April 22, 2022
Thank you for the opportunity to comment on the proposed rule to require companies to disclose their environmental and climate related impacts (S7-10-22). While I think the SECs goal here is admirable, I believe it is outside the scope of the SECs mandate.
Climate change is not a securities related matter. The mission of the SEC is to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. I struggle to see how requiring companies to make disclosures around greenhouse gas emissions falls within this mission statement. Such requirement though will certainly increase the cost of being a public company, which is opposed to the objective of facilitating capital formation.
I believe companies should be free to make environmental disclosures as they see fit in describing their business and its objectives, but mandating and enforcing such disclosure, including requiring assurance on such disclosures, is an overstep.
I strongly encourage the SEC to reconsider this requirement which will make it that much more costly to be a public company.
Thank you for your consideration.