Jun. 17, 2022
June 17, 2022 The Honorable Gary Gensler U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Submitted via https://www.sec.gov/cgi-bin/ruling-comments RE: SEC File No. S7-10-22 To Whom It May Concern: On behalf of the New Mexico Federal Lands Council (NMFLC), the New Mexico trade organization representing federal allotment and State Trust Land lessees, thank you for opportunity to submit comments on the above captioned rulemaking. The Commissions S7-10-22 proposed rule will place a huge burden on ranchers and landowners. A mandate that requires publicly traded companies that process or sell beef or lamb to report the greenhouse gas (GHG) emissions from their supply chain could have a devastating effect on the ability of ranchers to produce food and fiber for our nation and the world. The public is already suffering from exploding beef prices. This mandate will only exacerbate the problem and drive ranchers from the millions of acres of land and water they care for on a daily basis. It will also indirectly place a burden on every farmer or rancher whose goods are sent to publicly traded processing companies, restaurants, or retailers. The federal government has already acknowledged that collecting data will be nearly impossible. Further, this rule fails to protect cattle producers who, in good faith, submit data. Because there is no agreed-upon methodology for measuring agricultural GHG emissions it is highly likely that the accuracy of their data could be questioned. This creates unavoidable legal risk for every cattle producer. Representing livestock producers, we urge you to scrap this rulemaking and work on the real issues facing our nation including skyrocketing inflation, food and fuel supplies, and issues that are facing Americans. The SEC should be responsible for regulating major publicly traded companies, not family farms and ranches. Thank you for the opportunity to submit comments on this proposed rule. Sincerely, Bebo Lee Don L. (Bebo) Lee President New Mexico Federal Lands Council Alamogordo, New Mexico