Feb. 25, 2023
February 25, 2023 Please consider the following comments on proposed changes to the Securities and Exchange Commission (SEC) regulations published in Title 17 of the Code of Federal Regulations, to implement proposed rule, \"The Enhancement and Standardization of Climate-Related Disclosures for Investors.\" First, I support the goal of the rule to inform investors of potential risk associated with climate change. I also believe that the requirements for public companies to disclose such risks will be a forcing function for companies to evaluate climate change-related risk and develop appropriate resilience/mitigation strategies. This, ultimately, can be a component to support a U.S. economy that is more resilient to the potential impact of climate change. While I support the general concept of disclosures pertaining to climate change risk evaluation and resilience/mitigation planning, I question the appropriateness of SEC's proposed requirements for disclosure of Scope 1, Scope 2, and Scope 3 emissions. Please clarify how reporting of Scope 1 and Scope 2 emissions falls within the statutory purview of the SEC and how such reporting can help inform investors from a financial risk perspective. Although there may be a potential for Scope 3 emissions reporting to inform investment risk since it points to potential supply chain risk, the SEC proposed rule merely applies to those companies who report goals associated with such emissions. Please clarify how the SEC believes this collective set of Scope 1, 2, and 3 emissions reporting will provide consistent and useful information to investors. Finally, it is not clear how climate risk disclosure reporting will provide consistent information to investors. Please clarify the aspects of the proposed rule that ensure consistency in risk analysis and associated reporting. For example, there remains a high degree of uncertainty with respect to climate change science and related impacts that only consistently performed probabilistic risk analysis, that appropriately factors in uncertainty, can adequately inform. Please clarify how the SEC proposed rule ensures consistency in analysis to support consistent disclosure of risk to investors.