Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC from Climate Scientists/Experts on Proposed Rule on Climate-Related Disclosures

These comments from 15 climate scientists and experts discuss the science of climate change detection and attribution—the body of research that helps to characterize the role of human activity in climate change—as well as how models are used to develop climate change projections. The goal of these comments is to…
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…
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…
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…
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…
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…
Agency FilingEnvironmental JusticeRisk Management

Comments on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (Sabin Center)

These comments support an advance notice of proposed rulemaking by the Department of Labor's Occupational Safety & Health Administration (OSHA) on heat injury and illness prevention in outdoor and indoor work settings. The comments emphasize the importance of this initiative in combatting extreme heat, the most lethal climate disaster of…
Jacob Elkin
December 14, 2021