Jul. 27, 2026
I support the Commission’s proposal to completely rescind the 2024 climate-related disclosure rules. I take for granted that climate change is real. My support reflects the important distinction between measurable changes in climate and far more uncertain predictions concerning their long-term economic and social consequences. For almost 50 years, climate activists have been predicting that human civilization would be devastated within 10 to 20 years if we failed to reduce carbon emissions. Around 2014, advocates for human progress began pointing out that human beings have flourished over the same 50-year period during which we increased carbon emissions. Around 2015, many climate activists shifted to predicting that human civilization would be devastated 50 to 100 years into the future, which not only made their predictions harder to make with confidence but also made it harder for lawmakers and other laypeople to verify those predictions. Given our experts’ track record, asking non-experts from thousands of publicly traded companies to join the conversation risks producing large volumes of speculative, inconsistent, and ultimately arbitrary information. In addition, climate policy remains an intensely contested political and moral issue. Nothing good can come from the Securities and Exchange Commission using its rulemaking authority to propagate the views of one side of an ideological controversy. Consider that the current rules require companies to disclose climate-related risks but make it optional to disclose climate-related opportunities. This imbalance in the type of information required makes the SEC 2024 climate disclosure rules come very close to mandating morally suspect and, therefore, financially imprudent professions of faith. For these reasons, I respectfully urge the Commission to adopt the proposed rescission in its entirety. Kevin R. Douglas Associate Professor of Law Michigan State University kevin.douglas@law.msu.edu