Subject: File No. SR-NYSE-2023-09
From: SmithInWeston, LLC

Dear Sirs and Madams, I would echo others and request extensions of public comments regarding SR-NYSE-2023-09. Having examined the SEC proposal, Douglas Eger's corporate site and related posted interviews, and with an eye to my own role as a Wyoming ranch land owner-operator and family forest manager, I would respectfully offer the following comments. I'm personally not unsympathetic to the current economic reality that "nature" may not garner the monetary value it deserves. I've been fortunate enough to travel extensively around the globe, spending months and months of time deep within far flung ecosystems of the arctic, equatorial rain forests, duned deserts, and many, many points between. I infer that Mr. Eger, IEG, the SEC, and other proponents of this idea have similar experiences, and are wishing to somehow monetize both their passion and perceived environmental urgency in order to preserve all these natural blessings. But I'm sorry to opine that the proposed solution institutionalizing Natural Asset Companies won't land any of us in this idealized Natural Nirvana. First of all, and as pointed out by some early comments, there is by all appearances an intimate, perhaps incestuous, relationship between the SEC and IEG. One's "Spider Sense" tingles when the primary proponent of any economic venture or product very conveniently provides and manages its support and propagation. Sort of like the same sensation when a simple appliance works only when used in conjunction with expensive and proprietary consumables. Second, one of the key tenants of these entities is an absolute prohibition of anything "extractive". By this people assume something like coal or oil or minerals, but in reality when you graze a cow, cut hay, crops or farmed trees, or plant forage used by migratory wildlife, you're engaged in extraction. All of those products remove some part of the underlying landscape and take it somewhere else. Moreover, while we all know that climate concerns are all the rage, the simple reality is that basic thermodynamics will find the entire planet have an ongoing need of energy sources outside the scope and capability of current "green" energy sources. Not even to mention that, in reality, those "extractive industries" are a huge source of support and subsidy for all things "natural". Sorry, but this "non-extractive" element alone is a fatal flaw in the NAC, and ought to be taken back and reworked from scratch. Third, also as already reflected in many other comments, this proposal finds the SEC purporting a new business entity which may effectively "control" public resources into perpetuity. You all are about to launch us all into yet-another-string-of-interminable-lawsuits, as I can't conceive of an informed public willing to throw away their rights to a narrow group of well-heeled, idealistic investors (or perhaps less benign foreign states). Fourth, and also already previously mentioned, to the degree that the "NAC" may come to be born, the asset holders will quickly find themselves the "sucker born every minute". The brilliantly crafted ideas defining compliance and oversight will almost instantaneously fall prey to the "Benjamin under the table". The colossal administrative bloat required to make these entities actually compliant will find an enormous expense ratio. I'll posit that the investors will be limited to a tiny class of hobbyists with far more money than sense. Fifth, and in relation to the preceding comment, as a private property owner I wonder "just why do I need this?" Our own business's mission for holdings is "best sustainable use". There's nothing either enlightened nor novel about this new business entity that will further that goal. We're better off by monetizing ourselves with more direct local investment not further than arm's length from a "client". And just who is to tell us that this or that overarching NAC won't change course next year or decade? No thanks. Sixth.... I read and hear from Mr. Eger's presentations the importance of "local involvement". And within the context of this SEC proposal, just where is THAT!?! A narrow review period, impacted parties from local conservation districts to the Governors of four western states saying "hey, wait a minute here", and really only a smidge of commentary? To repeat a wise, ancient philosopher, "if you're five yards ahead, you're a leader, but if you're a hundred yards ahead, you're a target!" If this is such an important and compelling idea, just why is the SEC engendering concerns of temporal impropriety and painting that target? In closing, as typed earlier, our own business is founded on the mission of "best sustainable use". I would like to see all our resources optimally utilized and available for hundreds of generations to follow. But as currently defined by the SEC (or should I say "IEG"?), the NAC won't deliver. I therefore respectfully suggest that this proposal fail, and the idea revert to the blackboard. With best regards, GG Smith Manager SmithInWeston, LLC