The U.S. Security and Exchange Commission has issued a draft rule that would require publicly traded companies to report their greenhouse gas emissions. The rule doesn’t stop at the corporations themselves, though. The SEC rule requires disclosures for their entire supply chain, which in many cases includes everyday cattle producers, like you!
The SEC should be focused on regulating publicly traded companies, not family farms and ranches!
The Commission is accepting comments until June 17.
Please tell them how you feel! It’s easy, just scroll down. We’ve prepared draft comments that you can use or modify to your liking, and detailed instructions on how to submit your comments.
Thank you for helping fend off yet another challenge to raising the cattle American consumers demand!
June <date>, 2022 The Honorable Gary Gensler U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 SEC File No. S7-10-22 Submitted via https://www.sec.gov/cgi-bin/ruling-comments To Whom it May Concern: I appreciate the opportunity to submit comments on the Securities and Exchange Commission “Commission” proposed amendments to its rule under the Securities Act of 1993 and Securities Exchange Act of 1934 that would require registrants to provide certain climate-related information in their registration statements and annual reports. Cattle producers are natural conservationists, overseeing millions of acres of land while preserving water and air quality. Unfortunately, through the Commission’s S7-10-22 proposed rule we see a burden placed squarely on ranchers and landowners. A mandate such as this, that requires publicly traded companies that process or sell beef to report the greenhouse gas (GHG) emissions from their supply chain could have a devastating effect on my ability to raise cattle. This mandate by the Commission will 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. As a cattle producer, I urge you to limit the proposed rule to only scope one (direct) and scope two (energy/electrical) emissions while omitting scope 3 (supply chain) emission compliance. Please consider the immense cost and disruption this rule will pose to ranchers like me, 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 family farms and ranches. Thank you for the opportunity to submit comments on this proposed rule. Sincerely, <Your Name>
- Copy and paste the above text into your word processor (i.e. Microsoft Word).
- Helpful Hint: When you paste the text into your document, right-click and paste using the “Keep Text Only” button.
- Fill in the highlighted areas with the date, and your name, and make any other adjustments you would like to personalize the comments.
- Save the document as “Comments on SEC Proposed Rule S7-10-22”
- Go to the link below, and then:
- Fill out the appropriate boxes for your name, etc.
- In the “Comments” box be sure to copy and paste your comments or simply write “Comments Attached” if you choose to attach a file
- Click Continue
- Check to make sure your personal information is correct
- If you are attaching a file you may do so from here
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- Click Submit!
- Share your comments with your friends, so they can submit some too!
Alternately, you may submit an email to [email protected]
Please be sure to include “Comments on SEC Proposed Rule S7-10-22” on the subject line if you submit comments by email.