Jun. 13, 2022
June 13, 2022 Comments to SEC on The Enhancement and Standardization of Climate-Related Disclosures for Investors Proposed S7-17-22 Ruling The NC State Grange is writing to express concerns on the SECs proposed rule - The Enhancement and Standardization of Climate-Related Disclosures for Investors, and the impact it could have on agricultural production in North Carolina. In effect, this ruling could impact every single farm in our state. The NC State Grange supports North Carolina agriculture as well as the rural communities that are sustained by the agriculture industry. Agriculture is our biggest economic driver, and contributes $92.9 billion to North Carolinas economy annually. Farmgate sales provide almost a tenth of this total with manufacturing, wholesale and retail operations accounting for the remainder. The SEC is not in the business to regulate our farms. We are concerned that this rule and its requirement that public companies disclose their Scope 3 greenhouse gas emissions would in affect regulate all of our farms. This rule would require all farms, no matter the size, to disclose a significant amount of i nformation on climate-related items that they may not have the ability to measure. 98% of North Carolina farms are family owned and operated. Of the 46,000 farms in our state, almost 80% have revenues of $50,000 or less. These farms are not corporations with sophisticated compliance departments with dedicated staffing resources like you would find in a publicly traded company, and they should not be treated as such. Imposing additional reporting requirements around climate-related metrics would divert farms of all sizes from their focus on producing food, fiber and fuel. Given the challenges currently facing the farm economy from inflation and increased expenses, we are very concerned that this additional regulatory burden could put family farms out of business. Our country unfortunately could be faced with a food shortage in the not so distance future. For the SEC to activate this ruling in the midst of our country trying to recover from a global pandemic as well as currently faci ng inflation rates that havent been seen in 40 years and potentially facing a recession not to mention the labor shortage, is beyond reproach. If implemented, this rule could lead to loss of many of our farms but higher food prices, reduced availability and increased food insecurity for the most vulnerable members of our society. The NC State Grange asks that the proposed rule be immediately withdrawn. We appreciate your consideration.