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Climate Change Hero

Climate Change Blog

The Task Force on Climate-related Financial Disclosures (TCFD) Seeks to Revamp Climate Change Disclosures Worldwide

Investors and lenders are beginning to publicly urge companies from a wide variety of industries to implement the June 2017 Final Recommendations of the G20 Financial Stability Board’s (FSB) Task Force on Climate-related Financial Disclosures (TCFD) and account for climate-related risks and opportunities in their public financial filings. The TCFD’s recommendations are a voluntary disclosure framework, but shareholders, non-governmental organizations (“NGOs”), and others are pushing for their widespread adoption. The energy industry will certainly be a focus as the TCFD looks to implement its recommendations, and the recommendations themselves include a note that the group will promulgate additional, sector-specific guidance for the energy industry at a later time. This post provides a step-by-step analysis of the TCFD’s recommendations and how these recommendations incorporate but also move far beyond any current voluntary climate disclosure program. Energy companies should be aware of the full extent of what the TCFD is requesting as they consider their overall policies and strategy on climate change.

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Court Vacates BLM’s Postponement of Obama Methane Rule

On October 4, 2017, in a consolidated decision for Sierra Club, et al. v. Zinke, et al., No. 17-cv-03885, and State of California, et al. v. United States Bureau of Land Management, et al., No. 17-cv-03804, a Magistrate Judge in the U.S. District Court for the Northern District of California vacated BLM’s postponement of its 2016 final rule entitled “Waste Prevention, Production Subject to Royalties, and Resource Conservation” (the “Waste Prevention Rule” or “Rule”). The Waste Prevention Rule imposes additional emission control requirements relating to venting, flaring, and leaking of natural gas from oil and gas production operations on public lands in an effort to reduce methane emissions. The Rule required operators to submit “waste minimization” plans by January 2017 and includes other compliance deadlines, beginning in January 2018. On October 5, 2017, BLM published a proposed rule that would extend the January 2018 compliance deadlines to January 2019. The comment period for this proposed rule is currently open through November 6, 2017.

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  • 07
  • August
  • 2017

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D.C. Circuit Strikes Down EPA Stay on Key Parts of Quad OA — the 2016 Methane NSPS Rule for the Oil and Gas Industry

On July 2, 2017, in Clean Air Council, et al. v. E. Scott Pruitt, No. 17-1145, the D.C. Circuit vacated EPA’s 90-day stay of EPA’s 2016 final rule entitled “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources,” which EPA codified as Subpart OOOOa to 40 CFR Part 60 or “Quad Oa.” Quad Oa overhauled new source performance standards (“NSPS”) for the oil and natural gas sector. A deeper analysis of Quad Oa can be found here. As noted below, Quad Oa is now in effect unless EPA successfully finalizes a proposed rule that would stay for two years parts of Quad Oa. Quad Oa carries certain monitoring and reporting deadlines that will need to be complied with, unless EPA successfully extends those deadlines.

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  • 19
  • June
  • 2017

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EPA Proposes 2-Year Stay on Key Parts of Quad Oa — the 2016 Methane NSPS Rule for the Oil and Gas Industry

On June 16, 2017, the United States Environmental Protection Agency (EPA) published a proposed rule that would stay for two years parts of EPA’s June 3, 2016 final rule entitled “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources,” which amended and established updated new source performance standards (NSPS) for the oil and natural gas sector. This final rule was codified in EPA’s NSPS regulations as Subpart OOOOa to 40 CFR Part 60 or “Quad Oa.” Detailed information about Quad Oa can be found here.

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IHS Markit Challenges Recommendations of the Task Force on Climate-Related Financial Disclosures

In another chapter in the ongoing debate regarding the future of public company disclosures concerning the environment, the London-based consulting firm IHS Markit Ltd. has issued a lengthy report critiquing the Draft Recommendations published in December 2016 by the Task Force on Climate-related Financial Disclosures (TCFD). A handful of energy company supermajors provided financial support for the report, entitled Climate-Related Financial Risk and the Oil and Gas Sector.

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  • 01
  • June
  • 2017

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The Task Force on Climate-Related Financial Disclosures Calls for Never-Before-Used Scenario Analysis in Public Disclosures

In December 2016, the Task Force on Climate-Related Financial Disclosures (TCFD) published Draft Recommendations purporting to set forth “widely adoptable recommendations on climate-related financial disclosures that are applicable to organizations across sectors and jurisdictions.”  Appended to these Draft Recommendations is a Technical Supplement, explaining that the TCFD is calling for companies to analyze and disclose risks related to climate change using a “scenario” analysis. Whether the TCFD’s Draft Recommendations become, in fact, “widely adoptable” will depend in part on how the recommendations square with the current regulatory framework for public company disclosures and how ready companies and the SEC are to support the new methods of analysis and standards for disclosure advocated by the recommendations.

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