U.S. Chamber Supplemental Comment on SEC Climate Disclosure Proposal

The U.S. Chamber of Commerce writes to supplement its comments on the Commission’s proposed rules regarding climate-related disclosures (the “Proposed Rules”). As we previously explained, the Chamber supports policy solutions that serve the goal of reducing greenhouse gas (“GHG”) emissions as much and as quickly as reasonably possible based on what the pace of innovation allows and the feasibility of implementing technical solutions at scale. The Chamber, likewise, supports policies that provide for the disclosure of material information, including climate-related information, as necessary to protect investors. At the same time, policies must always be informed by the best science and a careful analysis of the available alternatives, outcomes, and cost-benefit tradeoffs to ensure that optimal policies are implemented. We are concerned that the Proposed Rules fail to strike the right balance. The Proposed Rules are vast and unprecedented in their scope, complexity, rigidity, and prescriptive particularity. Moreover, as is explained not only in the Chamber’s initial comments, but also in this letter, the Proposed Rules would saddle the U.S. economy with billions of dollars in added costs—often for little discernible benefit.