Comment and Declaration on the SEC’s Proposed Rule

“The Enhancement and Standardization of
Climate-Related Disclosures for Investors,”

William Happer,
Professor of Physics, Emeritus, Princeton University
Richard Lindzen,
Professor of Earth, Atmospheric, and Planetary Sciences, Emeritus,
Massachusetts Institute of Technology
June 17, 2022

Comment and Declaration
Thank you for the opportunity to comment on the proposed SEC requiring disclosures of climate related risk caused by fossil fuels and CO2.

We are career physicists who have specialized in radiation physics and dynamic heat transfer for decades.

In our opinion, science demonstrates that there is no climate related risk caused by fossil fuels and CO2 and no climate emergency.

Further, nowhere in the more than 500 pages of the proposed rule is there any reliable scientific evidence that there exists a climate related risk. None. It refers to the International Panel on Climate Change (“IPCC”), the Task Force on Climate-Related Financial Disclosures (“TCFD”) and other outside groups, but never provides any reliable scientific evidence that supports the rule. The science is just assumed. Therefore, there is no reliable scientific basis for the proposed SEC rule.

Further, contrary to what is commonly reported, CO2 is essential to life on earth. Without CO2, there would be no photosynthesis, and thus no plant food and not enough oxygen to breathe.

Moreover, without fossil fuels there will be no low-cost energy worldwide and less CO2 for photosynthesis making food. Eliminating fossil fuels and reducing CO2 emissions will be disastrous for the poor, people worldwide, future generations and the country.

Finally, the cost of the proposed rule is enormous and would have no public benefit. It would increase the reporting burden to companies $6.4 billion, which is 64% more than the $3.9 billion all SEC reporting requirements have cost companies from its beginning in 1934. Id., 87 Fed. Reg., p. 21461.

Thus, the rule must not be adopted or, if adopted, ruled invalid by the courts.

To view the entire comment view pdf here: Happer Lindzen SEC 6-17-22