Jun. 03, 2022
MS Word Document Sundance Ranch 16907 CR 399 Winona, TX 75792 June 2, 2022 The Honorable Gary Gensler U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 SEC File No. S7-10-22 Submitted via https://www.sec.gov/cgi-bin/ruling-comments Dear Mr. Gensler: Thank you for the opportunity to submit comments regarding 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. Cattle producers as natural conservationists oversee millions of acres of land while preserving water and air quality. Through the Commission’s S7-10-22 proposed rule a burden is placed squarely on ranchers and landowners. A mandate such as this, which requires publicly traded companies that process or sell beef to report the greenhouse gas (GHG) emissions from their supply chain, could have a devastating effect on my ability to raise cattle. This mandate will indirectly place a burden on every farmer or rancher whose goods are sent to publicly trade processing companies, restaurants, or retailers. The federal government has already acknowledged that collecting data on GHG emissions will be nearly impossible. This rule fails to protect cattle producers who, in good faith, submit data. Because there is no agreed-upon methodology for measuring agricultural GHG emissions it is highly likely that the accuracy of their data could be questioned. This creates unavoidable legal risk for every cattle producer. As a cattle producer, I urge you to limit the proposed rule to only scope one (direct) and scope two (energy/electrical) emissions while omitting scope 3 (supply chain) emission compliance. Please consider the immense cost and disruption this rule will pose to ranchers like me, 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 family farms and ranches. Rather than require cattle producers to report GHG emissions, perhaps you should consider rewarding us for the carbon dioxide that our farms, ranches, and included forests, grasslands, and brush lands capture and tie up in the produced biomass and soil. Sincerely, Vincent Haby Ranch Co-owner/ Manager