Under the proposed Securities & Exchange Commission rule, a Natural Asset Company (NAC) would be a corporation that holds the rights to the ecological performance of a specific area of land- the NAC would hold the rights to “the value of natural assets and production of ecosystem services” generated by a specific area of land. These rights would be licensed, much like water rights, mineral rights, etc. The NAC would have to license the rights from a private landowner or sovereign nation (the United States or a foreign government landowner).

UPDATE : Proposal removed as of 1/17/24

Background: The idea for NACs was developed by an activist eco-organization called the Intrinsic Exchange Group (IEG), funded in part by the Rockefeller Foundation, in partnership with the NYSE. NACs would pool investors’ money from around the world to buy the rights to public and private land in the United States and limit its use to “sustainable” endeavors.

Much of the land under federal control is intended for public use, which includes farming, ranching, hunting, fishing, drilling, mining, hiking, and camping, according to its designation by Congress. In many western states (including Idaho, Utah & Nevada), more than 60 percent of the land is government owned.

The NACs would require accounting and reporting systems regarding the assets they possess, which would be provided by IEG under license. The NYSE would acquire a stake in IEG as part of the agreement to establish NACs on the exchange. According to the NYSE filing, the intention of the NACs is to buy land management rights, including farming rights, mineral rights, water rights, and air rights.

It is possible that the proposed NYSE rule  intended to serve as the funding mechanism for the Bureau of Land Management’s (BLM’s) recent proposed rule, ‘Conservation and Landscape Health,’ which would authorize BLM to grant ‘conservation leases’ for public lands. A letter submitted by the Attorney Generals in 25 states (including Idaho) states “The BLM rule provides that ‘once the BLM has issued a conservation lease, the BLM shall not authorize any other uses of the leased lands that are inconsistent with the authorized conservation use.’

As part of the 3-legged stool, the plan to create NACs (1) coincides with efforts by the Biden administration to block access to public lands by farmers, ranchers, hunters, and most particularly, oil and mining companies as expressed in the ‘30×30 plan’ (2), (according to which 30 percent of the United States’ land and freshwater areas and 30 percent of U.S. ocean areas would be set aside for conservation by 2030), in addition to the BLM Conservation & Landscape Health ruling (3).

Why is this important to cattle producers in Idaho?

Over 60% of Idaho consists of public lands and continued grazing use of public lands is critical to the continued functioning of the livestock industry in Idaho and across the west.  Concurrently, livestock grazing provides many benefits to the landscape on which it is applied and to the surrounding communities.  Grazing plays a vital role in maintaining sustainable ecosystems on public lands.

Does ICA support this proposed action?

ICA does not have an official positition on this specific action, however, we are resolved to protecting grazing rights on Idaho’s public lands while promoting sustainable stewardship of our natural resources, as well as support the retention of grazing in National Recreation Areas. ICA membership is, in resolution, opposed to any programmatic removal of livestock grazing from public rangelands. Furthermore, ICA encourages due diligence by state and federal lawmakers to thoroughly and impartially consider state ownership or control of federal lands proposals before undertaking actions that could bring about negative unintended consequences to the ability of Idaho ranchers to graze livestock on these lands.

How do I take action?

You can participate by submitting individual comments through the US Securities and Exchange Commission federal register link here.

ICA has submitted comments and these can be viewed below for reference when crafting your individual comments.