April 24, 2022
In discussing the proposed rules to Enhance and Standardize Climate-Related Disclosure for Investors regarding Scope 1, Scope 2 and Scope 3 I support the proposed rules because investors will be provided with useful, decision-making information regarding not only the financial standpoint but also environmental stance before making a commitment with a public organization and taking on risks that they are not aware of. As an investor these proposed rules will hold the organizations accountable for climate risks and publicized goals of reducing GHG emissions. The proposal of these rules also has the capability to provide jobs for those in the environmental sector as some organizations will need to hire additionally employees to maintain these regulations. I specifically agree that there will be difficulties in obtaining activity data from suppliers or other third parties in the organizations value chain or to verify accuracy of their information in Scope 3 emissions, but the organization should be knowledgeable to some extent as this will possibly lead to liability being passed on to third parties and suppliers that could lead to fines and could possibly put the smaller businesses out of business.
As the proposed rules are detailed in scope, but one is to wonder on the accountability of the annual report. Will these results coincide with the EPA emission goals and regulations based on mobile to stationary sources be documented in the reporting? As investors this is detailed information that should be included so that all documentation will be in same report which will provide additional disclosures.