Subject: File No. SR-NYSE-2023-09
From: Bradley Young

I am writing to oppose the creation of Natural Asset Companies, primarily because they take control of public lands, ignoring the legislative process that represents we the people, thus overriding our natural rights - including local input and control of our own land as protected in the US Constitution. By what statute(s) are NACs allowed in the first place? NACs present a host of issues and problems, which can only be addressed correctly and by Constitutional design through Congress as lawful representative of the public and its rights and interests, not by government agency fiat. The problems and issues I am concerned with about NACs have been clearly and comprehensively presented to the SEC in the following public responses, which oppose NACs, and which I strongly recommend you research and consider: Board of Yakima County Commissioners, Dec. 26; Board of Commissioners, County of Elk, PA. I would also guide you to the letter to the SEC of November 2, 2023 by Senators Ricketts, Crapo, and Risch requesting clarification on the proposed rule: “Self-Regulatory Organizations; New York Stock Exchange LLC; Notice of Filing of Proposed Rule Change to Amend the NYSE Listed Company Manual to Adopt Listing Standards for Natural Asset Companies.” These issues should have been clarified in the SEC's proposal to begin with so the public could understand, and certainly should be addressed clearly and comprehensively before any decision is made, and only after Congress has decided on the matter. I spent my career as a Registered Investment Advisor and owned a Broker Dealer. I do not see the investment value in NAC's, certainly not for the investing public that the SEC was created to protect. I do see political value for the NACs themselves, who would gain power through taking control of land at the expense of citizens and localities, likely supporting agendas contrary to the public interest - why else would powerful interests want NACs? Smells like taxation without representation to me. Any "investment" that requires the creation of new and fuzzy accounting and regulation - which was sloughed over in the proposal - should be suspect on its face. These new accounting rules must be explained precisely before any decision is made. Finally, NACs appear to be an important mechanism through which the federal government applies its green agenda, without regard to the issues I and those I referenced herein raised. The Biden administration has suggested that it would cede power to NACs (under what authority?), while the Office of Science and Technology Policy has created a method to track the values of nature and place those so-called natural assets onto the federal balance sheet (under the new accounting? much danger lurks here); it described this effort as “the transition we need for sustainable growth and development, a stable climate, and a healthy planet (debatable - so let's have a legislative debate).” The Bureau of Land Management and U.S. Fish and Wildlife Service are taking similar steps to facilitate the enrollment of our federal lands into NACs (who put them up to this and under what authority and oversight?). The federal government is acting like NCAs are a fait accompli - I recommend we wait to see what Congress has to say about this, and then later the courts. Thank you for the opportunity to comment.