The Center for International Environmental Law (CIEL) respectfully submits the following comments regarding the Norwegian Government Pension Fund Global’s (GPFG) investments in coal and petroleum companies. These investments expose Norway to legal, financial, and reputational risks inherent to the fossil fuel sector. Currently, such risks are most intense in the coal sector. Moreover, continued fossil fuel investment is inconsistent with the GPFG’s duty to ensure inter-generational equity as well as Norway’s international obligations. Norway has committed to both protect the interests of future generations and to lead efforts to address climate change. In light of these commitments, the risks inherent to the fossil fuel industry, and the critical need to reduce global emissions, we call on the Expert Group to recommend that the GPFG divest.