Date:    11/18/97  11:59 AM

Subject: s7-26-97

Ladies and Gentlemen:
     
The American Society of Corporate Secretaries notified its members of 
bills HR 944 and HR 945 introduced by Representative Paul Gillmore.
     
Due to the timing of the notification, I was unable to comment in a 
timely manner.  However, the issues raised by these proposed bills 
warrant comment, whether timely or otherwise.
     
These proposals would be burdensome to all corporations.  The possible 
exemptions would not alleviate these burdens.  The extra effort and 
printing costs involved with reporting as proposed by HR 944 would most 
likely have the undesired effect of limiting charitable contributions 
for many companies.
     
There would be additional expense and efforts involved with shareholder 
approval as proposed by HR 945 in addition to those created by a 
reporting requirement.  This bill also steps into the area of giving 
shareholders management authority over the company's business decisions.
     
Passage of these bills could double proxy costs (due to additional 
printing costs, mailing costs, time and effort, etc.) while causing 
corporations to rethink whether charitable giving is worth the 
additional cost and aggravation of reporting and possibly asking for 
authority to give.
     
Sincerely,
     
Sherry Abbott
Corporate Secretary for
SEMCO Energy, Inc.
405 Water Street
Port Huron, MI  48060