CO2 Coalition Comment:

Securities and Exchange Commission Proposal on Climate Change Disclosures

The Securities and Exchange Commission’s (SEC) proposal to require that businesses take extraordinary measures to account for climate risks is based on a false premise that there is a climate emergency because emissions of carbon dioxide from human activity threaten Earth with catastrophic warming. None of this is so.

In fact, carbon dioxide is a beneficial gas absolutely necessary for life. More of it is good, as can be seen in an overall greening of Earth and record crop harvests that have paralleled modest warming and increasing CO2 levels in recent decades. Predictions of dangerous warming are based on flawed climate models and exaggerations of carbon dioxide’s potency as a greenhouse gas. In agreement with this view are many scientists, including the 95 members of the CO2 Coalition based at Arlington, Virginia.

One of those scientists is Dr. Patrick Moore, a former CO2 Coalition chairman and a co-founder of Greenpeace, who says that man-made CO2 emissions are life-saving. His 2016 paper, “The Positive Impact of Human CO2 Emissions on the Survival of Life on Earth,” states:

As recently as 18,000 years ago, at the height of the most recent major glaciation, CO2 dipped to its lowest level in recorded history at 180 ppm (parts per million), low enough to stunt plant growth. This is only 30 ppm above a level that would result in the death of plants due to CO2 starvation.

 It is calculated that if the decline in CO2 levels were to continue at the same rate as it has over the past 140 million years, life on Earth would begin to die as soon as two million years from now and would slowly perish almost entirely as carbon continued to be lost to the deep ocean sediments.

 The combustion of fossil fuels for energy to power human civilization has reversed the downward trend in CO2 and promises to bring it back to levels that are likely to foster a considerable increase in the growth rate and biomass of plants, including food crops and trees.

 Human emissions of CO2 have restored a balance to the global carbon cycle, thereby ensuring the long-term continuation of life on Earth.

 This extremely positive aspect of human CO2 emissions must be weighed against the unproven hypothesis that human CO2 emissions will cause a catastrophic warming of the climate in coming years.

 The one-sided political treatment of CO2 as a pollutant that should be radically reduced must be corrected in light of the indisputable scientific evidence that it is essential to life on Earth.

According to this understanding of the atmospheric cycle of carbon dioxide, it would be more appropriate to reward the burning of fossil fuels than to discourage it.

Even if one accepts the gloomy forecasts of global warming, says Stuart Kirk, former Head of Responsible Investments at the UK bank HSBC, “Climate change is not a financial risk that we have to worry about.”

Mr. Kirk says that the most pessimistic view of climate’s effect on gross domestic product (GDP) estimates a five percent loss by 2100. However, he says, that number is insignificant compared to projected growth of between 500 and 1,000 percent GDP growth over the next 80 years. “A thousand percent! You lop five percent off that and who cares? You will never notice,” said the banker.

In assessing Mr. Kirk’s statements, CEOWorld Magazine, wrote, “It would be foolish to argue that this statement is totally off base. It has a significant amount of truth as shown by actual investment behaviors and returns.” Indeed.

We urge the SEC to abandon its effort to inject the irrationality of a climate scare into the management of American business. The costs to businesses would be large and the effects minimal.