Jun. 07, 2022
Dear Special Counsel Staffin, Climate related risk is subjective and unmeasurable. Such data should not be collected and should never be used to regulate businesses. Why do I say it is subjective? No one can accurately measure the carbon dioxide production nor the sequestration of carbon through a particular manufacturing process. Where does the chain of impact end? Will auto manufacturers be required to calculate the carbon dioxide production related to manufacturing upholstry, batteries, wires or computer chips? Will food processors need data from farmers about their use of fuel to calculate their climate risk? Stop the proposal to collect climate risk data from any business. 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, Valerie Mertz