May 25, 2021
Hello,
I applaud the SEC's efforts to update its reporting requirements. I have one primary comment, which is that I strongly suggest the data associated with companies' climate metrics be made publicly accessible, to the greatest extent possible, ideally on a modern and highly accessible webpage/website. Today, the public has limited info to help guide their investing or purchasing power towards companies that are taking steps to mitigate global warming or otherwise taking steps to account for global warming risks. Current voluntary regimes, such as B Corps, provide very limited transparency into the actual performance of companies in environmental, or other social and governance, areas. The public has very limited access to any data about the environmental impact of companies operations, mostly relying on non-standard sustainability reports. However, the existence of such regimes speaks to the public demand for better transparency into these issues. At the very least, scopes 1, 2, and 3 greenhouse gas emissions (with as many previous years data as possible), and greenhouse gas reduction goals should be made public in multiple machine-readable formats (csv, json, etc.) for download and API consumption.
My secondary comments are that I believe global warming and climate change related metrics should be prioritized over other social and governance metrics, potentially making the latter optional. Global warming is a scientific fact with clearly defined metrics that many companies already measure. Though I believe social and governance concerns are legitimate and important, I believe the ability to objectively measure these areas across a diverse set of companies is more difficult, especially given competing concepts of social value and differing political views on what current social problems companies should be focused on. However, establishing guidelines or standards to ensure investment products with marketed as ESG-focused are legitimate does seem warranted.