I oppose the creation of the NACs in their proposed form for the following reasons: The definition of the ecosystem services is vague, but the rule is very strict in not allowing for ”any degradation of the ecosystem services' “. Defining framework for ecosystem service accounting left to a small activist group rather than a broad consortium of universities and industries currently involved in productive uses of natural resources. Once the rule is implemented and NACs are on the market it is clear that their value can be influenced to a very large degree by regulations requiring carbon offsets and other mitigation credits of productive industries rather that the endogenous market-generated value based on future income and services provided by these assets. It is unclear if fiduciary duty of financial asset managers should allow for spending client money on NACs, given that their value is all intangible and will be prone to extreme manipulation by interested actors. While prices of many assets are to some degree influenced by government regulation and sometimes by clever accounting tricks; NACs are completely artificial assets with weak link to financial performance, whose value would entirely depend on the current government regulations and requirements as well as very pliable accounting allowed under ecosystem services accounting framework.