Subject: File No. SR-NYSE-2023-09
From: Raúl Guevara

A mechanism like the NAC would be very beneficial in Latin America, as it would allow us to take advantage of the sustainability platform that has been built to generate income that would strengthen efforts and inject resources into many conservation programs. There are 3 fundamental pillars that this mechanism take into consideration of the Latin-American reality in cases of territories owned by States: • The natural capital located in Protected Wild Areas is owned by the State and will never be compromised. On the contrary, it is an essential element that provides security to investors. • The mechanism seeks to comply with the objectives established in laws and international conventions: the sustainability of the system, in this case economic. • Capital markets offer solutions to generate new income, and there are even investors willing to invest their money in innovative financial instruments, on the basis that the State is sovereign over its natural resources. This tool would help a countries like Costa Rica that has a lot investment in nature, current fiscal problems and lack of financial sustainability of the Wildlife Protected Areas: a. Cost of Decarbonization According to a 2020 study by the Inter-American Development Bank (IDB) titled "The Challenges of Decarbonizing the Costa Rican Economy," the total cost of implementing the National Decarbonization Plan is approximately US$100 billion, however, the Government does not have the money to comply with all projects required. b. Investment in Decarbonization Despite all the international commitments, due to fiscal constraints, the 2022-2023 budget for the execution of the decarbonization plan and the maintainace of the the Wildlife Protected Areas is 49% smaller than the 2021-2022. The fiscal discipline necessary to pay the government's high debt is generating disinvestment in health, education, security, and environmental protection. d. Debt to Finance The existing financing mechanisms relies on debt. Debt mechanisms or debt issuance for the financing of ordinary activities of the Administration prevail. e. Natural capital has not been adequately valued and financial mechanisms have limitations. The instruments for the use of natural capital to date, such as the Payment for Ecosystem Services (PES) program, the payment of carbon credits, among others, have not adequately recognized the value of the services provided by nature, which makes the financial resource limited to maintain and improve the performance of natural capital. Considering the aforementioned scenario, NACs are a unique instrument, as they would allow to reward the investment made and the ecosystem services that countries like Costa Rica provide to the world, having access to a very sophisticated market, with economic resources to help address environmental and climate challenge.