May. 11, 2022
Dear SEC Exchange Commission, I am writing to submit comments in response to the Securities and Exchange Commission's (SEC) proposed rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors. The proposed rule is an example of overreach by the commission and appears to fall well outside of the historic scope of the commission. The proposed rule's expansive reporting requirements for Scope 3 greenhouse gas emissions, would create substantial costs and liabilities, such as reporting obligations, technical challenges, significant financial and operational disruptions, and the risk of legal liabilities for farmers. Farm families are already dealing with razor thin profit margins due to the cost of inputs, labor shortages and supply chain disruptions. At this point when food security is a global concern, the last thing our government should be doing is proposing regulations that will make it harder for farmers to farm. The SEC's proposed rule seeks to further extend regulatory burdens on farmers and ranchers, all while lacking appropriate statutory authority. In fact, Congress has been very clear that agencies may not require mandatory reporting of greenhouse gas emissions from livestock. The SEC has exceeded its area of regulatory authority and is seeking to regulate industries that have never been under the SEC's jurisdiction in an apparent attempt to regulate climate activities. Additionally, this rule raises significant privacy concerns for farm families. Most of us live on the same piece of property we farm. If these reporting requirements were to be imposed, how will my privacy be protected? I strongly urge the commission to withdraw this proposed rule and focus on its traditional obligations of protecting investors' financial interests, and maintaining fair, orderly and efficient markets. Sincerely, Mark Pennington