I was pleased to see a copy of your Comment on environmental auditing disclosure issues. As you are aware, we have been actively involved in analyzing and encouraging private-sector environmental auditing for several years. It's nice to see informed analysis on these auditing issues.

Your "self-evaluation privilege" section [13 ELR 10306] was of particular interest. It suggests how well suited the privilege could be to the evaluative process involved in environmental auditing. As you indicated, the elements required for a company to assert the privilege include: (1) an internal review process akin to a self-evaluation, (2) a strong public interest in environmental auditing, and (3) a likelihood that environmentally beneficial auditing would be curtailed unless the disclosure issue were satisfactorily resolved.