Jun. 19, 2022
Dear Secretary Vanessa Countryman, Livestock producers and agriculture land owners are America’s original conservationists, caring for millions of acres of land while safeguarding water and air quality. Unfortunately, the SEC’s proposed rule S7-10-22 places a burden on family farmers and ranchers far outside the authority of the SEC. By mandating the disclosure of scope three emissions, the SEC is indirectly placing 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. In addition, there is no agreed-upon methodology for measuring agricultural GHG emissions. This creates unavoidable legal risk for every family farmer or rancher. The regulatory actions cannot be justified if the evidence is not from a consistent measurement for validity. This is poor policy development and cannot be afforded by the families working hard and dedicating themselves to producing quality food while caring for and preserving the natural resources for future generations to continue feeding America. This is short sided policy! Family agriculture businesses cannot afford to remain in business with this type of mandate. As an agricultural land owner , I urge you to limit the proposed rule to only scope one and scope two emissions. Please consider the immense cost and disruption this rule will pose to family farmers and ranchers, who already invest in conservation practices and lack the resources to comply with this highly technical rule. The SEC should be responsible for regulating major publicly traded companies, not private companies like small farms and ranches. Thank you for listening to America’s cattle producers. Sincerely, Saralyn Johnson