Demand the SEC force public companies to disclose their environmental impacts!

Consumers buying simple household products like toilet paper are unknowingly supporting corporations that slash global forests and accelerate climate change. The Securities and Exchange Commission allows corporations like Procter & Gamble to forgo disclosing environmental impacts. P&G’s products produce 17.8 MILLION metric tons of greenhouse gas emissions every year – that’s 3.8 million vehicles worth of pollution from just one company. Imagine all the other corporations creating similar destruction that you and I don’t know about because the SEC allows them to hide.

The SEC is considering a proposed regulation to require companies to disclose greenhouse gas emissions. There’s little time to lose. The comment deadline closes in just 2 weeks! Investors and the public deserve to know what these companies are up to. YOU deserve to know what companies are up to.

SEC

To the Securities and Exchange Commission and SEC Chair Gensler:

At the outset, I would like to commend SEC’s efforts to enhance and standardize climate-related disclosures given the code-red moment. I have specific appreciation for SEC’s inclusion of reporting for not only Scope 1 and 2 emissions, but also Scope 3 emissions reporting and its treatment of offsets and accounting mechanisms. The law is clear that SEC has the authority to undertake this proposal. Moreover, investors–including working people like nurses, teachers, and firefighters who have a retirement plan like a 401K, pension, or IRA–and their investment managers need access to standardized, comparable information about public companies’ vulnerability to climate change, their current greenhouse gas (GHG) emissions, their environmental justice impacts, and their plans to manage climate risks and make good on their public climate commitments. Access to this information will also greatly benefit consumers, who now care more than ever before about the impact their purchases may have on communities and the climate.

While this is a laudable first step toward mandating important disclosures, the proposed rule misses the mark by:

o	Failing to mandate disclosure of Scope 3 emissions for all industries, or in the least, for greenhouse gas-intensive industries such as fossil fuels and agriculture
o	Allowing companies to self-determine the materiality of their Scope 3 emissions, which invites bias and playing with numbers
o	Failing to require disclosure of the impacts of industrial, greenhouse-gas-intensive activities on indigenous populations and other frontline communities
o	And offering a safe harbor for liability that is too expansive and could shield fraudulent actors.

I respectfully request that SEC incorporate language into the final rule that remedies these oversights.

As such, I implore the SEC to strengthen the final rule by requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all industries, or at least, to require them from greenhouse gas-intensive industries. Failing to take this critical step will allow many emissions to go unaccounted for, as the majority of certain industry emissions are Scope 3. Further, I urge you to include disclosures around environmental justice, Indigenous peoples’ rights, just transition for dislocated workers, and community-level impacts. Finally, I strongly encourage you to tighten the safe harbor provided in the proposal. While we understand the need to shield actors who report in good faith, we do not support any protection for fraudulent actors who misrepresent information. I also support including a sunset provision so that the safe harbor comes to a close after registrants have had sufficient time to come into compliance with the new reporting requirements.

I want to reiterate that this proposal is a vital step forward in fixing a broken system of inadequate, not comparable, voluntary climate risk disclosure. However, as detailed above, more should be done to fully protect investors, encourage prospective retirement savers to invest in the U.S. capital markets, and provide market participants with the climate-related information they need to accurately price climate risk and make well-informed investment decisions.

Sincerely,
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{user_data~City}, {user_data~State} {user_data~Postcode}

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