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…
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Economic Analysis for Its Proposed Rule on Climate-Related Disclosures

In response to the Securities and Exchange Commission's proposed rule on climate-related disclosures, this letter commends the SEC for conducting an economic analysis that is consistent with relevant case law, and suggests some revisions that would provide additional context and support for the final analysis.
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…
Adaptation as Risk ManagementBlog/News ArticleEnergy RegulationRisk ManagementState Energy Regulation

Announcing the Electric Resilience Toolkit

This blog introduces the Electric Resilience Toolkit, a platform designed to provide engagement-focused information for use directly in regulatory proceedings to support well-designed climate resilience planning by electric utilities. The toolkit is available at: https://www.icrrl.org/electric-resilience-toolkit/
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…