Jun. 14, 2022
Please accept my comments below related to proposed SEC ESG rules included in S7-17-22. Please abandon your efforts to add regulations regarding man-made climate change. I am an engineer and businessman with broad experience in public, private and venture areas with multiple degrees from renowned technical universities including MIT and the University of Michigan. Along with countless engineers and scientists, we have studied the popular man-made climate change claims. Our findings have been scientifically vetted. From observed data over hundreds of millions of years, there is no credible data supporting the claims that any climate change is caused by humans burning fossil fuels. Consider the following facts which are supported by scientifically vetted principle and observed facts. These facts completely destroy the popular but misguided and uninformed narrative that humans are creating climate change and that humans can actually change the destiny of climate. 1-Earth has seen hundreds of similar and greater temperature changes, up and down, as we’ve seen since the beginning of the increased burning of fossil fuels, circa 1875. Claims that temperatures have risen depends totally on the starting date of the claim. It is easy to show that selecting different starting dates shows falling temperatures. 2-Current CO2 levels of approximately 400ppm are near all time record lows in the entire history of Earth. Only one period, about 300,000 years ago, were CO2 levels near current levels. 3-Life ceases to exit at 150ppm of CO2, only 250ppm below current levels. Now that, is the real existential threat of climate change…too little CO2. CO2 is not a dangerous emission and is required to sustain life, by increasing the “greenest” of the planet and increasing food production. 4-Temperatures change, both up and down, before CO2 levels change. This fact is simple physics since Nature dominates the absorption and creation of CO2. Mankind is an inconsequential contributor to CO2 levels. The observed fact that temperature changes before CO2 levels change, refutes the claim that CO2 levels are driving temperature changes. 5-Water vapor is well over 90% of our greenhouse gases which are required to maintain our very livable temperature. CO2, at low concentrations (20-200ppm), do impact greenhouse gases causing increased temperatures. However, at levels above 300ppm, CO2 has virtually no impact on temperatures since it is at its saturation point. 6-The facts show that CO2 production is directly correlated with higher standards of living since the beginning of the Industrial Revolution on a country be country basis. Higher standards of living has created higher prosperity, improved health and better education. Because of the above observed and irrefutable facts, the proposed SEC rules for ESG investing will have a serious detrimental impact on the economic well being of America while having absolutely no impact on climate. Climate change has been demonstrably under the complete control of nature, and it is a total waste of money and brain power to suggest mankind can impact it. There are serious issues to be solved for which mankind’s money and brain power can actually impact and make a positive difference. Please abandon your initiative to try to change climate and focus your efforts on supporting serious initiatives of capitalism to improve life. Don’t waste our scarce resources on failing initiatives. Regards, Don Runkle