Aug. 4, 2026
I am writing to oppose the Commission's proposal to rescind the 2024 climate-related disclosure rules in their entirety, and to urge the Commission to preserve this framework rather than dismantle it. The 2024 rules were built to give investors consistent, comparable, and accessible information about material climate risk: how companies identify and manage that risk, how leadership oversees it, what targets and transition plans are in place, and what financial exposure companies carry from severe weather, wildfire, drought, and other climate-driven events. Rescinding the framework does not make those risks disappear. It only makes them harder to see. In response to the Commission's rationale that the rules exceed its authority and impose unnecessary compliance costs: existing general securities filings and voluntary sustainability reports are not a substitute for a standardized disclosure framework. Without consistent requirements, investors are left to piece together climate risk information across scattered, non-comparable sources, voluntary reports that companies can revise or discontinue at will, state-level systems that vary widely, and general filings that were never designed to capture climate-specific exposure. That is a worse outcome for capital formation and market efficiency, because it increases the cost and difficulty of accurately pricing risk. This proposal also carries real consequences for environmental justice communities. Publicly traded companies own and operate fossil fuel, petrochemical, utility, transportation, manufacturing, housing, insurance, and financial assets in communities across the country. Climate disclosures are one of the few tools that let investors and the public see how these companies account for climate-related losses, calculate emissions, and follow through on publicly announced targets. Removing that visibility removes accountability precisely where it is needed most. I urge the Commission to withdraw this proposal and maintain the 2024 climate-related disclosure rules. Thank you for considering this comment.