General Electric 012406

Company Name: General Electric Co.
Public Availability Date: January 24, 2006

Document Sections:

[INQUIRY LETTER]

December 9, 2005

VIA HAND DELIVERY

Office of the Chief Counsel
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re: Shareowner Proposal of the Sisters of St. Dominic of Caldwell New Jersey et al Securities Exchange Act of 1934 - Rule 14a-8

Dear Ladies and Gentlemen:

This letter is to inform you that it is the intention of our client, the General Electric Company ("GE"), to omit from its proxy statement and form of proxy for GE's 2006 Annual Meeting of Shareowners (collectively, the "2006 Proxy Materials") a shareowner proposal (the "Proposal") and statement in support thereof (the "Supporting Statement") received from the Sisters of St. Dominic of Caldwell, New Jersey (the "Proponent") and numerous co-filers. ¹ For your convenience, the Proposal and related correspondence are attached hereto as Exhibit A.

On behalf of our client, we hereby notify the staff of the Division of Corporation Finance (the "Staff") of GE's intention to exclude the Proposal from the 2006 Proxy Materials on the basis set forth below, and we respectfully request that the Staff concur in our view that the Proposal has already been substantially implemented and thus may be excluded under Rule 14a-8(i)(10).

THE PROPOSAL

The Proposal at issue is captioned "Disclosure of Costs of Delay of Cleanup of Toxic Sites," and requests that GE's Board of Directors (the "Board"):

"report by August 1, 2006, at reasonable cost and excluding confidential information, its annual expenditures by category and specific site (where applicable) for each year from 1990-2005, on attorney's fees, expert fees, lobbying, and public relations/media expenses, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites."

ANALYSIS

GE Has Already Substantially Implemented the Proposal and May Therefore Exclude the Proposal under Rule 14a-8(i)(10)

Rule 14a-8(i)(10) permits a company to exclude a shareowner proposal if the company has substantially implemented the proposal. The Commission stated in 1976 that the predecessor to Rule 14a-8(i)(10) "is designed to avoid the possibility of shareholders having to consider matters which already have been favorably acted upon by the management." See Release No. 34-12598 (July 7, 1976). The Commission has refined Rule 14a-8(i)(10) over the years. In the 1983 amendments to the proxy rules, the Commission indicated:

In the past, the staff has permitted the exclusion of proposals under Rule 14a-8(c)(10) only in those cases where the action requested by the proposal has been fully effected. The Commission proposed an interpretative change to permit the omission of proposals that have been "substantially implemented by the issuer." While the new interpretative position will add more subjectivity to the application of the provision, the Commission has determined the previous formalistic application of this provision defeated its purpose. Amendments to Rule 14a-8 Under the Securities Exchange Act of 1934 Relating to Proposals by Security Holders, Exchange Act Release No. 20091, at §II.E.6. (Aug. 16, 1983) (the "1983 Release").

The 1998 amendments to the proxy rules, which implemented the current Rule 14a-8(i)(10), reaffirmed this position. Amendments to Rules on Shareholder Proposals, Exchange Act Release No. 40018 at n.30 and accompanying text (May 21, 1998).

As noted in the 1983 Release, in order to be excludable under Rule 14a-8(i)(10), a shareowner proposal need only be "substantially implemented," not "fully effected." The Staff has stated "a determination that the company has substantially implemented the proposal depends upon whether [the company's] particular policies, practices and procedures compare favorably with the guidelines of the proposal." Texaco, Inc. (available March 28, 1991). See also, Nordstrom, Inc. (avail. Feb. 8, 1995) (concurring in the exclusion as moot a proposal that the company commit to a code of conduct for its overseas suppliers, as such a code was substantially covered by existing company guidelines); The Gap, Inc. (avail. Mar. 8, 1996) (concurring in the exclusion of a proposal that requested a company to report on its actions to ensure that foreign suppliers satisfied basic standards of conduct, as the proposal had been substantially implemented by the company's previously published report).

In this case, the Proposal requests that GE publish a report detailing "expenditures ... relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites." Moreover, the Proposal has a detailed description of how it requests this information to be presented. Specifically, the Proposal requests that the information be segregated by year, by site and by category "(where applicable)" and the proposal lists five separate categories of expenses: "attorney's fees, expert fees, lobbying, and public relations/media expenses ... as well as expenditures on actual remediation".

As described in more detail below, GE has substantially implemented the Proposal by publishing on its website detailed and itemized information about its PCB expenditures from 1990 to 2005 (the "PCB Report"). A copy of the PCB Report is available on GE's website at www.ge.com/pcbreport, and is also attached as Exhibit B.

It is important to note that three sites (Hudson River, Pittsfield, Massachusetts/Housatonic River and Rome, Georgia) comprise approximately 81% of GE's expenditures on PCB sites during the 1990-2005 period. For these three sites, we have reported seven categories of expenditures. These three sites are the only sites at which more than de minimis amount of expenditures have been made for press or government relations, so providing them for any other site would not be meaningful. In addition, there are four sites that each represent more than $10 million in PCB expenditures during the 1990-2005 period. For these sites, we have disclosed site investigation & remediation costs and legal costs separately; we have not disclosed any other costs as they would provide little additional informational benefit, particularly when considered against the unreasonable time and expense to produce them.

In addition, GE is involved in approximately 74 other sites where PCBs are present. At these other sites, PCBs are either one of a number of constituents of concern and/or GE is one of a number of potentially responsible parties. In the aggregate, these other sites constituted approximately $106 million in PCB-related expenditures, or less than 11% of GE's overall PCB-related expenditures during the 1990-2005 period. Specific expenditure information about each of these other sites would provide little additional benefit, particularly when considered against the unreasonable time and cost to produce them.

The table below illustrates that the PCB Report addresses each element of the Proposal. |[NCCDEF,20] |[UCA1] |[TDC4,MP2,QL,VU] |[TCC4,M'BB',QL,VU] |[TCC4,M'BB',QL,VU] |[TCC4,MP3,QL,VU] |[NCCHEAD] |[RN249,0,5D] |[DRR1,LC1-.4,249] |[DRR2,CG2,249] |[DRR3,CG3,249] |[DRR4,CG4,249] |[DRR5,RC4+.4,249] |[ST]|[LC10]|[BVR1,R2,R5]|[HRH249,R1,R5] |[ST]|[LC3]|[RS5]Information requested under the Proposal |[TN2,3]Responsive information from the PCB Report: |[ST]|[LC5]|[BVR1,R2,R5]|[HRH249,R1,R5] |[XT]|[LA3] |[ST]|[RS4]The Proposal requests information on expenditures `'by site (where applicable)'' |[TA]|[CP55D]|pi|9|[RS4] |[TN3,2]The PCB Report provides itemized information for seven different sites for the requested 1990-2005 period. Collectively, these sites accounted for approximately 89% of GE's PCB-related expenditures during the requested period. |[ST]|[LC5] |[TA]|[CP55D]|pi|9|[RS4] |[TN3,2]The PCB Report provides the aggregate expenditures during the 1990-2005 period for the approximately 74 other sites where PCBs are present. Collectively, these sites accounted for less than 11% of GE's PCB-related expenditures during the requested period. |[ST]|[LC5]|[BVR1,R2,R5]|[HRH249,R1,R5] |[ST]|[LC3]The Proposal requests information itemized in five categories, where applicable (specifically, `'on attorney's fees, expert fees, lobbying, and public relations/media expenses ... as well as expenditures on actual remediation'') |[TA]|[CP55D]|pi|9|[RS4] |[TN3,2]The PCB Report provides information on the three major sites itemized in seven categories: |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Site investigation and remediation (including costs incurred with respect to scientific and engineering professionals who are experts in their profession and technical personnel working under their direction on PCB remediation and the human health and environmental effects of PCBs); |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Scientific research at GE's Global Research Center and other scientific institutions on the chemical properties and toxicological effects of PCBs; |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Legal costs; |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Government relations, including costs reported under the Lobbying Disclosure Act of 1995; |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Press initiatives and Hudson River, Pittsfield-Housatonic and Rome, GA informational campaigns; |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Reimbursement of government costs; and |[ST]|[LC3] |[TA] |[TA]|pi|4 |[TA]Overhead (internal staff and related costs). |[ST]|[LC3] |[TA]|[CP55D]|pi|9|[RS4] |[TN3,2]The PCB Report provides information on expenditures for support for GE's positions on non-site specific PCB science, PCB legislation and regulation, and hazardous substance regulation which could affect PCB regulation. |[ST]|[LC3] |[TA]|[CP55D]|pi|9|[RS4] |[TN3,2]The PCB Report provides information on the four additional sites for which GE's expenditures for PCB-related work at each such site during the requested period exceeded $10 million. In the aggregate, these four sites accounted for approximately 9% of GE's PCB-related expenditures during the requested period. The PCB Report states with respect to these four sites that GE "provide[s] only site investigation & remediation costs and legal costs for each of these sites, as the other costs would provide little additional informational benefit, particularly when considered against the unreasonable amount of time and expense to produce them." |[ST]|[LC5]|[BVR1,R2,R5]|[HRH249,R1,R5] |[ST]|[LC3]The Proposal requests `'at reasonable cost ... annual expenditures ... for each year from 1990-2005'' |[TA]|[CP55D]|pi|9|[RS4] |[TN3,2]The PCB Report provides aggregate expenditures for the period from 1990-2005. |[ST]|[LC5]|[BVR1,R2,R5]|[HRH249,R1,R5] |[EV] |[ET]

It should be noted that the costs provided in the PCB Report are not audited. During the 15-year period covered by the Proposal, in some instances, data may not have been originally kept or reported in the categories requested. For these costs, GE has made its best estimates of amounts and allocation of costs in an attempt to provide the requested information and to fairly report its expenditures for the requested period.

We believe that the PCB Report substantially implements the Proposal because the information set forth in the PCB Report "compares favorably" with that requested in the Proposal. The itemized information included in the PCB Report regarding the seven sites where more than $10 million was expended during the 1990-2005 period represents more than 89% of GE's applicable expenditures during the time period requested. Moreover, GE has provided the total expenditures for the additional 74 sites where PCB costs are present. Although the PCB Report does not provide categorization of costs for all sites, it provides categorization at the sites where meaningful information is available. The PCB Report also provides costs for general scientific research and legislative and government relations support not directly attributable to a particular site. Thus, the Proponent has received the information requested, including the sites where essentially all of the costs in requested categories were expended. The Proposal itself indicates that the requested information is to be provided "at reasonable cost and excluding confidential information," and thus contemplates that the information furnished in response to the Proposal need not be comprehensive.

The Proposal also requests that the requested information be provided "for each year from 1990 - 2005," while the PCB Report sets forth the requested information on an aggregate basis for the years 1990 through 2005. We believe that this variation from the format requested under the Proposal does not alter the conclusion that the PCB Report "substantially implements" the Proposal, and that the information "compares favorably" with that requested under the Proposal. Our view is supported by the Staff's determinations in See Ford Motor Co. (avail. Mar. 7, 2005); General Motors Corp. (avail. Mar. 30, 2005); Ford Motor Co. (avail. Mar. 2, 2004). In those letters, the Staff concurred that, when the company already had issued a report addressing the topic of a proposal, and the proposal called for extensive additional detail, the proposal could be excluded under Rule 14a-8(i)(7), on the grounds that the proposal related to the company's ordinary business operations (i.e., "the specific method of preparation and the specific information to be included in a highly detailed report"). Although the level of detailed information requested in the Ford and General Motors proposals was much more extensive than that requested under the Proposal here, we nonetheless believe that the principle is equally applicable in this context. The goal of Rule 14a-8(i)(10) is, as stated by the Commission in 1976, "to avoid the possibility of shareholders having to consider matters which have already been favorably acted upon by the management." If proponents could avoid that goal by requesting additional detail in contexts where management has already acted affirmatively to respond to a proposal, the goal of Rule 14a-8(i)(10) would be eviscerated.

While the Proposal asks for annual information for the years 1990 through 2005, neither the Proposal nor the Supporting Statement explain why annual information is of significance. The Supporting Statement states only "It is long overdue that our company discloses to shareholders the actual costs of its long term resistance to the remediation of this and other toxic sites." Thus, the Proposal does not articulate any compelling rationale for requesting annual data and in fact emphasizes only a long-term focus. We believe the PCB Report therefore compares favorably with the information requested by the Proposal, consistent with prior no-action positions of the Staff. For example, in The Gap (March 16, 2001), the Staff concurred in the exclusion of a proposal that requested a report on child labor practices as substantially implemented even though the company's report did not provide all the information sought by the proposal. See also, e.g., H.J. Heinz Company (June 19, 1997) (concurring that a proposal had already been substantially implemented despite the proponent's letter detailing a number of differences between the company's existing corporate governance guidelines and the information requested in the proposal).

For the foregoing reasons, we believe that GE has substantially implemented the Proposal and therefore may exclude the Proposal from the 2006 Proxy Materials pursuant to Rule 14a-8(i)(10).

* * *

Based upon the foregoing analysis, we respectfully request that the Staff concur that it will take no action if GE excludes the Proposal from its 2006 Proxy Materials. Pursuant to Rule 14a-8(j), enclosed herewith are six copies of this letter and its attachments. Pursuant to Rule 14a-8(j), this letter is being filed with the Securities and Exchange Commission (the "Commission") no later than 80 calendar days before GE files its definitive 2006 Proxy Materials with the Commission. On behalf of GE, we hereby agree to promptly forward to the Proponent any Staff response to this no-action request that the Staff transmits by facsimile to us only.

Consistent with the provisions of Rule 14a-8(j), we are concurrently providing copies of this correspondence to the Proponent. We recognize that the Staff has not interpreted Rule 14a-8 to require proponents to provide GE and its counsel a copy of any correspondence that is submitted to the Staff by or on behalf of proponents. Therefore, in the interest of a fair and balanced process, we request that the Staff notify the undersigned if it receives any correspondence on the Proposal from the Proponent or other persons, unless that correspondence has specifically confirmed to the Staff that GE or its undersigned counsel have timely been provided with a copy of the correspondence. If we can provide additional correspondence to address any questions that the Staff may have with respect to this noaction request, please do not hesitate to call me at (202) 955-8671 or Thomas J. Kim, GE's Corporate and Securities Counsel, at (203) 373-2663.

Very truly yours,

/s/

Ronald O. Mueller

Enclosures

cc: Thomas J. Kim, General Electric Company

Sr. Patricia A. Daly, OP, Sisters of St. Dominic of Caldwell New Jersey

-----FOOTNOTES-----

¹ Co-filers of the Proposal include the Sisters of the Humility of Mary of Villa Maria, Pa., The American Baptist Home Mission Society of The American Baptist Churches, USA, The Sisters of Saint Ursula, The Sisters of Charity of the Blessed Virgin Mary, Clean Yield Asset Management, The Sisters of Charity of Cincinnati, The Sisters of Mercy of the St. Louis Regional Community, Inc., The Dominican Sisters of Hope, Mercy Investment Program, The Sisters of Mercy Regional Community of Detroit, The Ursuline Sisters of Tildonk, The Amityville Dominican Sisters, The Congregation of the Sisters of Saint Joseph, Philadelphia, The Catholic Foreign Mission Society of America, Inc., the Nuns of the Third Order of St. Dominic, The Sisters of the Sorrowful Mother, Green Century Capital Management, The Sisters of St. Joseph of Carondelet, The Sisters of Charity of Saint Vincent de Paul of New York, The Maryknoll Sisters of St. Dominic, The Domincan Sisters, St. Mary of the Springs, Columbus, OH, The Sisters of St. Joseph of La Grange, The Brothers of Holy Cross, Eastern Province, The Ursuline Provincialate, Eastern Province U.S. and The Dominican Congregation of Our Lady of the Rosary.

[INQUIRY LETTER]

October 31, 2005

By Federal Express

Sisters of St. Dominic of Caldwell New Jersey
Attention: Sr. Patricia A. Daly, OP
52 Old Swartswood Station Road
Newton, NJ 07860-5103

Re: Shareowner Proposal on Disclosure of Hudson River Cleanup Costs

Dear Ms. Daly:

We received the Sisters of St. Dominic. of Caldwell New Jersey's shareowner proposal relating to disclosure of Hudson River cleanup costs on October 27, 2005.

Rule 14a-8(b) under the Securities Exchange Act of 1934, as amended, states that a shareholder must submit sufficient proof that the shareholder has continuously held at least $2,000 in market value, or 1%, of the company's common stock for at least one year as of the date the shareholder submitted the proposal. We are sending you this letter to notify you that we have not received your required proof of ownership.

You must satisfy this requirement. Under Securities and Exchange Commission interpretations, sufficient proof of ownership may be in the form of:

a written statement from the "record" holder of your shares (usually your broker or a bank) verifying that, at the time you submitted this proposal, you continuously held the shares for at least one year; or

if you have filed a Schedule 13D, Schedule 13G, Form 3, Form 4 or Form 5, or amendments to those documents or updated forms, reflecting your ownership of the shares as of or before the date on which the one-year eligibility period begins, a copy of the schedule and/or form, and any subsequent amendments reporting a change in your ownership level, and your written statement that you continuously held the required number of shares for the one-year period.

Under the SEC's rules, your response to this letter must be postmarked, or transmitted electronically, no later than 14 days from the date you receive this letter. You can send me your response to the address or fax number as provided above.

For your information, I enclose a copy of Rule 14a-8.

I am sending this letter to you on October 31, 2005 by Federal Express.

Thank you.

Very truly yours,

/s/

Thomas J. Kim

Enclosure

[INQUIRY LETTER]

October 26, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Dominicans of Caldwell continue to be concerned at the lack of transparency regarding the efforts that have been exerted in avoiding the responsibility for cleaning up the Hudson River and other toxic sites. Recent announcements that 10% of the clean-up will proceed, and then research will follow, appears to us as an additional, unnecessary, and lengthy delay. Our company's continued legal challenge to Super Fund is also a serious issue for us.

The Community of the Sisters of St. Dominic of Caldwell, NJ is the beneficial owner of three hundred seventy-eight (378) shares of General Electric common stock, which we intend to hold at least until after the next annual meeting. Verification of ownership follows under separate cover.

I am hereby authorized to notify you of our intention to file the attached proposal asking the GE Board of Directors to report on the costs of the delay of clean-up of the Hudson River, for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the proxy statement in accordance with rule 14-a-8 of the general rules and regulations of The Securities and Exchange Act of 1934.

We are happy to anticipate an upcoming meeting with executives at General Electric to discuss the status of the clean-up and the requests of this proposal.

While there will be other shareholders submitting this resolution, I will continue to serve as the primary contact for these concerns.

Sincerely,

/s/

Sr. Patricia A. Daly, OP
Corporate Responsibility Representative

[APPENDIX]
DISCLOSURE OF COSTS OF DELAY OF CLEANUP OF TOXIC SITES

WHEREAS:

General Electric disposed of at least 1.3 million pounds of PCBs (polychlorinated biphenyls) into the Hudson River. GE plants in Fort Edward and Hudson Falls, NY are heavily contaminated with PCBs. The Environmental Protection Agency designated 200 miles of the Hudson River as a Superfund site in 1984. The plant sites are New York State Superfund sites. In February 1976, a state Department of Conservation Hearing Officer, in a case against GE, described GE's actions as "corporate abuse" and found that the record "overwhelmingly" demonstrated that GE violated NY State law by discharging large quantities of PCBs into the Hudson River.

The federal government regulates PCBs as a known animal carcinogen and probable human carcinogen. Additional independent evidence indicates that PCBs may affect the immune and reproductive systems, cause endocrine disruption and have neurological effects.

PCB concentrations in Upper Hudson fish, sediment and water continue to exceed federal and state guidelines, creating unacceptable health and environmental risks.

GE has historically engaged in extensive public relations efforts, suggesting that "there is no credible evidence that PCBs in the Hudson River pose a risk to people or wildlife."

GE pursues its lawsuit challenging the constitutionality of key provisions of Superfund, placing implementation of EPA's decision and the remediation of other Superfund sites in jeopardy. Through a North Carolina Congressman, GE successfully attached report language to the USEPA funding bill, calling upon the agency to work with the National Academy of Science to conduct yet another study of PCB-contaminated sites.

EPA's cleanup of the Hudson River was to begin in 2005. The EPA has announced two-one year delays, with the cleanup now put off until Spring 2007. GE has only agreed to implement 10% percent of EPA's remedy, as public health and the environmental threats persist. GE may opt out of completing the other 90% of this cleanup. GE's design of the remedy shows a number of inconsistencies with the EPA plan to clean up the River. GE plant sites continue to leak PCBs into the Hudson River and surrounding communities. GE still has not compensated the people of New York for damages to natural resources caused by its PCBs.

RESOLVED: Shareholders request the Board of Directors to report by August 1, 2006, at reasonable cost and excluding confidential information, its annual expenditures by category and specific site (where applicable) for each year from 1990-2005, on attorney's fees, expert fees, lobbying, and public relations/media expenses, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites.

STATEMENT OF SUPPORT

This resolution has been sponsored by dozens of religious, public and private pension funds and received 27.47% of the vote last year. It is long overdue that our company discloses to shareholders the actual costs of its long term resistance to the remediation of this and other toxic sites. Shareholders have the right to this transparency.

[INQUIRY LETTER]

November 4, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Inunelt:

We, The Sisters of the Humility of Mary of Villa Maria, PA. are the beneficial owner of General Electric Stock which we intend to hold at least until after the next annual meeting. Verification of ownership will be forthcoming from our Financial Officer, Ms. Cathy Weiss of Villa Maria, PA 16155.

The Sisters of the Humility of Mary of Villa Maria, Pa. continue to be concerned about the lack of responsibility for clearing up the Hudson River and other toxic sites. Continual delay of plans to clean up the Hudson troubles us. It is also my understanding that our company continues to hold up a payment of $ 20 million to the EPA. Our company's legal challenge to Super Fund is also a serious issue for us.

We are joining with other religious investors in submitting the enclosed proposal, in accord with the Rule 14-a-8 of the General Rules and Regulations of the Securities Act of 1934, for inclusion in your proxy statement and for the consideration of the shareholders at the annual meeting. In this proposal we are asking the General Electric Board of Directors to report on the costs of the delay of clean up of the Hudson River, for consideration and action by the stockholders at the next annual meeting.

The primary filer of this proposal is the Sisters of St. Dominic of Caldwell, New Jersey, represented by Sister Pat Daly, O.P. Please address correspondence to them with a copy to me at the Fairlawn, Ohio address. We have authorized the primary filer to act on our behalf. We would appreciate your indicating in the proxy statement that we are a cosponsor of this resolution.

We look to you for increased responsibility and leadership in the critical environmental issue.

Sincerely yours,

/s/

Sister Dolores Bourquin, H. M.
Sisters of the Humility of Mary
2881 Morewood Road, #103
Fairlawn, Ohio 44333

Sister Pat Daly, O. P.
Sisters of St. Dominic
52 Old Swartswood Station Road
Newton, N.J. 07860-5103

[INQUIRY LETTER]

November 3, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

For decades, The American Baptist Home Mission Society of The American Baptist Churches, USA has played a leading role in encouraging corporations to transform their policies and actions to be environmentally responsible. We are concerned about the continued toxicity of the Hudson River and other sites of contamination. The delay of plans to clean up the Hudson troubles us. I understand that our company is holding up a payment of $20 million to the EPA and continues to challenge the legality of Super Fund.

The American Baptist Home Mission Society of The American Baptist Churches, USA are the beneficial owners of 78 shares of General Electric common stock, which we intend to hold at least until after the next annual meeting. Verification of ownership is attached.

Sister Patricia A. Daly will serve as our representative for these concerns.

Sincerely,

/s/

Dr. Margaret Ann Cowden
Treasurer & Chief Financial Officer

MAC/ttd

Enclosures

[INQUIRY LETTER]

October 31, 2005

Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt,

The Sisters of Saint Ursula are owners of 600 shares of General Electric common stock. We live and work in the Mid-Hudson Valley and are very concerned about the delay in cleaning-up the PCB's in the Hudson River Ecosystem.

Our company has spent too much time and money to delay the clean up efforts. While plans to clean up the Hudson River are under way, it is long over due that our company discloses to shareholders the actual costs of its long-term resistance to the remediation of this and other toxic sites. Shareholders have the right to this transparency.

GE has only agreed to implement 10% of EPA's remedy, as public health and the environmental threats persist. GE may opt out of completing the other 90% of this cleanup. GE's design of the remedy shows a number of inconsistencies with the EPA plan to clean up the River.

Through this letter we are now notifying the company of our sponsorship of the enclosed resolution and present it for inclusion in the proxy statement for a vote at the next stockholders meeting in accordance with rule 14-a-8 of the General Rules and Reulations of the Securities Exchange Act of 1934. We are filing this resolution along with other concerned investors.

The primary filer is Pat Daly and the Sisters of St. Dominic of Caldwell, NJ. All correspondence and communications should be directed to the Tri-State CRI office. (52 Old Swartswood Station Road, Newton, New Jersey 07860-9337)

Proof of ownership of shares of common stock in our company for at least the last twelve months is enclosed. It is our intent to maintain ownership of these shares through the date of the annual meeting. There will be a representative present at the stockholders meeting to present this resolution.

It is our tradition, as religious investors, to seek dialogue with General Electric to discuss the "sustainability" issues involved. We hope to work together constructively we hope that such a dialogue is of interest to you.

Sincerely,

/s/

Kathleen A. Donnelly, SU
Social Justice Coordinator

[INQUIRY LETTER]

November 1, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

I am writing to you on behalf of the sisters of Charity of the Blessed Virgin Mary. We are the owners of General Electric common stock and intend to hold the stock at least through the date of General Electric's 2006 Annual Meeting. Verification is enclosed.

For several years we have been in contact with you regarding our concerns about our company's responsibility and expenditures related to the health and environmental consequences of PCB exposures in the Hudson River and surrounding communities. We are filing the enclosed resolution requesting the Board of Directors to report to shareholders the actual costs of resistance to the remediation of this and other toxic sites.

I am hereby authorized to notify you of our intention to submit this shareholder proposal along with Patricia A. Daly, Executive Director, Tri-State Coalition for Responsible Investment, 52 Old Swartswood Station Road, Newton, NJ 07860-5103. I submit it for inclusion in the proxy statement for consideration and action by the shareholders at the 2006 annual meeting in accordance with Rule 14-1 8 of the General Rules and Regulations of the Securities and Exchange Act of 1934. Please send any materials for the filers of the resolution to all filers and to Pat Daly as the contact person. Please address any correspondence regarding the Sisters of Charity, BVM to me at the address below.

Sincerely,

/s/

Sister Gwen Farry, BVM (for) Sisters of Charity, BVM
205 W. Monroe 2-W
Chicago, IL 60606-5062
e-mail: farry@claret.org
Fax: 312-641-1250

[INQUIRY LETTER]

November 2, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828

Re: Shareholder Resolution, Disclosure of Costs of Delay of Cleanup of Toxic Wastes

Dear Mr Immelt:

Clean Yield Asset Management is a money management firm serving social and environmental investors. Our clients and we are deeply concerned about the costs to GEfinancial and reputationalof delays in cleaning up toxic sites.

With this letter, we are presenting a shareholder resolution, Disclosure of Costs of Delay of Cleanup of Toxic Wastes. The resolution is offered on behalf of an individual who is beneficial owner of 30,704 shares of General Electric Corporation common stock, an ownership position held since 1991. (A letter of authorization to file and a certification of beneficial ownership are available upon request.) Additionally, the individual has instructed Clean Yield, as manager of the account holding these shares, to retain an ownership position in GE well in excess of the $2,000 SEC requirement for introducing resolutions, through GE's Annual Meeting in 2006.

As you may be aware, this identical resolution is being proposed by a number of GE shareowners. The Lead Contact for this resolution is Sr. Patricia Daly, OP, of the Sisters of St. Dominic of Caldwell, NJ. We request that all communication related to this filing be directed through Sister Daly at: 52 Old Swartswood Station Road

Newton, NJ 07860-5103
973 579-1732(v) 973 579-9919 (f)

Thank you for your consideration.

Sincerely,

/s/

Rian Fried, President

cc: Leslie Lowe, ICCR; Sr. Pat Daly; Beneficial shareowner

enc: Shareowner proxy proposal

[INQUIRY LETTER]

November 1, 2005

BY CERTIFIED MAIL

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06431-0001

Dear Mr. Immelt:

It seems we have been coming to General Electric with a concern about the delay that the company has caused for the cleanup of PCB toxics in the Hudson River for many years. This cleanup operation should have begun years ago. The damage caused to the River's natural resources and to the people of New York needs to be compensated.

Because of our concern and that fact that the company has not yet begun cleanup of the Hudson River, we join with other religious congregations in filing the enclosed shareholder resolution. The primary filer of this resolution is the Caldwell Dominicans. We submit it for inclusion in the proxy statement under Rule 14a-8 of the general rules and regulations of the Securities Exchange Act of 1934.

The Sisters of Charity of Cincinnati are the beneficial owners of 6,000 shares of General Electric Co. and have held this stock for more than one year. Verification of ownership is enclosed. We will continue to hold the necessary number of shares in the company through the shareholder meeting.

We hope that our company will continue to dialogue with shareholders regarding the delays in the cleanup of this and other toxic sites. While the cost of these delays is a concern to us, the failure to make the cleanup happen is even more problematic. The environmental damage to this important waterway is very disconcerting.

Sincerely,

/s/

Mr. Timothy Moller

Chief Financial Officer

/s/
S. Ruth Kuhn, SC
Chair - SC Corporate Responsibility Committee

Enclosures

Copies: Pat Daly, OP; Julie Wokaty (ICCR); SC CRC; Region VI CRI
5900 Delhi Road
Mount St. Joseph, Ohio 45051
(513) 347-5300
www.srcharitycinti.org

[INQUIRY LETTER]

October 26, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT, 06828-0001

Dear Mr. Immelt:

The Sisters of Mercy are very concerned about the pollution in the rivers that comes from the use of PCB's and the clean up time. We are therefore filing the enclosed resolution.

The Sisters of Mercy are beneficial owners of 100 shares of General Electric Common stock since 1987. Verification of ownership is enclosed. We intend to retain at least 100 shares of General Electric through the date of the 2006 annual meeting.

I am hereby authorized to notify you of our intention to jointly file this shareholder proposal with the Sisters of St. Dominic of Caldwell, New Jersey. I trust that it will be considered for action by the shareholders at the 2006 annual meeting. I hereby submit the resolution for inclusion in the proxy statement in accordance with Rule 14-a-8 of the general rules and regulations of the Securities and Exchange Act of 1934.

Please note that if you wish to discuss this proposal, please contact Patricia Daly, OP whom we are designating as our contact person on this issue. Her address is 52 Old Swartswood Station Road, Newton, NJ 07860-5103. Her email is tricri@mindspring.com.

If you should for any reason desire to oppose this please be kind enough to include it in the corporation's proxy material and the filed statement as required by aforesaid mentioned rules and regulations.

Please contact me at the above address if you require additional information.

Sincerely,

/s/

Sister Katherine Marie Glosenger, RSM
Treasurer

SKMG/jr

Enclosure

cc: Julie Wokaty, ICCR
Susan Jordan, SSND
Patricia Daly, OP
David Schilling, ICCR

[INQUIRY LETTER]

October 29, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

On behalf of the Dominican Sisters of Hope, I am authorized to notify you of our intention to present the attached proposal asking a report on annual expenditures by certain categories and specific site (where applicable) for each year from 1990-2005, on attorney's fees, expert fees, lobbying, and public relations/media expenses, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites, for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the 2006 proxy statement in accordance with Rule 14a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934.

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

For many years, the Dominican Sisters of Hope have addressed environmental stewardship within their congregation and among their missions. We continue to join in this action to encourage corporations to act responsibly toward the environment.

The Dominican Sisters of Hope is the beneficial owner of 75 shares of General Electric stock. Verification of ownership follows. We plan to hold the stock at least until the time of the annual meeting and will be present in person or by proxy at that meeting.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Consultant, Corporate Responsibility
205 Avenue C, Apt 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@jno.com

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, Chair and CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

On behalf of the Mercy Investment Program, I am authorized to notify you of our intention to present the attached proposal asking a report on annual expenditures by certain categories and specific site (where applicable) for each year from 1990-2005, on attorney's fees, expert fees, lobbying, and public relations/media expenses, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites, for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the 2006 proxy statement in accordance with Rule 14a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934.

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

Mercy Investment Program has addressed environmental stewardship within its member institutions and among their missions. We continue with this action to encourage corporations to act responsibly toward the environment.

Mercy Investment Program is the beneficial owner of 200 shares of General Electric stock. Verification of ownership follows. We plan to hold the stock at least until the time of the annual meeting and will be present in person or by proxy at that meeting.

Yours truly,

/s/

Valerie Heinonen, o.s.u.

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-001

Dear Mr. Immelt:

On behalf of the Sisters of Mercy Regional Community of Detroit Charitable Trust, I am authorized to notify you of our intention to present the attached proposal asking a report on annual expenditures by certain categories and specific site (where applicable) for each year from 1990-2005, on attorney's fees, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites, for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the 2006 proxy statement in accordance with Rule 14a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934.

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

We join with the many religious communities with headquarters in New York State, particularly those along the Hudson, in an effort to encourage our Company to take responsibility and clean up the environment it polluted.

The Sisters of Mercy Regional Community of Detroit Charitable Trust is the beneficial owner of 14,750 shares of General Electric stock. Verification of ownership follows. We plan to hold stock at least until the time of the annual meeting and will be present in person or by proxy at that meeting.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Corporate Responsibility Consultant
205 Avenue C, Apt 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@juno.com

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

On behalf of the Ursuline Sisters of Tildonk, United States Province, I am authorized to notify you of our intention to present the attached proposal asking a report on annual expenditures by certain categories and specific site (where applicable) for each year from 1990-2005, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites. for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the 2006 proxy statement in accordance with Rule 14a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934.

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

The Ursuline Sisters of Tildonk, United States Province, are the beneficial owners of 4,000 shares of General Electric. Verification of ownership follows. We plan to hold the stock at least until the time of the annual meeting and will be present in person or by proxy at that meeting.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Consultant, Corporate Responsibility
205 Avenue C, Apt. 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@juno.com

[INQUIRY LETTER]

October 27, 2005

Jeffrey R. Immelt,CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06431

Dear Jeffrey R. Immelt:

The Sisters of the Order of St. Dominic looks for social, as well as financial, accountability in its investments. The Sisters of the Order of St. Dominic, Inc. is a religious organization that is interested in the well being of all people and the environment in which they live. We intend to take an active role in assuring that our finances are used towards those ends.

The Amityville Dominican Sisters are the beneficial owners of 3,000 shares of common stock which we intend to hold until after the annual meeting. Verification of ownership is attached.

I am hereby authorized to notify you of our intention to present the attached proposal regarding the request for disclosure of costs of delay of cleanup of PCB's for consideration and action by the stockholders at the next annual meeting, and I hereby submit it for inclusion in the proxy statement in accordance with the rule 14-a-8 of the general rules and regulations of the Securities Exchange Act of 1934.

Patricia Daly, Community of the Sisters of St. Dominic of Caldwell,NJ will be the contact person for this resolution. We look forward to discussing the issues surrounding the Hudson River at your earliest convenience.

Sincerely,

/s/

Linda Hincken, CFO

[INQUIRY LETTER]

October 26, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Re: Shareholder Proposal for 2006 Annual Meeting

Dear Mr. Immelt:

As a faith-based investor, the Congregation of the Sisters of Saint Joseph, Philadelphia, is concerned about the environment. The particular concern we have is the history of our company's discharge of more than one million pounds of PCBs (polychlorinated biphenyls) into the Hudson River and the environmental risks caused by the ongoing delay in cleanup of the river. Therefore, we are co-filing the Disclosure of Costs of Delay of Cleanup of Toxic Sites resolution with the primary filer, Sisters of Saint Dominic of Caldwell, NJ represented by Patricia Daly, OP.

This resolution is for consideration and action by the shareholders at the next meeting and I hereby submit it for inclusion in the proxy statement in accordance with Rule 14 a - 8 of the general rules and regulations of the Security and Exchange Act of 1934.

The Sisters of St. Joseph are beneficial owners of more than $2,000 of common stock in General Electric Company, which we have held for several years. Verification of our holdings is enclosed. We will continue to hold these shares at least through the company's annual meeting.

We believe the points made in the shareholder resolution are vital for the company to address. We would welcome dialogue with our company on this important issue.

Thank you for your attention to this matter.

Sincerely,

/s/

Sister Patricia Kelly, SSJ
President
The Corporation of the Convent of the Sisters of Saint Joseph, Chestnut Hill, Philadelphia

Enclosures: Resolution

Proof of Ownership

cc: Pat Daly, OP

ICCR

[INQUIRY LETTER]

October 31, 2005

Mr. Jeffrey R. Immelt
Chairman and CEO
General Electric
135 Easton Turnpike
Fairfield, CT 06431

Dear Mr. Immelt,

The Maryknoll Fathers and Brothers, whose legal title is the Catholic Foreign Mission Society of America, Inc. are the beneficial owners of 90 shares of General Electric common stock and will maintain the required number of shares through the scheduled shareholders' meeting in accordance with SEC standards. Verification of ownership is attached.

One reads with horror and shame about the constant and repetitious call for studies upon studies of the effects of the PCB pollution in the Hudson by General Electric. This is a family name, a name so treasured in my growing up, an organization that supplied so many of my needs both at home and during my 20 years in the military. To note that it refuses to accept its responsibility in fully cleaning up after itself in the Hudson betrays that family name. Additionally, legal resistance fighting the call to clean up the Hudson has cost our company millions of dollars.

We, therefore, request the Board of Directors to report by August 1, 2006, at reasonable cost and excluding confidential information, its annual expenditures by category and specific site (where applicable) for each year from 1990-2005, on attorney's fees, expert fees, lobbying, and public relations/media expenses, relating in any way to the health and environmental consequences of PCB exposures, GE's remediation of sites contaminated by PCBs, and/or hazardous substance laws and regulations, as well as expenditures on actual remediation of PCB contaminated sites.

In asking for this, I am authorized to notify you of our intention to present the attached proposal regarding disclosure of costs of delay of cleanup of toxic sites for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the proxy statement in accordance with rule 14-a-8 of the general rules and regulations of the Securities Exchange Act of 1934. We would appreciate your indicating in the proxy statement that we are sponsoring this resolution. A representative of the filers will attend the stockholders' meeting to move the resolution as required by the SEC Rules.

It is our tradition, as religious investors, to seek dialogue with companies to discuss the issues involved with the hope that the resolution might not be necessary. We trust that a dialogue of this sort is of interest to you as well. Sr. Patricia Daly, OP of the Sisters of St. Dominic of Caldwell, NJ will be the contact person for this resolution, [973] 579 1732.

Sincerely,

/s/

Rev. Joseph P. La Mar, M.M.
Assistant CFO

CC: Sr. Pat Daly

[INQUIRY LETTER]

November 1, 2005

Mr. Jeffrey R. Immelt
Chief Executive Officer
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Dominican Sisters of Great Bend, KS (Legal title: Nuns of the Third Order of St. Dominic) is a religious order of women seeking to reflect its values, principles and mission in its investment decisions.

As a concerned investor we evaluate a company on its social, environmental and financial performance. We are very troubled by our company's failure to disclose to shareholders the costs of its long-term resistance to the remediation of sites contaminated by PCBs.

The Nuns of the Third Order of St. Dominic is the beneficial owner of 100 shares of General Electric common stock. Through this letter I notify you of our co- sponsorship of the enclosed resolution with the Sisters of St. Dominican of Caldwell, NJ, and other concerned investors. We present it for inclusion in the proxy statement for action at the next stockholder meeting in accordance with Rule 14, A-8 of the General Rules and Regulations of the Securities and Exchange Act of 1934. In addition, we request that we be listed as a co-sponsor of this resolution with the Sisters of St. Dominican of Caldwell, NJ, in the company proxy statement.

Proof of ownership of common stock in the company is enclosed. We have held the requisite amount of stock for over a year and intend to maintain ownership through the date of the annual meeting. Patricia A Daly, OP, representing the Sisters of St. Dominican of Caldwell, NJ, will serve as primary contact for the co-sponsors.

Sincerely,

/s/

Sister Judith Lindell, OP
Dominican Sisters of Great Bend, KS

cc: Patricia A Daly, OP

Leslie Lowe - ICCR

Julie Wokaty - ICCR

[INQUIRY LETTER]

October 26, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Sisters of the Sorrowful Mother, members of the Interfaith Center on Corporate Responsibility and shareholders of General Electric, are concerned with GE's apparent resistance to the EPA's call for the cleanup of the Hudson River because of the health risks posed by the PCBs your company deposited there.

I am authorized to notify you of our intention to cosponsor the resolution submitted by the Sisters of St. Dominic of Caldwell, NJ, for action by the stockholders at the next annual meeting. The resolution asks the Board of Directors for a disclosure of the costs of the delay of cleanup by August 2006. We hereby request its inclusion in the proxy statement in accordance with Rule 14a-8 of the general rules and regulations of the Securities Exchange Act of 1934. A representative of the filers will be present at the annual stockholders meeting to move the resolution.

The Sisters of the Sorrowful Mother have owned 106 shares of General Electric common stock for over a year. We will hold the stock to cover requirements until after the annual shareholders meeting. Verification of ownership is enclosed.

Very truly yours,

/s/

Sister M. Cecile Paulik
Controller

Cc: Sisters of St. Dominic of Caldwell, NJ
Interfaith Center on Corporate Responsibility

[INQUIRY LETTER]

November 3, 2005

Mr. Benjamin W. Heineman, Jr.
Secretary
General Electric Company
3135 Easton Turnpike
Fairfield, Connecticut 06828

Dear Mr. Heineman:

Green Century Capital Management is co-filing the enclosed shareholder resolution, for inclusion in General Electric Company's proxy statement pursuant to Rule 14a-8 of the general rules and regulations of the Securities and Exchange Act of 1934.

Green Century Capital Management is concerned with General Electric's handling of the Hudson River clean up of PCBs and with the slow pace of progress on the matter. Thus we are asking for a disclosure of the expenditures related to this matter since 1990.

Green Century Capital Management is the beneficial owner of at least $2,000 worth of General Electric Company stock. We have held the requisite number of shares for over one year, and will continue to hold sufficient shares in the Company through the date of the annual shareholders' meeting. Verification of ownership will follow this letter. We ask that the proxy statement indicate that Green Century Capital Management is a co-filer of this resolution.

Thank you for your prompt attention to this matter. If you have any questions, please contact my associate, Andrew Shalit, at 617-482-0800.

Sincerely,

/s/

Amy Perry
President, Green Century Capital Management

[INQUIRY LETTER]

October 31, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Sisters of St. Joseph of Carondelet have long-standing concerns about the social and environmental impact of our investments. As your neighbors near Ft. Edward, we continue to have concerns about the clean-up of the River and the lack of transparency from our company. We are disturbed about the continued legal challenge to Superfund, and the plan in place to clean-up only 10% of the combination of the Hudson.

The Sisters of St. Joseph of Carondelet is the beneficial owner of forty-five thousand five hundred and fifteen (45,515) shares of General Electric common stock, which we intend to hold at least until after the next annual meeting. Verification of ownership is attached.

I am hereby authorized to notify you of our intention to co-file the attached proposal asking the GE Board of Directors to report on the costs of the delay of clean-up of the Hudson River, for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the proxy statement in accordance with rule 14-a-8 of the general rules and regulations of The Securities and Exchange Act of 1934.

Sr. Patricia Daly, OP of the Sisters of St. Dominic of Caldwell, NJ represents us on these concerns.

Sincerely,

/s/

Sister Ranah Phelan, CSJ
Province Leadership Team

[INQUIRY LETTER]

October 28, 2005

Mr. Jeffrey Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Sisters of Charity of New York are a religious community with our historic roots along the Hudson River. We have been interested in the matters pertaining to the clean-up of the Hudson and the actions against General Electric for over a decade. As shareholders over these many years, we are dismayed by our company's intransigence on this matter. We seek to know more of the costs of clean-up delays and to see a stop to these delaying tactics.

I am hereby authorized to inform you of our intention to submit the enclosed shareholder proposal in coordination with Sr. Patricia Daly of the Sisters of Saint Dominic of Caldwell, NJ, who shall serve as the primary contact for the shareholder group. I submit it for inclusion in the proxy statement for consideration and action by the 2006 shareholders meeting in accordance with Rule 14(a)(8) of the General Rules and Regulations of the Securities and Exchange Act of 1934. A representative of the shareholder group will attend the annual meeting to move the resolution.

The Sisters of Charity of Saint Vincent de Paul of New York are the beneficial owners of 29,580 shares of General Electric stock. Verification of ownership is enclosed. We have held the stock for over one year and plan to continue our holding through the 2006 shareholders meeting.

Thank you for your attention in this matter.

Sincerely,

/s/

Sr. Claire Regan
Corporate Responsibility Coordinator

cc: Sr. Patricia Daly, OP

Leslie Lowe, ICCR

[INQUIRY LETTER]

October 27, 2005

Mr. Jeffrey R. Immelt
Chief Executive Officer
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06431

Dear Mr. Immelt,

The Maryknoll Sisters of St. Dominic, Inc. are the beneficial owners of 100 shares of General Electric Company. The Sisters have held these shares continuously for over one year and will continue to do so at least until after the next annual meeting of shareholders. A letter of verification of ownership is enclosed.

As you know, the Maryknoll Sisters have joined with other religious congregations located in the Hudson Valley Region to try and engage our Company on GE's history with the Hudson River and its efforts to remediate environmentally damaging practices. While GE's agreeing to undertake a one-year project for cleaning up the Hudson River is a positive step, we are concerned that this may not reflect a long-term clean-up commitment.

Therefore, I am authorized to notify you of our intention to present the attached proposal for consideration and action by the stockholders at the next annual meeting. I submit this resolution for inclusion in the proxy statement, in accordance with Rule 14-a-8 of the General Rules and Regulations of the Securities and Exchange Act of 1934.

The contact person for this resolution is Patricia Daly, representing the Sisters of St. Dominic of Caldwell, New Jersey.

As always, we welcome dialogue with the company on this issue.

Sincerely,

/s/

Catherine Rowan
Corporate Social Responsibility Coordinator

enc.

[INQUIRY LETTER]

November 2, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Dominican Sisters, St. Mary of the Springs, Columbus, OH is a religious order of women seeking to reflect its values, principles and mission in its investment decisions.

The Dominican Sisters, St. Mary of the Springs, Columbus, OH is the beneficial owner of 2,000 shares of General Electric common stock. Through this letter I notify you of our co-sponsorship of the enclosed resolution with the Sisters of St. Dominican of Caldwell, NJ, and other concerned investors. We present it for inclusion in the proxy statement for action at the next stockholder meeting in accordance with Rule 14, A-8 of the General Rules and Regulations of the Securities and Exchange Act of 1934. In addition, we request that we be listed as a co-sponsor of this resolution with the Sisters of St. Dominic of Caldwell, NJ, in the company proxy statement.

Proof of ownership of common stock in the company is enclosed. We have held the requisite amount of stock for over a year and intend to maintain ownership through the date of the annual meeting. Patricia A. Daly, OP, representing the Sisters of St. Dominic of Caldwell, NJ, will serve as primary contact for the co-sponsors.

Sincerely,

/s/

Sister Helena M. Sause, OP
Dominican Sisters, St. Mary of the Springs, Columbus, OH

cc: Patricia A. Daly, OP

Leslie Lowe - ICCR

Julie Wokaty - ICCR

Mr. Jeffrey R. Immelt
Chief Executive Officer
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828

Patricia A. Daly
Executive Director
Tri-State Coalition for Responsible Investment
52 Old Swartswood Station Road
Newton, NJ 07860-5103

Julie Wokaty
ICCR
475 Riverside Drive, Room 1842
New York, NY 10115

Leslie Lowe
ICCR
475 Riverside Drive, Room 1842
New York, NY 10115

[INQUIRY LETTER]

October 26, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt,

The Sisters of St Joseph of La Grange are owners of 8200 shares of common stock in General Electric Company. We are concerned about the environment and also about the social responsibilities of the companies in which we invest. We are certain that it is possible for corporations to be both concerned about the social implications of their policies and also to make a fair profit for investors.

We are concerned our company's role about the PCB's contamination of the Hudson River ecosystem. We ask that our company report by August 1, 2006, its annual expenditures by category and specific site for each year from 1990-2005, as requested in the attached resolution. This would be seen as a positive effort by our company to respond to the ecological and health effects of PCB contamination.

Through the letter we are now notifying the company of our sponsorship of the enclosed resolution and present it for inclusion in the proxy statement for a vote at the next stockholders meeting in accordance with rule 14-a-8 of the General Rules and Regulations of the Securities Exchange Act of 1934. We are filing this resolution along with other concerned investors. The primary contact for you for the filers, Sisters of St. Dominic of Caldwell, New Jersey, is Sister Patricia Daly, O.P.

Proof of ownership of shares of common stock in our company for at least the last twelve months is attached. It is our intent to maintain ownership of these shares through the date of the annual meeting.

It is our tradition, as religious investors, to seek dialogue with companies to discuss the issues involved in the resolutions. We hope that a dialogue of this sort is of interest to you as well.

Sincerely,

/s/

Joellen Sbrissa, CSJ
Chairperson,
Social Responsible Investments Committee

Enc. Resolution
Verification of stock Ownership

cc: Leslie Lowe (Interfaith Center on Corporate Responsibility)
Patricia Daly, OP (Sisters of St Dominic of Caldwell, New Jersey

[INQUIRY LETTER]

November 2, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt,

The Brothers of Holy Cross, Eastern Province, look for social as well as financial accountability in our investments. Our mission as educators in the faith who have a preferential option for the poor motivates us to monitor our portfolio against various social criteria. One of these criteria is the care and concern that our companies demonstrate for the environment.

The Brothers of Holy Cross, Eastern Province, is the beneficial owner of 300 shares of common stock that were purchased on October 8, 1998. We intend to hold these shares until after the annual meeting. Verification of ownership is attached.

I am authorized to notify you of our intention to present the attached proposal regarding disclosure of the costs of delay of cleanup of PCBs in the Hudson River for consideration and action by the stockholders at the next annual meeting. I hereby submit it for inclusion in the proxy statement in accordance with rule 14-a-8 of the general rules and regulations of the Securities Exchange Act of 1934.

Patricia Daly of the Sisters of St. Dominic, Caldwell, NJ, will be the contact person for this resolution. We look forward to discussing the issues surrounding the costs to our company related to the delay in cleanup of the contamination in the Hudson at your earliest convenience.

Sincerely,

/s/

George C. Schmitz, CSC
Provincial

[INQUIRY LETTER]

November 2, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Ursuline Sisters of the Roman Union, Eastern Province, have had long-standing concerns about the health of the Hudson River. With most of our Sisters living and working near the Hudson we continue to be troubled about the current plan to remediate the River and the lack of transparency from our company. We are disturbed by reports that our company continues to postpone its responsibility to dean-up, while pursuing a legal challenge to Super Fund.

The Ursuline Provincialate, Eastern Province U.S., Inc. is the beneficial owner of twelve hundred (1200) shares of General Electric common stock, which we intend to hold at least until after the next annual meeting. Copies of certificates are attached.

Sr. Patricia Daly, OP of the Sisters of St. Dominic of Caldwell, NJ represents us on these concerns.

Sincerely,

/s/

Sr. Mary Sullivan OSU
Corporate Responsibility Representative

[INQUIRY LETTER]

November 2, 2005

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairfield, CT 06828

Dear Mr. Immelt:

The Dominican Sisters of Sparkill continue to be seriously concerned about the PCB contamination of the Hudson River. With most of our Sisters living and working near the Hudson we are troubled about the state of the clean-up of the River and the lack of transparency from our company. Reports that our company is holding up this process, while continuing a legal challenge to Super Fund, raises serious concerns for us.

The Dominican Congregation of Our Lady of the Rosary is the beneficial owner of three hundred (300) shares of General Electric common stock, which we intend to hold at least until after the next annual meeting. Verification of ownership is attached.

Sr. Patricia Daly, OP of the Sisters of St. Dominic of Caldwell, NJ represents us on these concerns.

Sincerely,

/s/

Sr. Margaret M. Sweeney, OP
Treasurer

[INQUIRY LETTER]

January 23, 2006

VIA HAND DELIVERY

Office of Chief Counsel
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: General Electric Company Withdrawal of December 9, 2005 Request on Shareowner Proposal of the Sisters of St. Dominic of Caldwell New Jersey et al. Securities Exchange Act of 1934 - Rule 14a-8

Dear Ladies and Gentlemen:

On December 9, 2005, we submitted a letter on behalf of our client, General Electric Company ("GE"), requesting that the staff of the Division of Corporation Finance (the "Staff") concur that GE could properly exclude from its proxy statement and form of proxy for its 2006 Annual Meeting of Shareowners a shareowner proposal (the "Proposal") and a statement in support thereof received from the Sisters of St. Dominic of Caldwell, New Jersey (the "Proponent") and numerous co-filers. ¹

Enclosed is a letter from the Proponent, on its behalf and on behalf of all co-filers of the Proposal, dated January 4, 2006, stating that the Proponent voluntarily withdraws the Proposal. See Exhibit A. In addition, attached as Exhibit B is a press release dated January 10, 2006, issued by the Proponent and the co-filers (which press release lists as co-filers all of the organizations listed in footnote 1 to this letter), announcing, among other things, that they are withdrawing their 2006 GE shareholder resolution. In reliance upon the enclosed letter from the Proponent, as well as this press release, we wish to withdraw the December 9, 2005 no-action request relating to GE's ability to exclude the Proposal pursuant to Rule 14a-8 under the Securities Exchange Act of 1934, to reflect the fact that GE and the Proponent were able to reach a mutually agreeable resolution of this matter.

In addition, we have been furnished a copy of correspondence from Sister Valerie Heinonen of the Interfaith Center on Corporate Responsibility to the Staff, dated January 17, 2006 and attached hereto as Exhibit C, noting that The Dominican Sisters of Hope, Mercy Investment Program, The Sisters of Mercy Regional Community of Detroit and The Ursuline Sisters of Tildonk, each of which is a co-filer of the Proposal, were not provided a copy of our original correspondence to the Staff, dated December 9, 2005, with respect to the Proposal. The letters that these co-filers, as with correspondence received from other co-filers of the Proposal, named Sister Patricia A. Daly as the cofilers' contact with respect to the Proposal. That correspondence is attached hereto as Exhibit D and was filed as an exhibit to our original submission to the Staff with respect to the Proposal on December 9, 2005. In reliance upon that designation, we furnished copies of the original submission to the Staff to Sister Patricia Daly as the co-filers' designated contact.

Please do not hesitate to call me at (202) 955-8671 or Thomas J. Kim, GE's Corporate and Securities Counsel, at (203) 373-2663 if you have any questions relating to this matter.

Very truly yours,

/s/

Ronald O. Mueller

Enclosures

cc: Thomas J. Kim, General Electric Company
Sr. Patricia A. Daly, OP, Sisters of St. Dominic of Caldwell New Jersey
Sr. Valerie Heinonen, o.s.u, Interfaith Center on Corporate Responsibility
Sr. Patricia Kelly, SSJ, Congregation of the Sisters of Saint Joseph, Philadelphia
Timothy Moller, The Sisters of Charity of Cincinnati
S. Ruth Kuhn, SC, The Sisters of Charity of Cincinnati
Sr. M. Cecile Paulik, The Sisters of the Sorrowful Mother
Andrew Shalit, Green Century Capital Management

-----FOOTNOTES-----

¹ Co-filers of the Proposal include the Sisters of the Humility of Mary of Villa Maria, Pa., The American Baptist Home Mission Society of The American Baptist Churches, USA, The Sisters of Saint Ursula, The Sisters of Charity of the Blessed Virgin Mary, Clean Yield Asset Management, The Sisters of Charity of Cincinnati, The Sisters of Mercy of the St. Louis Regional Community, Inc., The Dominican Sisters of Hope, Mercy Investment Program, The Sisters of Mercy Regional Community of Detroit, The Ursuline Sisters of Tildonk, The Amityville Dominican Sisters, The Congregation of the Sisters of Saint Joseph, Philadelphia, The Catholic Foreign Mission Society of America, Inc., the Nuns of the Third Order of St. Dominic, The Sisters of the Sorrowful Mother, Green Century Capital Management, The Sisters of St. Joseph of Carondelet, The Sisters of Charity of Saint Vincent de Paul of New York, The Maryknoll Sisters of St. Dominic, The Dominican Sisters, St. Mary of the Springs, Columbus, OH, The Sisters of St. Joseph of La Grange, The Brothers of Holy Cross, Eastern Province, The Ursuline Provincialate, Eastern Province U.S. and The Dominican Congregation of Our Lady of the Rosary.

[INQUIRY LETTER]

October 29, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

The Dominican Sisters of Hope is the benefieial owner of 75 shares of General Electric stock. Verification of ownership follows. We plan to hold the stock at least until the time of the annual meeting and will be present in person or by proxy at that meeting.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Consultant, Corporate Responsibility
205 Avenue C, Apt 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@jno.com

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, Chair and CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

Yours truly,

/s/

Valerie Heinonen, o.s.u.

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-001

Dear Mr. Immelt:

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Corporate Responsibility Consultant
205 Avenue C, Apt 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@juno.com

[INQUIRY LETTER]

January 4, 2006

Mr. Jeffrey R. Immelt, CEO
General Electric
3135 Easton Turnpike
Fairtield, CT 06828

Dear Mr. Immelt:

On behalf of the proponcnts of the shareholder resolution: Disclosure of Costs of Delay of Cleanup of Toxic Sites, I want to thank you for responding to our request. Shareholders continue to look forward to an upcoming meeting with your colleagues to discuss this information and the status of the cleanup of the Hudson River.

I am hercby authorized to notify you of our withdrawal of the proposal asking the GE Board of Directors to report on the costs of the delay of clean up of the Hudson River. I do so on behalf of all the filers.

We are happy to anticipate an upcoming meeting with executives at General Electric to discuss the status of the cleanup and the information provided by the requests of this proposal.

Sincerely,

/s/

Sr. Patricia A. Daly, OP
Corporate Responsibility Representative

[INQUIRY LETTER]

January 4, 2006

Office of the Chief Counsel
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Dear Sir or Madam:

Attached please find our letter withdrawing the sharcholder resolution: Disclosure of Costs of Delay of Cleanup of Toxic Sites from the General Electric Company. Thank you for your attention.

Thank you for your attention.

Sincerely,

/s/

Patricia A. Daly, OP
Corporate Responsibility Represcntative

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Consultant, Corporate Responsibility
205 Avenue C, Apt. 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@juno.com

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-001

Dear Mr. Immelt:

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Corporate Responsibility Consultant
205 Avenue C, Apt 10E
NY NY 10009
212 674 2542 (phone and fax)

heinonenv@juno.com

[INQUIRY LETTER]

October 28, 2005

Jeffrey R. Immelt, CEO
General Electric Company
3135 Easton Turnpike
Fairfield, CT 06828-0001

Dear Mr. Immelt:

Our intention is to cosponsor this resolution with the Sisters of St. Dominic, Caldwell, NJ and other religious institutional investors. The contact person for this resolution is Patricia Daly.

Yours truly,

/s/

Valerie Heinonen, o.s.u.
Consultant, Corporate Responsibility
205 Avenue C, Apt. 10E
NY NY 10009
212 674 2542 (phone and fax)
heinonenv@juno.com

[INQUIRY LETTER]

January 24, 2006

Ronald O. Mueller
Gibson, Dunn & Crutcher LLP
1050 Connecticut Avenue, N.W.
Washington, DC 20036-5306

Re: General Electric Company

Dear Mr. Mueller:

This is in regard to your letter dated January 23, 2006 concerning the shareholder proposal submitted by the Sisters of St. Dominic of Caldwell New Jersey; The Sisters of the Humility of Mary of Villa Maria, PA; The American Baptist Home Mission Society; the Sisters of Saint Ursula; the Sisters of Charity of the Blessed Virgin Mary; Clean Yield Asset Management; the Sisters of Charity of Cincinnati; the Sisters of Mercy of the Americas; the Dominican Sisters of Hope; the Mercy Investment Program; the Sisters of Mercy Regional Community of Detroit Charitable Trust; the Ursuline Sisters of Tildonk, United States Province; the Sisters of the Order of St. Dominic; the Congregation of the Sisters of Saint Joseph, Philadelphia; the Maryknoll Fathers and Brothers; the Dominican Sisters of Great Bend, KS; the Sisters of the Sorrowful Mother; Green Century Capital Management; the Sisters of St. Joseph of Carondelet; the Sisters of Charity of New York; the Maryknoll Sisters of St. Dominic, Inc.; the Dominican Sisters, St. Mary of the Springs, Columbus, OH; the Sisters of St. Joseph of La Grange; the Brothers of Holy Cross, Eastern Province; the Ursuline Sisters of the Roman Union, Eastern Province; and the Dominican Sisters of Sparkill for inclusion in GE's proxy materials for its upcoming annual meeting of security holders. Your letter indicates that the proponents have withdrawn the proposal, and that GE therefore withdraws its December 9, 2005 request for a no-action letter from the Division. Because the matter is now moot, we will have no further comment.

Sincerely,

/s/

Mark F. Vilardo
Special Counsel

cc: Sisters of St. Dominic of Caldwell New Jersey and co-proponents
% Sr. Patricia A. Daly, OP
Corporate Responsibility Representative
Sisters of St. Dominic of Caldwell New Jersey
Office of Corporate Responsibility
52 Old Smartswood Station Road
Newton, NJ 07860-5103

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Company Name: General Electric Co.
Public Availability Date: January 24, 2006