Subject: File Number S7-10-22
From: Jeff Pape
Affiliation:

Jun. 12, 2022

Dear Commissioner Gary Gensler, 

As a family farmer of our 171 year old family farm, 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. 

Under scope 3 farmers are at the very beginning of the value chain. What the SEC would be asking for would add yet another layer of Government oversite to an already heavily regulated business. Farms and ranches, will face a disproportionate burden in having to provide unknown costs if this rule proceeds. 

Farmers play a leading role in climate sustainability. On our family farm we have not turned soil for crops in 20 years, we utilize no-till, cover crops, we have buffer strips, we planted over 1700 trees. Many farms have become carbon sequesters and very few plow the ground anymore. Almost all utilize minimum till efforts. Proof of which is the agricultural equipment manufacturer John Deere who started its business with a plow, has announced they are no longer going to build moldboard plows due the lack of sales. 

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. 

Regards, 
Jeff Pape