Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, I -- and the people like me -- have a right to get standardized information for companies I invest in -- or want to invest in -- about greenhouse gas (GHG) emissions, management of climate risks, and vulnerability to climate change. Voluntary disclosure is woefully insufficient. The Securities and Exchange Commission (SEC)’s recent proposal (87 FR 21334; File No: S7-10-22) is a response to this widely-felt need. Please finalize both Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I am counting on you to strengthen the final rule by also requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all large registrants, and by including disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. Please do the right thing. Sincerely, Debbie Notkin