Subject: SR-NYSE-2023-09: Webform Comments from Frank Cooney
From: Frank Cooney
Affiliation: Investor/Citizen of US

Jan. 13, 2024

To whom it may concern,
We would like to strongly OPPOSE the formation of NACs and the trading
of the same on the NYSE or any other equity stock exchange for the
following reasons among many others:
1) The NACs will not use GAPP accounting rules and therefore there
will be no way to compare the value of NACs with traditionally
incorporated firms traded on the same exchange
2) NACs will by definition have defacto regulatory control over
traditionally incorporated entities and there are no rules to govern
this engagement
3) There is no financial mechanism within the US government to
transfer the value of these natural assets from the books of the US
government to an exchange and account for the impact on the credit
picture of the US government debt. 
4) Management rights of Lands and regulatory authority associated
could be used to arbitrarily harm other members of an exchange with no
means to arbitrate.
4) Water and Air are not stationary and move freely in the
environment. There is not way to account for this fact in the
"ownership" and management of these so called assets. If a
traditionally formed corporation moves assets they encounter new
taxing authorities, regulation, etc.
5) The 10 amendment to the constitution affords these rights to the
states
6) The formation of such entities is not the purview or right of the
NYSE or the SEC is the right of the Congress of the US.
This is just a very bad idea and presents a serious threat to the
wealth and prosperity of every American with no defined monetary or
tangible benefit.
Kind Regards,
Frank Cooney