Subject: SR-NYSE-2023-09
From: Luke Starbuck
Affiliation:

Jan. 1, 2024

The New York Stock Exchange should not change their rules to adopt a new listing standard of Natural Asset companies. Natural Asset companies should not be created.
According to the proposal, “The purpose of the company is to actively manage, maintain, restore and grow the value of natural assets and the production of ecosystem services.” Yet, there is no clear explanation of how a natural asset or the production of ecosystem services can generate revenue. The proposal goes on to say that, "the NAC will not be able to engage in any activities that cause any material adverse impact on the condition of the natural assets under its control” such as perpetuating industrial agriculture. Land creates revenue by using it for grazing, farming or recreation. Because it is not clear exactly what activities create an adverse impact and exactly what is considered “industrial” or “unsustainable” or who decides the criteria for these things there is no guarantee this type of company would produce revenue. Millions of Americans are invested in the Stock Market, but most do not select what companies they invest in because these investments are their pensions or retirement savings that are managed by someone else. Allowing the creation of this type of company which will not create much, if any, revenue is not protecting investors. Investors will lose money and many will not have the choice whether they are invested in these companies or not.

The creation of this type of company will also create less competition and hinder a free and open market. Large natural asset companies, with money from investors such as large public pension funds, will be able to outcompete individuals and smaller companies who do not have the benefit of these large blocks of capital behind them. This will essentially end land ownership for individual Americans and small businesses and end their ability to compete. This type of company should not be allowed.