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, NMPF said in comments submitted June 17.

“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.”

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 in its comments 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 through the National Dairy Farmers Assuring Responsible Management (FARM) Environmental Stewardship program.

NMPF also pointed out that 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 FARM Program in 2017 launched the Environmental Stewardship 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 Environmental Stewardship.

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 Lauds Progress on Growing Climate Solutions Act, Welcomes Conservation Proposals

NMPF applauded bipartisan work being done on legislation that would bolster the many conservation and environmental efforts dairy producers are leading as they continue their everyday stewardship of air, land, and water resources.

Senator Mike Braun (R-IN) and Senate Agriculture Committee Chairwoman Debbie Stabenow (D-MI) reintroduced on April 20 their bipartisan Growing Climate Solutions Act, which creates a USDA certification program permitting the department to informally endorse technical service providers that can help farmers implement environmental stewardship practices that may generate carbon credits.

The legislation, if passed, would greatly help dairy farmers seeking to achieve the sector’s goal to achieve carbon neutrality or better by 2050 through dairy’s Net Zero Initiative.

“We commend Chairwoman Stabenow and Senator Braun for continuing their bipartisan leadership on the Growing Climate Solutions Act, which would encourage greater farmer participation in environmental markets,” said Jim Mulhern, president and CEO of the National Milk Producers Federation. “This legislation will enhance the proactive, sustainable initiatives dairy farmers are expanding as our sector strives to achieve carbon neutrality.”

The Senate Agriculture, Nutrition, and Forestry Committee passed the bill on April 22 with broad bipartisan support. On the same day, Reps. Abigail Spanberger (D-VA) and Don Bacon (R-NE) reintroduced the companion House measure. NMPF submitted written testimony supporting the measure on behalf of Mulhern and Environmental Issues Committee Chair Mike McCloskey for a hearing held on the bill last June.

NMPF additionally commended House Agriculture Committee Ranking Member Glenn ‘GT’ Thompson (R-PA), who last month put forward several measures to adapt farm bill conservation programs that help address climate change: allowing private sector funding to meet conservation program demand; emphasizing soil health and increasing funding for Conservation Innovation Trials; and incentivizing the adoption of precision agriculture systems.

“We thank Ranking Member Thompson for furthering the conversation on climate and sustainability by putting forward several proposals for discussion,” said Mulhern. “We agree that farm bill conservation programs can be vital to helping producers reduce their environmental footprint, and we look forward to more closely examining this suite of legislation and other proposals that may be introduced in the coming weeks.”