WASHINGTON, D.C., June 17, 2022 — The National Pork Producers Council (NPPC) filed comments today to the U.S. Securities and Exchange Commission (SEC) regarding its controversial reporting requirements proposal on climate-related disclosures for investors.
In its comments, NPPC and other agricultural groups requested that the SEC reconsider its application of burdensome and unnecessary climate disclosure requirements under Scope 3 of the proposed rules. As currently drafted, these requirements would overly burden American farmers, forcing them to take on costly and expensive reporting that will set back farm environmental performance, and would be in violation of federal law. These requirements will ultimately be neither accurate nor serve any useful purpose.
“The U.S. pork industry represents a mere one-third of 1% of U.S. climate emissions. Despite this, American pig farmers have managed to shrink their GHG footprint by over 21% over the last three decades while at the same time, the industry has increased its production of affordable pork for consumers 77%,” said Michael Formica, assistant vice president and general counsel, NPPC. “This demonstrates not only the commitment of farmers to address long-term sustainability challenges we all face, but also that voluntary, market-based incentives have helped make real progress on climate change.”
NPPC submitted comments in conjunction with ten other agricultural organizations, including the American Farm Bureau Federation and various crop and livestock organizations. Among the seven recommendations made, NPPC asked the SEC to consider removing the “value chain” concept, removing or substantially revising the Scope 3 emissions disclosure requirement and revising the proposed rule to ensure alignment of GHG emissions disclosures with existing federal emissions reporting programs and federal law protecting livestock farmers from costly, inaccurate and unduly burdensome GHG emissions reporting. Read the full comments here.
“American pig farmers are committed to transparency in climate-related matters and believe in doing this in a manner consistent with existing practices,” Formica said. “Costs associated with the proposed rule would be significant, especially for small to mid-sized farms and would lead to industry consolidation and further impact not just rural communities where those farms are located but the ability of every American to enjoy bacon with breakfast.”