From: S. Auchincloss [sauchincloss@earthlink.net]
Sent: Saturday, May 24, 2003 7:04 PM
To: rule-comments@SEC.gov
Subject: SEC File # 4-463

Dear Mr. Jonathan Katz,

	I am writing in support of the rulemaking petition (SEC File # 4-463) 
submitted by the Rose Foundation for Communities and the Environment.  The 
Sierra Club is both an investor and an environmental campaigning 
organization.  With better disclosure we could be better investors as well 
as better campaigners.  The Rose Foundation petition recommends the SEC 
adopt the requirement that companies report according to the standards 
developed by the American Society of Testing and Materials for evaluating 
and disclosing environmental liabilities.

	Every investor who breaths the air and drinks the water of the United 
States needs the Commission to take action requiring the reporting of 
financially material environmental liabilities.  These liabilities are 
under-reported by SEC registrants.  For example, in March 2001, the United 
States Environmental Protection Agency released a report that demonstrated 
that 74% of companies facing environmentally-related legal actions 
contemplated or initiated by a governmental agency seeking $100,000 or 
more, do not adequately disclose these liabilities to shareholders as 
mandated by SEC Regulation S-K, Item 303.  As if that were not bad enough, 
the same report showed that 96% of publicly traded companies facing 
Resource Conservation & Recovery Act (RCRA) corrective actions failed to 
accurately disclose these liabilities.

	Companies failing to report environmental liabilities often seek to 
justify their conduct by maintaining that such liabilities are difficult or 
impossible to quantify.  Many companies also currently hide environmental 
liabilities from investors by practicing piecemeal accounting - where each 
environmental liability is evaluated in isolation and deemed immaterial, 
even when the sum of all environmental liabilities is huge.

	The new environmental and reporting guidelines developed by the American 
Society for Testing and Materials would close these loopholes.  By 
incorporating these consensus-based, industry-generated standards, the 
Commission would enhance investor confidence by helping to ensure that 
material environmental liabilities are accurately and consistently reported.

	I urge the Commission to initiate rulemaking to define environmental 
materiality based on the ASTM guidelines as soon as possible, for our 
families and for our future.

	Sincerely,

	Stuart Auchincloss

Stuart Auchincloss, 367 Strawtown Road, New City, NY  10956
Tel. (845) 639-6972, Fax (845) 639-7032

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