Subject: SR-NYSE-2023-09: Webform Comments from Glen Martin
From: Glen Martin
Affiliation: Retired

Jan. 12, 2024

I am strongly opposed to “Natural Asset Companies” on
the NYSE. Treasurer Oaks of Utah has stated the case in much better
terms than I would use so I attach part of Treasurer Oaks remarks
below. 
Glen Martin.
Treasurer Oaks opposes a proposal under consideration by the
Securities and Exchange Commission (SEC) that would allow for the
creation and listing of a new type of company called a Natural Asset
Company (NAC) on the New York Stock Exchange (NYSE). The proposal
poses a significant risk to rural economies by creating a mechanism
for public and private land to be permanently removed from productive
use in the name of solving climate change.
“The proposed creation of Natural Asset Companies is one of the
greatest threats to rural communities in the history of our
country,” Treasurer Oaks said. “Under the proposal, private
interests, including foreign-controlled sovereign wealth funds, could
use their capital to purchase or manage farmland, national and state
parks, and other mineral-rich areas and stop essential economic
activities like farming, grazing, and energy extraction. Recreating on
Utah’s incredible natural lands could also face significant
curtailment.”
Unlike other types of companies, the purpose of a NAC is to maximize
the value of the land’s “ecological services,” rather than
generate a profit from traditional activities. "Unsustainable
extractive activities" including energy extraction and the use of
farm machinery and synthetic fertilizers, would be prohibited on
NAC-managed land.