Recently, hundreds of new groups have submitted comments to the Securities and Exchange Commission (SEC), expressing their opposition to the New York Stock Exchange's (NYSE) Proposed Rule Change to Natural Asset Companies (NACs). Among these opposing entities are grassroots organizations such as the Texas Farm Bureau, the Women’s Mining Coalition (WMC), and the Allegheny Forest Alliance (AFA).
In collaboration with the Intrinsic Exchange Group (IEG) and in partnership with the NYSE, the SEC proposed new investment vehicles known as "Natural Asset Companies (NACs)" on October 4. According to Federal Newswire, this proposed rule would permit federal lands, including national parks, to become part of NACs. These NACs would be granted substantial "management authority," while also enabling foreign interests, including China, to establish and invest in NACs.
Jay Bragg, the associate director of Commodities and Regulatory Activities at Texas Farm Bureau, voiced his concerns in a Jan. 2 letter to SEC Secretary Vanessa Countryman. He stated that "The underlying premise for the creation of NACs is fundamentally flawed. The proposal presumes the only motive for businesses is profit, at the expense of nature and NACs are needed to protect natural assets." Bragg further elaborated that "'Natural assets', 'ecosystem services', and 'community well-being' are not tangible assets that can be easily valued. Their value is (and will continue to be) highly subjective. This makes these investments ripe for fraud and abuse."
The Texas Farm Bureau operates as a member of Farm Bureau and is a national grassroots organization with memberships across America according to its website. It aims to build strong and prosperous agricultural communities as "the unified voice of Texas agriculture."
Emily Hendrickson, president of WMC, along with Debra W. Struhsacker, WMC co-founder and Board Member, expressed "grave concerns" about the SEC's proposed rule change in a Jan. 2 letter to Countryman. Among these concerns is that "Establishing NACs on public and National Forest System lands is unlawful because it conflicts with the Federal Land Management and Policy Act of 1976 (FLPMA)." WMC stated that "Under the SEC’s proposed NAC listing rules, NACs would be prohibited from allowing mining, logging, fossil fuel development, and industrial-scale agriculture on NAC-held lands because these activities are explicitly and categorically defined as 'unsustainable.'"
WMC is a grassroots organization with over 200 members nationwide that advocates for today’s modern domestic mining industry according to its website. Its members span various sectors including hardrock and industrial minerals, coal, energy generation, manufacturing, transportation, and service industries.
Julia McCray, the executive director of the AFA, voiced her concerns in a Dec. 18 letter to Countryman. She said "NAC’s will not be sensitive to, or even be aware of, the unique qualities of the local communities in and around the ANF (Allegheny National Forest) or the outsized impacts the NAC's policies will have on those communities. By definition, NACs will operate with generic ideas of 'sustainable' use on lands they do not own, don't understand the needs of, and likely will never even use/visit." McCray added that "Turning over land management control to NACs and their investors, leaving local stakeholders, landowners, and land managers out of the decision-making process, is not only impractical but violates standing law and policy."
The AFA is a non-profit coalition which serves as a voice for various groups according to its website. This includes citizens, school districts, townships, boroughs timber lumber wood product manufacturers sporting wildlife conservation groups trade associations others focused on the wellbeing of the Allegheny National Forest and the stability of ANF host communities.
