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
Agency FilingFinancial RegulationRegulatory Activities

Comments on Department of Labor Proposed Rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

These comments support a Department of Labor proposed rule that clarifies that retirement plan fiduciaries should consider climate risk and other ESG factors whenever relevant to financial risk-return analysis for investment and proxy voting decisions. The comments additionally offer suggestions on potential improvements to the proposal for the Department's consideration.
Adaptation as Risk ManagementAgency FilingRisk Management

Comments on Federal Agency Climate Adaptation and Resilience Plans

These comments support the development of the Federal Agency Climate Adaptation and Resilience Plans, which establish a foundation for actions to protect government operations and facilities, and all who rely upon them. The comments recommend that agencies consider the following steps as they build on that foundation: (1) Agencies should…
Adaptation as Risk ManagementAgency FilingEnergy RegulationFederal Energy RegulationRisk Management

Supplemental Comments on FERC’s Technical Conference on Climate Change, Extreme Weather, and Electric System Reliability

These post-technical conference comments provide further recommendations on how FERC can support effective climate resilience planning throughout the energy system, supplementing an earlier set of pre-technical conference comments.
Agency FilingEnergy RegulationRisk ManagementState Energy Regulation

Comments on Petition to New York PSC to Comprehensively Study the Impacts of Climate Change on Utility Infrastructure

In response to a Proposed Rulemaking, these comments support a petition by the Sabin Center, EDF, and other entities for the NYPSC to require utilities to engage in climate change vulnerability studies. The comments draw on sources including the joint Sabin Center and EDF paper Climate Risk in the Electricity…
Agency FilingFinancial DisclosureFinancial Regulation

Comments to SEC on Climate Risk Disclosure (ICRRL, Policy Integrity, EDF, Professors)

These comments make recommendations on the establishment of mandatory climate risk disclosure requirements that produce comparable, specific, and decision-useful information for investors, in response to the SEC's request for public input on climate disclosures.
Agency FilingFinancial DisclosureFinancial Regulation

Comments to SEC on Climate Risk Disclosure (Sabin Center)

These comments, in response to the SEC's request for public input on climate disclosures, focus on the science of climate attribution, detection, and prediction—the body of research drawing on multiple lines of evidence that describes the role of human activity in climate change. The goal of these comments is to…