Dear U.S. Securities and Exchange Commission,
I am writing to express my gratitude and comments regarding the proposed rule changes under Section 19(b)(1)(1) and Rule 19b–4 of the Securities Exchange Act of 1934 (“Act”)(2). Self-regulated companies, specifically voluntary carbon markets (“VCMs”) have effectively impeded large corporations and industries from assuming conscientious responsibility for the adverse impacts of rising carbon levels in the atmosphere. In theory, the idea of an offsetting carbon initiative sounds like a novel idea, however, when there are no checks and balances in place to make sure all of the carbon is being accounted for – these companies operate rather as a front to allow their allowed their customers to deceive the public by positing notions of “carbon-neutrality” or “net-zero carbon company” (ie. Disney, Delta, Shell, etc.) These statements are not only grandiose but also nearly impossible to promise from carbon credit institutions alone. A Columbia Center on Sustainable Investment study found that roughly two-thirds of companies that make said promises and statements rely solely on unreliable carbon offset companies. Large corporations know that these expenditures are not a long-term investment or a silver bullet for making their company sustainable; but as long as their consumers are under the impression that their favorite brands are green – it is enough for now. To reiterate, VCMs are a band-aid for a bullet wound that are being exploited to buy the masses' hearts.
Whilst, it is reliving for many that VCM companies have garnished some attention from a government entity, it is still of extreme saliency for the SEC and other bureaucratic regulatory agencies to keep a keen eye on the carbon credit market. I urge the SEC to prompt continued efforts to mitigate the adverse effects of carbon credit companies. Specifically, this comment is not demanding for said companies to be made illegal – but for means to be established to better account for their operations. Dozens of these companies have already found themselves in legal jeopardy via cases of fraud (ie. Mayanna Berrin v. Delta Air Lines Inc., Golden Door Properties, LLC v. County of San Diego, Choose Energy, Inc. v. American Petroleum Institute, etc.), thus there must be regulations enacted to make such companies credible and reliable.
Thank you,
James (Jimmy) D. Milas
Loyola University Chicago Class of '26