Jun. 15, 2022
Secretary Vanessa A. Countryman Countryman, Often common working Americans aren’t given much of a choice whether to invest in the stock market- through 401K/403B plans replacing pensions for retirement planning, or people saving for their own retirement through an IRA. People often don’t have a choice whether to put their money in the market- but they are entitled to thoroughly know what they are investing in. Investors 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. 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 people who have money in the stock market to make ethical choices about where their money goes. I support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute terms. I strongly ask that the SEC 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 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, Aleah ALEAH Gerdes