A pair of letters approved by the Warren County School District board Monday night express opposition to a rule change allowing a new type of listing on the New York Stock Exchange and requesting further clarification.

The NYSE, in partnership with the Intrinsic Exchange Group, has developed a new type of company, called a natural asset company, that could have shares traded on the NYSE.

Such companies would be able to purchase land and resource rights, both public and private, with a chartered goal “to protect, restore, and grow the natural assets under their management to foster healthy ecosystems,” according to IEG’s website.

Under a rule before the U.S. Securities and Exchange Commission, companies would put a monetary value on “ecosystem services.” Examples of ecosystem services listed in the proposed rule include production of clean air and water, flood protection, climate stability and wildlife habitat. The rule would allow purchase of land and resource rights by NACs and provide them management rights, while requiring them to “conduct sustainable revenue-generating operations.”

“This proposal is complex and based on a novel, nontraditional investing mechanism that would seemingly allow for the buying and selling of certain undefined ‘rights’ to certain private and public lands, including to foreign nations and noncitizens, to terminate and prevent all economic activity on such properties,” the district says in a letter to SEC Chair Erik Gerding. “This proposed rule is not only complex but has far reaching implications for the future management and use of our public and private lands. The SEC, however, is seemingly trying to push it through quickly and discreetly, as showcased by the short comment period and the minimal public notice and engagement outside of the Federal Register.”

The letter goes on to request further information on what “unique listing requirements” an NAC would have to meet, whether the SEC would claim oversight of such entities, and what authority the SEC claimed to transfer management rights over federal lands.

“This proposal has the possibility to fundamentally change U.S. land access, management, use, and ownership as we know it, including by auctioning our most prized resources off to the highest foreign bidder, including to hostile regimes that clearly do not have our best interests at heart,” the letter states.

It requests the comment period for the rule be reopened for an additional 60 days and further information be provided.

In a separate letter to SEC Secretary Vanessa Countryman, the district expresses outright opposition to the rule change, citing concerns about the amount of public land within the bounds of the district and potential for serious revenue decreases.

“About one third of our land area is the Allegheny National Forest and state owned which means that our taxing capacity is limited. We rely on sustainable forestry and environmental stewardship to ensure the stability of our communities and ensure that we are able to educate our students,” the letter states. “Communities that host public lands are denied tax revenues those lands could generate if they were privately owned. In our region, the ANF occupies about 33 percent of Warren County. When forest management produces timber sales, at least 25 percent of those proceeds are distributed to the host communities in lieu of taxes. Because of the number of acres occupied by the ANF, if our schools and municipalities lost these revenues, they would have to drastically increase the tax burden on private property owners just to stay afloat and push our residents further into poverty.”

The letter also cites a Congressional Research Service report stating, “Federal agencies cannot delegate management of federal land to states or other outside entities unless there is express statutory authority to do so.”

The district is not alone in opposing the rule change. Counties, attorneys general and municipalities nationwide have expressed opposition in recent months, claiming the change would violate existing law and take control of resources and development – even in areas neighboring those controlled by NACs – out of the hands of local stakeholders.

Superintendent Amy Stewart developed the letters in conjunction with the Forest Area School District.