May. 09, 2022
Dear Commissioner Gary Gensler, As a farmer and land owner , 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 is an example of overreach by the Securities and Exchange Commission. It is not the responsibility or legal mandate of the SEC to gather such information from privately held businesses. Further the proposed requirements appear to violate the constitutional rights of private citizens by mandating disclosure from private businesses if they are part of the supply chain of an SEC regulated company. Nearly all farm commodities eventually reach a point in the value chain that involves an SEC regulated corporation, and thus would be subject to these regulations. Farmers and ranchers like me are already heavily regulated by multiple agencies at the local, state and the federal level. the sale of bulk farm commodities makes it extraordinarily difficult to document specific information related to commodity use by a specific corporation. 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 complicated and complex information with unknown costs for compliance and minimal actual scientific information upon which to make those determinations. Farmers play a leading role in climate sustainability. Of all of this nation's citizens farmers may be the most involved in the day to day real life aspects of climate change and sustainability. It is the job of elected lawmakers, not unelected regulators at the SEC, to adopt policies related to farms and ranches. I urge you to stay within your jurisdiction. Do not adopt these proposed regulations. Regards, donald wauthier