California Public Employees’ Retirement System (CalPERS) is the largest-defined benefit public pension fund in the United States, with about $450 billion in global assets under management. CalPERS actively protects its rights as an investor and the Board Governance and Sustainability program sits at the center of this effort. Collectively, the authors of this Comment have more than 40 years-experience in corporate governance and have been very close to CalPERS’ work on engagement, advocacy and integration of climate change risk and opportunity, as well as the conduct of this work through partnerships. The Comment provides background on CalPERS' focus on climate change, the authors' work with Climate Action 100+, and and the authors' thoughts on Madison Condon’s Externalities and the Common Owner given their knowledge of the common ownership debate.