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Agency FilingEnvironmental JusticeRisk Management

Comments on the National Flood Insurance Program’s Community Rating System Redesign Effort

The Federal Emergency Management Agency (FEMA) issued a Request for Information regarding potential future changes to the Community Rating System (CRS) under the National Flood Insurance Program (NFIP). CRS is a voluntary incentive program offering NFIP premium discounts to eligible communities that exceed minimum NFIP floodplain management requirements. The program…
Talley Burley, Jesse Gourevitch and Carolyn Kousky
September 6, 2024
Agency FilingEnergy RegulationRisk ManagementState Energy Regulation

Comments to the New York Public Service Commission on the Electric Utilities Climate Change Resilience Plans

Organizations Involved: Sabin Center Abstract These comments were submitted to the New York State Public Service Commission in response to the request for comments concerning climate vulnerability and resiliency plans submitted by six New York State electric utilities on November 21, 2023 in compliance with New York Public Service Law §66(29).
Romany Webb and Chloe Field
August 30, 2024
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Amicus Brief in Case Challenging SEC Climate-Related Financial Disclosure Rules

In March 2024, the Securities and Exchange Commission (SEC) finalized its rules on The Enhancement and Standardization of Climate-Related Disclosures for Investors (Rules). The Rules will require public companies in the United States to make certain climate-related disclosures in their registration statements and annual reports, giving investors critical information to…
Donald Goodson, Bridget Pals and Erin Shortell
August 15, 2024
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Amicus Brief in Case Challenging SEC Climate-Related Financial Disclosure Rules

This amicus brief was filed by the Americans for Financial Reform Education Fund, Environmental Defense Fund, Natural Resources Defense Council, Sierra Club, and Sierra Club Foundation, a coalition of non-profit organizations that have differing missions and areas of focus but share a common assessment that climate-related impacts pose significant and…
Hana Vizcarra, Deena Tumeh, Adrienne Y. Lee, Andres Restrepo, Thomas Zimpleman, Stephanie Jones, Gabrielle Stephens and Peter Zalzal
August 14, 2024
Agency FilingEnergy RegulationRisk ManagementState Energy Regulation

Comments to the CPUC on the Order Instituting Rulemaking to Update Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems

Organizations Involved: Sabin Center & Institute for Policy Integrity Abstract These comments were submitted to the California Public Utilities Commission (CPUC) in response to its order instituting a rulemaking to update the Rules for the Safety, Reliability, and Resiliency of Electrical Distribution Systems.
Romany Webb, Chloe Field and Elizabeth B. Stein
July 8, 2024
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeRisk Management

Comments on the National Flood Insurance Program: Standard Flood Insurance Policy, Homeowner Flood Form

The Federal Emergency Management Program (FEMA) proposed a rule to revise the Standard Flood Insurance Policy (SFIP) under the National Flood Insurance Program. The proposed reforms take important steps to: 1) increase transparency and clarity for policyholders; 2) build resilience through investment in flood mitigation; 3) expand coverage options; and…
Carolyn Kousky, Karina French and Talley Burley
May 31, 2024
Agency FilingRisk Management

Comments to FEMA on Proposed Rule to Modify the Standard Flood Insurance Policy Under the National Flood Insurance Program

Organizations Involved: Policy Integrity Abstract The Federal Emergency Management Agency (FEMA) proposed a rule to modify the standard flood insurance policy under the National Flood Insurance Program by creating a new “Homeowner Flood Form,” which applies specifically to homeowners of single-family homes and owners of buildings with one-to-four units. The…
Dena Adler, Bridget Pals and Jason Schwartz
May 31, 2024
Agency FilingEnergy RegulationFederal Energy Regulation

Comments to DOE on Voluntary Carbon Dioxide Removal Purchasing Challenge (Policy Integrity)

Organizations Involved: Policy Integrity Abstract In March 2024, the Department of Energy (DOE) published a Notice of Intent Regarding Launching a Voluntary Carbon Dioxide Removal Purchasing Challenge (Purchasing Challenge). To participate in the Purchasing Challenge, organizations must disclose to DOE several details about each associated carbon dioxide removal (CDR) credit,…
Donald Goodson, Jason Schwartz, Erin Shortell and Derek Sylvan
May 15, 2024
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Amicus Brief on Major Questions Doctrine in Fifth Circuit Case Over DOL’s 2022 Investment Duties Rule

The Institute for Policy Integrity filed an amicus brief in the Fifth Circuit arguing that the lower court correctly concluded the Department of Labor's 2022 Investment Duties Rule does not trigger the major questions doctrine because past regulatory practice demonstrated the case was not extraordinary enough to trigger the doctrine.…
Donald Goodson and Jessie Arnell
March 26, 2024
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to CFTC on Proposed Guidance on Voluntary Carbon Credit Derivatives (Policy Integrity)

Organizations Involved: Institute for Policy Integrity Source: Institute for Policy Integrity Abstract In December 2023, the Commodity Futures Trading Commission (CFTC) proposed guidance that identifies key features of high-integrity voluntary carbon credits (VCCs) for exchanges that list certain VCC derivatives. The Institute for Policy Integrity submitted comments that highlight additional…
Donald Goodson, Jason Schwartz and Erin Shortell
February 16, 2024