Letter to Secretary of Securities and Exchange Commission requesting an extension for the SEC Proposed Rule on The Enhancement and Standardization of Climate Related Disclosures for Investors

BY EMAIL AND ELECTRONIC SUBMISSION
Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-1090
rule-comments@sec.gov

File Number:
S7-10-22
RIN 3235–AM87

Re: Request for Extension to the Comment Period for Proposed Rule on The Enhancement and Standardization of Climate Related Disclosures for Investors, (87 FR 21334)

The undersigned organizations, representing the overwhelming vast majority of agriculture, livestock and poultry farmers and ranchers across the United States, respectfully request a 180-day extension, from May 20, 2022 until November 16, 2022 to the comment period for the Securities and Exchange Commission’s (SEC) Proposed Rule on The Enhancement and Standardization of Climate Related Disclosures for Investors. Our members grow plentiful and affordable meat, eggs, milk, fruits and vegetables, grain and fibers, as well as produce the fertilizers and crop protectants necessary to feed, fuel and clothe America and large portions of the world population. Members grow virtually every agricultural commodity produced commercially in the United States, including much of the U.S. wheat, corn, rice, soybean, cotton, wool, sugar, milk, poultry, egg, pork, lamb, and beef supply. Agriculture and livestock-related industries contributed over $1 trillion to the U.S gross domestic product in 2020 and employed 20 million people.

Our members, who are entities ranging from small family farms to the largest multinational corporations, are nevertheless overwhelmingly not “registrants” or otherwise subject in any way to the jurisdiction and oversight of the SEC. The proposed rule changes this. We must be granted more time to read, absorb, analyze and then draft meaningful comments. More time would be warranted simply on the basis of the voluminous nature of the proposed rule; 510 pages in length1 with 1068 technical footnotes and nearly 750 direct questions, all of which must be read, digested and considered for possible comment. We require the additional time in order to fully review the SEC’s proposal, retain legal and technical expertise, and understand the myriad ways it might impact our members.

Further justification for this extension is the fact that the proposed rule’s expansive treatment of the reporting of “Scope 3” greenhouse gas emissions not only directly affects our members’ operations, but in doing so may create multiple, new sources of substantial costs and liabilities. These include almost certain reporting obligations, technical challenges, significant financial and operational disruption and the risk of financially crippling legal liabilities. In doing so, the rule would have meaningful consequences for our members’ ability to produce this country’s food, fuel and fiber as well as for the security and stability of US agricultural supply chains.

Read the full letter submitted by CropLife America and more than 50 other signatories.