Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, Investors and our investment managers need reliable, standardized, apples-to-apples comparisons from publicly owned companies. These "publicly-owned companies" BELONG to their investors including working people like nurses, teachers, and firefighters. Their investment managers need access to information about public companies’ liabilities to the climate crisis. This includes 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 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 at all is simply not good enough! This laissez-faire attitude cannot continue... It puts investors and other market participants at a disadvantage because we cannot 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, Bruce Hlodnicki