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Thank you for the opportunity to comment on the Securities and Exchange Commission’s (SEC) proposed rule “Disclosure of Payments by Resource Extraction Issuers”, 2020-0060-0001.¹ Please accept this comment on behalf of Earthworks and our members. ²

We respectfully urge the SEC to withdrawal this proposal and, in consultation with Congress, investors, and the public, issue a new Advanced Notice of a Proposed Rulemaking (ANPRM) more consistent with the intent and requirements of the law.³

Earthworks is a national nonprofit advocacy organization dedicated to protecting communities and the environment from the impacts of mineral and energy development while promoting a just, fair, and equitable energy transition. We advocate for good governance, transparency, and public participation. Our perspective stems from our experience with minerals leasing, payment, and reporting procedures for resource extraction issuers on federal and some state public lands.