March 22, 2022
I read that the proposed rule includes two primary parts. 1) how climate-related risks could affect the company's business, strategy and projections, and 2) the company's greenhouse gas emissions would need to be audited by an outside party.
It is obvious the climate is changing and those changes are a risk to all, including companies. As a result, I support including how climate risks may impact a company's business, strategy and projections.
What is much less obvious is how a company's greenhouse gas emissions are related to business risks a company may face. SEC reporting must avoid issues du jour and focus on enduring risks. There simply is no reliable evidence that an individual company's greenhouse gas emissions can or will have any impact on the climate. In addition, there is merit to Commissioner Peirce's concern that this proposal steps outside SEC statutory limits by using the disclosure framework to achieve objectives that are not it's to pursue and by pursuing those objectives by means of disclosure mandates that may not comport with First Amendment limitations on compelled speech.
In conclusion, I suggest the rule proposal be abandoned. If not, then I strongly recommend it be modified to include only how climate risks may impact a company's business, strategy and projections.
Thank you for the opportunity to comment.