Subject: RE: SR–NYSE–2023–09, Proposed Rule Change To Amend the NYSE Listed Company Manual To Adopt Listing Standards for Natural Asset Companies
From: Markus Eldred
Affiliation:

Dec. 13, 2023

I am opposed to  SR–NYSE–2023–09, Proposed Rule Change To Amend the NYSE Listed Company Manual To Adopt Listing Standards for Natural Asset Companies.

My reasons are:

To lock up air, water, minerals, agriculture on private and/or public lands in Natural Asset Companies (NACs) will take economic benefit away from all citizens and concentrate such economic benefit in unelected investors.

NACs will become the next great asset bubble as essentially they would be derivatives attempting to put a value on ‘nature’. Your own SR–NYSE–2023–09 proposed rule says that the estimated value of ‘nature’ is estimated to be $100,000,000,000,000 per year.

No one who invests in such NAC stocks, derivatives, futures etc in a $100 trillion a year market will allow anyone to mine, pump, grow, harvest, water, etc on any public or private lands encumbered by a NAC. To do so would substantially if not totally degrade their investment in a ‘natural’ asset such as water, land, air, etc.

Congress has said public lands are to be stewarded by BLM, Forest Service, and other federal agencies and allowed to be used for agriculture, mineral extraction, grazing, timber, energy production, etc. This cannot be delegated to the SEC or a private concern such as the NYSE.

NACs would constitute the largest takings of private land use by unelected, elite stock holders of the NYSE. Imagine the overwhelming power of the lawsuits brought by a $100 trillion valuation NAC versus a landowner simply wishing to graze a few cattle on her privately owned land, but whose cattle flatulence ‘pollutes’ the natural air over her private lands. Air which is encumbered by an NAC.  What landowner, even a billionaire, could withstand even a bogus lawsuit essentially funded by unlimited NAC monies? Why? Because that amount of valuation of NACs is equal to 100,000 billionaires per YEAR.

Thank you,
Markus Eldred





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