Jun. 08, 2022
Dear Mr. Gensler, I am a retired public company co-founder and senior executive who served in a variety of roles from general counsel through chief operating officer, for a publicly traded company for 16 years. In my retirement, I am heavily involved in regenerative agriculture. I hold in my hand a newsletter from the Kansas Livestock Association. It reports with pride that more than 115 members of Congress, including several from Kansas, have written to the SEC to express their concerns with a new proposed rule that would require publicly traded companies to disclose their greenhouse gas emissions, including that of their supply chain. I note they are careful to couch the Congresspersons’ letter writing in terms of expressing their concern, rather than their opposition. However, the KLA goes on to furnish a web link by which their members can indicate to your agency that they oppose this move by your agency. Leaving aside the fact that the vast majority of those indicating such opposition have no experience whatsoever in securities regulation or public company law, based on my experience both in agriculture and in publicly traded corporations, I feel you are on the right track and I want to encourage you to continue with the rule. This does not mean that there will not need to be some discussion and perhaps a modification of the rule, but it does mean that for too long agriculture has had a free pass when it comes to abiding by regulations that the rest of the country has to adhere to, to the detriment of the American public. I refuse to believe that the only way that we can feed ourselves is by poisoning our environment. I do not deny that this course correction may be uncomfortable for some of the large and not so large corporations involved in industrial agriculture. But that does not mean that is not the right thing to do, nor that the investors in those companies do not have the right to know what the greenhouse gas effect of the company they invest in, and its supply chain, is likely to be. Please know that there are professionals in both fields who believe you are doing the right thing. Yours very truly, William F. Bradley Jr. “People who can make you believe in absurdities will eventually make you commit atrocities.” Voltaire