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 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 co-generation, 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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