Jun. 15, 2022
Secretary Vanessa A. Countryman Countryman, Investors need to know about how vulnerable public companies are to climate change. They also deserve to know what the current greenhouse gas emissions of these companies are what their climate plans ate, as well as whether they are actually making good on these climate promises. In the face of the most overwhelming threat to our way of life, climate change, not making this information accessible is akin to closing our eyes and pretending it doesn't matter. At the moment it is not possible for investors to even have an overview over what climate-related financial risks companies face, as reporting this is voluntary. Investors cannot truly understand the risks and opportunities of their investments without this vital information. This is why I support the Securities and Exchange Commission (SEC)’s recent proposal (87 FR 21334; File No: S7-10-22). This would make it mandatory for public companies to disclose their climate-related financial risks. Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting should be included. I also 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. Additionally, since all issues are intertwined at the end of the day, I want these disclosures to include environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. We currently have a broken system of inadequate, not comparable, voluntary climate risk disclosure. Changing this can protect investors, encourage new investments, and provide market participants with the necessary information to judge risks and opportunities. Sincerely, Rebecca Schwutke 1254 Arms Ct Rochester Hills, Michigan 48307