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Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to the FAR on the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk

These comments support the Federal Acquisition Regulatory Council's proposed rule on the disclosure of greenhouse gas emissions and climate-related financial risk. The Proposed Rule is an important step to safeguarding and promoting efficient and economical procurement, and ensuring resilience of essential government functions in light of escalating climate-related financial and…
Michael Panfil
February 13, 2023
Agency FilingEnergy RegulationFederal Energy Regulation

Comments to FERC on One-Time Informational Reports on Extreme Weather Vulnerability Assessments

In these comments, EDF and the Sabin Center support the Commission’s proposal to require transmission providers to file one-time informational reports describing their current or planned policies and processes for conducting extreme weather vulnerability assessments. In promulgating a final rule, EDF and the Sabin Center recommend that the Commission supplement…
Michael Panfil
August 30, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the ISSB on Climate-Related Disclosures Exposure Draft

These comments support the Climate-Related Disclosures Exposure Draft of the International Sustainability Standards Board (ISSB), which will provide investors around the globe with the information necessary to inform their investment decisions. The comments commend the ISSB’s goal of creating a global baseline and encourage the ISSB to consider certain modifications…
Michael Panfil
July 29, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Reasoned Explanation for Its Proposed Rule on Climate-Related Disclosures

This letter focuses on two aspects of the justification provided by the Securities and Exchange Commission (SEC) for its proposed rule on climate-related disclosures. First, the letter evaluates the Commission’s rationale for using prescriptive—as opposed to principles-based—disclosure requirements for climate-related financial risk. Second, the letter evaluates the Commission’s rationale for…
Michael Panfil
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Regulatory Precedents for Its Proposed Rule on Climate-Related Disclosures

In her dissent from the Securities and Exchange Commission's proposed rule on climate-related disclosures, Commissioner Peirce describes the SEC as “discover in a long-extant statute an unheralded power to regulate ‘a significant portion of the American economy’” and impermissibly transforming its regulatory role into that of a “Securities and Environment…
Michael Panfil
June 17, 2022