April 5, 2022
Hello,
Please adopt this proposed rule with one change to category 3. The category 3 emissions should not be exempt from all litigation. If the rule is adopted as written, there will be no incentive for companies to change their downstream emissions. I know that category 3 emissions are harder to track and to control, but you can draft the guidelines that put some sideboards on potential litigation in order to avoid broad lawsuits. But just exempting all litigation is not going to educate us shareholders as to emissions and will not be an incentive for changing our way of doing business as we edge closer to the brink of climate change.
Thank you.