes the models that the U.S. taxpayer has funded at NOAA and NASA), The model demonstrates clearly that any evaluation would have an unmeasurable effect on the temperature or sea level rise given the overwhelming impact of global GHG emissions from China and India. The proposed rule would severely undercut American energy and economic security. As we have learned from the Russian invasion of Ukraine and the China COVID plague, we need more, not less, investment in U.S. energy and critical supply chain companies. A.G. Randol III, PhD, Co-Founder VA Scientists and Engineers for Energy and Environment
(Attached File #1:s71022-20132274-302803.pdf)(Attached File #2:s71022-20132275-302803.pdf)