Subject: File No. SR-NYSE-2023-09
From: Dewey Rundus

STOP I want to urge you to delay further consideration of the creation and NYSE listing of Natural Asset Companies(NACs). Securitization and exchange listing would be very significant and fraught with uncertainties, have possible undesirable outcomes, and would be exceedingly difficult to later undo. It is imperative that there be clarifying discussions conducted with both Legislative Representatives and in open, public forums. These are our property and property rights and must not be handled with anything less than extreme diligence. Because full and clear explanations of the listing proposals are unavailable, the following are my impressions of what would be done and my reactions (objections) to what I perceive to be the aims and possible outcomes. I oppose the creation of these Natural Asset Companies whose purpose is to manage and control US land, water, and air resources in perpetuity in conjunction with UN agenda 30 by 30. The idea for Natural Asset Companies derives from the government program of Conservation Easements, used as a device by the Land Trust and sold to private landowners. As a farm boy who grew up in Kansas, I am fully aware of the history of Conservation Easements and their use for years by the Land Trust, to convince landowners to place property into a state where the land will never be developed. The Land Trust owns the development rights from the day of the contract and the property owner is restricted to the baseline use on that signing date. I am concerned that the Land Trust could enroll the Conservation Easement, which they now own, in a Natural Asset Company without the owners permission, and the Land Trust will reap the profits. I oppose the SEC permitting the listing of this new investment vehicle on the New York Stock Exchange. An investment group could file to list the Natural Asset Company and the NAC could raise money from global investors, including sovereign wealth funds, even from nations hostile to the US. I absolutely oppose the rule in Exhibit 3 which clearly states that National Parks can be enrolled in the NACs, with management authority over the assets. I oppose the use of the United Nations proposed System of Environmental Economic Accounting (SEEA) displacing Generally Accepted Accounting Principles (GAAP). The latter measures cash flows to describe net present value. The SEEA measures the value of blocking others from utilizing lands for maximum economic benefit. It is very difficult to assign value to non production and would certainly open the door to “clever” manipulation. This proposal is complicated and evolving. It will radically change the idea of property rights and property use in the United States. It will affect all of us in ways not even contemplated much less understood. It should be presented, fully explained, and debated in a forum for the public at large as well as for our elected representatives. It is only in this way that we can be confident that such a major step has fully informed buy in.