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Comments to SEC on Environmental Disclosures

We recently submitted comments to the U.S. Securities and Exchange Commission on business and financial disclosures related to environmental risk. Specifically, we urge the agency to provide rules or interpretive guidance to ensure consistent and effective disclosure of risks from offshore oil and gas activities. Our comments demonstrate that offshore oil and gas operations, particularly in frontier areas like ultra-deepwater and the Arctic Ocean, create material risks that are not being adequately disclosed. We then encourage the SEC to require additional disclosure from companies on the likelihood, cost, and response plan for a catastrophic well blowout; spill prevention policies and practices; and comprehensive data on day-to-day environmental, health, and safety performance. The comments grew out of a project in our Regulatory Policy Clinic with Oceana, and we submitted them collaboratively with Oceana and the University of Chicago Abrams Environmental Law Clinic.