Jun. 18, 2022
This elaborate proposal is not based in the reality of climate and the measurement of related risks, if applicable. In California during the comment period for regulations regarding AB32 Global Warming Solutions Act of 2006, we wrote for consistency and availability of data. There is a clearinghouse but with limited information and lacking important statistical data from all local, state and federal agencies. Government regulatory process is at the hub of the environment. Companies are being asked, in this proposal to replace that process and ignore their responsibility, individually, in the permitting process and related compliance issues. This proposal barely touches the state, regional and local needs. This complex process is being treated as a reporting requirement for risk and not a requirement for environmental compliance. There is insufficient statistical and scientific data to derive improvement. With that gaping hole, the process becomes model-based. There are no qualifications for who can identify a model that reflects accuracy. There are insufficient testing sites to determine who contributes to any type of environmental degradation. Methane emissions were filmed coming up from the ground on the Miracle Mile in Los Angeles known for the La Brea Tar Pits. Where does this data exist. https://saveballona.org/oil-and-gas/methane.gas.leaks.from.wilshire.blvd.museum.row.miracle.mile.html The City of Los Angeles passed Measure O-Clean Water Bond for $500,000,000. The science was supposed exist. There was never any statistical data or testing to reflect improvement. Contracts were given to a group of companies under RFQ Request for Qualifications ahead of any designated project.. There was no competitive bidding. Projects were awarded on a rotation-type basis. Some companies were not qualified for the project assigned. With this internal process, public comment was eliminated. Any modeling varied by company, even though all regions were within Los Angeles. There was no proof of accuracy of the modeling. The County of Los Angeles, not involved, did not even have any measurable .or historic data to use. The County is one if the permit holders in the regional water governance. This entire half a billion dollar project was a capitalization process under the disguise of improvement. No one could ever determine if any water quality improved, if flooding was reduced or stormwater captured and reused. Many companies profited from this bond. These same companies could influence any reporting that you are requesting to be disclosed to investors without any basis in reality. So reporting companies could be dependent on data not even measured or proven to be true and factual. In regional water permitting under the EPA but governed by the state, the water body determines the basis of compliance. Unless they are permitted as a company with compliance requirements, how are companies expected to address climate change under designations foreign to them. The Floodplain Management Plan submitted to FEMA lacked my written public comments. The City of Los Angeles acknowledged receipt of them, but deliberately chose to omit them from the record and not address problem issues submitted. Economic analysis is important but you have not analyzed properly the cost if compliance by companies. It is much more than hiring employees to fill out a report. It takes the knowledge to address the finer details. This proposal us asking for hearsay and not measurable and accurate facts. There are too many players in the environmental/climate game. This proposed rule opens the companies for lawsuits by the investors with no recourse for inaccuracy of their reporting. You omit the responsibility of the companies to address their role geographically. Climate change has no borders, but compliance can only be addressed locally. The United Nations or any foreign organization has no jurisdiction over local issues. California’s AB32 resulted in a financial market of Cap and Trade and offset credits. How are credits to be addressed when climate degradation still occurs. How do companies address foreign government climate issues. This proposal should be rejected. It does not reflect the role of the SEC to inform and protect investors. Joyce Dillard Los Angeles, CA 90031