Subject: File No. S7-10-22
From: Clay Downing

March 23, 2022

I support the proposed rule.

In the state where I reside, California, local governments and state agencies are working hard to conduct municipal and community level climate action plan implementation including GHG mitigation and climate adaptation measures. However, these local and state actions do not ensure that businesses have a consistent framework and level playing field for their climate and ESG reporting. Inclusion of Scope, 1, 2, and 3 reporting in the proposed rule are key parts of the rule that must be retained in order to ensure the rule's effectiveness. Further, as the business sector crosses both state and national boundaries, the proposed rule fits squarely within the federal purview of the SEC.

The proposed rule makes great strides in ensuring a consistent approach to reporting and managing how our business sector responds to the threat of climate change which is crucial to shareholder knowledge of the risks that businesses can reasonably expect to encounter.