Subject: File Number S7-10-22: Withdraw Proposed Greenhouse Gas Rule
From: Joe Arens
Affiliation:

Jun. 08, 2022

Dear Special Counsel Staffin,

Regulating the farm industry for their carbon footprint is a ridiculous idea. Sure, maybe it kind of makes a little sense to try to protect our climate but at what cost? If enough farmers say "I've had enough, I'll find something else to do", the world as we know it today will change drastically to where we are dependent upon non-existent resources from other countries. Also, why should the SEC impose these rules on the US agricultural community when other large countries will continue to produce just as much if not more than to what they are already producing? This in turn punishes the agricultural community without any benefit to climate control.

As a consumer of farm produced goods, 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 many farm operations 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.

The agriculture community is 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 the agricultural industry and increased supply chain volatility, I urge the SEC to immediately halt this development of this rule.

Sincerely,

Joe Arens