Category Archives: Climate Change

Freedom of Information and Industrial Pollution

By | February 15, 2022

Industrial pollution has staggering consequences in terms of premature deaths, productivity losses, and health care costs. In 2015, conservative estimates put the number of pollution-related deaths at nine million, which represents roughly 16% of all deaths worldwide, and the financial cost of pollution-related deaths and sickness at 4.6 trillion US dollars, which represents about 6.2%… Read More »

Recent Comments on Improving Accountability in Net-Zero Commitments

By | February 9, 2022

With the rapid expansion of corporate net-zero commitments and the recent pledge by financial institutions (FIs) – with over $130 trillion in assets – at COP26 in Glasgow to hit net-zero emissions by 2050, a credible mechanism to measure these commitments and hold companies accountable for meeting them is of critical importance. To that end,… Read More »

Comments to the Commodity Futures Trading Commission on the proposed creation of a carbon markets subcommittee of the Energy and Environmental Markets Advisory Committee

By | September 23, 2021

The following is an edited comment letter that was submitted to the Commodity Futures Trading Commission (CFTC, or Commission) on September 22nd for the invitation to comment on the proposal by the Commercial Energy Working Group to form an EEMAC carbon markets subcommittee.[1] The proposed stakeholder group would produce a report on principles for designing the derivatives… Read More »

Nature’s locus standi: Taking the Environment to Court

By | September 6, 2021

With institutions, both public and private, defining the functioning of major world economies, we have come a long way from the early days of industrialization to extensive urban development and technical advancement. In this developmental process, vital players in the economy seem to have neglected the importance of safeguarding the natural environment. Actions of individuals,… Read More »

Do Extreme Weather Events Alter Investors’ Support for the Environment?

By | August 27, 2021

Dramatic images showing icebergs melting, global warming-related avalanches, and destructive landslides and wildfires caused by extreme weather events are now commonplace in news broadcasts. It is no surprise then that climate change-related corporate proposals have increased steadily in recent years, reflecting growing investor demand for corporate accountability around this issue. Given such a stance, what… Read More »

The Global Green Finance Index

By | August 18, 2021

Background Just a few years ago, green finance was dismissed as a fringe activity. However, the rise of new financial instruments – such as Green Bonds and Fintech applications which reduce risk and open up new markets – has firmly moved green finance into the mainstream. When combined with public concern on climate change and policy makers’ preoccupation with low-carbon economic growth, it… Read More »

Where the Rubber Meets the Road: How Can an SEC Climate Risk Disclosure Rule Survive Cost-Benefit Analysis?

By | August 9, 2021

In a recent post, we summarized comments submitted to the Securities and Exchange Commission (SEC or Commission) regarding the request for public input on climate change disclosures (RFPI) released by then Acting Chair, Allison Herren Lee on March 15, 2021. With the Commission set to release a Notice of Proposed Rulemaking on climate disclosure by… Read More »

Summary of Comment Letters for the SEC’s Climate Risk Disclosure RFI

By | July 9, 2021

Recognizing that “investor demand for, and company disclosure of information about, climate change risks, impacts, and opportunities has grown dramatically,” former Securities and Exchange Commission (SEC or Commission) Acting Chair Allison Herren Lee released 15 questions for consideration on March 15, 2021 “with an eye toward facilitating the disclosure of consistent, comparable, and reliable information… Read More »

SEC Climate Risk Disclosure Comment Letter: Executive Summary

By | June 22, 2021

Climate change poses serious risks to almost every aspect of the economy, and its impacts will have long-term disruptive effects on financial markets around the world. Currently, these risks are not adequately addressed by financial regulators in the United States. As a result, climate-related information is not accurately incorporated into financial markets, leaving firms, investors,… Read More »

Recent Risk Alert Highlights Need for SEC Action Regarding Potential Greenwashing by Financial Firms

By | April 16, 2021

On April 9th, the SEC’s Division of Examinations issued a “Risk Alert” regarding three types of financial firms – investment advisers, registered investment companies, and private funds – that offer Environmental, Social & Governance (“ESG”) products and services. The Examinations Division is prioritizing review of ESG practices in response to the rapidly growing demand by… Read More »