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Re: Corporate Enviro Compliance Reporting and the SEC

Dear Richard and Chet,
It is true the SEC doesn't mandate corporate financial environmental
compliance reporting as GM reports to shareholders in their corporate
environmental health and safety report, however the SEC does mandate under
SEC Regulation S-K:

1.all environmental proceedings, including governmental proceedings, which
are material to the business or financial condition of the registrant;
2.damage actions, or governmental proceedings involving potential fines,
capital expenditures or other charges, in which the amount involved exceeds
10 percent of current assets;
3.governmental proceedings, unless the registrant reasonably believes such
proceedings will result in fines of less than $100,000.

And this SEC environmental financial reporting mandate is not enforced in
the US despite the complaints of the US EPA.
see: http://es.epa.gov/oeca/oppa/secguide.html

Europe has no environmental regulations that are come near the mandates of
the Clean Air Act,Cl ean Water Act, Resource Conservation and Recovery Act ,
Comprehensive Environmental Response Compensation and Liability Act,
Superfund Amendment and Reauthorization Act (SARA), Toxic Substance Control
Act, Atomic Energy Act, Occupational Safety and Health Act (OSHA), and
Hazardous Material Transportation Act.

Nor does Europe have a government securities enforcement body similar in
power to the SEC.

Europe may propose social/environmental accounting recommendations but they
are not mandating such issues and can not account for how they will be
enforced if at all.
Please see:
Europe Tightens Corporate Environmental Accounting Rules

In short there is a lot of smoke and mirrors action in the securities market
in both the US and Europe on corporate financial environmental accounting.

That said however the US environmental regulations are stricter then Europes
and more litigiously enforced which in my opinion sets a benchmark for
corporate environmental performance.

Which makes US corporations compling to US environmental regulations greener
than European and Asian firms.

Do you think GM's corporate financial environmental compliance matrix and
indices would be a good model for all US publicly traded corporations?

Donald Sutherland

----- Original Message -----
From: <sumpter.richard@epamail.epa.gov>
To: <donaldsutherland-iso14000@worldnet.att.net>
Cc: <p2tech@great-lakes.net>; <rp-cinet@igc.topica.com>
Sent: Monday, July 15, 2002 6:24 AM
Subject: Re: Corporate Enviro Compliance Reporting and the SEC

> I shared your note with an associate.  He writes -
> Dick,
>       Thanks for sharing the email.  Please reply to Don Sutherland that
> the only reason that GM reports any environmental information is because
> the EU and member countries require it as a condition of doing business
> in their countries.  The SEC requires no environmental reporting or
> social reporting (coming in the EU in 2007).  America's answer to the
> reporting requirements was the Global Reporting Indicators which we
> proposed to substitute for the EMAS requirements to the World Trade
> Association but has never been acted on as a substitute.  Consequently
> US firms operating in the EU can report or quit doing business there.
> No other US firms collect such data unless they are extremely
> conscientious.  Should the SEC require such reporting by all US
> companies?  Absolutely and have them do third party audits to assure the
> numbers are reasonable.  Does the SEC intend to require such reporting?
> Not under this administration.
> Chet

>                       Donald Sutherland
>                       <donaldsutherland-iso14000@worldn        To:
>                       et.att.net>                              cc:
>                                                                Subject:
Corporate Enviro Compliance Reporting and the
>                       07/11/02 09:16 AM                         SEC
>                       Please respond to
>                       donaldsutherland-iso14000
> As the US accounting scandals mushroom and reveals the vagarities in
> corporate revenue financial reporting it seems corporate financial
> reporting of waste stream permit performance is a clearer indicator of
> whether a company is abiding by SEC financial reporting requirements or
> hiding financial debt.
> Particularly if the federal government (US Environmental Protection
> Agency) is in a national campaign for publicly traded corporations to
> provide shareholders this information in their SEC financial filings to
> shareholders.
> See: http://es.epa.gov/oeca/oppa/secguide.html
> General Motors annually reports to shareholders corporate conformance
> with legal environmental requirements for wastestream permits and
> corporate environmental policies (including Carbon dioxide (C02)
> emission of greenhouse gases (GHG).
> In an easy to read matrix with legal environmental indicies GM gives
> shareholders a financially transparent easy to read corporate
> environmental performance to shareholders in the annual corporate
> environmental health and safety performance report.
> ie.Admininstrative and Judicial Matters
> Number of Resolved Matters.......total value of penalties/fines paid
> Clean Air Act (CAA)
> Clean Water Act (CWA)
> Resource Conservation and Recovery Act (RCRA)
> Comprehensive Environmental Response Compensation and Liability Act
> Superfund Amendment and Reauthorization Act (SARA)
> Toxic Substance Control Act
> Atomic Energy Act (AEA)
> Occupational Safety and Health Act (OSHA)
> Hazardous Material Transportation
> ie.Stationary Source C02 emissions
> Mobile Source CO2
> Total Greenhouse Gas Emissions in metric tons of CO2
> Is it fair to say if other publicly traded corporations aren't providing
> shareholders a financial transparency of the same legal environmental
> indicies as GM reports on to its shareholders it raises a red flag on
> their overall SEC financial debt/depreciation reporting to shareholders?
> Thank you for your consideration of my inquiry.
> Best Wishes,
> Donald Sutherland
> Member of the Society of Environmental Journalists
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