Apr. 16, 2022
Dear Chair Gary Gensler, I write in support of your agency’s proposed new rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (S7-10-22). It is an essential step in fulfilling your mandate to ensure public companies meet investors' needs for information to protect their investments. With my background in earth sciences, I am deeply concerned about how heat-trapping emissions and rapidly worsening climate impacts pose a major risk across so many areas of human society, including to our financial and economic systems. For this reason, I urge the Commission to adopt a strong, and comprehensive rule without delay. Specifically, I believe the final rule should mandate and standardize disclosure by publicly listed companies of all heat-trapping emissions associated with corporate operations, products, and supply chains, as Scope 3 emissions can account for 80-90% of companies’ total emissions in some business sectors. Prompt adoption, implementation and enforcement of a strong rule will help businesses meet the needs of international capital markets and ensure that investors have the consistent and comparable data they require to make informed decisions and hold corporations accountable for their total impact on the climate, their plans to mitigate such impacts, and their progress in meeting their climate-related goals. Please protect our financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible. Sincerely, Dr. Wallace Elton Middlebury, VT 05753