Subject: Proposed Rule File Number S7-10-22 - Support of The Ocean Foundation's submission
From: Deep Sea Mining Campaign
Affiliation:

Jun. 16, 2022

 

16 June 2022 

RE: File Number S7-10-22 

Dear Securities and Exchange Commission, 

Please note these comments are regarding File Number S7-10-22 (the Proposed Rule regarding Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices).
My organisation, the Deep Sea Mining Campaign, wishes to register its support for the comments already submitted by The Ocean Foundation (dated 10th June). For the avoidance of any confusion, we attach again those comments, already submitted by The Ocean Foundation. 

We particularly wish to emphasise the comments which start on p.2 of the The Ocean Foundation submission re "Definitions should enumerate risks and include ocean-related risks". The example given on p.3 regarding deep-sea mining is particularly pertinent, and we have already made submissions to the SEC raising such concerns at the time regarding information in the S-4 Registration Statement of the merger of the SPAC Sustainable Opportunities Acquisition Corp. (“SOAC”) and DeepGreen to form The Metals Company. That letter is also attached for your information only, specifically as it reiterates the arguments on how deep sea mining cannot be viewed as sustainable. 

Thank you for the opportunity to make these comments. 

Yours faithfully,
Andy Whitmore 

Andy Whitmore
Finance Advocacy Officer
Deep Sea Mining Campaign
Ph: +44 775 439 597
www.dsm-campaign.org
Supported by MiningWatch Canada
Project of the Ocean Foundation

(Attached File #1:s71022-20131701-302111.pdf)(Attached File #2:s71022-20131700-302111.pdf)