Date:    12/12/97 10:17 PM
     
     
To the SEC:
     
The current shareholder resolution process is one of the best mechanisms 
this country has for using market-based solutions to social and 
environmental problems. Your proposed regulations (S7-25-97) are about to 
destroy this invaluable tool.
     
Part of what makes our economy strong is our system of active shareholders 
engaged in debate with corporations over matters of mutual concern. Social 
and environmental issues are not just personal concerns for shareholders, 
they seriously affect a companys bottom line. 
     
ICF Kaiser released a study in January of 300 of the largest public 
companies in the United States, showing that when public companies improve 
their corporate environmental practices, they are able to increase 
shareholder wealth by over 5%. Corporate environmental improvements are not 
a measure of goodwill with costly negative impacts on a company, but make 
the company a more attractive investment to current and future 
stockholders.
     
History notes several examples of shareholder resolutions pushing 
management to act on issues, which, if mismanaged, would have seriously 
affected the companys reputation and profitability. Fair employment in 
Northern Ireland, China, sweat shops, tobacco, workplace discrimination, 
and violence in the media are a few examples.
     
The shareholder resolution process as it stands today is an important 
marketplace mechanism for promoting corporate accountability and corporate 
responsibility. It is reasonable, it is responsible, and it works. Please 
protect this process, and stop these rules from going forward.
     
Sincerely,
     
Steve Kirch
shareholder, investor