Subject: S7-10-22: WebForm Comments from christopher hurdzan
From: christopher hurdzan
Affiliation:

Feb. 17, 2023

February 17, 2023

 The proposed rule is natural, necessary, time appropriate, and practicable:

    1. Natural: The role of the SEC is to provide investors with \"consistent, comparable and decision-useful information for making their investment decisions\".  Climate has now established itself as an fundamental metric in popular, comprehensive investment strategy, both in monetary valuation (e.g., risks posed, opportunities uncovered) and civic valuation (e.g., social justice / climate activism) terms. Thus it is natural for climate to be included among the classic subject matter of boilerplate investor disclosure documents.

    2. Necessary: Depending upon the industry/sector, congressional action (statutory) and / or regulatory action (rulemaking) can have a marked influence on shareholder value (e.g., profit levels / allocation).  Thus it is necessary that the SEC adopt this rule to ensure conformance with it's congressional mandate (purpose).

    3. Time appropriate:  Failure to formally require holistic climate data disclosure is a politically unsavvy and socially aloof position both in North America and globally.  The US takes great pride in being, and remains, the leader of the free world, and has attained this position of leading by example (action).  Thus the resulting, time appropriate message of the federal government becomes \"it is time that retail investors, in particular, have the tools to sort those firms offering feelgood and fashionable \"greenwashing\" from those firms who can objectively demonstrate environmentally conscious/considerate initiatives which better align with my personal ideologies.

    4. Practicable:  The information requested already exists (in part or in whole), for such data is a normal part of managing any/all proper public businesses in 2023.  Thus it is practicable for these firms to provide such data when it is already in their possession (i.e., no additional costs incurred).

It is my view that this proposed rule may be regarded historically as the first arrival in a hopefully long line of guests collectively representing a shining, public and well-characterized nexus between elected big business practices and their substantive environment impact.  Such data closes an otherwise open loop between consumer practices / consumption preferences and the methods public companies employ to meet with those preferences.  Therefore it appears to me highly probable that this proposed rule will embolden consumers, through such standardized, plain language environmental knowledge to collectively laud, or punish until present those otherwise untouchable but environmentally influential entities by \"voting with their pocketbook\".