Apr. 05, 2022
Reference https://www.sec.gov/rules/proposed/2022/33-11042.pdf Dear Sirs A very simple comment: As each entity discloses within the 3 scopes from their point of view, this, it seems to me, creates a practically exponential rise in the required effort. If there was a map of value chains - energy suppliers also being part of the value chain - and disclosures containing each player’s own direct emissions (and the identification of value chain participants they are interacting with where this information is not otherwise available to the tool this map would be) only, it may provide the same information and save a lot of work. Also, this can provide a tool to further enhance value chains with regard to climate at the planning stage within enterprises, before entering into business with the one or the other potential value chain participant. Regards Alève Mine Founder The OneGoal Initiative and the Zurich AR/VR Meetup