Jun. 17, 2022
To whom it may concern, Please find 3 suggestions for consideration: 1. As the proposal is currently written, companies may feel discouraged from setting carbon reduction goals (“if your company has stated goals, you must report…”). The objective should be to encourage them to set realistic goals and transparently report on progress toward those goals. 2. Keep the SEC disclosures aligned to the evolving integrated ESG disclosures: TCFD, ISSB, etc. Companies are already burdened by having a number of different disclosure frameworks. Ideally, the SEC disclosure requirements will be met through current data gathering and reporting. 3. ISO 14064 should be an acceptable (if not preferred) standard for greenhouse gas inventory validation. Given the management system approach, it is most relevant to not only verify greenhouse gas data accuracy, but also to ensure a sound methodology has been used in the data gathering and calculation processes. Jana D. Lake, MBA, SEP, WELL AP, LEED GA [she/her/hers] President 3R Sustainability www.3Rsustainability.com