Jun. 01, 2022
Dear Secretary Vanessa Countryman, New York cattle producers among America’s first conservationists, and are an important caretaker for productive New York farmland acres with a focus on 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. Further, this rule fails to protect cattle producers who, in good faith, submit inaccurate data—an issue which is highly likely considering that there is no agreed-upon methodology for measuring agricultural GHG emissions. This creates unavoidable legal risk for every family farmer or rancher. As a cattle producer, 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. Often over looked, the bovine is a significant contributor to efficiencies because they are upcyclers who use byproduct stream such as wet distillers, brewery grains and other feedstocks that would be destine for landfills. These cattle ferment and capture volatile fatty acids from fiber digestion which would otherwise generate considerably more methane when not fed but instead composted. Numerous researchers have found a net protein advantage from these feed stock uses. Please revisit the calculation that misrepresented agriculture's greenhouse gas contribution. Thank you for listening to America’s cattle producers. Sincerely, Steven Smith