To:
Gregory Regaignon
Business & Human Rights Resource Centre
From
David M. Kiser, Ph.D.
Director, Health, Safety, Environment and Sustainability
Vice President, Eastman Kodak Company
Regarding:
Kodak in our Weekly Update - Invitation to respond
Thank you for the opportunity to respond to the ranking by the Political Economy Research Institute
(PERI). We appreciate that your organization makes the effort to provide a balanced view of these
important issues.
We believe the information relative to Kodak is misleading. First, the report used old data from 2005.
Since that time, Kodak has closed one of the two power plants that account for 95% of the impact cited in
the report.
Second, the PERI report is based on the U.S. Environmental Protection Agency (EPA) Risk Screening
Environmental Indicators (RSEI) model, which is a preliminary screening tool with a number of technical
limitations. The RSEI model assumes that all of the air emissions from our power plants are from process
stacks with a height of 15 meters. In fact, 95% of Kodak’s impact within PERI's analysis is from emissions
from power plant operations released at 110 meters. A more precise analysis would allow these
emissions to be treated just as RSEI factors emissions from utility company power plants – utilizing the
higher stack height.
The EPA has also identified some of these limitations (see www.epa.gov/opptintr/rsei/pubs/faqs.html) and
has participated in continuing discussions with us about clarifying the Kodak data.
For many years, Kodak has had public voluntary goals focused on continuing to reduce the environmental
impacts of our power plant operations. These facilities are extremely efficient in that they employ cogeneration, where both electricity and steam are utilized for productive purposes. This nearly doubles the
energy value from fuel as compared to power plants that produce only electricity. Furthermore, our
aggressive energy conservation programs have enabled a 36% reduction in energy usage since 2002
and a corresponding reduction in greenhouse gas emissions. This energy conservation progress has
allowed the shutdown of one of the two power plants at our major manufacturing site in Rochester, N.Y.,
as noted previously.
Kodak is proud of its record for social responsibility, including its commitment to the environment. Each
year, we provide a detailed annual report to the public. This year's report can be accessed on our website
through the environmental sitelet: kodak.com/go/hse . We invite you to review our environmental
performance data because we think it speaks to the strength of our record – a record that has been
recognized in a top ranking regarding sustainability initiatives by several leading independent
organizations. We thank you again for taking the time to contact us.
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