These comments offer support and provide recommendations for the adoption of CEQ’s interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.
These comments offer support and provide recommendations for the adoption of CEQ's interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.
Eleonor Dyan Garcia, Romany Webb and Jessica WentzApril 10, 2023
The Sabin Center supports the Proposed Guidance as a valuable step in DFS’ effort to ensure its regulated institutions integrate climate-related financial risks into their risk management frameworks. In light of the urgency of the climate crisis, the timeline for implementation of the Proposed Guidance should be expeditious and concrete.…
Eleonor Dyan Garcia and Cynthia HanawaltMarch 20, 2023
Comments to the FAR on the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk
These comments support the Federal Acquisition Regulatory Council's proposed rule on the disclosure of greenhouse gas emissions and climate-related financial risk. The Proposed Rule is an important step to safeguarding and promoting efficient and economical procurement, and ensuring resilience of essential government functions in light of escalating climate-related financial and…
These comments support the Draft Principles as an important step in the Board’s efforts to guide banks to update their risk management practices as needed in light of climate-related financial risks, thereby promoting safety and soundness. We recommend that the Board continue building upon these Draft Principles with final guidance,…
These comments support the Federal Insurance Office's proposal to collect information from property and casualty insurers regarding current and historical underwriting data on homeowners' insurance. This data collection would mark a critical step towards understanding how climate-related disasters may affect the availability and affordability of insurance for U.S. householders. This…
Stephanie Jones, Michael Panfil, Karina French and Jeffrey FralickDecember 20, 2022
These comments strongly support the Commodity Futures Trading Commission's ("Commission") efforts to respond to the financial consequences of climate change and highlight the legal basis for appropriate rule-making to address these risks. Regulations to address climate risk are consistent with the Commission's mandate to ensure the integrity of transactions under…
Eleonor Dyan Garcia, Cynthia Hanawalt and Romany WebbOctober 7, 2022
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…
The SEC has proposed a series of new disclosures for investment companies regarding their Environmental, Social, and Governance (ESG) activities. These disclosures would reduce "greenwashing" - a practice where companies misrepresent the sustainability of their investments in order to advertise to investors looking to invest in green funds - by…
Jack Lienke and Bridget PalsAugust 16, 2022