Subject: S7-10-22: WebForm Comments from Climastry, Inc.
From: Climastry, Inc.
Affiliation: CEO

May. 02, 2022

Dear Chair Gary Gensler,

We are writing to express our support for Proposed Rule S7-10-22: Enhancement and Standardization of Climate-Related Disclosures for Investors. However, we have three recommendations to improve rule maturity.

- Live GHG data feeds from listed organizations in lieu of or in addition to a quarterly reporting structure.

- Alignment with EU SFDR and CSRD regulation.

- Scope 3 emissions to be phased into rule scope within 3 years.

Our planet has warmed 1.2C degrees since the pre-industrial baseline and we are already experiencing compounding crises resulting from climate and biodiversity system collapse. Future impacts will be multifactorial and nonlinear, impacting the world's poorest and most vulnerable, including those within our own borders. Of particular concern is the destabilization of the AMOC.

In my own lifetime, the IPCC projects a 3.2C likely scenario. Precipitating a future landscape devoid of any resemblance to the one today. One in which entire food webs and economies have collapsed.

This outcome is a betrayal to youth and future generations by all institutions, including the SEC. Failure to respond to this threat in kind could see those in power, such as the current SEC leadership - be held personally liable for the resulting crises.

Recommendation rationale in detail:

- Re: Data Feeds. Many ESG frameworks have been shaped by thought leadership from central banks and NGO's. Those frameworks are in some instances adopted from financial regulatory tools. As \"Sustainability\" undergoes \"soxification\" and becomes a pillar within corporate entities on par with \"Finance\". It should adopt modern disclosure methods such as real-time data feeds. This will help the United States understand its NDC in real-time gaps and address them with greater agility.

- Re: EU SFDR  CSRD Alignment. The EU has spent more time and resources researching the fine details of climate disclosure. Given the urgency of the crisis we face, further misalignment between governmental disclosure frameworks risks continued inability to have comparable GHG methodologies and resulting disclosures. This only serves to increase the risk of an extreme climate scenario in the near future.

- Re: Scope 3 Phase-in. \"Scope 3\" was a flawed classification from its inception. It is too encompassing and why many organizations are unable to even estimate it with any meaningful confidence. However on average, it comprises over 75% of the emissions of organizations. Failure to regulate this would represent gross negligence of climate disclosure rule making. It must be included in the rule scope. We recommend phasing it in over three years to spur greater investment in this critical piece of decarbonization strategy.

Thank you for presenting this important rule for public debate. It is an important step forward for our country and society. However, it must go further for our children and the millions of species subject to extinction otherwise.