Friends of the Earth
1025 Vermont Ave., N.W., 3rd Floor
Washington, D.C.  20005
(202) 783-7400
     
12 April 1999
     
Jonathan G. Katz
Secretary
U.S. Securities and Exchange Commission 
450 Fifth Street, N.W., Stop 6-9
Washington, D.C. 20549.
Via email: rule-comments@sec.gov
     
Re: File S-7-399
     
Dear Mr. Katz:
     
Friends of the Earth is pleased to provide public comment on File S-7-399, 
proposed rule 
regarding amendments to Form 20-F.
     
Friends of the Earth is frequently asked by investors and financial analysts 
to provide 
information on environmental impact/ liabilities and political risk with 
respect to foreign 
companies, and domestic firms with overseas operations. Some ôtraditionalö 
investors 
and analysts seek this information because they recognize strong 
environmental 
performance as a proxy for risk reduction and quality corporate management. 
Other 
investors seek environmental information for ethical reasons, and commonly 
incorporate 
environmental and social criteria into their financial decision-making 
process.  As these 
ôsocially responsibleö investors seek to diversify their assets into 
international securities, 
they are faced with obstacles to research and analysis stemming from the lack 
of 
information on foreign companiesÆ environmental performance and liabilities. 
     
We are pleased to note the inclusion of environmental matters in 20-F 
disclosure 
requirements provided in Part One, Item Four-D, ôProperty, Plants and 
Equipment.ö This 
requirement asks the filer to ôdescribe any environmental issues that may 
affect the 
company's utilization of [material tangible fixed] assets.ö  This requirement 
reflects the 
costs and liabilities associated with environmental clean-up and compliance, 
and U.S. 
Generally Accepted Accounting Principles (GAAP) governing environmental 
issues. But 
as currently worded, it is unclear about whether the SEC requires information 
on certain 
environmental liabilities, such as responsibility for off-site remediation; 
and readers may 
question whether the term ôutilizationö includes activities such as the sale 
or disposal of a 
property.
     
Friends of the Earth encourages the SEC to provide more clarity to this 
disclosure 
requirement, a step which can easily be taken by referencing examples of the 
U.S. 
environmental GAAP (such as SEC Staff Accounting Bulletin 92 for 
environmental exit 
costs, for example). By integrating the environmental GAAP into Form 20-F, 
the 
Securities and Exchange Commission will help international companies prepare 
for and 
respond to the emerging and rapidly evolving field of environmental 
accounting.
     
Sincerely,
     
Michelle Chan-Fishel
International Policy Analyst
Friends of the Earth û U.S.