Subject: File No. SR-NYSE-2023-09
From: Robert Sturgell

1 January 2024 I write to express my grave concerns regarding Natural Asset Companies (NACs) and request that you withdraw the SECs proposed rule permitting the listing of NACs as a “self-regulating” organization on the New York Stock Exchange (SEC Release 34-98665; SR-NYSE-2023-09). In the proposed rule, the SEC is creating the ability to have non-government corporate control over our publicly shared lands through these NACs. The proposed rule would allow for federal lands, including our National Parks, to be included in private investment portfolios. The proposed rule allows for NACs to then have management authority over the private investment portfolio, including our public lands and National Parks. What is even more disturbing is the NACs permit foreign investment. This would permit foreign management authority over U.S. public lands and National Parks! The creation of this entirely new corporate framework raises significant questions about asset valuation and corporate accountability. It seemingly sidesteps existing accounting rules, standard and fiduciary accountability. It also permits a small number of private investors to have full management control over the use of our public lands; private control of public lands is unconstitutional. I strongly urge you to withdraw this proposed rule.