This 1975 document from Imperial Oil Ltd, the Canadian subsidiary of Exxon, is a “Review of Environmental Protection Activities” undertaken by Imperial Oil Limited. This document is part of the ClimateFiles Imperial Oil document set, gleaned by DeSmog researchers from the Glenbow Imperial Oil Archive Collection.

The report demonstrates Imperial’s internal concern with the growing “vast bureaucracy” in environmental regulation, which “exists to deal with world environmental problems” and which the authors of this report perceive as “seemingly irresistibly growing in numbers and complexity.”

This document specifically mentions the efforts made by Exxon and API in the United States to combat some of this proposed regulation: “there is a growing tendancy [sic] and stated policy of Exxon, U.S.A to use the courts ‘whenever it is concluded that any regulatory body is mandating environmental requirements beyond the scope of legislative intent.’ Exxon was involved in at least seven such challenges of EPA authority, alone, with API, or in amicus curiae positions.” 

The report encourages Imperial to continue “working with government agencies to develop realistic and achievable regulations,” noting that “in general, industry associations have been reasonably effective in dealing with governments. Imperial’s input to these groups has brought the company favourable recognition. It would therefore seem advisable to make the maximum use of industry vehicles in our dealings with government on environmental matters wherever it is advisable to do so.”