Jun. 15, 2022
Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Dear Ms. Countryman: The U.S. Geospatial Executives Organization (U.S. GEO) is an informal coalition of senior executives of the nation’s lead geospatial firms. Our members are among the most qualified and competent professionals in surveying mapping, land records, and geographic information systems (GIS). U.S. GEO believes the proposed SEC rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors has a serious flaw, oversight, and shortcoming. We have numerous concerns about the practicality of the proposed rule and its impact, not only on publicly traded companies, but privately held small businesses as well. In order for the SEC to administer, oversee, and manage this rule, it must have in place a system to measure, monitor, verify, and validate information about climate-related risks and metrics of each registrant, including suppliers and customers. As has been well documented in numerous studies and reports by and for the Federal government, the United States lacks a national parcel system or inventory. This baseline data, which the SEC would need to implement this rule, does not exist. We would respectfully recommend that such a parcel system be created, addressed, and implemented in the final rule. The following are links to several such studies, reports, and documents: https://www.fgdc.gov/resources/whitepapers-reports/CRS_Reports/CRS-R40717-Issues-Regarding-a-National-Land-Parcel.pdf https://www.iaao.org/uploads/FGDC_609_Report.pdf https://nationalcad.org/ParcelDashboard/index.html https://www.fig.net/resources/proceedings/fig_proceedings/fig2010/papers/ts07a/ts07a_cowen_buhler_4022.pdf https://www.fgdc.gov/resources/whitepapers-reports/annual%20reports/2009/web-version/index_html#Main https://cdn.ymaws.com/www.mapps.org/resource/resmgr/federal_issues_parcels/letter_commending_chairmando.pdf https://nap.nationalacademies.org/catalog/10989/need-for-a-multipurpose-cadastre https://nap.nationalacademies.org/catalog/11978/national-land-parcel-data-a-vision-for-the-future Please do not hesitate to contact me if you desire further information. John M. Palatiello Founder, U.S. GEO Miller/Wenhold Capitol Strategies, LLC 10340 Democracy Lane, Suite 300 Fairfax, VA 22030