Subject: File No. SR-NYSEArca-2020-105
From: Lance Coogan
Affiliation: Veles Water Limited

April 5, 2021

RE question number 3

The underlying water spot markets are highly regulated markets, which requires verification of trades on various levels.
It would be extremely difficult to manipulate this market and it is most probably the most difficult market to manipulate in all the commodity markets.
Reasons for trades have to be justified and signed off by California regulators.
In addition to this conveyance conduits such as aqueducts and pipelines have to be booked to accommodate the transport of the water from seller to buyer and often transporting large quantities of water can take weeks which sets it apart from other commodity markets.
This index is cash settled and the introduction of the ETF will help the market.