Subject: Help protect the planet from climate catastrophe
From: Carolynn Kohout
Affiliation:

Jun. 11, 2021


Dear Securities and Exchange Chair Gensler,

Thank you for SEC’s invitation to provide public comment on Climate Change Disclosures,
- which rightly identifies the urgent need for
- mandatory climate,
- environmental,
- social, and
- governance (ESG)
disclosures.

Climate change poses potentially catastrophic risks to
- the environment,
- communities, and
- the financial system.

As a result, it is vital for you to require climate-related disclosures
- in order to meet the SEC’s mandate to
  - protect investors;
  - ensure fair, orderly, and efficient markets; and
 - facilitate capital formation.

In particular, the fossil fuel industry and sectors that rely on agro-commodities,
- including the agribusiness and consumer goods sectors,
pose risks to the financial system
- that must be disclosed by companies whose
- direct operations and
- supply chains
are involved in these sectors
- as well the financial institutions
that enable them.

Disclosures must:
1. Be mandatory and standardized
  - in a way that makes them comparable across firms and sectors.

2. Be easily
  - accessible,
  - transparent,
  - clear, and
  - decision-useful
to all investors across different levels of sophistication.

3. Include both qualitative disclosures, such as
  - the information currently reported
  - under the voluntary Task Force for Climate
Related Financial Disclosures,
  - as well as specific line-item, quantitative disclosures.

4. Be published in annual and quarterly SEC filings, and
- to the extent possible,
should be included in the audited financial statements.
- Include quantitative metrics and qualitative information about
  - governance,
  - strategy, and
  - risk management.

5. Cover both physical risks and transition risks
  - that affect enterprise value,
  - the impacts that issuers have on society,
  - the natural environment,
  - the global financial system, and
  - investors as a whole,
including risks associated with
  - human rights and
  - the rights of Indigenous Peoples and
  - other vulnerable and marginalized populations.

6. Report on total greenhouse gas emissions (Scopes 1, 2, and 3)
  - linked to their own operations and
  - their tier one suppliers.
 Include quantitative and qualitative data
 - used in scenario analysis in regards
 - to scope 3 emissions and
 - specifically direct and supply chain emissions
    - from land use,
    - land use change, and
    - forestry.
This data should include detailed data on
- company land banks,
- land and forest management practices,
- sustainability and governance policies, and
- deforestation-reduction targets.

7. Be in a machine-readable format
- to allow academics and other stakeholders
- to easily use this information and
- compare, analyze, and identify
  - discrepancies
which could be the basis for shareholder pressure and enforcement action.

Sincerely,
Carolynn Kohout