Subject: S7-10-22: WebForm Comments from Brian Reid
From: Brian Reid
Affiliation: professional earth scientist

Jun. 02, 2022

June 2, 2022

 I am submitting comments that relate to proposed amendments to SEC Act of 1993 that requires registrants to give climate related information in registration and annual reports.
I object to the proposed rule S7-10-22 that requires companies that are in the beef or other agricultural businesses to report greenhouse gases throughout their supply chain. This mandate will put a burden on farmers and ranchers whose products are sent to market.
The data submitted in this process will be difficult if not impossible to collect accurately. Cattle producers will submit data, for which there is no consistent or meaningful standard. This data will be flawed, but will be used anyway. Worse, data submitted in good faith could be used for legal action against agricultural producers who are not public companies and over whom the SEC was never intended to have jurisdiction. This adds risk to to the already difficult business of small agriculture.
I request that you limit SEC involvement to scope one and scope two emissions and remove scope three (supply chain) emissions from the proposed rule.
Please consider the high cost to cattle producers, who are already trying to protect the environment, but do not have the resources or legal protection to comply with this rule.
Thank you for the opportunity, provided by Federal law, to comment on this proposed rule.

Sincerely,
Brian Reid