Jun. 07, 2022
The Honorable Gary Gensler: Thank you for the opportunity to comment on the above-noted proposed rule. My wife and I own and operate a 300 +/- acre cattle ranch in South Central Texas. We do this in a conservative manner trying to rebuild our soil with non chemical carbon sequestration techniques including rotational grazing practices. I was surprised to hear about the above proposed rule and the vast and complicated reporting it would force on small cattle producers such as our family. Even large public companies will have complexity in trying to comply within this proposed rule. The complicated reporting under this proposed rule would be fairly unauditable, of questionable benefit to anyone and include futile collection of highly unreliable data. The proposed rule would be a mandate from the SEC placing a burden on every farmer or rancher and could have a devastating effect on the USA’s ability to raise produce for the American people- exactly the opposite impact of what most people are seeking in these times of snarled supply chains. The optics of this proposed rule in these times is terrible. It seems that estimating greenhouse gases(GHG) would be more accurately estimated at a macro economic level by some other existing federal government agency with their existing staff and would not necessitate any new rule-making from the SEC. As a cattle producer I urge you to abandon proposed rule S7-10-22 and rely on your other colleagues in other federal government departments to estimate GHG. David E. Hessel Owner/ Operator of Hessel Family 3H Ranch 1018 CR 249 Weimar, Texas 78962 Come visit us at threehranch.com!