Jun. 07, 2022
Dear Special Counsel Staffin, With the average age of the US farmer approaching 60 years old, I would like to think we would be making things easier for those who feed, clothe and otherwise support us to stay in business instead of imposing more and more burdensome restrictions and practices upon them. I fear by applying more and more burdensome rules and invasive government accountability on producers will create a tidal wave of those producers that have had enough to exit business. If people think times are hard now, wait until more agricultural producers leave farming with no one to take their place. Then what? Where will our food, fiber and fuel come from then? As a farmer, I support stewardship of our natural resources, and work hard to leave our land and water in better shape for future generations. Agriculture has reduced its greenhouse gas emissions by 24% since 1990, while also increasing production to feed, clothe and fuel an ever-growing population. I am concerned about new requirements that could be forced upon my operation from publicly traded companies who will be affected by the proposed rule. Recording every drop of fuel, pound of feed and gallon of propane used at each step on the farm will be wildly expensive and burdensome for any farmer to comply with, especially for small family farmers. I am also worried that the proposed rule will be incredibly invasive, forcing farmers like me to hand data over to the SEC that would tell it nearly every single detail about my business. We in agriculture are committed to producing more while using fewer inputs. The best way to achieve this goal is a continuation of voluntary, market-driven approaches, not heavy-handed government mandates such as this proposed rule. To avoid harm to my industry and increased supply chain volatility, I urge the SEC to immediately halt this development of this rule. Sincerely, RANDALL LIGHTFOOT