Jun. 03, 2022
Dear Commissioner Gary Gensler, I am a farmer. I write these comments on behalf of my family farm to the Securities and Exchange Commission. Your proposed rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors is a rule and requirement that will affect my farm. This proposed rule is an egregious example of overreach by the Securities and Exchange Commission. Carbon footprint has nothing to do with fiduciary transparency, nothing to do with your mission and purposes. Farmers and ranchers like me are already heavily regulated by multiple agencies at the local, state and the federal level. If you pass this rule and a supplier ask for our farm carbon foot print I will face huge challenges in calculating those numbers. Frankly I will tell any supplier who asks for that information to take a hike. I will not waste time complying a bunch of vague guesses on carbon to placate a supplier that you all forced to engage in this nonsense. The proposed rule's focus on the value chain for climate-related risks and impacts under Scope 3 means the start of the value chain, like farms and ranches, will face a disproportionate burden, trying to provide unknown carbon estimates at what cost. It is the job of elected lawmakers, not un-elected regulators at the SEC, to adopt policies related to businesses, processors, farmers and ranchers. The world is on the precipice of a massive bout of food shortages stemming from the sick war in Ukraine caused by that POS Putin. Now more than ever the world needs American farmers and food producers to increase food production. Yet you all sit there - well fed - in your safe little Bureaucratic Palaces and promulgate stupid wasteful rules like this. SHAME ON YOU!!! Stay in your jurisdiction and quit making rules outside your expertise and authority. William Gordon Regards, William Gordon