Sep. 16, 2022
Dear Chair Gensler, Thank you for developing climate risk disclosure rules that provide crucial information for investors like me. As a small investor, I need to know whether companies have taken steps to prepare for success in an economic environment that will require reduced carbon emissions. I am asking you to make sure that strong disclosures on greenhouse gas emissions are included in SEC rules. More and more economies are adopting policies and taking steps to align with the goals of the Paris Agreement. Companies not working to reduce their Scope 1, 2 and 3 greenhouse emissions may not be prepared for that future. Without this information, I won't be able to tell what companies are likely to continue to be profitable as the economy transitions to clean energy and which companies could put my savings at risk. Earlier this summer you proposed a rule to require publicly traded companies to disclose "material" Scope 3 emissions. Many investors - both asset managers and individual investors like me - asked you to make this a requirement for all large public companies, and I am hopeful that you will listen to the voices of regular people like me, not just big corporations looking to hide their risks. As you look to finalize these rules, I wanted to thank you for doing everything in your power to ensure that investors like me have the information we need to be able to make smart investing decisions for a low-carbon future. I am looking forward to seeing strong greenhouse gas disclosures, inclusive of Scope 3 emissions, in your final ruling later this year. Dr. Charles MacArthur