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

Agency FilingFinancial Regulation

Comments to the FIO on Climate-Related Financial Risk Data Collection

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 Fralick
December 20, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the CFTC on Climate-Related Financial Risk (Sabin Center)

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 Webb
October 7, 2022
Agency FilingEnergy RegulationFederal Energy Regulation

Comments to FERC on One-Time Informational Reports on Extreme Weather Vulnerability Assessments

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…
Ted Kelly, Noha Haggag, Michael Panfil, Nicole Buell, Natalie Karas, Jason Gray and Romany Webb
August 30, 2022
Financial RegulationRisk ManagementSummary Document

Summary Report: Workshop on Physical Climate Risk and the United States Financial System

In May 2022, CarbonPlan, the Environmental Defense Fund (EDF), and the Initiative on Climate Risk and Resilience Law (ICRRL) co-convened a Chatham House Rule workshop to better understand how climate science is used in risk assessment and decision-making across the financial sector. Pursuant to the rule, the meeting organizers and…
Jeffrey Fralick and Sadie Frank
August 19, 2022
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