March 23, 2012
Lima, March 23th, 2012
Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-5546
Dear Secretary Murphy,
Our organisation appreciates the opportunity to provide comments to the Securities and Exchange Commission on the proposed rules regarding the Disclosure of Payments by Resource Extraction Issuers to implement Section 1504 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. We are a peruvian non-governmental organization that promotes soustainable development in Amazon Forests (Southamerica), to improve environmental managment and human rights in our region.
We believe that Section 1504 is a great opportunity for our country to obtain information to continue to combat corruption and demand accountability and transparency for our use of natural resources. Recently, Peru has been designated as member of EITI, however, all our countries could take a chance to improve our own legislation related, especially, to transparency on extractive industries if, for example, Section 1504 could be aproved in USA.
With greater transparency regarding payments in the extractives sector, we will be able to hold our government accountable and ensure that the natural resources benefit all citizens and not just a small elite. Our organisation is particularly concerned over the environmental impacts of exploration and extraction of natural resources, and feel that information on natural resource agreements will help us hold the government to account.
The purpose of this letter is to support the recommendations and comments on the proposed rules submitted to you by the Publish What You Pay coalition.
Specifically, we agree with Publish What You Pay that no exemptions should be provided, that the Commission should define project in relation to each lease, license and/or other concession level arrangement entered into by a resource extraction issuer, and that a reasonable minimum threshold for payments to be reported should be set.
Yours sincerely,
Cesar Gamboa
Policy Director
Derecho Ambiente y Recursos Naturales DAR