Jun. 08, 2022
Dear Commissioner Gary Gensler, As Farm Bureau member, I am writing to submit comments to the Securities and Exchange Commission’s proposed rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors. The proposed rule may have serious negative effects on family owned farms and should be reconsidered in its current form. Farmers and ranchers are already heavily regulated by multiple agencies at the local, state and the federal level. The proposed rule's focus on the value chain for climate-related risks and impacts under Scope 3 means the start of the value chain, like farms and ranches, will face a disproportionate burden in having to provide information at unknown costs. Family farms and ranches do not have teams of compliance officers to manage additional regulations. This comes as our family farms and ranches are already struggling to manage labor costs, fertilizer costs, record high inflation, and supply chain issues. Farmers play a leading role in climate sustainability. It is the job of elected lawmakers to adopt policies related to those farms and ranches to support farmers in fighting climate change, The SEC should defer to those lawmakers rather than implement new rules that venture outside of your traditional role. I urge you to stay within the established jurisdiction of the Securities and Exchange Commission and not to inadvertently implement rules that will have a negative effect on family farms. Regards, Philip Klimbal