Dec. 3, 2023
SECURITIES AND EXCHANGE COMMISSION Release No. 34-98665 File No. SR-NYSE-2023-09 Proposed Rule Change to Amend the NYSE Listed Company Manual to Adopt Listing Standards for Natural Asset Companies 31 Pages In this comment set forth below, we will discuss: 1. What is the Economic Purpose of a Natural Asset Company. 2. Anthropogenic CO2 Global Warming is Junk Science. 3. Summary and Recommendation. 1. What is the Economic Purpose of a Natural Asset Company. A Natural Asset Company is, by design, a lousy money losing investment. A wasting asset. Any stock that never makes money and never pays a dividend is worth zero. So why this Proposed Rule authorizing NACs? Advocates of this Proposed Rule authorizing NACs are the middlemen who will get fat fee income from launching and trading NACs. The middlemen are the investment bankers, expensive environmental consultants, NAC managements, stock trading houses, environmental non profits, and the NYSE which hopes to get listing fees and trading fees. Investment bankers get fat fees for monetizing assets, and these assets can get pretty exotic, but they all have a nominal goal, of a return to the investor, which may or may not be realized. NACs are the first asset which, by design, are a money losing investment. The locust swarm of NAC middlemen advocates of this Proposed Rule must believe, to paraphrase P. T. Barnum: There is an NAC investor born every minute. There is no return on the investment, NACs are a wasting asset, and that's fine for the 1% wealthy accredited investors. They get to feel good, and grandstand virtue signaling among their like minded friends in echo chamber cocktail parties on their yachts in The Hamptons. "What NAC is in your portfolio?" What about the other 99% of investors? Investors who invest for retirement. People who work for a living. And the institutions that manage money for the 99%? NACs are completely unsuitable and illegal as the fiduciary best interest of the investor. A NAC that never makes money and never pays a dividend is worth zero. How can the SEC ban NACs for the hapless 99%? Research has shown returns of Environmental, Social, and Governance funds have underperformed. The ESG fad is fading. Investors are dumping ESG funds and ESG funds are closing. In addition, research has found diversity has not made companies more profitable, which calls into question the entire diversity, inclusion, and equity fad infesting Corporate America. DIE is DIEing. ESG and DIE are good for virtue signaling but not making money. Even worse, NACs are a pure play on losing money. 2. Anthropogenic CO2 Global Warming is Junk Science. NACs are proposed to alleviate The Global Warming Crisis by abating atmospheric CO2. Set forth below is strong evidence that CO2 abatement is an especially frivolous waste of money for an NAC. A. Global Warming Data Fraud. Global Warming Alarmists have used lies and doctored data for decades to promote their hidden policy agendas toward income and wealth redistribution. Global Warming Alarmist perfidy was rampant in the infamous Climategate Scandal. Leading global warming climatologists were caught fraudulently doctoring temperature data to increase Global Warming. The United Nations Nobel prize winning Intergovernmental Panel on Climate Change (IPCC) used temperature data from the late East Anglia University's Keith "Fudge Factor" Briffa whose computer code contained what he called "fudge factors" adding up to 0.75 of a degree to increase the recent temperature data. In addition, climate scientists conspired to expunge the high historic temperatures of the Medieval Warming Period. In the MWP the Earth was so warm that Greenland was actually green. Deleting the MWP made the current warming look unique. It is not. Furthermore, Pennsylvania State University Prof. Michael "Hide the Decline" Mann fraudulently spliced two temperature data sets. To make them match he raised the lower data set to match the higher data set where they overlapped. This hid a discrepancy that would have shown declining temperatures. Prof. Mann was nearly fired for this breach of academic research protocol. Nobel prize winner, Oscar winner, and former Vice President Al Gore's Climate Reality Project video titled “Climate 101” featured a "simple high school physics experiment". In the experiment, a bottle of CO2 heats up faster than a bottle of ambient air. The experiment is faked. A Photoshop difference analysis of the two images of the CO2 and ambient air thermometers showed the images exactly match, except the CO2 image was doctored to show a higher temperature. If Al Gore had to fake this experiment, what else has he faked? So we have doctored temperature data from the United Nations IPCC and East Anglia University's Keith "Fudge Factor" Briffa. Doctored temperature data from Pennsylvania State University Prof. Michael "Hide the Decline" Mann. And experimental fraud by Al Gore. The Climategate Scandal showed man-made global warming data are abundant. But not so much man made global warming. Like the made up temperature data, Nobel Prize winner President Obama made up a number when he said "97 percent of climate scientists agree that climate change is real, man-made and dangerous." In fact there are a lot of respected scientists that disagree, and probably many more that silently disagree. What we have here is an Asch conformity syndrome. Pressure from a group leads people to conform, even when they know that the rest of the group is wrong. Pressure is endemic. The academic peer review process has been corrupted. It's a lynch mob. Doubting scientists can't get research grants, can't get their research published, and don't get hired for climate policy jobs. Among academia, these "Climate Deniers" are one cut above a leper with a bell. B. Proof that Man Made CO2 Has Not Warmed the Earth. The science is not settled. Blaming man made Carbon Dioxide, CO2 molecules, for The Global Warming Crisis is junk science. We can agree that the Earth has warmed about +1.0C degree during the Industrial era. We can also agree that CO2 has increased +0.013% from 0.028% of the atmosphere to 0.041% during the Industrial Era. However, correlation does not prove causality. CO2 is a tiny trace gas. Envision this: If you are in a room with a 9 ft ceiling and all the gasses are stacked, the pre-industrial CO2 layer would be as thin as a credit card. The raised letters on the credit card are as tall as all the extra CO2 added during the industrial age. It is this tiny thin layer of invisible gas that has got potty mouthed Greta Thunberg, Nobel Prize winner Al Gore, befuddled Mr. Biden, and all the other Global Warming alarmist's panties in a bunch. An invisible layer of gas as thin as the raised letters on a credit card. How an infinitesimal +0.013% increase in CO2 can cause a +1.0C degree increase in the remaining 99.987% of the atmosphere defies any common sense explanation. The Global Warming - CO2 gas math is quite simple. And physically impossible. The Earth’s atmosphere has warmed +1.0C degrees during the industrial era. The added CO2 during the industrial era is one part in 7,700 of the atmosphere. To heat the atmosphere +1.0C degrees, the added CO2 molecules must contribute +1.0C x 7,700 or +7,700C degrees of heat. The surface of the Sun, 93 million miles away, is 5,700C degrees. It defies common sense, and physics, that the Sun's surface heat, at 5,700C degrees, can travel 93 million miles through space, and then heat Earth's CO2 molecules hotter than the Sun at 7,700C degrees. To make the CO2 heat pencil out, Global Warming Alarmists claim there is a CO2 greenhouse heat feedback effect which amplifies the Sun's warming, a gimmick with the fancy name of "Radiative Forcing". The extra heat is impossible. CO2 can't add more heat than it absorbs. CO2 is an inert gas. There is no exothermic chemical reaction. Climate scientists have hailed the planet Venus as an example of CO2 caused Global Warming. Yes, Venus is very hot, 460C degrees. But conditions on Venus are extreme. The dense atmosphere is 96.5% CO2. Surface air pressure is 1,300 Pounds per square inch, equal to 93 Earth atmospheres. That amounts to 220,000 times as much CO2 as the Earth. Plus, at 67 million miles from the Sun, Venus receives twice the sunlight energy per square meter as the Earth. The extreme CO2 density, high pressure, and strong sunlight conditions combine to make the Venus CO2 warming effect 4.1 million times greater than the Earth's CO2. Man made CO2 molecules are not the control knob for the Earth's temperature. Don't be hornswoggled by Global Warming Alarmists. It's junk science! 3. Summary and Recommendation. In summary, NACs are by design a wasting asset, with no economic return on investment. A NAC that never makes money and never pays a dividend is worth zero. NACs are unsuitable for an investment manager's fiduciary mandate to act in the best interest of investors. Furthermore, NACs focused on CO2 abatement are especially bad because they will have no benefit on The Global Warming Crisis. The SEC should not approve the Proposed Rule Change to Amend the NYSE Listed Company Manual to Adopt Listing Standards for Natural Asset Companies.