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Regulator & Court Approaches to Managing Uncertainty in the Climate Risk Context

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…
Michael Burger, Jeffrey Fralick, Radley Horton, Romany Webb and Others
June 17, 2022
Adaptation as Risk ManagementBlog/News ArticleEnergy RegulationRisk ManagementState Energy Regulation

Announcing the Electric Resilience Toolkit

This blog introduces the Electric Resilience Toolkit, a platform designed to provide engagement-focused information for use directly in regulatory proceedings to support well-designed climate resilience planning by electric utilities. The toolkit is available at: https://www.icrrl.org/electric-resilience-toolkit/
Romany Webb, Noha Haggag and Michael Panfil
June 16, 2022
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…
Stephanie Jones and Alex Song
March 14, 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 and Michael Panfil
January 13, 2022
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.
Stephanie Jones, Michael Panfil, Sarah Ladin, Jack Lienke and Alex Song
December 13, 2021
Adaptation as Risk ManagementBlog/News ArticleEnvironmental JusticeFinancial DisclosureFinancial RegulationPrivate GovernanceRisk Management

Climate Change Comes to Insurance

This opinion piece explains the risks climate change poses to insurers, both as underwriters and as investors. It argues that it is necessary to align incentives in the insurance industry to prevent widespread defaults that would leave policyholders unprotected and examine areas where risks are distributed inequitably.
Bridget Pals and Michael Panfil
December 3, 2021
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationPrivate GovernanceRisk Management

Comments to Federal Insurance Office on the Insurance Sector and Climate-Related Financial Risks

These comments make recommendations to the Treasury Department's Federal Insurance Office on how it can monitor, analyze, and address climate-related risks in the insurance industry.
Jack Lienke, Bridget Pals, Alex Song, Madison Condon, Michael Panfil, Stephanie Jones and Romany Webb
November 15, 2021