Sep. 21, 2022
Dear Chair Gensler, I am writing to thank you for taking steps to make it easier for investors like me to understand climate risk. There is very real and significant economic risk in the impact of fossil fuel burning and high-carbon activities; as an investor looking to maximize my returns, I need to know whether or not a company is preparing to be successful in a low-carbon world. More and more economies are adopting policies and taking steps to align with the goals of the Paris Agreement, and those companies run much different risks than corporations that are using my money in risky business practices that depend on climate models that it is increasingly clear are no longer valid predictors of the future. 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. As the SEC was created to ensure that investors have the information they need to make intelligent investing decisions, this is a significant component of the regulatory space. 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.