Jun. 05, 2022
Thank you for the opportunity to submit comments on the Securities and Exchange Commission “Commission” proposed amendments to its rule under the Securities Act of 1993 and Securities Exchange Act of 1934 that would require registrants to provide certain climate-related information in their registration statements and annual reports. I am a third generation family ranching family and my understanding of the Commission’s S7-10-22 proposed rule is that this mandate requires publicly traded companies that process or sell beef to report the greenhouse gas (GHG) emissions from their supply chain that would have a devastating effect on my ability to raise cattle. This is an incredible overreach by the government and places a huge burden on small ranchers like me Virtually every rancher I know take cares of the land since it’s their livelihood. The average size cattle herd in Texas is only about 39 head, so this is not a real source of GHG. I have no problem with the Commission regulating publicly traded companies but to have it trickle down to the family rancher is not necessary and makes it even harder for folks like me to make a living. It’s just one more rule to follow that in this case is really unnecessary, unless you’re company is publicly traded. This mandate by the Commission will indirectly place a burden on every farmer or rancher whose goods are sent to publicly traded processing companies, restaurants, or retailers. Please limit the proposed rule to only scope one (direct) and scope two (energy/electrical) emissions while omitting scope 3 (supply chain) emission compliance. The SEC should be responsible for regulating major publicly traded companies, not family farms and ranches like me. Since I’m not a little guys in this issue, the Commission may not pay attention to my opinion but I hope it does. My goal is to have my children continue ranching, despite its hardships, and having this proposed rule only apply to publicly traded companies will help me accomplish my goal. Sincerely, Bragg Smith