Subject: File No. SR-NYSE-2023-09
From: Mark J Stansell

Cease and desist with File Number: SR-NYSE-2023-09 (Notice of Filing of Proposed Rule Change to Amend the NYSE Listed Company Manual to Adopt Listing Standards for Natural Asset Companies (NACs)) From page 5 of the proposal, “NACs will be corporations that hold the rights to the ecological performance (i.e., the value of natural assets and production of ecosystem services) produced by natural or working areas, such as national reserves or large-scale farmlands, and have the authority to manage the areas for conservation, restoration, or sustainable management. These rights can be licensed like other rights, including “run with the land” rights (such as mineral rights, water rights, or air rights), and NACs are expected to license these rights from sovereign nations or private landowners.” This is so far out of the purview of the SEC as to not even be funny. The Exchange Act is “designed to protect investors against manipulation of stock prices,” NOT to regulate or encourage imaginary concepts such as a “financing gap” for “biodiversity” and “climate change.” As a land owner in West Virginia, where tracts are often well over 100 acres, I can only imagine an NAC preying on less than savvy elderly farmers for their air rights, and the NAC then telling the land owner that they can now longer raise the Black Angus cows because the cow farts are causing global warming. This is far from a fantasy and such scenarios are already happening across the country by other means. NACs will only make it easier. This kind of BS makes my blood boil. And as a retired Naval Officer, even more alarming, the proposed rule will enable foreign actors to obtain perpetual control over public lands, either directly through organizing and registering as NACs or through obtaining controlling interests in NACs. This raises serious national security concerns, particularly given the importance of energy production and natural resource availability to America’s geopolitical position. What in God’s name are you thinking!? The States of Utah and Kansas, along with the Attorney Generals from twenty-three other states have filed a six-page commentary urging the SEC to disapprove SR-NYSE-2023-09. I implore you to head their advice. Mark J Stansell LCDR, USN (ret)