Jan. 1, 2024
I request you to not adopt the SEC ruling on Natural Asset Companies (NACs), which would allow the listing of corporations that manage natural assets and their ecosystem services on the New York Stock Exchange. This ruling is detrimental to the public interest, the environment, and the sovereignty of our nation. Here are some of the concerns that I have about the SEC ruling on NACs: - The ruling would enable the transfer of our public lands, including national parks and other protected areas, to private entities that can have management authority over them. This would reduce the public oversight and accountability of our natural heritage and the multiple-use mandate of federal land agencies. - The ruling would expose our public lands to foreign ownership and influence, potentially threatening our national security and interests. NACs could be owned or controlled by foreign actors, such as China or Russia, which do not share our values or respect our laws and regulations. - The ruling would create a new and uncertain market for natural assets, which could pose significant risks and challenges for investors and the economy. The valuation, measurement, and verification of natural assets and their ecosystem services are complex and subjective, and the SEC has not shown that it has the capability or expertise to regulate them effectively. - The ruling would favor the conservation of natural assets over their sustainable use and development. NACs would be restricted from engaging in any activities that degrade the ecosystems, such as mining, logging, or agriculture, regardless of their social or economic benefits. This would limit the opportunities and choices for rural communities and industries that rely on natural resources. For these reasons, I respectfully ask you to not amend the NYSE Listed Company Manual to adopt a new listing standard for the listing of NACs. Thank you for your time and attention. Sincerely, Christine Kutler