Subject: File No. SR-NYSE-2023-09
From: Sandy Newsome

Subject: File No. SR-NYSE-2023-09 Asking the SEC to NOT ALLOW NACs To all involved at the SEC: I am urging the SEC to NOT allow the NYSE to list “Natural Asset Companies” or NACs, pursuant to File No. SR-NYSE-2023-09. My name is Sandy Newsome and I live in Cody, Wyoming. I am writing to oppose File No. SR-NYSE-2023-09. As the Wyoming House Representative of House District 24 and the chairwoman of the Wyoming House Travel, Recreation, Wildlife and Cultural Committee, I strongly oppose this change. This could affect the entire nation and every type of use on public lands from off-roading, overlanding, primitive camping, snowmobiling, dirt-biking, mountain biking, hiking to hunting and fishing. The U.S. Bureau of Economic Analysis showed that in 2021 the outdoor recreation industry generates $821 billion nationwide in economic activity. In Wyoming outdoor recreation is a $2 billion industry. NAC's could become restrictive for users and could harm local economies. It would rob my constituents of potential income. NAC's could restrict access for all user groups. Public lands should benefit the public and not corporations. Because the social and economic impact of NACs will be substantial, the creation of NACs through an SEC rule making is likely a violation of the Major Questions Doctrine. Only Congress should be enacting policy changes of this magnitude. I do not believe that there is a statute that allows the SEC to specifically authorize “management authority” over federally owned lands and natural resources to private investment companies. The northern parts of Yellowstone National Park and the Shoshone National Forest are in the Wyoming House district that I represent. The proposed rule would allow for federal lands, including national parks and other publicly owned lands, to be included in private investment portfolios. The proposed rule also allows for NACs to have management authority over assets held in the portfolio, including our public lands. I am concerned that corporate involvement in the stewardship and control of our federal lands would create unintended consequences. The proposed rule could lead to a preservationist-only approach to federal land management instead of an “all-of-the-above” working lands approach as intended by the creation of our federal land programs. lands. This would negatively impact tourism which is Wyoming’s number two industry. NACs are also a direct threat to oil and gas production, mineral development, and the farming and ranching communities. Energy production is the number one industry in Wyoming. Agriculture is our number three industry. Under this proposal you would see private interests, including foreign-owned sovereign wealth funds, purchasing productive farmland and mineral-rich land, and stopping essential economic activity such as grazing and energy extraction. Reduced production in agriculture, mining, and oil, means higher prices on food and energy, especially harming those who can least afford it. I am also alarmed by the SEC’s allowance under the proposed rule of foreign investment in these uniquely U.S. assets. At a time in which we are actively working to deter our adversaries, we should not be open our federal lands up to investment from the same adversaries. Allowing a few corporations to benefit off of free public land will be catastrophic to our nation and to Wyoming. Thank you for considering my comments. Sandy Newsome Wyoming House District 24 Chairwoman of Wyoming House Travel, Recreation, Wildlife and Cultural Resources Committee