I oppose the creation of Natural Asset Companies (NACs) that will be used to sell off, and sell out, America. I do not want our country’s public lands, waters and even air sold to private interests obliged to preclude the productive use of such resources to the betterment of our society and the strengthening of our economy. I also reject the imposition of unconstitutional restrictions via such means on individual Americans’ property rights and other freedoms. My sentiments are further intensified by the prospect that those private interests may include hostile foreign powers like the Chinese Communist Party, Russia and Iran who may have their own reasons for wanting to lock down our hydrocarbon-based fuels, our minerals, forests, etc. The only reason the NYSE would need a new rule to authorize the listing of NACs is because they do not qualify under the current, tested and legally sound rules. Adopting the proposal is inconsistent with the protection of investors, the promotion of capital formation, and the maintenance of fair and orderly markets. The Proposal purports to create a novel way to measure the value of these services and assets, by reference to a set of accounting standards. But these standards are not recognized under Generally Accepted Accounting Principles (GAAP) nor elsewhere else in U.S. law. NACs are vehicles for fraud. An investment vehicle that proposes to take investor money, use it to acquire assets that cannot be used in tangible ways to create economic value, and thus are to be valued using completely novel and untested accounting methods designed expressly for the purpose of attributing value where none exists under traditional accounting methods, is a fraud. Clean air, for example, does not have an economic value in the way that cows or minerals have. Thus, whatever else a NAC might be, it is not a business since a NACs business model is based exclusively on taking money from investors and not creating or obtaining anything of economic value as currently conceived under the securities laws. The Proposal raises national security concerns. Under the proposal NACs are expected to license rights to natural resources that can include such vital resources as the ability to grow food or mine for critical minerals. In addition, some of these rights may grant the NAC access to or even control of lands located near sensitive U.S. government facilities. There is nothing in the Proposal to prevent a hostile foreign power from sponsoring or subsequently acquiring a controlling interest in a NAC, at which point the foreign power may have the ability, or indeed, the responsibility, to prevent productive use of America’s natural resources, or access to sensitive lands. There is no need for a new rule. If NACs are for-profit businesses, why would the NYSE need to create a special rule to accommodate their listing on the Exchange? The SEC’s Listed Company Manual lays out exacting requirements to ensure that companies listed on the Exchange follow its rules, the Nation’s securities laws, accounting rules and best ethical guides and practices. If NACs were like the other companies on the NYSE they would not need their own special category. The Proposal seeks to add this new listing standard because NACs are not like other companies. The Proposal sets out a pathway for listing entities that have no clear path to profitability using any recognized accounting method. I urge the Commission to reject proposed Rule SR-NYSE-2023-09.