Climate 411

Climate change creates financial risks. Investors need to know what those are.

Flooding in Baton Rouge, LA in August, 2016. Coast Guard photo by Petty Officer 1st Class Melissa Leake

(This post was co-authored by David G. Victor, nonresident senior fellow at the Brookings Institution. It is also posted here.)

The U.S. Securities and Exchange Commission (SEC) voted recently to move a proposal forward that would require publicly traded companies to disclose the financial risks they face from climate change. These rules aim to bring corporate obligations for the disclosure of climate risk level with the requirements for disclosure of other forms of financial risk. Doing so is long overdue and a critical step to ensuring investors have access to information about the investment risks faced from climate. Those financial harms include “transition risks” stemming from shifts in innovation, technology, and competitive landscape as well as “physical risks”, such as more severe wildfires to more frequent flooding.

Our financial system has always relied on publicly traded companies being transparent about the risks their businesses navigate. This open accounting of business prospects is fundamental to the healthy operation of our economy — reliable information is the bedrock of efficient markets. Publicly traded companies are required to regularly issue disclosure reports that investors — from Wall Street to Main Street — rely on when choosing where to invest their money seeking opportunity and avoiding unwarranted risk.

The consequences of climate change are creating new and growing forms of financial risk that investors need to consider when choosing how to prudently allocate capital. In the last two years alone, the U.S. suffered more than 40 weather disasters that inflicted at least $1 billion in economic damage each. A recent study found that 215 of the world’s largest companies face almost $1 trillion in climate-related risk. These climate risks pose sprawling challenges, disrupting “food supplies, business operations, and economic productivity, while damaging homes and personal property, public infrastructure, and critical ecosystems across the country.” The most recent assessment by the Intergovernmental Panel on Climate Change concluded similarly, finding that “extreme events and climate hazards are adversely affecting multiple economic activities across North America and have disrupted supply-chain infrastructure and trade.”

Disclosure is necessary because climate risk is investment risk, and market participants have a significant interest in understanding the size and scope of that risk. Other countries, from the U.K. to New Zealand to Japan, have taken concrete steps to require that the mounting harms of climate change to their financial systems are proactively identified and understood. Yet in the U.S., companies are not currently required to disclose the financial risks created by climate change. Our existing rules are voluntary and inadequate. One recent study found that only one percent of companies participating in a voluntary set of standards provided sufficient information on their transition plans for the lower-carbon future. Another, jointly conducted by researchers at Brookings Institution and EDF, found similar results, particularly on the disclosure of physical risk. Another study from Brookings, cited by the SEC in its new draft rule, found highly uneven patterns of disclosure about climate risks — especially on physical risks.

An efficient market requires more information. That’s why the investment community has been among the most vocal in calling for the SEC to act. Ninety-three percent of institutional investors believe that climate-related financial risk “has yet to be priced in by all key financial markets globally.” Many of the world’s largest asset managers have called for strong, mandatory climate disclosure rules to improve their ability to prudently manage investments — in their comments to the SEC they also urged (and the SEC heeded) some caution so that disclosure rules stayed in line with the information that the markets most needed to function well. Many of the large publicly-traded American businesses that would be subject to these rules have also expressed support for mandatory SEC climate risk disclosure, including AppleWalmart, and FedEx. These businesses and many others understand that the U.S. financial system is healthiest when market participants are able to make well-informed decisions.

The proposed rule addresses these barriers by setting forth a range of information requests, all designed to address investor need. Physical risk disclosure, such as disclosure of risks associated with more severe extreme weather or increasing wildfires, is a critical part of the proposal, which requires registrants to disclose “any climate-related risks that are reasonably likely to have a material impact on the registrant’s business or consolidated financial statement.” The extent to which the company uses specific tools to understand the financial risks they face from climate, such as scenario analysis or transition plans, is likewise subject to the proposed rule. Other aspects of a registrant’s climate risk are additionally subject to disclosure, including provisions of information relevant to the company’s specific risk management processes, greenhouse gas emissions, line-item metrics on the effects of climate-related risks on corporate finances, and climate-related targets.

Understanding and responding to the danger climate change poses across the American economy will be complicated. Getting this right will take time and will require a lot of learning. Mandatory climate risk disclosure by the SEC is a necessary early step. It will bring disclosure of climate risk level with other forms of financial risk and will help ensure that investors have access to relevant information for prudent management of the capital they invest. The SEC’s new proposal aims to achieve this end, consistent with the agency’s clear and explicit authority. Commissioners should swiftly move to finalize the proposal and put this much-needed rule into effect.

Posted in Economics, News, Partners for Change, Policy / Comments are closed

Power companies, businesses, and experts support EPA authority to address climate pollution at Supreme Court

More than a dozen amicus curiae – or “friend of the court” – briefs were filed in support of EPA in West Virginia et al. v. EPA, a Supreme Court legal challenge brought by coal companies and their allies in an effort to undermine EPA’s authority to safeguard human health and the environment from the climate pollution emitted by power plants.

Amicus briefs are common in Supreme Court cases and can provide the Justices with important information or arguments from entities that are not themselves party to the legal challenge. But the amici supporting EPA here are especially notable for their breadth and expertise. They represent a far-reaching set of interests and entities, including a large coalition of the nation’s power companies, former power company leaders, major American businesses and manufacturers, power sector experts, climate scientists, legal scholars, medical and public health experts, almost 200 members of Congress, and the Edison Electric Institute – which represents numerous companies that would themselves be regulated under any hypothetical EPA rule filed in support of EPA’s authority here.

Such a substantial showing of amici underscores the significance of maintaining EPA’s authority to regulate climate pollution and protect human health and the environment in the face of aggressive attacks from the coal petitioners and their allies.

Here’s more about the amicus briefs:

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Posted in Clean Power Plan, EPA litgation, Greenhouse Gas Emissions, News, Policy / Comments are closed

Safeguarding EPA’s authority at the Supreme Court is a climate imperative

Coal companies and supporting states recently filed opening briefs in West Virginia v. Environmental Protection Agency, a case involving the Trump Administration’s repeal of, and weak replacement for, the 2015 Clean Power Plan regulating carbon dioxide emissions from power plants.

Although neither regulation is in effect – indeed, EPA has indicated that it plans to adopt a new rule working from a clean slate — Petitioners seek to use this case to effect sweeping changes in longstanding legal doctrine and well-established norms. Petitioners are not only asking the Court to do extraordinary damage to EPA authority, but also set forth their arguments expansively so as to apply to a wide range of vital services and laws – turning this case into one broadly relevant to the ability for expert agencies to protect human health, the environment, and other public values.

These concerns are not theoretical. Petitioners have filed papers with the Supreme Court that argue that tight constrictions should be put around EPA’s efforts to address climate change. What Petitioners seek stands in stark contrast to what this moment demands and ignores the fact that Congress intended EPA, through the Clean Air Act, to address big problems like nationwide air pollution coming from the country’s largest industries.

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Posted in Clean Power Plan, EPA litgation, News, Policy / Comments are closed

Washington and Wall Street must act now to protect Americans’ financial futures from unfolding climate change harms

This piece was co-authored by Stephanie Jones, Attorney, Climate Risk and Financial Regulations, and Gabe Malek, Project Manager, Investor Influence at EDF.

Climate change poses grave risks across society, including “more frequent and intense storms, wildfires, and heatwaves as well as more damaging droughts and more extensive ecosystem losses.” All people face climate harms, today: “this year alone, extreme weather has upended the U.S. economy and affected one in three Americans.” Policymakers must act with urgency to protect all Americans in the face of the unfolding climate crisis, and safeguarding peoples’ financial health and stability is urgent and paramount – no American should face financial jeopardy due to the harms climate change poses to their retirement account or ability to prudently manage personal and home finances.

Importantly, Washington and Wall Street are increasingly taking steps to recognize and manage climate risks. A number of important activities have taken shape in recently weeks, all designed to protect Americans’ financial futures. Measures range from proposed rules that would improve lifelong retirement savings plan selection to report findings that make transparent the harms climate change presents to the foundational stability of our banking system.

Eight of the most significant recent U.S. developments in the last few months of 2021 are highlighted below. It is crucial that we build upon these steps and take concrete, urgent action now to protect families, all people with bank accounts small and large, investors from main street to wall street, retirees, and all who depend on a financial system that is not destabilized by climate change.

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Posted in Greenhouse Gas Emissions, Policy / Read 2 Responses

Why Electric Utilities Must Engage in Climate Resilience Planning

(This post was co-authored by EDF’s Sarah Ladin and Romany Webb of the Sabin Center for Climate Change Law at Columbia Law School)

As the owners and operators of immense infrastructure, electric utilities are particularly vulnerable to the impacts of climate change.

Many electric utilities are already struggling to respond to higher temperatures, changing rain patterns, more intense storms, and other climate impacts. Those impacts impair the operation of electric generation, transmission, and distribution infrastructure. The situation will only worsen in coming decades, which makes it imperative that electric utilities act now to identify future climate impacts and develop tools and processes to manage them.

This type of planning is not just good practice, however. In our new report, Climate Risk in the Electricity Sector: Legal Obligations to Advance Climate Resilience Planning by Electric Utilities, we show that it is also legally required under state public utility law and tort law.

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Posted in Energy, News, Partners for Change / Comments are closed

DOE seeks unprecedented action to exempt coal from competitive markets

(This post was co-authored by EDF’s Rama Zakaria)

Secretary of Energy Rick Perry today announced a sweeping and unprecedented proposal to pay coal and nuclear power plants, a move that would increase electricity bills and climate pollution for Americans.

The proposal would impose a new cost on all electric ratepayers that would be paid primarily to owners of coal plants, undercutting billions of dollars of investment by people risking their capital to compete in and transform our energy markets.

The decision, based on mischaracterized reliability concerns, ignores a recent Department of Energy (DOE) report Secretary Perry commissioned that found no reliability concern. The report’s finding is consistent with voluminous literature and evidence that concludes there are no signs of deteriorating reliability on the grid today, and cleaner resources and new technologies being brought online are strengthening reliability.

DOE’s proposal will increase electricity bills and hurt American families

DOE’s proposal provides cost recovery for uneconomic baseload generators such as coal-fired power plants at the expense of Americans’ electricity bills, families and communities’ health, and the environment.

Cost recovery, put simply, means that no matter how expensive coal-fired power gets Americans must foot the bill. No matter how old, expensive, or dirty a coal plant may be, it would be paid to remain online at the expense of cleaner, newer, and less expensive energy resources.

Such regulatory intervention would stand in the way of an economic and efficient electric grid required by law and would impose massive financial losses on the companies that have been investing to build a new and lower cost power system.

Multiple studies have already shown that coal generators that are retiring are old, inefficient units that are relatively expensive to operate. According to one study, coal units that announced plans to retire between 2010 and 2015 were 57 years old – well past their intended life span of 40 years. These units are not retiring prematurely; they are retiring because they are unable to compete against cheaper, more efficient, and cleaner resources.

As Secretary Perry’s own report stated, coal retirements are primarily driven by low natural gas prices. Yet with this proposal, DOE again appears determined to ignore competitive market forces and instead attempt to bail out coal-fired power plants, no matter the cost to Americans. Not only would this increase electricity bills for the public but also unnecessarily expose the public to dangerous and harmful air pollution.

The costly solution to a non-existent problem

A wide range of literature, including DOE’s own baseload study, confirm that electric reliability remains strong and bulk power system resilience continues to improve. Yet, DOE ignores its own findings and suggests that coal bailouts are needed for reliability and resiliency. Not only is DOE trying to solve a problem that doesn’t exist, it is doing so by forcing ratepayers to pay for a solution that doesn’t work.

DOE’s proposal would compensate coal units for a 90-day on-site fuel supply, yet just recently we saw in the aftermath of Hurricane Harvey that W.A. Parish, one of America’s largest coal plants, was forced to shutter two of its units after its coal piles were flooded. Indeed, available data indicates that coal plants fail more than any other resource.

In contrast, clean energy resources are increasingly demonstrating their ability to support reliable electric service at times of severe stress on the grid. For instance, wind energy contributed critical power during Hurricane Harvey. In another example, during the 2014 polar vortex – when frozen coal stock piles led to coal plant failures – wind and demand response resources were increasingly called upon to help maintain reliability.

Cleaner resources and new technologies boost grid reliability and resiliency

Many studies have highlighted the valuable reliability services that emerging new technologies, such as electric storage, can provide. DOE’s own report found that cleaner resources and emerging new technologies are creating options and opportunities and providing a new toolbox for maintaining reliability in the modern power system.

FERC has also long recognized the valuable grid services that emerging new technologies could provide. From its order on demand response to its order on frequency regulation compensation, FERC recognized the value of fast and accurate response resources in cost-effectively meeting grid reliability needs. More recently, FERC’s ancillary service reforms recognize that, with advances in technologies, variable energy resources such as wind are increasingly capable of providing reliability services such as reactive power.

Any action should allow all technologies to compete to provide the least-cost solution to a reliable and resilient grid

Essential Reliability Services, such as frequency and voltage support, are already being procured today to meet grid reliability needs. For instance, frequency regulation is procured as part of the ancillary services markets. These markets allow all resources to compete and to provide the necessary grid services at least cost to Americans.

FERC should ensure that any additional action taken in response to DOE’s proposal continues to be fuel-neutral, non-discriminatory and in-market. By doing so, Americans can not only have reliable and affordable electricity but can also reap the benefits of cleaner and healthier environment.

Posted in Economics, Energy, News, Setting the Facts Straight / Read 6 Responses