Climate Change

Dengue Fever in US Headlines: Not Breaking News

July 18, 2010 16:27
by J. Wylie Donald
When the "Dengue Fever1 in Key West" story broke last week, we were all set to regale you on the IPCC's prediction of tropical diseases expanding their range, Disney cruise lines re-routing their vessels and tourists canceling their vacations.  It was a good thing other activities got in the way of blogging.  As it turns out, the story gets much more interesting.      One of the concerns raised by climate change is that tropical diseases such as malaria and dengue fever will infect more people.  The theory is that the altitudinal and latitudinal ranges of the vector - the mosquito - will increase as temperature rises.  This in turn will bring infected mosquitoes in contact with more people and raise the incidence of disease.  In 2007, it was reported "Climate change is accelerating the spread of dengue fever throughout the Americas and in tropical regions worldwide."  http://news.nationalgeographic.com/news/2007/09/070921-dengue-warming.html.  The science, however, since then concludes that climate change is a minor factor in the incidence of dengue and attributes more significance to population growth, urbanization, lack of sanitation, increased long-distance travel, ineffective mosquito control, and increased reporting capacity.  http://www.cdc.gov/dengue/entomologyEcology/climate.html   The "Dengue Fever in Key West" story may have hit the national press last week, but it was the subject of a Department of Homeland Security "National Terror Alert" in May, http://www.nationalterroralert.com/updates/2010/05/23/dengue-fever-hits-key-west-florida/, after the CDC reported in its Morbidity and Mortality Weekly Report of an increased incidence in Key West based on cases emerging in the previous 10 months.  http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5919a1.htm    The CDC made no connection to climate change:  "Why dengue has reemerged in Florida at this time is unknown. Dengue might have been present in the community earlier and is only now being detected. The environmental and social conditions for dengue transmission have long been present in south Florida: the potential for introduction of virus from returning travelers and visitors, the abundant presence of a competent mosquito vector, a largely nonimmune population, and sufficient opportunity for mosquitoes to bite humans."   If not new news, what precipitated the national furor?  It turns out that the CDC resurrected the story with a press release in anticipation of the International Conference on Emerging Infectious Diseases held last week in Atlanta.  The CDC announced:  "Report Suggests Nearly 5 Percent Exposed to Dengue Virus in Key West."  http://www.cdc.gov/media/pressrel/2010/r100713.htm  This headline was based on the cases reported in the May report, which were then extrapolated to the Key West population, but using an inaccurate value.  http://www.keysnet.com/2010/07/17/239503/cdc-errs-in-level-of-dengue-cases.html Key West authorities were upset and extracted this statement from the CDC (which was reported yesterday):  "In no way, shape or form do we want to discourage people from going to Key West."   So what can we take from all this?  First, while climate change may be involved in many of the changes we see around us, it may not be the significant factor in the new event.  Second, the headline may not accurately state the substance of the story.  As the CDC acknowledges, the conditions "have long been present" for dengue in Key West and the current detections may be reflective of ongoing but undetected dengue infections.   Third, someone's ox is always gored.  The CDC's paramount concern is protecting the public health.  But that is tempered with its knowledge of the economic harm an epidemiological indictment of an area can cause.   Public officials will not let the CDC forget that part of the equation.      And now we come back to Disney cruises and vacations.  The CDC reports that the most effective way to protect against dengue fever is to avoid being bitten, which might suggest canceling a cruise or a vacation.  A cautious traveler will have procured travel insurance; however, a word of caution is in order:  read your cancellation coverage; not all policies cover cancellation for an epidemic or fear of an epidemic.   1Dengue or dengue fever is a tropical disease infecting globally nearly 100,000,000 people annually; 25,000 of those infections turn out to be fatal.  Symptoms of dengue fever are high fever, headaches, eye pain and joint pain.  Dengue is not uncommonly reported along the Texas-Mexico border.  Before detection in 2009, it had not been seen in Florida since 1934.

Climate Change

NFIP Renewal. Finally. For a Moment.

July 6, 2010 16:22
by J. Wylie Donald
Well, they finally got around to it. Since May 31 the National Flood Insurance Program has had no authority to issue flood insurance contracts. The House approved extending the NFIP's authority on June 23, the Senate on June 30, and the President signed the bill July 2, retroactive to June 1 (fittingly, the first day of the official Atlantic hurricane season). This is not a new circumstance. The NFIP's authority first lapsed on March 1, again on March 28 and will do so again on September 30, absent a long-term extension. So what does it mean when the NFIP can't make loans? Dante described a place of sadness and hopelessness in Limbo, the first circle of hell. The metaphor seems apt: a would-be home or small business buyer that cannot get required flood insurance, cannot purchase; she is stuck in a bureaucratic Limbo from which there is no escape but the grace of Congress. Ditto for the home or small business seller. Is there reason to think otherwise? The various National Flood Insurance Acts forbid lenders from making loans on property located in a Special Flood Hazard Area where federal flood insurance is available. 42 U.S.C. § 4012(a). Since the lapse in NFIP authority means that federal flood insurance is not available, lenders are authorized to make loans on property in the flood plain, without requiring flood insurance first. The FDIC confirms this in its May 7, 2010 Financial Insitution Letter FIL-23-2010 (click here.)  However, lenders are not released from the obligations under the Acts to make flood determinations, provide notices to borrowers and otherwise comply with the flood insurance regulations. The FDIC confirms that lenders "should evaluate safety-and-soundness and legal risk and prudently manage those risks during the lapse period." Lenders are also required to establish a program to ensure that borrowers obtain flood insurance when (as has happened) the program is reauthorized.   So, what is a prudent lender to do during the lapse period. The FDIC recommends: 1) postpone closing the loan (see Limbo above), 2) close the loan and require the borrower to obtain private flood insurance (which, if such existed at favorable rates, would demonstrate the NFIP is unnecessary), and 3) make the loan without requiring the borrower to apply for flood insurance. But that is a Catch-22 as well. As the FDIC points out, "Each lender remains responsible for protecting its collateral from risk in a manner appropriate to the circumstances ...." If the property is in a SFHA, a loan is given and the property is destroyed by flood, what regulator will recognize that as a prudent lending practice "appropriate to the circumstances"? So, even if lenders may lend when the NFIP lapses, it seems evident that they will not. As we have written before, the NFIP has numerous issues (premiums that do not match risk, billion dollar deficits, lack of penetration into the populations at risk). Serial lapses of authority and serial reauthorization simply compound these problems.

Climate Change | Climate Change Litigation | Weather

A Cell Phone EMF Ordinance in San Francisco - Bad Precedent for the Smart Grid

June 16, 2010 17:43
by J. Wylie Donald
In a setback for cell phone providers, San Francisco is likely to become the first city in America to require cell phone companies to provide information on how much RF (radiofrequency) radiation their devices emit.  Yesterday San Francisco's board of supervisors voted 10-1 to approve this requirement and it is expected that the mayor will sign the ordinance into law.  Opponents of the measure point out that all cell phones emit at levels far below federal standards.  The new law is likely to create expectations in consumers that cell phones with lower emissions are safer, when there is no evidence this is the case.   What does this have to do with climate change and renewable energy?  We were hoping you would ask.  California is also the site of challenges to the Smart Grid1 based on assertions of unacceptable risks arising from electromagnetic radiation emitted by the devices comprising the Smart Grid's Home Area Network.  Notwithstanding the ubiquity of electromagnetic radiation emitted by cell phones and wireless networks, a small group of determined opponents, the EMF Safety Network, has asked the California Public Utilities Commission to modify its final opinions on the applications of Pacific Gas and Electric Company (PG&E) "for authority to deploy an Advanced Metering Infrastructure (AMI) project known now as the Smart Meter program," and to change the technology used in the Smart Meter program (Click here).   The Network is no shrinking violet.  It successfully challenged a wireless provider that wished to provide free wireless service to downtown Sebastopol, California.  Today, although you can get wireless at Starbucks in Sebastopol, do not look for it in Ives Park.    Against PG&E the Network argues that the Commission "did not adequately address health, environmental, and safety impacts related to widespread deployment of RF Smart Meter technologies, either in the scoping memo or the decision in either proceeding."  According to the Network "PG&E’s Smart Meter RF emissions data is inconsistent, contradictory and at odds with other RF expert findings. An independent RF emissions study, reflecting actual operating conditions for the Smart Meter program, is critical for interested parties to evaluate evidence of health, environmental, and safety impacts, including but not limited to Federal Communications Commission (FCC) compliance."   We don't want to give too much, or even any, credit to the Network's arguments.  A paper they like to cite, the BioInitiative Report, has been reviewed by the EMF working group of the European Commission. (Click here) The group's words are plain:    Ms Cindy Sage of Sage Associates (USA) is the author of the "Summary for the public" that is written in an alarmist and emotive language and whose arguments have no scientific support from well-conducted EMF research. She is also the author of five more chapters (with a total of 6 out of 17 chapters) and the co-author of the final key chapter on policy recommendations. There is a lack of balance in the report; no mention is made in fact of reports that do not concur with authors’ statements and conclusions. The results and conclusions are very different from those of recent national and international reviews on this topic (see Annex 1 and 2). The Network's other arguments are equally far out of the mainstream.  Nevertheless, PG&E has to deal with them.  And so will other utilities.  We have seen similar types of attacks before.  In our work dealing with concerns over radioactive isotopes in the baby teeth of children living around nuclear power plants, the same tired unsupported pseudo-scientific arguments were trotted out at public meetings in numerous jurisdictions.  As soon as one public health authority or nuclear regulator rejected the position, it would surface in the state next door as if it had never been knocked down. Nevertheless, the regulators did not back down and continued to close the door to the Tooth Fairy Project (as it called itself).   Utility regulators should do the same with these attacks on the Smart Grid.  The public health risk from climate change is immense.  The Smart Grid is one of the technologies central to reducing carbon emissions and efficiently utilizing numerous energy resources.  We adopt pseudo-science and alarmism at our peril.   1For those unfamiliar with the Smart Grid, briefly described, the Smart Grid applies digital processing and communications technology to the electricity distribution system, all the way to the end user.  Application of this technology permits, among other things, utilities to better manage demand (including that of individual households), connect small power sources such as solar cells and individual wind turbines to the grid, and respond to power grid failures.  In the end this should lead to increased efficiency and reliability of the grid and will save consumers money and reduce carbon dioxide emissions.

Climate Change

TransCanada renewable lawsuit scores a win in MA

June 11, 2010 09:33
It’s only been about three months since TransCanada Power Marketing Ltd. sued the Massachusetts Department of Public Utilities (DPU), its commissioners, and several other Commonwealth agencies, claiming that Section 83 of the Green Communities Act discriminates against out-of-state renewable energy projects in violation of the U.S. Constitution, but the case has already scored a win for TransCanada. This week, the DPU issued an emergency rule eliminating the in-state requirement from the regulation that mandates electric utilities buy their renewable energy from projects installed in Massachusetts or off-shore wind in the Cape Cod area.  The emergency rule came just 9 days after TransCanada filed a notice of dismissal “with prejudice” to drop its lawsuit against the three named individual commissioners of the DPU. Renewable energy industry insiders were buzzing with talk about this case at the 17th Annual New England Energy Conference in Providence, RI, Monday and Tuesday.  Rumors had it that Commonwealth lawyers and officials were anxious to settle with TransCanada to make this case go away.  And so the emergency rule issued on June 9th takes a major step in that direction.  In fact, the Boston Herald observed this week that the Legislature apparently suspected this provision was unconstitutional when the Green Communities Act was enacted two years ago because the act allowed the DPU to specifically strike down the provision in the event of legal action to challenge it. Without a court decision on the merits of the TransCanada case, however, the question remains how far a state can go in promoting in-state installations of renewable energy projects without running afoul of the Dormant Commerce Clause of the U.S. Constitution. Can a state survive a constitutional attack if it mandates in-state renewable installations in exchange for in-state qualifying renewable energy certificates? While it’s possible the federal court in Massachusetts might get a chance to decide this issue as part of TransCanada’s pending motion for a preliminary injunction, I expect that the rest of the case will get settled quickly as well and the court will not get a chance to issue a decision on the merits.  We will likely have to wait another day for the courts to answer the constitutional questions presented by renewable carve-out provisions.

Climate Change | Legislation | Regulation | Renewable Energy

MIRANT Sues in Challenge to Montgomery County Carbon Tax

June 3, 2010 05:22
by J. Wylie Donald
"First in the nation" touts one website. Another speaks of the "kickstart ... to a low-carbon future." Montgomery County, Maryland has leaped over the gridlock in Washington and passed a tax of $5 per ton from any stationary source emitting more than a million tons of carbon dioxide per year. One web site quotes the bill's sponsor: "This is a chance for us to lay claim to a revenue stream and clean up after a polluter at a time when we are under financial constraints." (click here) There is no dissembling here. Two points come through loud and clear: 1) carbon dioxide is being lumped in with PM10, NOx and SOx, mercury and all the other things that might go up a stack; and 2) a new revenue stream has been found and tapped.

Carbon Dioxide | Climate Change

2010 Hurricane Season: A Product of Climate Change, or Not?

May 28, 2010 04:13
by J. Wylie Donald
On Monday night on the last day of May we will make our way home from our various Memorial Day activities and on Tuesday welcome the 2010 Atlantic hurricane season.  It looks ominous.  The National Oceanic and Atmospheric Administration reports that this year could be “one of the more active on record.”  A few things form the basis for this prognostication. First, wind shear in the upper atmosphere is deadly for hurricanes.  In 2009 El Niño in the eastern Pacific was strong, and so was the wind shear it generated.  This year El Niño has dissipated.  Second, sea surface temperatures are higher than average.  Low wind shear and high sea surface temperature support hurricane formation.  Third, favorable wind flows off the west coast of Africa are expected.  Scientists refer to the pattern of warm waters and favorable winds over decades as the “tropical multi-decadal signal.”  A component of the tropical multi-decadal signal is the “Atlantic multi-decadal oscillation” or AMO, which is primarily identified with Atlantic sea surface temperatures.  The current state of the oscillation favors the formation of hurricanes and began in 1995. It is worth noting that the AMO arises independently of climate change.  The IPCC includes a discussion of the AMO in its 2007 report.  The language is dense but the graphs are not and I commend them to you. Click here.  To even a lay reader like myself, it is quite apparent that something is cycling and that, whatever it is, we are in the middle of the hot portion. So the interesting question is whether the AMO and climate change together will lead to more severe and more frequent hurricanes.  A working group of the World Meteorological Organization addressed this question in a statement published in 2006. Click here.  To quote the WMO:  “The scientific debate … is not as to whether global warming can cause a trend in tropical cyclone intensities. The more relevant question is how large a change:  a relatively small one several decades into the future or large changes occurring today?” This is no small question.  If climate change will increase the severity and frequency of hurricanes today, then many of the steps society is taking right now may be inadequate.  Building codes, zoning decisions, and emergency response planning are all based on the likely scenarios to be encountered.  But it just may be that we don’t know the likely scenarios.  By the same token, if the climate change effect will not be noticed for decades, strategies for adaptation can be successful. The WMO working group meets again at the end of hurricane season in November.  For planning purposes, let’s hope they can provide more guidance.  In the meantime, maybe a trip to Kansas is in order.

Climate Change | Wind Energy | Weather

Cape Wind Approval Signals (Regulatory) Tide is Turning for U.S. Offshore Wind Development

April 29, 2010 09:53
Several European countries already have offshore wind farms, including Denmark, Ireland, the Netherlands, Sweden, and the United Kingdom.  Earlier this year, China completed the installation of its Shanghai Donghai Bridge offshore wind farm project, which has a total installed capacity of 102 MW (enough to power 200,000 Shanghai homes) and is the first large scale offshore wind farm constructed outside Europe.  As for the United States, the Department of Interior (DOI) had issued a report last April which noted (in part) that 28 of the contiguous states have a coastal boundary (including the Great Lakes), 78% percent of the electricity demand in the United States is from the coastal states, and offshore wind has the potential to meet a large proportion of that demand.  As analyzed by the National Renewable Energy Lab, over 1,000 gigawatts (GW) of wind potential exists off the Atlantic Coast and over 900 GW of wind potential exists off the Pacific Coast.  Despite the great potential for offshore wind in the United States, not one offshore wind project has been approved for construction in the United States…until now.  On Wednesday, April 28, 2010, Secretary Salazar approved the Cape Wind project to be constructed on the intercontinental shelf off of Massachusetts.  The regulatory tide is turning…  Approval of the Cape Wind offshore wind project despite contentious opposition by certain groups provides regulatory support for offshore wind and provides some guidance for several other offshore projects that have been proposed in the last few years.  The development of wind projects in the United States, which are (by all accounts) capital-intensive, has been hampered by concerns about the financial markets, the overall economic downturn, regulatory uncertainty as to the future role for renewables in energy policy, and environmental issues.  While Congress has yet to pass comprehensive climate and energy legislation, the approval of the Cape Wind project signals that large scale renewable energy development can play a role in economic recovery and in energy independence and that opposition by those who believe offshore wind farms are unsightly will not prevail when other factors align in favor of the development.   The process for the Cape Wind project began in 2001, when Cape Wind Associates, LLC, submitted an application to the United States Army Corps of Engineers (the Corps) for a permit to construct an offshore wind power facility in Nantucket Sound.  Public review and opposition followed.  According to the DOI, the proposed Cape Wind project is expected to meet 75% of the electricity demand for Cape Cod, Martha’s Vineyard, and Nantucket combined and cut carbon dioxide emissions from traditional power plants by 700,000 tons per year.  The Cape Wind facility will occupy a 25-square-mile section of Nantucket Sound and produce enough energy to serve more than 200,000 homes in Massachusetts.  The maximum energy output of Cape Wind is 468 MW, with an average anticipated output of 182 MW.  The project includes a 66.5-mile buried submarine transmission cable system, an electric service platform, and two 115-kV lines connecting to the mainland power grid. Success begets success.  And so, even though the United States is not the first country to approve the construction of an offshore wind farm, this is very encouraging for wind energy developers, the construction industry, and financial investors who were waiting to see whether the 9-year old Cape Wind proposal would pass regulatory - and especially environmental - muster and then survive the aesthetic opposition raised by some.       

Climate Change | Renewable Energy | Solar Energy

How Do You Spell Certiorari? Climate Change Suits En Banc

April 1, 2010 18:33
by J. Wylie Donald
"Plaintiffs' homeowner's insurance premiums have dramatically increased as a result of global climate change." So asserts Ned Comer and his co-plaintiffs in their Supplemental Brief on Rehearing En Banc, filed yesterday with the Fifth Circuit in the en banc appeal of Comer v. Murphy Oil USA. Although those premiums do not resurface anywhere else in the brief, presumably their insertion is to demonstrate "an invasion of a legally protected interest which is (a) concrete and particularized and (b) actual and imminent, not 'conjectural' or 'hypothetical'. Lujan v Defenders of Wildlife, 504 U.S. 555, 560 (1992). In other words, they may establish the constitutional base for standing. Little did we know ....   Unfortunately for the plaintiffs, the requirements for standing do not stop there. The Lujan decision continues: "there must be a causal connection between the injury and the conduct complained of - the injury has to be fairly traceable to the challenged action of the defendant ..." Id. Plaintiffs are dismissive of the Comer defendants' abilities to sustain their arguments on this point. That may be myopic. The causation hurdle was expressly enunciated in the district court's opinion: "I foresee daunting evidentiary problems for anyone who undertakes to prove, by a preponderance of the evidence, the degree to which global warming is caused by the emission of greenhouse gases; the degree to which the actions of any individual oil company, any individual chemical company, or the collective action of these corporations contribute, through the emission of greenhouse gases, to global warming; and the extent to which the emission of greenhouse gases by these defendants, through the phenomenon of global warming, intensified or otherwise affected the weather system that produced Hurricane Katrina."  Comer v. Nationwide Mut. Ins. Co., Civ. A. No. 1:05 CV 436-LTD-RHW, 2006 WL 1066645, *4 (S.D. Miss. 2006). Defendants recognize a winning argument and are pressing it in their papers: "Plaintiffs' claims require a piling of inference upon inference to causally connect Defendants' GHG emissions with damages suffered by Plaintiffs during Hurricane Katrina." Petition for Rehearing En Banc.  As stated in the defendants' introduction: "Plaintiffs seek to impose liability on Defendants premised on conclusory and speculative allegations: Defendants' GHG emissions over decades, along with the emissions of millions of other actors around the world, contributed to global warming, which in turn increased ocean temperatures, which in turn raised the possibility of hurricanes forming with increased ferocity, which in turn contributed to Hurricane Katrina's strength, which in turn harmed Plaintiffs."  Id.  Plaintiffs counter, however, that proximate cause simply is not an element of standing analysis. Coupled with the causation element of standing, defendants also re-assert the political question doctrine, which was adopted by the Native Village of Kivalina v. ExxonMobil trial court (now on appeal to the Ninth Circuit) and the California v. General Motors trial court (appeal abandoned), but rejected by the Second Circuit in Connecticut v. American Electric Power. The Second Circuit likewise rejected the Connecticut defendants' petition for rehearing or rehearing en banc. Observers feel that a petition for certiorari is inevitable. Oral argument in Comer is scheduled for the week of May 24. It is sure to be interesting. If defendants prevail, the circuit court split increases the chances that climate change will lodge another appearance before the Supreme Court. For my purposes (following insurance issues), I will be watching to see if plaintiffs' premium argument is indeed a premium argument.

Climate Change | Weather | Greenhouse Gases

Remember Hurricane Wilma? The Damage is Still Not Paid For

March 7, 2010 18:15
by J. Wylie Donald
There was scary news out of Florida at the end of last month. Insurers were lobbying the cabinet for an increase in catastrophe fund insurance policyholder fees. This is the surcharge Florida regulators place on every automobile and property policy to pay for the Florida Catastrophe Fund, which needs up to $710 million to pay for 2005 (sic) claims that are still coming in. The Fund managers sought to increase the current surcharge from 1% to 1.3% of premiums. The increase was rejected by the Florida cabinet, ostensibly because of concerns over fraud. Seems public adjusters in Florida are too effective and have precipitated an unbudgeted increase in payouts from the Fund. The explanation for the increase in claims and payouts is that fraud is being carried on. Cynical observers cite a different reason. Governor Crist is running for the Senate and is not going to be tagged with increasing the cost of insurance. Whatever the reason, what should really be cause for concern is that the Fund may need an additional $710 million. I have blogged repeatedly and skeptically on the beach pools and wind pools. Turns out I am not alone. Zurich Insurance Company published a White Paper last summer that makes the point far more eloquently than I did.   In The Climate Risk Challenge: the role of insurance in pricing climate-related risks, http://www.zurich.com/main/insight/introduction.htm, Zurich posits that in addressing climate change, there is a great need to engage the insurance industry's skill in managing risk. The trick is how to engage an industry whose business is protecting private assets, so that that protection furthers the public good. Zurich points out that this has been done before. Fire protection codes and vehicle safety requirements are two areas of note. Following along in that vein, climate-friendly requirements that are built into zoning and building codes, such as hurricane-proofing structures, mandating energy efficiency, and restricting construction in flood -prone areas, can be supported by insurance products, which will bring market forces into play. However, as Zurich notes, "The ability of the insurance industry to assist public policy-makers in the effective and efficient implementation of climate change policy is to a large extent dependent on [policymakers'] willingness to resist the temptation to distort markets in a manner that interferes with the role of and ability of insurers to send price signals about risk." Distortion seems rampant in Florida. In the fifth year after Hurricane Wilma, the Florida Catastrophe Fund still lacks sufficient funds to pay for those claims. Perhaps more significantly, the procedure in place to pay for those losses cannot do so. Zurich's tag-line is "Because change happenZ." I would amend that. "Because climate change is happening." Policymakers need to tap into the experts who manage the balance between risk exposure and financial sustainability. Until the Florida insurance market reflects true price signals for risk, those experts are very likely to remain sitting on the sidelines and Florida's hurricane risk effectively uninsured.

Climate Change | Flood Insurance | Insurance | Weather

CDP 2010 Is Upon Us

March 5, 2010 17:02
by J. Wylie Donald
We talked in January about the SEC's disclosure guidance and noted the relevance of the Carbon Disclosure Project. It's almost as if I have a hotline to 40 Bowling Green Lane in London, where the CDP offices are. I receved earlier this week their announcement of the 2010 questionnaire. It has been sent to 4,500 companies globally. The number of institutional investors behind the mailing is over 500 "with a combined US$64 trillion of assets under management." The email has this to say about the SEC guidance: "CDP welcomes the recent climate change risk disclosure guidance by the Securities and Exchange Commission (SEC); an important step in helping US companies better report material climate change impacts to their investors." Following one of the links in the email, I proceeded to the CDP webpage, where I learned more. The CDP recognizes one of the critical weaknesses of climate change data in a global marketplace: "There is currently no global carbon disclosure framework and ... to minimize the financial and reporting burden for companies, guidance on disclosure of climate change information must be as harmonized as possible." To achieve that end, CDP manages the activities of the Carbon Disclosure Project(CDSB). The CDSB has prepared a draft Reporting Framework www.cdsb-global.org/uploads/pdf/CDSB_Reporting_Framework.pdf to further the dialogue of disclosure. In the CDSB's words: "the Reporting Framework provides a workable filter for companies to identify, and for investors to see, the major trends and significant events related to climate change that affect a company’s current or future financial condition."

Carbon Dioxide | Climate Change

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