based on industry averages, which do not represent a robust emissions source for any individual company, especially considering the proposed attestation requirements. Specific to organizational boundaries, as the proposal suggests, a registrant would be required to include all the emissions data from entities that it either consolidates, proportionately consolidates, or qualifies for the equity method of accounting. Companies will likely need to have estimated data to achieve the annual report timeline, adding a high degree of uncertainty. This exercise will be costly to obtain for all entities and ensure it will represent a robust emission data source, especially for voluntarily disclosed GHG data beyond Scope 1 and 2. • GHG Protocol needs an update A press release on March 31, 2022, noted there are plans to update the GHG Protocol but the timeline needed to research and develop applicable guidance may not match the proposal’s enactment timeline. 3 Absent our suggestion to delay the timeline for proposed Scope 3 reporting, the SEC should evaluate the protocol to address needed changes in the proposed rules once the protocol is referenced, as recommended above. The SEC should also partner with the World Resources Institute (“WRI”) and the World Business Council for Sustainable Development (“WBCSD”) to establish the appropriate governance framework and process to provide ongoing updates and revisions to the GHG protocol’s existing guidance, like the investments made in U.S. GAAP. • Attestation efforts will be challenging in the proposed timeline Achieving the reasonable assurance within the proposed annual report timeframe will be difficult, given the need for investments in companies' existing processes, controls, and IT systems. Separate from ESG reporting, we have already undertaken efforts to accelerate financial reporting filings to provide data more quickly to investors. The proposal could reverse prior progress with the added assurance work noted above. 3 https://ghgprotocol.org/blog/ghg-protocol-assess-need-additional-guidance-building-existing-corporate-standards --.:I AUTODESK