Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, Ordinary working people such as me who have pensions, IRAs, and 401(k)s--as well as the people who manage and help me manage these funds-–need 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. All of these items represent financial risk over both the short- and long-term. The current practice of permitting companies to voluntarily choose what and how they want 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, and sadly, what you don't measure, you can't account or plan for. That’s why I 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, including Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I also would 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. All of these issues must be addressed as we move together into our collective future. This proposal is a good step forward to fix a broken system of haphazard climate risk disclosure. It will protect investors like me, encourage other 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, Edward Chadd