Subject: File No. SR-NYSE-2023-09
From: Howard Walter

I do not support the creation of Natural Asset Companies on the New York Stock Exchange (or any type of similar company or function) and ask that you vote against it. The creation of this type of 'company' is just wrong and will place the United States in great peril. This type of 'company' will not help the environment. In addition, the creation and listing of Natural Asset Companies on the New York Stock Exchange would have a catastrophic effect on rural economies by removing land from productive use. Natural Asset Companies would raise capital to purchase public and private land, such as forests, parks, and farms, and permanently lock it away from human impact. Unlike other company types, the goal of a NAC is not to make a profit, but rather to maximize the value of the land’s “ecological services.” Consequently, many essential economic activities would be permanently barred from occurring on the land. Under the proposal, private interests, including foreign-owned sovereign wealth funds, could purchase farmland and mineral-rich land and stop activities, such as grazing and energy extraction, in the name of solving climate change. This poses significant risks of encumbering natural resources and devastating rural economies by removing land from productive use. Under the proposal before the SEC, you would see private interests, including foreign-owned sovereign wealth funds, purchasing productive farmland and mineral-rich land, and stopping essential economic activity such as grazing and energy extraction. Reduced production in agriculture, mining, and oil, means higher prices on food and energy, especially harming those who can least afford it. There are national security implications as well. Chinese, Russian, or Saudi sovereign wealth funds, might see particular value in locking up U.S. natural resources.