Subject: Comment on S7-10-22
From: Martha E. Gifford
Affiliation:

Sep. 18, 2022

Dear Chair Gensler: 


I am writing to thank you for taking important steps to make it easier for investors like me to understand climate risk. As an investor, my goals are to maximize my returns, but to do so without investing in the production and use of greenhouse gases. I need to know whether or not a company is committed to these same goals, and is taking concrete steps to be successful in a low-carbon world. 


More and more economies are adopting policies and taking steps to meet the goals of the Paris Agreement, or more. I am concerned that companies not working to reduce their Scope 1, 2 and 3 greenhouse emissions will not be prepared for that future. Without this information, I won't be able to tell which companies are likely to be profitable as the economy transitions to clean energy and which companies could put my savings at risk. Earlier this summer you proposed a rule to require publicly traded companies to disclose "material" Scope 3 emissions. Many institutional and individual investors asked you to make this a requirement for all large public companies.  I am hopeful that you will listen to the voices of regular people like me, not just big corporations looking to hide their risks. As you prepare to finalize these rules, I want to thank you for doing everything in your power to ensure that investors like me have the information we need to be able to make smart investing decisions for a low-carbon future. I am looking forward to seeing strong greenhouse gas disclosures, inclusive of Scope 3 emissions, in your final ruling later this year. 


with best regards, 


Martha E. Gifford