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Re: Corporate Enviro Compliance Reporting and the SEC

Please note I am responding to what I believe are serious
over-generalizations by Mr. Sutherland regarding environmental
regulation in Europe and Asia. I am not commenting on his financial
environmental reporting comments. 

I was an auditor for a Fortune 50 company in the mid-1990's and did
audits over much of Europe in that time. Then (pre-European Union [EU]),
environmental regulations and enforcement varied considerably from more
stringent than the US (Germany, Scandanavian countries) to almost Third
World levels (parts of Italy, Spain, and Portugal). Some European
countries were going well beyond the US, for example, in regulation of
PBT's (persistent, bio-accumulative,and toxic chemicals) and Extended
Producer Responsibility (you make it, you deal with it at the end of its
useful life).

I am not current on EU environmental regulation, but from a little
surfing, it seems they are moving from general principles and broad
generalities to more specific regulations like for diesel trucks and
cars ( http://www.europarl.eu.int/factsheets/default_en.htm ). In the
mean time, countries have maintained their own regulations and
enforcement, which as I said earlier, covers a pretty broad spectrum.
>From a recent cycling trip to France (it was Great!), I know that
enforcement of EU regulations is a big concern to many and that already
there are big backlogs of enforcement actions against countries who are
not implementing EU requirements.

While I didn't have personal experience in Asia, I think Japan was
pretty well regulated and things went down from there. Certainly,
Japanese, US, and European firms were all guilty of environmental abuses
throughout the rest of Asia. Some Asian countries were starting to
require new facilities to meet emission limits comparable to US
standards. Some had adopted US or European standards chapter and verse,
but enforcement was inconsistent.

Again, I think it is a serious over-generalization to say US firms
meeting US standards are greener than European or Asian firms.

I will agree that the US leads the world in litigious enforcement.
However, I am not sure that this sets as meaningful a benchmark for
environmental performance as Mr. Sutherland suggests. In European
countries, there is much more of a feeling "we are all in this together"
and government regulators and companies are able to reach agreements in
a more pragmatic and efficient way than in the US. I'm sure at times
this process has been abused by kick-backs and political pressure, etc.
(like in the US), but it still seemed pretty effective. Someone from
Europe or with more European experience would have more insight into
this process.

The one thing that was really different was level of public access and
transparency. In Germany, for example, one company in an industrial area
had created a serious groundwater plume. Our facility could only find
out about the groundwater under its own property and the whole picture
was only known by the government and the facility that started the
plume. In the US, pretty much all that information would be available to
the public. I think the level of public access to environmental
information in the US helps to prevent abuses and keep everyone honest.

I would hope that someone with more recent information or more in-depth
international experience could weigh in on this. I would also hope that
we in the US do not feel we can rest on our laurels while the rest of
the world catches up. We all have much work to do to reach sustainable
levels of resource, toxics, and energy use.

Kirk Mills
Pollution Prevention Program
Colorado Department of Public Health 
     and Environment
4300 Cherry Creek Drive So.
Denver, Co  80246-1530
Ph: (303) 692-2977
Fax: (303) 782-4969
Email: kirk.mills@state.co.us

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