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Climate Central argues that the Department of Energy (DOE) report, “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate,” fails to represent the scientific consensus and should not serve as a policy basis. The organization asserts that the DOE report selectively ignores two decades of scientific developments and omits major international assessments. Specifically, Climate Central contends that the DOE understates the link between human-caused climate change and the increasing intensity, rainfall, and rapid intensification of hurricanes, as well as the acceleration of sea-level rise. It further argues that the DOE's analysis of temperature extremes is misleading by focusing on the 1930s Dust Bowl era without global context and that its assessment of wildfires in the western U.S. is incomplete. Finally, the document disputes the DOE's claims regarding solar variations and the validity of extreme event attribution (EEA) methodologies, while arguing that the DOE's use of GDP to downplay disaster costs ignores the increasing physical hazards of climate change.

The document argues that medical debt is a systemic issue in the United States, disproportionately affecting vulnerable populations and causing severe financial and physical harm. It specifically highlights the role of private equity in increasing healthcare costs and employing aggressive debt collection strategies through Revenue Cycle Management (RCM) companies. The authors support the CFPB's proposed rule to stop the reporting of medical debt to credit agencies, noting that such data is an unreliable indicator of financial responsibility and is often inaccurate.

The Clean Air Task Force and Pacific Environment argue that proposed LCFS amendments, including strengthened carbon intensity targets and the inclusion of intrastate aviation fuel, risk driving up demand for crop-based biofuels. They warn this could lead to increased greenhouse gas emissions from land use changes and disruptions to food markets. The authors recommend volume limits on first-generation vegetable oil-based fuels, annual market impact assessments, and extending sustainability requirements to used cooking oil and waste oils.

TESS expressed support for the finalized MC13 ministerial statement on plastics pollution, viewing it as a positive step that complements the Intergovernmental Negotiating Committee (INC) process. TESS encouraged the development of a post-MC13 workplan that prioritizes the interests of developing countries, least developed countries, and small-island developing states, and suggested that members highlight specific trade-related actions to combat plastic pollution during MC13.

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted comments on the Draft 8th National Greenhouse Gas Inventory Report (NGHGIR) on 31 August 2022. The submission argues that the draft significantly undercounts methane emissions due to the omission of fugitive emissions from the oil and gas industry, pipeline transport, and abandoned mines, and criticizes the use of outdated global warming potential (GWP) metrics and low emission factors for coal mining.

A joint statement from Earthjustice and numerous environmental and community organizations urging the Federal Permitting Improvement Steering Council to withdraw a proposed rule that would add mining as a covered sector under FAST-41. The commenters argue that mining's unique environmental risks, including toxic waste and acid mine drainage, require rigorous and flexible permitting rather than the accelerated timelines and limited judicial review provided by FAST-41.

The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted comments to the National Energy Regulator of South Africa (NERSA) regarding a draft ministerial determination to procure 2,000 MW of new generation capacity. The CER argues that this procurement must prioritize clean, affordable, and renewable energy sources over fossil fuels to align with constitutional obligations and public interest, while criticizing the lack of transparency regarding Request for Information (RFI) responses and the inadequacy of the public consultation process.

A submission by the Canadian Association of Physicians for the Environment (CAPE) and several other health organizations supporting the phase-out of coal-fired electricity generation in Canada by 2030. The document argues that coal plants are major sources of greenhouse gases and toxic pollutants, such as mercury and criteria air contaminants, which cause significant respiratory and cardiovascular diseases and developmental issues in children.

The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted additional comments to the South African Department of Energy regarding the Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP). The CER argues that these plans must incorporate missing cost calculations for coal and nuclear energy, as well as findings from recent studies suggesting that accelerating the decommissioning of coal plants and cancelling new coal and nuclear capacity is the most cost-effective path for Eskom and the national grid.

The document provides scientific justification for the permanent protection of the Northeast Canyons and Seamounts Marine National Monument (NECSMNM). It highlights the area's extreme habitat diversity, its role as a biodiversity hotspot for deep-sea corals, marine mammals, and mesopelagic fish, and its importance as a carbon sequestration site. The authors argue that the current boundaries are the smallest area necessary to protect these 'objects of scientific interest' and serve as a critical reference site for studying climate change and human impacts in the Atlantic.

The document argues that the EPA's proposed 20-month delay of the Chemical Disaster Rule is unlawful, arbitrary, and dangerous to public health and national security. It contends that the delay violates the Clean Air Act's three-month limit on reconsideration stays and ignores the agency's own findings regarding the urgent need for updated risk management programs to prevent catastrophic chemical releases.

The Centre for Environmental Rights (CER) submitted comments to the Department of Environmental Affairs on October 7, 2016, regarding proposed amendments to the Financial Provisioning Regulations, 2015. The CER argues that several proposed deletions of appendices and clauses would create legal uncertainty, reduce transparency, and weaken the state's ability to ensure that mining rehabilitation funds are available and used correctly.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 8 February 2016 regarding the Draft Declaration of Greenhouse Gases as Priority Pollutants and the Draft National Pollution Prevention Plans (PPP) Regulations. The submission argues for greater alignment between these regulations and South Africa's international commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC), while advocating for increased transparency, public access to data, and more rigorous monitoring and verification of greenhouse gas (GHG) emissions.

The Centre for Environmental Rights (CER), acting on behalf of several community and environmental organisations, submitted comments on 11 December 2015 regarding the updated Terms of Reference (ToR) for the implementation of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the ToR must be expanded to ensure broader government participation, mandatory attendance from industry and municipal leaders, and improved transparency and accessibility of air quality data and meeting documentation.

The Clean Air Task Force supports the EPA's first direct regulation of methane in the oil and gas sector but argues that the proposal is insufficient. It recommends expanding the rule to cover liquids unloading, pneumatic controllers, well site compressors, and storage vessels. It further contends that the proposed variable frequency for leak detection and repair (LDAR) is inadequate, advocating instead for a fixed quarterly minimum. Finally, it urges the EPA to use section 111(d) to regulate existing sources, noting that 90 percent of 2018 emissions are expected to come from sources existing in 2011.

The Clean Air Task Force (CATF) supports the readoption of California's Low Carbon Fuel Standard (LCFS) through 2020 but argues against reducing the indirect land use change (ILUC) emissions score for corn ethanol. CATF contends that current modeling, specifically the CA GTAP-BIO model, underestimates emissions by ignoring water scarcity, failing to differentiate between commercial and non-commercial forests, and using flawed yield price elasticity assumptions. The document also highlights the negative impact of corn ethanol on global food security and proposes liquid ammonia as a scalable, low-carbon fuel alternative for the post-2020 period.

The Centre for Environmental Rights submitted additional comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases as priority pollutants, specifically requesting clearer distinctions in the classification of land use and land use change.

The Centre for Environmental Rights, representing several environmental justice organisations and community groups, submitted comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases (GHGs) as priority air pollutants. The submission specifically argues that natural ecosystems should be excluded from the requirement to submit pollution prevention plans.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 21 February 2014 regarding the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. The submission primarily argues that the draft regulations fail to ensure adequate public access to atmospheric emission data and provides recommendations to align the regulations with constitutional rights to information and a healthy environment.

The Centre for Environmental Rights, acting on behalf of groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on 5 February 2013 regarding the draft National Dust Control Regulations published on 7 December 2012 under the National Environmental Management: Air Quality Act, 2004 (AQA). The submission argues for stronger protections for vulnerable populations, more rigorous monitoring standards, and the inclusion of government entities in enforcement.