Jun. 17, 2022
June 17, 2022 As an agriculturist, I am writing to submit comments to the Securities and Exchange Commissions proposed rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors. The proposed rule is an example of significant and unnecessary overreach by the Securities and Exchange Commission. Farmers and ranchers like me are already heavily regulated by multiple agencies at the local, state and the federal level. Farmers have voluntarily done more to lessen their contributions to GHGas than any other collective industry in the US and the world. It would be lovely to think other sectors have equally stepped up, but alas, they have not. 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 documentation and calculations of emissions. I urge you to stay within your jurisdiction. This proposal is made especially dangerous for the function of the facets of society that enable this country to have domestic food security, a foundation for the ongoing stability of the United States. Methods of measuring contributions to emissions are highly inconsistent, and affected by many, many variables. There is no confidence that any consistency will be established anytime soon, and unless something can be quantified accurately, it cannot be improved upon, nor can it be implemented with any level of confidence. I am hopeful that common sense prevails, and that this proposed Rule is tabled for a long time, and perhaps forever. There are too many moving parts that could lead to an economic disaster for the United States. Again, please do not allow the SEC to implement this Rule. Thank You for your support in this battle. Yours, Julie Walker