Agency Filing – Page 2 – Initiative on Climate Risk and Resilience Law
Agency Filing
Agency FilingFinancial Regulation
Comments on Office of Comptroller of the Currency Fair Access Rule
These comments argue that OCC's Fair Access Rule violates the APA.
Michael Panfil and Jack LienkeJanuary 4, 2021
Comments on New York PSC Proceeding on Climate Risk Disclosure
These comments argue that New York State should require its electric and gas utilities—not their holding companies but the operating utilities themselves—to assess and disclose the climate risks they face.
Justin Gundlach, Jayni Hein, Sarah Ladin, Michael Panfil, Christine Pries and Romany WebbDecember 9, 2020
Comments to the SEC on Regulation S-K and Climate Risk
The SEC should adopt a more specific line-item approach to climate risk reporting similar to the TCFD's framework in order to limit manager discretion in disclosure and encourage corporate preparedness for climate change.
Madison Condon, Jack Lienke, Alex Kristofcak and Alex LangerApril 28, 2020
Adaptation as Risk ManagementAgency FilingEnergy RegulationRisk ManagementState Energy Regulation
Comments to Connecticut PURA on Value of Distributed Energy Resources
These comments to the Connecticut Department of Energy and Environmental Protection and Public Utilities Regulatory Authority discuss their proposed distributed energy resource value categories, encouraging the agencies to include electricity system resilience and community resilience in their list of value categories.
Justin GundlachAugust 21, 2019
Adaptation as Risk ManagementAgency FilingEnergy RegulationFederal Energy RegulationRisk Management
Comments on FERC’s Notice of Inquiry on its Certification of New Interstate Natural Gas Facilities
These comments were submitted in response to FERC's Notice of Inquiry into possible changes to its natural gas certification policy. The comments argue, among other things, that FERC should consider how climate change will affect the construction and operation of natural gas infrastructure in its certification decisions.
Romany Webb and Jessica WentzJune 18, 2018
Agency FilingEnergy RegulationFederal Energy Regulation
Comments to FERC on Electric Grid Resilience Order
These comments to FERC on its grid resilience docket argue that the Commission should not take mandatory national or regional action, but instead encourage RTOs to continue to systematically evaluate the resilience of the bulk power system and be open to proposals to make specific resilience improvements. The comments more…
Burcin Unel and Avi ZevinMay 9, 2018
Comments on FERC’s Review of Grid Resilience in Regional Transmission Organizations and Independent System Operators
These comments were submitted in response to FERC's request for input on the resilience of the bulk power system in areas overseen by regional transmission organizations and independent system operators (RTO/ISOs). The comments argue that RTO/ISOs' efforts to address resilience have given insufficient weight to the impacts of climate change,…
Romany WebbApril 13, 2018