Jan. 11, 2024
RE: The Security Exchange Commission proposal to list natural asset companies (NAC) on the New York Stock Exchange. I am against the listings of NAC’s on the NYSC for the following reasons. 1. I am a sheep and cattle rancher (5 generations) that utilizes Federal land to graze. Our deeded lands hold all our rights – including water, minerals, and ownership. 2. Allowing NAC’s to purchase natural assets would destroy our 170 mile long contiguous migratory grazing pattern used by BOTH livestock and wildlife, because the Federal land we depend on for this grazing could be bought and/or closed by an NAC. We have made hundreds of thousands of dollars of water improvements along this route. Are the NAC’s going to pay us for that? Are they going to maintain them? 3. The valuation process for the assets is suspect. The way the assets are valued by the ecological services groups do not consider the full scope of the asset. By its own admission, the natural asset industry does not produce or improve anything. The focus is preservation, which means no use of the asset as opposed to conservation, which maintains the quality of the resource but can still be productive. IEG’s have overstated the value of the NAC’s. They stated that the value would be 5000 trillion dollars, when the total of the world economy is 1540 trillion dollars. Why have they overstated this value? 4. Any investor will be able to own rights not only on private property but also State and Federal lands, including National Parks. Foreign entities can buy our natural resources, close them off to development and force the United States to buy from a foreign entity, causing inflation and foreign dependence. The distribution of essential commodities can be withheld from Americans at the will of foreign entities. This is tyranny. 5. The rule allows for the purchase of existing conservation easements and natural resources on any land that has taken government payments or has a split estate designation. This will stop any rational landowner from utilizing Federal funding to enhance their property. The NRCS/FSA has been responsible for many years in accomplishing what the NAC claims they will do. 6. Gaining clear title to lands being purchased by the NAC’s will be a massive undertaking. It will overwhelm local assessors and disrupt regular business transactions by overwhelming the system. 7. If this is allowed, it will cause the largest transfer of land ownership and wealth in the history of the United States. This will challenge basic property rights which are the foundation of the American Republic. It will consolidate too much power and wealth in too few hands. Respectively, Peter Arambel – Arambel Ranches, Rock Springs, Wyoming