March 8, 2022
In my view, it is imperative that the SEC require public companies to disclose Scope 1, 2, and 3 emissions. I understand that companies are concerned about legal liabilities as it relates to Scope 3 emissions, but the SEC can offer safe harbor legal protection on this. As you may be aware, carbon emission disclosures without Scope 3 reporting will be meaningless, as they account for the vast majority of emissions by U.S. companies. Scope 3 emissions pose meaningful risk to investors as they pose an existential threat to humanity and the planet in the near to medium term. Also, simply reporting Scope 1 and 2 emissions will give investors a false sense of reality on this topic, as many U.S. companies are reducing Scope 1 and 2, but are increasing Scope 3 emissions faster.