Agriculture, Food, and Land-Focused Organizations Support SEC on Scope 3 Emissions Disclosure

Eighteen organizations submitted a letter to the Securities and Exchange Commission to express their support for the SEC’s proposed rule on climate disclosure, including its provisions on Scope 3 greenhouse gas emissions


Jayson O’Neill,, (406) 570-5019

Nydia Gutierrez,, (202) 302-7531

Eighteen organizations, many of which have missions focused on food, agriculture, and land issues, submitted a letter to the Securities and Exchange Commission (SEC) this week to express their support for the SEC’s proposed rule on climate disclosure, including its provisions on Scope 3 greenhouse gas (GHG) emissions.

In recent months, the proposed rule has faced pushback from interest groups–including the American Farm Bureau Federation and the American Petroleum Institute — seeking to avoid publicly-traded companies from disclosingthe risks associated with their carbon footprint . Scope 3 emissions in particular — which include those released from a company’s products and supply chain–account for the vast majority of most public companies’ emissions.

In addition, the letter offers suggested additions to the preamble and rule text to alleviate concerns that the rule will negatively impact non-publicly traded private businesses, like family farms and ranches.

“Big Ag’s attempt to evade the SEC’s climate-related disclosure rules, particularly Scope 3 (indirect) emissions, would keep investors in the dark about ag’s massive greenhouse gas emissions. Given that Scope 3 totals comprise upwards of 90% of agribusiness emissions, ignoring these incriminating numbers would undermine investors’ ability to make informed decisions on climate-related risks.” Monique Mikhail, campaigns director, Agriculture & Climate Finance, Friends of the Earth U.S.

“The reporting of Scope 3 emissions by SEC listed companies provides investors with an important estimated benchmark of the climate related financial risk to be managed by each company,” said Steve Suppan, senior policy analyst at the Institute for Agriculture and Trade Policy. “The proposed rule provides companies with a phase-in period before compliance is required to learn how to apply the Greenhouse Gas Protocol reporting methodology to their operational and supply chain emissions. This is a necessary and workable rule that does not apply to or require farm and ranch operations to report their emissions, contrary to disinformation about the proposed rule.”

“Family farmers and ranchers have been decimated by consolidated agro-industries that receive most of the revenues while leaving the larger footprint on the environment. Diversifying local farmers would not be affected by the proposed rule, but concentrated livestock and large-scale monocropping operations should be accountable for unsustainable practices” commented Antonio Tovar, senior policy associate at the National Family Farm Coalition, “A consolidated food system weakens our resilience in more than one way. but this kind of instrument can reduce pollution throughout rural communities.”

“Industrial agriculture drives as much climate change as transportation. Yet most investors don’t know this, in large part because most of the greenhouse gas emissions are not from the slaughterhouses or processing plants, but from the livestock upstream, their waste, and their feed. Those are scope 3 emissions that must be disclosed if investors are to have any realistic and accurate understanding of the industry.” Carrie Apfel, senior attorney, Sustainable Food & Farming, Earthjustice.

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