The U.S. Chamber of Commerce appreciates the opportunity to comment on the proposed rules (the “Proposed Rules”) of the Securities and Exchange Commission (“SEC” or “Commission”) governing climate and the environment in Release No. 33-11042 (the “Proposing Release”).1 Combating climate change requires citizens, governments and businesses to work together. American businesses play a vital role in creating innovative solutions and reducing greenhouse gases (“GHGs”) to protect our planet. The SEC, working in coordination with other government agencies whose primary responsibility it is to protect the environment, also has a role to play to the extent climate risk implicates the SEC’s tripartite mission of investor protection, maintaining fair, orderly and efficient markets, and facilitating capital formation. The Chamber believes that policy solutions addressing climate change should serve the goal of reducing emissions as much and as quickly as possible based on what the pace of innovation allows and the feasibility of implementing technical solutions at scale. The Chamber also believes that practical, flexible, predictable and durable market-based solutions and mechanisms are at the core of efforts to address climate risk and are reflected in the actions of the Chamber’s members. Promoting private sector innovation across industry sectors will be central to solving climate change. The Chamber supports climate policy that includes the disclosure of material information for investors to use, as well as policies that are not distorted or duplicative as a result of overlapping regulations and are not skewed by political interests. U.S. climate policy should recognize the need for action, while maintaining the national and international competitiveness of U.S. industry and commerce and ensuring consistency with free enterprise and free trade principles. Climate policy should also be informed by the best science and observations available and a rigorous assessment of available alternatives, outcomes, and cost-benefit tradeoffs to ensure that the optimal policies are implemented.
