Subject: RE File Number S7-10-22 The SEC must adopt rules to mitigate and disclose climate risks!
From: Wendy Feen
Affiliation:

Jun. 14, 2022

 


Secretary Vanessa A. Countryman Countryman,
It's time to require that companies explain their plans for reducing pollution and the risk of a climate-fueled disaster risks.
Working people who have a retirement plan need transparency and access to standardized, comparable information about public companies’ vulnerability to climate change, their current greenhouse gas (GHG) emissions, and their plans to manage climate risks and make good on their public climate commitments.
The current practice of voluntary choices of what and how a company wants to report, and even whether or not they want to disclose their climate-related financial risks, makes it impossible for investors and other market participants to fully understand and compare the risks and opportunities associated with different investments.
That’s why we support the Securities and Exchange Commission (SEC)’s recent proposal (87 FR 21334; File No: S7-10-22) to require public companies to make standardized, mandatory disclosures about their climate-related financial risks within annual SEC filings.
We support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. We strongly encourage the SEC to strengthen the final rule by requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all large registrants, and to include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts.
This proposal is a vital step forward to fix a broken system of inadequate, not comparable, voluntary climate risk disclosure. It will protect investors, encourage prospective retirement savers to invest in the U.S. capital markets, and provide market participants with the climate-related information they need to accurately price climate risk and make well-informed investment decisions.
Sincerely,
Wendy Feen