1/13/24 Re: Notice of Filing of Proposed Rule Change to Amend the NYSE Listed Company Manual to Adopt Listing Standards for Natural Asset Companies; SR-NYSE-2023-09 Dear Secretary Countryman: I am opposed to the NYSE Proposed Rule SR-NYSE-2023-09! I urge the Sec NOT to ADOPT the NYSE’s proposed rule! This proposal would give private investors who have neither America’s best interests nor the public’s economic well-being in mind, total control of our lands and profit from them simultaneously. Handing rights to America’s greatest national treasures – along with the air we breathe – to wealthy special interests is an extravagantly bizarre idea! Federal lands including National Parks were created by the people for the people’s use and enjoyment! The Proposed Rule Inappropriately Authorizes Federal Lands, Including National Parks, to be Enrolled into the NAC. 2. The Proposed Rule Unconstitutionally Gives “Management Authority” to NACs 3. This Proposal Charts the Course for the Biden Administration to Systematically and Unlawfully Enroll Federal Lands into NACs. 4. The Proposed Rule Invites Foreign Entities to Use NACs to Undermine National Security and American Foreign Policy 5. The Proposed Rule Allows Land Trusts to Enroll Conservation Easements for Profit into the NAC Without Opportunity for Public Participation or Congressional Authorization 6. The Proposed Rule Arbitrarily Monetizes Exclusive Rights to Natural Processes and Authorizes them to be Assigned to Well-Funded and Well-Connected Special Interests 7. The Proposal Fails a Benefit-Cost Analysis By Categorically Prioritizing Protection of Resources over Human Flourishing. 8. The Proposed Rule is Certain to Have a Disparate Impact on Disadvantaged Communities. 9. Traditional accounting standards would not be used to regulate NACs. 10. The land belonging to sovereign nations and private landowners alike can be subject to the control of NACs. Sovereign nations, such as the United States Government, can provide their lands to private investors, including those outside the United States. China, for example, may be able to invest in an NAC and effectively be a stakeholder in our national parks. Russia could assume control of lands currently leased to produce oil and place them off limits for future natural resource development. 11. Private landowners would, possibly even involuntarily, also be ceding their control of land to NACs, who would in turn require them to use the land in a “sustainable” way. NACs would prevent the productive use of the land, which would hurt the landowners financially, but also reduce the supply of minerals, food, and other goods that come from the land. RECOMMENDED ACTIONS: For the above reasons, the SEC should not adopt the NYSE’s Proposed Rule. Further, steps should be taken to actively prevent NACs from being recognized as an appropriate or federally recognized form of a public company eligible to be listed on the NYSE. No federal funds should be used to support NACs, nor should federal lands or assets be made available to them. Sincerely, Ann Benson