This blog explains that the SEC’s proposed climate risk disclosure rule is not novel or unique, but well-centered within the constellation of prior SEC regulations.
Bridget PalsJuly 15, 2022
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…
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…
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.
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…
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 PanfilJune 16, 2022
This annual report summarizes ICRRL's work in the first year following its launch on June 14, 2021.
Jeffrey FralickJune 13, 2022
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…
This opinion piece explains that with above-average temperatures forecast for much of the U.S. in coming months, electric system operators are facing the prospect of high electricity demand and reduced supply, which will make it difficult to keep the lights on. It argues that it is well past time for…
Romany WebbMay 19, 2022