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Noha Haggag

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…
Noha Haggag
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…
Noha Haggag
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…
Noha Haggag
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…
Noha Haggag
June 17, 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…
Noha Haggag
January 13, 2022