The Women’s Mining Coalition (WMC) has grave concerns about the Securities and ExchangeCommission’s (SEC’s) October 4, 2023, proposed rule at Federal Register (FR) Volume 88, No.191, Pages 68811-68819 to amend the New York Stock Exchange (NYSE) Listed CompanyManual to adopt listing standards for Natural Asset Companies (NACs) hereinafter referred to as“the NAC Rule”. Establishing NACs on public and National Forest System lands1 is unlawfulbecause it conflicts with the Federal Land Management and Policy Act of 1976 (FLPMA), 43U.S.C. §§ 1701 et seq, which governs public lands; several statutes pertaining to the managementof National Forest System Lands;2 and the U.S. Mining Law, 30 U.S.C. §§ 21a et seq.Consequently, the NAC Rule must be revised to clearly state that a NAC cannot involve publiclands; it can only apply to private lands with a consenting landowner, or state-owned lands whereincluding state lands in a NAC would be consistent with the laws pertaining to specific state-ownedparcels…
