Given Dairy’s Progress, NMPF Voices Concern with Proposed SEC Climate Rule

The U.S. Securities and Exchange Commission’s (SEC) proposed rule mandating extensive climate disclosures from publicly traded companies could undermine the dairy industry’s progress toward its sustainability goals and create far-reaching technical and financial challenges for American dairy farmers and their cooperatives, the National Milk Producers Federation (NMPF) said in comments submitted today.

“Dairy farmers are on the frontlines confronting the many challenges associated with climate change and remain committed to making progress to reduce the industry’s environmental impact,” said Jim Mulhern, president and CEO of NMPF. “The SEC rule, as written, could hamper our ability to make progress through the industry’s robust, voluntary greenhouse gas (GHG) assessment program, and jeopardize our goal of reaching GHG neutrality by 2050.”

U.S. dairy farmers have been leading environmental stewards for decades, tending their animals, land and water with great care. Thanks to improvements in productivity, new technologies and evolving best management practices, the environmental impact of producing a gallon of milk requires less water, less land and has a smaller carbon footprint than ever before. Still, the industry remains committed to its continued progress, devoting resources to programs, research and services that advance its 2050 goals to achieve industrywide neutral or better greenhouse gas emissions, optimize water usage and improve water quality.

To track progress and reach these important environmental goals, the National Dairy Farmers Assuring Responsible Management (FARM) Program in 2017 launched the Environmental Stewardship (ES) platform. The program provides a comprehensive estimate of GHG emissions and energy use on dairy farms with a suite of tools and resources for farmers to measure and improve their environmental footprint. FARM ES is the dairy community’s platform for a consistent, unified approach to GHG measurement that is free and accessible to all dairy farmers. Currently, over 80 percent of U.S. milk is handled by cooperatives and processors participating in FARM ES.

SEC’s proposed rule, “The Enhancement and Standardization of Climate Related Disclosures for Investors”, would require public companies to disclose GHG emissions, including emissions from upstream and downstream activities in its value chain, known as Scope 3. NMPF cautioned SEC that the inclusion of Scope 3 emissions disclosure within the rule is premature, and risks undermining the extensive efforts the dairy industry has made toward developing trust and buy-in for its voluntary GHG assessment program.

NMPF also emphasized the significant financial burden the proposed rule would have on dairy farmers and their cooperatives related to the collection and aggregation of on-farm GHG data.

NMPF, NCFC Lead Coalition Call for Climate-Smart Ag Investments

The National Milk Producers Federation (NMPF) and the National Council of Farmer Cooperatives (NCFC) today led a coalition of 12 agricultural and conservation organizations on a letter advocating for significant new funding for climate-smart agricultural practices that can help farmers to build on their environmental stewardship leadership.

Congressional efforts toward infrastructure legislation provide opportunities for substantial new investments in conservation support, with more emphasis on climate-smart agricultural practices. USDA conservation financial incentives provide farmers with voluntary technical assistance to carry out numerous stewardship practices. But more can be done to enhance practices that can yield meaningful environmental benefits, such as climate-smart manure and feed management on dairy farms.

“Dairy farmers are proactive stewards of their land and water resources, but they are always seeking to innovate further. Dairy farmers in 2020 committed to become carbon-neutral or better by 2050 and maximize water quality around the country. Bolstering conservation investment and focusing on climate-smart practices better positions dairy farmers to fulfill the dairy sector’s 2050 environmental stewardship goals as envisioned in the Net Zero Initiative,” said Jim Mulhern, president and CEO of NMPF.

“America’s farmer co-ops and their producer-owners stand ready to help address the global challenge posed by climate change. Increasing conservation funding for climate-friendly farming practices is essential to giving them the tools they need to do that and to continue their stewardship of our shared natural resources,” said Chuck Conner, president and CEO of NCFC.

NMPF, NCFC, and their colleagues call in the letter for increased spending on conservation incentives, including strong technical and financial assistance, with a greater focus on climate-smart practices. The organizations also support new rural broadband resources in pending infrastructure legislation. The letter also reiterates the major concerns that many of its signers have already voiced regarding several proposed changes to tax policy that would undermine the transfer of family farms from one generation to the next.

Organizations joining NMPF and NCFC on the letter include the Agricultural Retailers Association, American Seed Trade Association, CropLife America, National Association of Conservation Districts, National Association of State Departments of Agriculture, National Association of Wheat Growers, National Farmers Union, National Potato Council, Produce Marketing Association, and U.S. Apple Association.