Jun. 03, 2022
Dear Secretary Vanessa Countryman, The SEC’s proposed rule S7-10-22 places a burden on family farmers and ranchers far outside the authority of the SEC. By mandating the disclosure of scope three emissions, the SEC is indirectly placing a burden on every farmer or rancher whose goods are sent to publicly traded processing companies, restaurants, or retailers. The USDA and EPA already estimate industry wide emissions and that collecting data will be nearly impossible. Further, this rule fails to protect cattle producers 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 family farmer or rancher. As a cattle producer, I urge you to limit the proposed rule 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. Thank you for your attention to this matter. Sincerely, Barbara Cooksley