Subject: File No. SR-NYSE-2023-09
From: Greg Epstein

I’m in opposition to the idea of Natural Asset Corporations (NACs) as outlined in the following bullets. 1. **Undermining U.S. Land Management and Ownership Principles**: The proposal could drastically alter how U.S. lands are accessed, managed, and owned. This shift could undermine long-established principles and practices, potentially disrupting the balance between conservation, public access, and economic activities. 2. **Lack of Clarity and Legal Concerns**: The mechanism for buying and selling "rights" to land, especially public land, is vaguely defined and potentially legally questionable. Such ambiguity could lead to legal disputes and confusion about land rights and usage. 3. **National Security and Foreign Influence**: Allowing foreign nations and noncitizens, including potentially adversarial countries, to buy and control U.S. land raises significant national security concerns. It could lead to the shutdown of critical U.S. energy and mineral production, impacting the country's economic and energy independence. 4. **Prohibition of Traditional Land Uses**: Banning activities like fossil fuel development, mining, logging, and grazing could have far-reaching economic impacts, especially in communities reliant on these industries. Such prohibitions might also disregard the sustainable practices that many of these industries have adopted. 5. **Questionable Oversight and Regulation**: Concerns about the SEC's oversight authority of NACs and the nature of their regulatory activities remain unanswered. It's unclear how the SEC would manage these new entities and what the “unique listing requirements” entail. 6. **Limited Public Engagement and Transparency**: The short 21-day comment period and lack of public awareness about the rule raise questions about transparency and public participation in a decision that could have wide-ranging implications. 7. **Conflict with Existing Environmental Policies**: The proposal appears to be a reaction to the perceived slow pace of environmental policies and ESG (Environmental, Social, and Governance) principles. This approach might conflict with existing, more balanced environmental strategies. 8. **Centralization of Power and Rights**: The rule could centralize power and control over land rights in the hands of a few, potentially at the expense of the broader public interest and rights. This centralization may lead to imbalances and unfair practices. 9. **Impact on Climate Change Policies**: While intended to address climate change, the approach might be too radical and not in line with established, more pragmatic environmental strategies. It risks alienating stakeholders crucial for effective climate action. 10. **Economic Disruption**: The prohibition of certain land uses under NACs could lead to significant economic disruption, affecting jobs and local economies, particularly in areas dependent on the targeted industries.