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 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…
Environmental JusticeEvent/ConferenceRisk Management

Testimony of Stephanie Jones on OSHA Initiatives to Protect Workers From Heat-Related Hazards

This testimony from an Occupational Safety and Health Administration (OSHA) stakeholder meeting supports OSHA’s efforts to develop strong heat protections for workers, including rulemaking to establish a heat standard as well as complementary research, education, and enforcement initiatives. It recommends that OSHA incorporate thorough and reliable information on climate impacts…
Stephanie Jones
May 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…
Blog/News ArticleFinancial RegulationRegulatory Activities

How a Proposed Department of Labor Rule Would Help Protect Retirement Savings From Climate Risk

This blog explains how a Department of Labor proposal would help protect Americans’ retirement savings by highlighting the financial relevance of climate change; undoing harmful Trump administration rules; affirming that fiduciaries should consider ESG factors like climate change when relevant to investment risk-return analysis; applying the same rational principles to…
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…