Adaptation as Risk ManagementAgency FilingEnergy RegulationFederal Energy RegulationRisk Management

Comments to Federal Energy Regulatory Commission on Climate Impact Analysis in Natural Gas Project Reviews

These comments recommend that the Federal Energy Regulatory Commission (FERC) supplement its draft policy statement on natural gas project reviews with additional guidance on the evaluation of climate impacts on projects under the National Environmental Policy Act (NEPA). Holistic, specific, and actionable climate impact analysis is necessary to meet NEPA’s…
Michael Panfil
April 25, 2022
Adaptation as Risk ManagementEnvironmental JusticeReportRisk Management

Evaluating Climate Risk in NEPA Reviews: Current Practices and Recommendations for Reform

This report finds that in order to meet the National Environmental Policy Act (NEPA) requirement that federal agencies take a “hard look” at the environmental effects of proposed actions, agencies must consider how the changing weather and environmental conditions brought by climate change might impact an action and alter its…
Michael Panfil
February 15, 2022
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

Comments to the OCC on Principles for Climate-Related Financial Risk Management for Large Banks

These comments to the Office of the Comptroller of the Currency (OCC) support the OCC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the OCC as it continues building on these principles with more detailed guidance. The comments recommend that the OCC consider: (1) providing…
Michael Panfil
February 14, 2022
Agency FilingEnvironmental JusticeRisk Management

Comments on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (EDF, Institute for Policy Integrity)

These comments support an advance notice of proposed rulemaking by the Department of Labor's Occupational Safety & Health Administration (OSHA) as an important step in OSHA’s efforts to develop strong heat stress protections for workers. The comments recommend that OSHA consider climate change amplification of occupational heat risks and the…
Michael Panfil
January 26, 2022
Adaptation as Risk ManagementAgency FilingRisk Management

Comments to Federal Acquisition Regulatory Council on Minimizing the Risk of Climate Change in Federal Acquisitions

In the normal course of operation for federal procurement under the Federal Acquisition Regulation (FAR), care is taken to structure purchases and contracts consistent with principles of efficiency, risk management, and cost minimization. Existing procedures, however, do not yet incorporate and manage financial risks posed by the consequences of climate…
Michael Panfil
January 13, 2022