Date:    1/5/98  6:19 PM
Subject: s7-25-97

Jonathan G. Katz, Secretary
U.S. Securities and Exchange Commission 
450 Fifth Street, N.W.
Washington, DC 20549
     
Regarding: File No. s7-25-97
     
Dear Mr. Katz:
     
      I am writing in opposition to proposed changes in the rules governing
shareholder resolutions.  Those changes would make it much harder to sponsor 
shareholder proposals addressing environmental concerns, both by increasing 
the percentage of votes a resolution must win to be resubmitted, and by 
allowing companies to refuse to include a resolution on the proxy statement 
if, in management's sole judgment, a resolution's sponsors are motivated by a 
special interest, including, apparently, a special interest in the 
environment.
      From a purely financial standpoint, companies that improve environmental
performance tend to improve their stock performance as well.  If shareholders 
are not able to encourage companies to act as better environmental stewards, 
it is not clear who will.
      I urge you to withdraw the proposed rule changes.
     
Very truly yours,
     
Alan M. Silverblatt
ctps@aol.com
328 Glen Echo Road
Philadelphia, PA  19119-2560