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Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

Comments to the FDIC on Principles for Climate-Related Financial Risk Management for Large Financial Institutions

These comments to the Federal Deposit Insurance Corporation (FDIC) support the FDIC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the FDIC as it continues building on these principles with more detailed guidance. The comments recommend that the FDIC consider: (1) providing more detail on…
Michael Panfil
June 3, 2022
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