Subject: File No. SR-NYSE-2023-09
From: William A. Coates

Natural Asset Companies are a new kind of creature, and should be handled with caution. There are likely to be large fluctuations in value as initial offerings and investors develop, and I suggest that they be handled as renewable fixed-term leases rather than ownership in perpetuity. Terms should start out as no more than ten years, to reduce investor risk on both the upside and downside. Terms could then be adjusted or negotiated as the market stabilizes. It is apparently felt that consumption of 'natural resources' is too high and valuations of them are too low, so we should expect the valuations to start out quite high if the region being sold has real physical resources such as oil or gas. The agenda of decarbonization demands this. Use of the UN System of Environmental-Economic Accounting implies that COP28 levels of ecological fear will be used, but they are quite unrealistic. Areas such as the American Southwest, currently in a drought cycle, would be valued lower. Such climate cycles would make valuation difficult.