May. 23, 2022
Dear Secretary Vanessa Countryman, Farmers are America’s original conservationists, caring for millions of acres of land while safeguarding water and air quality. Unfortunately, the SEC’s proposed rule S7-10-22 places an undue burden on PA farm families. By mandating the disclosure of scope three emissions, the SEC is indirectly placing an unmanageble requirement and cost on every little farmer whose goods are ultimately sent to publicly traded processing companies, restaurants, or retailers. The federal government has already acknowledged that collecting data will be nearly impossible. Can you imagine what that will be like for our small farms in Pennsylvania? Further, this rule fails to protect farmers who, in good faith, submit inaccurate data—an issue which is highly likely considering that there is no agreed-upon methodology for measuring agricultural GHG emissions. This creates unavoidable legal risk for every farm family in PA and throughout the U.S. If this government activist overreach is inevitable, I urge that the proposed rule be limited to only scope one and scope two emissions. Please consider the immense cost and disruption this rule will pose to family farmers and ranchers, who already invest in conservation practices and lack the resources to comply with this highly technical rule. The SEC should be responsible for regulating major publicly traded companies, not private companies like small farms. I sincerely hope that America’s farm families, the real backbone of our food supply and environmental stewardship, are taking into consideration as this is considered. Thank you. Sincerely, Caroline Evans