Oct. 26, 2022
October 26, 2022 Dear Commissioners and staff members, The Securities and Exchange Commission's new draft rule for climate risk disclosure is an important first step in protecting investors. Its a great start to making companies more transparent about their greenhouse emissions and will allow millions of Americans to make more informed investment choices in everything from retirement funds to college savings accounts. But the proposed rule doesnt go far enough. By leaving it up to companies to determine the significance of Scope 3 emissions particularly when the rule can also shield issuers from liability if they provide false or misleading information the proposed rule may allow companies to omit some (or most) of their emissions from disclosures. For example, many technology equipment companies like the ones I used to work for outsource all of their manufacturing to contract manufacturing companies, and all of their IT infrastructure operations to data center hosting companies. The electricity used to power these operations are often the two biggest sources of greenhouse gases from these companies. How can we let them go without reporting these emmissions? Please strengthen the final rule to address these loopholes to increase transparency for Americans and protect our planet. Sincerely, Adam Sweeney Manager, Hummingbird Climate Capital