Jan. 16, 2024
We are in strong opposition to SR-NYSE-2023-09. We live in a rural community in Oregon that has already had severe economic impacts due to decisions made by state and federal government. This proposed rule will further harm rural communities and the schools who serve these communities. Here are some of our concerns: The proposed rule creating Natural Asset Companies within NYSE exceeds the statutory authority allowed by Congress. The funding streams created by these assets will invite corruption and political paybacks. The Federal Lands Policy and Management Act provides guidelines for federal lands management and that includes multiple use. This proposal prioritizes environmental projects at the expense of current federal leases for grazing, further devastating the agriculture sector of our state (which has a heavy proportion of public land) and the dollars agriculture brings into our local communities. The rule appears to give NAC's the unlimited ability to set rules, definitions, permissions, etc that will infringe upon the rights, conveyed by federal statute, that require federal agencies to coordinate the management of federal lands within local jurisdictions. The proposed rule prioritizes the protection of resources over human resources. Special interest NAC's have the potential to eliminate multiple use. We are concerned about the SEC's statement that NAC's are required to manage their acquisitions for "ecological and socially equitable goals." Will the impacts to rural America be an ecological or socially equitable goal? Rural counties and the people who live here can see that this will not be a decision that will be beneficial to us. The possibility of "no use" to the conservation and sustainability of natural resources will have a devastating impact on fire suppression for our forests and rangelands. Foreign entities are allowed to use NAC's, with the potential of undermining our national security and American foreign policy. The rule conflicts with many states' laws. The proposed rule skirts Congressional authorization and will be devastating to our country. It is scary that a supposedly independent federal agency would implement a rule on climate change due to political pressure. We hope you will disapprove of the formation of Natural Asset Companies. Sincerely, Mike and Sallie Peila