My name is Robert Herz. I appreciate this opportunity to provide comments on the proposed rule change by the NYSE to adopt a new listing standard for Natural Asset Companies (NACs). I am an advisor to the Intrinsic Exchange Group that developed the NAC concept and worked with the NYSE on the proposed listing standard. I also currently serve on the Steering Committee of the G7 Impact Taskforce (G7 ITF) that was established in 2021 to provide recommendations on ways to accelerate the mobilization of capital to address climate change and other global sustainability challenges, on two advisory committees to the International Sustainability Standards Board (ISSB) and the IFRS Foundation, as a member of the board of directors of the International Foundation for Valuing Impacts, and as a member of the boards of directors and various board committees of Fannie Mae, Morgan Stanley, and Workiva, including chairing the audit committees of Fannie Mae and Morgan Stanley. For many years I served on the boards of directors of the Sustainability Accounting Standards Board and Value Reporting foundations. From 2002-2010 I was Chairman of the Financial Accounting Standards Board (FASB) and in 2001-02 I was one of the original members of the International Accounting Standards Board (IASB). Prior to that I was for many years a partner at PricewaterhouseCoopers serving as an audit partner and in various senior roles including heading the firm's Corporate Finance Advisory Services and leading the professional, technical accounting, auditing, and SEC reporting, risk management, and practice quality functions within the audit and assurance line of service. I have served on many professional and regulatory committees, including the 2007-08 SEC Advisory Committee on Improvements to Financial Reporting and chairing the AICPA SEC Regulations Committee. I believe the creation of a public market for common equity securities of NACs represents an important development in providing a potentially significant new source of capital to help address critical environmental goals that might not otherwise be available due to corporate and governmental budget considerations and constraints. As such it is very consistent with the urgent call by the G7 ITF in its December 2021 report "Time to deliver: Mobilising private capital at scale for people and planet" to harness the power of the financial markets towards these goals. It will also provide investors with a new investment option in their portfolio allocation decisions. And very importantly, as discussed below, I believe the proposed listing standard is consistent with the Securities Exchange Act of 1934 and with the SEC's three-part mission of protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation. Because of the distinct purpose of NACs, in addition to the usual listing requirements for NYSE-listed companies, the proposed NAC listing standard includes a number of other requirements specific to NACs regarding their charters, license agreements, and written policies designed to help ensure that each NAC develops, implements, and adheres to policies and actions that contribute to fulfilling its stated purpose. And, of critical importance, in addition to the traditional financial information, NACs will be required to provide additional statistical information on its ecological performance in accordance with a specific Reporting Framework - information that that in my view will be very relevant and decision useful to NAC shareholders and potential investors. As set forth in Exhibit 3 to the proposed rule change, the Reporting Framework that will be used by NACs to produce the required Ecological Performance Reports (EPRs) is based on the United Nations' System of Environmental - Economic Accounting - Ecosystem Accounting and provides extensive guidance on the steps required to perform the required annual Technical Ecological Performance Study and to prepare the annual EPR containing detailed statistical information on the biophysical measures and economic values of a NAC's production of ecosystem services and stocks of natural assets and additional information on underlying asset conditions and the calculations used to compute the statistical information. The listing standard also requires that the EPR be subject to external assurance at the examination level by an Independent Reviewer in accordance with PCAOB or AICPA attestation standards and that the reporting and assurance processes be overseen by the audit committee of the NAC. For all of these reasons I believe that the proposed rule change and NAC listing standard will provide the transparency, oversight, and investor safeguards that may not be afforded by other potential innovations brought to market through unregulated channels. I hope that my comments are helpful in the Commission's evaluation of the proposed rule change and NAC listing standard.