Comments Related Proposed SEC Rule Creating Natural Asset Companies The North Carolina Grange is not in support of amending the NYSE Listed Company Manual for adoption of listing standards for Natural Asset Companies. Please note that the NC Grange always encourages and promotes the conservation and preservation of our natural resources to secure a better tomorrow for the next generation but not at the expense of an individual’s property rights and freedoms. Based upon the September 29, 2023, listing by the SEC Notice of Filing of this Proposed Rule Change the State Grange does not support the approval to list NACs until the following noted items have been addressed and revised to protect the Constitutional rights of American citizens including right to freedom to use the air, land and water resources of the United States that the proposed NACs would potentially threaten in its current proposed format. These reservations as listed in the Notice are as follows: 1. “Fresh water resources are being consumed and polluted. Agriculture is contributing to the loss of natural habitat and soil degradation. These are significant threats to life on earth and the economy. “ According to the purpose of the NAC, it would have total authority to address any issue pertaining to water or land resources without regard to private landowner rights, the authority of oversight of United States government or its people. When addressing such issues, there should be a checks and balances to protect people and their needs for life above a natural resource. The NC Grange strongly disagrees with the statement that agriculture is contributing to the loss of natural habitat and soil degradation. 2. “NACs will be corporations that hold the rights to the ecological performance (i.e., the value of natural assets and production of ecosystem services) produced by natural or working areas, such as national reserves or large-scale farmlands, and have the authority to manage the areas for conservation, restoration, or sustainable management. These rights can be licensed like other rights, including ‘‘run with the land’’.” The NAC as described in the Notice has the right to take away large tracts of land and resource areas where private ownership exists. Private landowners’ rights are threatened by this type of governance and oversight. This oversight power has not established checks and balances which takes away the freedom of an American citizen. 3. Natural Asset Companies (NACs)— Corporations that hold the rights to the ecological performance of a defined area and have the authority to manage the areas for conservation, restoration, or sustainable management. The Grange has major concerns that the NAC will have the authority to strip individual property rights of landowners to manage and operate their lands, which we would not support. The NAC will have clear authority over farmers and ranchers that produce the food and fiber that we depend upon for survival and is essential in keeping the United States independently secure. Without the ability of the landowners to manage their land and associated resources to meet market needs, the USA and world food economy is threatened as is our national security. Additionally, the NAC listing as a public traded company allows for foreign investors to have direct oversight with influence on the policies and governance of our United States and its territories with limited oversight which could have potential negative consequences. Some of these potential consequences have been outlined in an “Issue Briefing – SEC Proposed Rule for “Natural Asset Companies” on October 18, 2023, by American Stewards of Liberty. This document outlined seven key points that would have a negative influence on Americans pertaining to their property and natural rights. These points are: 1. Proposed Rule Authorizes Federal Lands, Including National Parks, to be Enrolled into NACs. 2. Proposed Rule Gives “Management Authority” to the NAC. 3. The Biden Administration is Preparing to Enroll the Federal Lands into NACs. 4. Proposed Rule Invites Foreign Interests to Invest in an NAC. 5. Land Trusts can Enroll Conservation Easements without Landowner’s Permission. 6. Exclusive Rights to Natural Processes will be Monetized and Assigned to NACs. 7. Protection of the Resources is Prioritized over Human Flourishing.