Jun. 06, 2022
Dear Securities and Exchange Chair Gensler, Thank you for SECs invitation to provide public comment on Climate Change Disclosures, which rightly identifies the urgent need for mandatory climate and environmental, social, and governance (ESG) disclosures. Climate change poses potentially catastrophic risks to the environment, communities, and the financial system. As a result, it is vital for you to require climate-related disclosures in order to meet the SECs mandate to protect investors ensure fair, orderly, and efficient markets and facilitate capital formation. In particular, the fossil fuel industry and sectors that rely on agro-commodities, including the agribusiness and consumer goods sectors, pose risks to the financial system that must be disclosed by companies whose direct operations and supply chains are involved in these sectors as well the financial institutions that enable them. Disclosures must: Be mandatory and standardized in a way that makes them comparable across firms and sectors. Be easily accessible, transparent, clear, and decision-useful to all investors across different levels of sophistication. Include both qualitative disclosures, such as the information currently reported under the voluntary Task Force for Climate-Related Financial Disclosures, as well as specific line-item, quantitative disclosures. Be published in annual and quarterly SEC filings, and to the extent possible, should be included in the audited financial statements. Include quantitative metrics and qualitative information about governance, strategy, and risk management. Cover both physical risks and transition risks that affect enterprise value, but also the impacts that issuers have on society, the natural environment, the global financial system, and investors as a whole, including risks associated with human rights and the rights of Indigenous Peoples and other vulnerable and marginalized populations. Report on total greenhouse gas emissions (Scopes 1, 2, and 3) linked to their own operations and their tier one suppliers. Include quantitative and qualitative data used in scenario analysis in regards to scope 3 emissions and specifically direct and supply chain emissions from land use, land use change, and forestry. This data should include detailed data on company land banks, land and forest management practices, sustainability and governance policies, and deforestation-reduction targets. Be in a machine-readable format to allow academics and other stakeholders to easily use this information and compare, analyze, and identify discrepancies which could be the basis for shareholder pressure and enforcement action. Sincerely, Rebecca Palacios