Monthly Archives: June 2022

The French Environmental Policy Agency ADEME has acknowledged Adaptation Leader for its contribution to the Critical Review of the methodology for its Corporate Adaptation Strategy Assessment. ADEME is about to launch a pilot project to road test the methodology with companies implementing adaptation or resilience strategies. Adaptation Leader teamed with Climate Adaptation Works to provide analysis and recommendations

Stephia Latino of ADEME posted on June 19, 2022:

The Article 7 of the Paris agreement defines the global goal of “enhancing adaptive capacity, strengthening resilience and reducing vulnerabilities to climate change.” Despite recommendations including from #TCFD, the Europe Commission on #CSRD standards, #GFANZ et #IFRSISSB, there is no operational framework about adaptation for companies.

To support this goal, ADEME, through the ACT Initiative, has developed the ACT Adaptation methodology. By providing this climate adaptation accountability framework for companies from all sectors, it aims at assessing the quality and comprehensiveness of company’s adaptation strategy, from their physical risk analysis to their governance. As part of the #ACTinitiative methodology development process, the methodology is being road-tested for 7 months with around 15 volunteered companies from various sectors.

Thank you Adelphi Consult GmbH and the Climate Adaptation Works – Adaptation Leader team for their Critical Reviews that enable to enhance the methodology for the Road Test!

ACT Adaptation methodology for the Road Test available at: https://lnkd.in/egc6T-x7

For further information contact Ira Feldman <ira@adaptationleader.org>.

Urges Greater Attention to Adaptation and Resilience in Final Rule, Calls for Enhanced “Adaptation Literacy” among All Stakeholders

The comments submitted to the Securities & Exchange Commission (SEC) on June 17, 2022 are limited to the need for SEC to address adaptation, not just mitigation or GHG reduction.  Adaptation Leader’s comments as submitted are available here.

Adaptation Leader stated its area of interest and expertise in the introduction to its comments: “We will focus on our core adaptation issues and leave the multitude of important comments on mitigation to the many other organizations and individuals who will weigh in before the deadline.  As you may be aware, GHG issues are much more familiar to US audiences, but we hope that the SEC will consider the comments received on adaptation and resilience as seriously.”

Adaptation Leader believes that SEC emphasized mitigation (GHG reduction) in its proposal and therefore did not adequately consider disclosure for adaptation activities and strategies for publicly-held companies.  At the same time, Adaptation Leader described as “excellent” the mitigation provisions proposed by SEC which track the TCFD framework.  Unfortunately, claims Adaptation Leader, the TCFD guidance is heavily mitigation-centric (“adaptation was not in the remit of TCFD”), so SEC will need a separate basis or source for adaptation and resilience provisions.

As a separate point, Adaptation Leader noted its disappointment that SEC opted to limit this proposed disclosure rule to “climate disclosure” rather than a broader ESG scope or full spectrum sustainability. Climate change is an important consideration within ESG disclosure and sustainability reporting, and the topic may be viewed as a useful surrogate, but it does not present the full picture for disclosure purposes.  Earlier petitions to the SEC had called for disclosure regulations that more fully aligned with ESG as it is understood in the financial sectors and investor community.

Adaptation Leader provided specific comments to point SEC staff to passages in the proposed rule that could serve as “hooks” for a more robust adaptation discussion.  Similarly, the comments suggested the need for additional provisions on adaptation and resilience that are analogous to those included in the proposed rule for mitigation, such detailed guidance on metrics and a strong explanation of attestation.

While acknowledging that adaptation lags behind mitigation with respect to standards, practices and financing, Adaptation Leader asserted that “[t]he fact that the adaptation space is not as developed as the mitigation space does not justify SEC’s inattention to adaptation and resilience disclosures in the proposed rule.  To the contrary, SEC should strongly acknowledge how important adaptation is in the climate risk equation and therefore urge greater corporate attention to developing and implementing adaptation strategies.”  Adaptation Leader suggested that the SEC should encourage innovation and experimentation, including through pilots, and, as best practices emerge, SEC “can issue circulars providing more specificity on adaptation metrics and guidance on the materiality of adaptation and resilience related expenses.”

As next steps, Adaptation Leader recommended that the SEC convene a multi-stakeholder dialogue or, as preferred by Federal agencies, a series of “listening sessions,” to become better informed on adaptation and resilience.  Adaptation Leader offered to assist SEC in any such outreach effort to build “adaptation literacy.”

Finally, Adaptation Leader placed this SEC rulemaking in the larger context of US government policy on climate change, noting that: “[i]n the Biden administration’s ‘whole of government’ approach to climate change, the SEC must play its part.  The SEC proposed rule cannot be isolated or cordoned off in its own financial silo.  SEC’s efforts must mesh with the climate initiatives launched by other Federal agencies.”  The only coherent approach tor SEC to take, according to Adaptation Leader, is one that addresses both climate mitigation and climate adaptation.

Adaptation Leader has already received positive feedback that our comments provide not only solid recommendations for SEC, but also useful background information and cites for anyone trying to get up to speed on adaptation as a co-equal concern to mitigation when considering the totality of climate action.  Indeed, the first half of its comments, Adaptation Leader intentionally provided a strong argument for market needs and potential relating to adaptation and resilience.  As Adaptation Leader Founder & Managing Director Ira Feldman explained, “The intended audience for these comments was not limited to SEC staff — there are many others who need to build their adaptation literacy with some urgency.”

For further information, please contact:  Ira Feldman <ira@adaptationleader.org>

The events convened by Bruce Piasecki and his AHC Group each year in Arizona and in Saratoga Springs bring together senior corporate leaders in environment and sustainability to share insights on best practices and learn about emerging trends.  Adaptation Leader was invited to join this high-level gathering on June 16 to present its latest thinking on climate adaptation and resilience, especially as viewed in the ESG context for the financial sectors and the investment community.  The Adaptation Leader ESG team — Peter Soyka, Nina Gardner and Ira Feldman — provided the attendees in Saratoga and online with a preview of their forthcoming white paper, “Viewing ESG through an Adaptation Lens.”  Earlier in the day, Peter Soyka also delivered a sophisticated overview of the current state of play in the ESG space, “ESG: A Dynamic Landscape,” a presentation that was well-received by the attendees and organizers.

In the “Viewing ESG through an Adaptation Lens” presentation, Ira Feldman covered the basics of adaptation and resilience for the benefit of those who had previously only focused on the mitigation component of climate action.  Ira then presented a recap of Adaptation Leader’s recent work on ESG issues, including two prior published commentaries recommending the need for greater attention to adaptation and resilience by the investor community and suggesting that the influential TCFD framework, while strong on mitigation, had inadequately addressed adaptation.

The balance of the presentation, led by Peter Soyka and Nina Gardner, highlighted key points from the soon-to-be released Adaptation Leader white paper.  Climate change is seen as a material risk to businesses and some companies are already planning for anticipated climate impacts.  It was noted, however, that most companies currently have large gaps in climate adaptation strategies and implementation.  In playing catch up on adaptation, large corporations have the ability to innovate and quickly mobilize capital and resources.  The clear message sent was that “the next few years will be pivotal in determining which prosper and which fail as climate-related hazards further disrupt complex market environments.”  Within the capital markets, while ESG is “going mainstream,” the understanding of climate adaptation and resilience remains limited because the “financial risks are not well understood, particularly among retail investors.”

Peter and Nina effectively articulated the implications of the current state of play, i.e., that “unprepared companies expose others to severe risk,” and that “our changing climate requires substantial and decisive action.”  It was suggested that there are “leadership opportunities for corporate executives and board members,” and that companies would be well-served to not wait for regulation.  In the forthcoming white paper, Adaptation Leader identifies a set of key actions required and how both the public and private sectors must lead.  In its concluding “Call to Action,” Adaptation Leader emphasized the urgent need for concerted action on climate adaptation through both awareness raising and the formation of partnerships to address the challenge of climate adaptation.

For further information, please contact:  Ira Feldman <ira@adaptationleader.org>

At the most recent meeting of the steering committee (SC) of the International Platform on Adaptation Metrics (IPAM), Adaptation Leader was elected to join the new-expanded IPAM SC, along with 9 other new members.  Adaptation Leader’s founder & Managing Director will continue to represent the organization for all IPAM matters.

Joining the IPAM SC was a key goal for the not-for-profit Adaptation Leader in 2022 to cement our leadership role with IPAM and in adaptation metrics generally.  One of Adaptation Leader’s core “sweet spots” is Metrics, Standards & Assurance.  Our metrics work will be largely framed by our participation in IPAM activities.

Last year, for example, Adaptation Leader co-hosted a successful pre-COP 26 webinar with IPAM on the state of play in adaptation metrics and what might be addressed at and after the COP in this space.  The recording of that event is available here.

Adaptation Leader’s Ira Feldman has been involved in IPAM activities as an individual member and Adaptation Leader formally became an organizational member of IPAM earlier this year.  Ira continues to actively participate in the IPAM Techniques & Tools Committee.  Recently, he agreed to co-chair that committee’s effort to develop a Compendium of adaptation metrics.  Among IPAM’s other committees, Ira is also participating in its Cities Committee where he will contribute to an ongoing effort to synthesize the relevant scientific literature.

For further information, please contact:  Ira Feldman <ira@adaptationleader.org>