Ohio Farm Bureau submitted comments to SEC

On Friday, Ohio Farm Bureau submitted public comments in a letter to the Securities and Exchange Commission regarding a proposed rule that could severely impact family farms by requiring climate disclosures by public companies.

This letter was in addition to 8,500 comments sent in by Farm Bureau members across the country who took part in the action alert from American Farm Bureau on this issue. The letter emphasized that Farm Bureau members are committed to transparency in climate-related matters to inform our stakeholders in a manner consistent with existing practices in the agriculture industry.

“However, without changes and clarifications, the Proposed Rules would be wildly burdensome and expensive if not altogether impossible for many small and mid-sized farmers to comply with, as they require reporting of climate data at the local level,” the letter read. “The rule will only encourage consolidation for those without the resources to comply.”

Such consolidation would have far-reaching socioeconomic consequences, including further eroding rural tax bases. If further consolidation were to occur, this could seriously impede the ability of local communities to fund education, social services and access to health care.

The letter urged the SEC to realize that farming plays a vital role in the social fabric of rural communities that largely revolve around the agricultural industry, especially small and medium-sized farmers.

“We do not believe the SEC fully considered nor has sufficiently sought to mitigate the potential socioeconomic impact of the Proposed Rules on agricultural communities,” said Brandon Kern, senior director of state and national policy with Ohio Farm Bureau. “We also believe that the Proposed Rules will not only adversely impact farmers, but also harm consumers and erode the strength of America’s agricultural industry.”

In the letter, it was pointed out how proactive efforts already underway by Ohio farmers will make a more significant impact on reducing carbon emissions and promoting carbon capture in agriculture than the proposed rule and shared how Farm Bureau members are concerned that the rule could have a chilling impact on proactive efforts if farmers are forced to spend more resources on new regulatory compliance.

Ohio Farm Bureau encouraged the Commission to consider removing the “value-chain” concept from the Proposed Rules, remove or substantially revise the Scope 3 emissions disclosure requirement to include a carveout for the agricultural industry and to ensure the Final Rules do not include location data disclosures for GHG emissions, which may inadvertently disclose the private information of Farm Bureau members, among other requests.

With the comment period now over, the SEC must file a final rule, which is expected in late summer or fall. In the meantime, Farm Bureau will be working with members of Congress on legislative action if their requested changes to the rule are not accepted by the SEC.


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