Jan. 16, 2024
The creation of an entirely new corporate taxonomy based on protecting public natural resources by placing them under the direction of NACs raises significant questions about asset valuation, investment risk, and corporate accountability. I believe that a comprehensive evaluation of the unique listing requirements relating to NACs is critical to safeguard the interests of potential investors and that the Commission has not sufficiently demonstrated that it has the capabilities to oversee appropriate disclosures around land and water stewardship. The proposed rule would allow for federal lands, including national parks and other publicly owned lands, to be included in private investment portfolios. The proposed rule also allows for NACs to have management authority over assets held in the portfolio, including our public lands. In the proposed rule, the SEC is creating a new incentive for non-government corporate control over our publicly shared lands. I am concerned that corporate involvement in the stewardship and control of our federal lands would create unintended consequences. The proposed rule could lead to a preservationist-only approach to federal land management instead of an “all-of-the-above” working lands approach as intended by the creation of our federal land programs. I am also alarmed by the SEC’s allowance under the proposed rule of foreign investment in these uniquely U.S. assets. At a time in which we are actively working to deter our adversaries, I am not open our federal lands up to investment from the same adversaries. Under what statute is the SEC specifically authorized to confer “management authority” over federally owned lands and natural resources to private investment companies? The proposed rule indicates SEC will use the United Nations System of Environmental and Economic Accounting—Ecosystem Accounting Framework (SEEA EA)—in its financial disclosure reports. Does the SEC find the SEEA EA framework to be consistent with U.S. Generally Accepted Accounting Principles (GAAP) and U.S. law? The rule shares examples of revenue-generating operations, including eco-tourism, production of regenerative food crops, and carbon credits. If NACs are deemed eligible for federal conservation dollars, such as under the United States Department of Agriculture (USDA) Conservation Reserve Program, will these federal funds be counted as revenue? You (the SEC) don't have the authority to make these rules. Concerned U. S. Citizen.