Jan. 17, 2024
For File number SR-NYSE-2023-09, I am asking that the SEC not allow the rule change for listing of Natual Asset Companies or NACs on the New York Stock Exchange. I am writing as private land owner of agricultural land, and I am concerned about the implications of enabling a mass influx of capital into agribusiness. This capital has the potential to represents outside or foreing interest as opposed to those close to the land. Part of the premise of the NAC is that agriculture is a depleting activity for the land. This is not what I have seen in farming communities with family farms and engaged land owners. Conservation and stewardship of the land is central to maintaining the land for future generations. This creativity seems ripe for unintended consequences by allow outsiders to dictate sustainable practices. I have watched as well financed companies have come into the natural areas to develop wind farms, solar fields, and pipelines to address a number of environmental concerns. There is a great deal of disruption to the land without much follow through on the benefits of these projects. The control of "ecological performance" appears to be more of this. Yes, I am skeptical of the institution's ability to enact meaningful change from the top down. I don't see this as a good reason for asset class rule change. With the NYSE as an investor in Intrinsic Exchange Group (IEG), it looks like this rule change is self-serving and not in the true interest of an environmental improvement. There are no shortages of organizations looking to make positive impact on the environment (i.e. Duck Unlimited, Sierra Club, Nature Conservancy, etc). If there is real value and a real need for this service, IEG should be able to operate as a profitable company serving land owners that are looking for environmental management. Please prove the concept can solve a problem first rather than trying to create a product. Lastly, the language of the proposal is nebulous. It is crafted in the language of the green economy as opposed to business principles. It reads more like oversite and policy than business value. It is not clear how these NACs interface with individual property rights, and it refers more to the collective benefit of the communities. Today in my community, the parks and natural areas are already managed for the collective. I am also concerned about the broad term of sustainable. There was a general feeling in California and Maui that they were employing sustainable practices for the forests and open space, but it is clear that those methods have contributed to the tragedy of their fires. I would think that the Department of Agriculture or the Department of the Interior would need to be in agreement on a change of this magnitude since there are implications to our food supply and national lands. This whole thing is tricky, like buying Manhattan island for some beads and trinkets. Please stop it, Shannon Siefken