Subject: File No. SR-NYSE-2023-09
From: Victoria McColm

NAC's must be stopped. Just as ESG is evil and designed to demonize legitimate business, NACs share the same characteristics. They are unlawful and unconstitutional. From Andrew Langer article: I agree with Mr. Langer. Recent developments in the investment world have brought to light a concerning trend: the introduction of Natural Asset Companies (NACs). The New York Stock Exchange (NYSE) and the Intrinsic Exchange Group (IEG) are pushing for NACs, ostensibly as a means to fight climate change and protect biodiversity. However, there's more than meets the eye, and it's crucial to understand why NACs are sparking widespread concern and opposition. What are NACs? NACs are proposed as a new kind of investment. They aim to manage, maintain, or restore lands (both public and private) to improve ecosystems. The twist? They put a dollar value on the resulting benefits, such as clean air or wildlife habitat. The concept is being reviewed by the Securities and Exchange Commission (SEC) for potential listing on the NYSE. The Controversy Surrounding NACs Ownership of Nature: One of the core criticisms of NACs is the monetization of nature – essentially putting a price tag on elements of nature that should be free and accessible to all. This concept of monetizing public lands and their "ecological performance rights" is seen by many as overreach. Property Rights and Foreign Investment Concerns: There's anxiety that NACs could lead to stringent management restrictions on public lands and open doors to foreign investment on federal lands. Critics, including conservative lawmakers and property rights advocates, worry about the implications for national sovereignty and security. Questionable Viability: Doubts have been raised about the practical viability of these investments. The concern is whether the revenue generated through NACs can truly support conservation and restoration efforts while remaining profitable for investors. Potential Impact on Land Management: NACs could significantly alter the management of millions of acres of land, possibly restricting multiple uses and recreational activities. This shift in land management philosophy is seen as a move away from local control and traditional land-use practices. Carbon Credits and Environmental Impact: The SEC suggests that NACs could monetize ecosystem services by selling carbon credits. However, the effectiveness and transparency of carbon credits have been increasingly questioned, casting doubt on the environmental benefits of this approach. National Security Risks: There's a fear that NACs could enable foreign powers, potentially adversaries, to gain control over significant land resources in the U.S. This aspect raises alarms about the potential for intelligence gathering and other security risks.