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Voluntary Measures: An Inadequate Solution to a Pressing Problem
The Clean Air Task Force criticizes the EPA's reliance on voluntary programs to reduce methane emissions from existing oil and gas infrastructure, arguing that such measures lack the enforceability and participation rates necessary to achieve significant climate goals compared to mandatory regulations under the Clean Air Act.
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Document type: Statement
EU ETS review proposal earmarks €160 billion for Europe’s largest polluters
Carbon Market Watch argues that the EU ETS review proposal prioritizes industrial interests over climate goals by earmarking at least €160 billion in free pollution permits after 2020. While the proposal increases the linear reduction factor to 2.2% to meet 2030 targets, the organization contends this is offset by the release of surplus allowances and the continuation of free allocations to prevent hypothetical carbon leakage.
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Document type: Statement
catf_filings_biomass_commentsombepaproposedtreatmentbiomasscpp-64f0c45a1e712307.pdf
The document argues that biomass combustion should not be part of the Clean Power Plan's 'best system of emission reduction' because it emits more CO2 per megawatt-hour than coal and relies on speculative, delayed carbon offsets. The authors contend that the EPA lacks a rational scientific framework for biomass carbon accounting and that 'sustainability' standards are an inadequate proxy for carbon dynamics.
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Document type: Statement
Administrative Appeal of the Final Rule: “Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains,” Docket No. PHMSA 2012-0082 (HM-251), 80 Fed. Reg. 26,644 (May 8, 2015)
Earthjustice and a coalition of local governments and environmental groups are appealing the 'Hazardous Materials: Enhanced Tank Car Standards and Operational Controls for High-Hazard Flammable Trains' final rule. They contend that the rule violates the Administrative Procedure Act by abandoning the notification requirements of the May 2014 Emergency Order without public comment. The appeal argues that the new system—which relies on rail routing analysis and voluntary industry practices—provides retrospective, aggregated data that is less useful to first responders than the weekly, county-level notifications previously required. Furthermore, the petitioners argue that the DOT is improperly restricting public access to train route information by treating it as sensitive security or confidential business information without a legal basis.
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Document type: Statement
Appel des organisations de la société civile à leurs gouvernements concernant la Nouvelle Alliance pour la Sécurité Alimentaire et la Nutrition en Afrique
Civil society organizations gathered at the World Social Forum in Tunis in March 2015 to oppose the G8's New Alliance for Food Security and Nutrition in Africa. They argue the initiative promotes corporate-led agriculture, facilitates land grabbing, and undermines the rights of small-scale farmers. The statement calls for a shift toward food sovereignty, agro-ecology, and the protection of peasant seed systems, demanding that governments suspend New Alliance commitments and prioritize human rights-based agricultural systems.
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Document type: Statement
Call of civil society organizations to their governments on the New Alliance for Food Security and Nutrition in Africa
A statement by social movements and civil society organizations opposing the G8 New Alliance for Food Security and Nutrition in Africa, arguing that it prioritizes corporate interests over small-scale producers and undermines food sovereignty.
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Document type: Statement
El dia mundial del medio ambiente celebramos la gestion comunitaria
Friends of the Earth International advocates for community-based biodiversity management, contrasting it with privatized approaches like bioprospecting and financial mechanisms such as carbon credits. The text highlights the failure of the National Biodiversity Institute (INBio) in Costa Rica as evidence against the privatization of genetic resources and calls for the respect of community rights and traditional knowledge as outlined in the Convention on Biological Diversity.
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Document type: Statement
Comments of the Environmental Integrity Project, Sierra Club, and Earthjustice on FirstEnergy’s application for a minor modification of Permit No. 300370 for the Hatfield’s Ferry Power Station Coal Combustion By-Product Landfill to dispose of coal combustion waste generated at the Bruce Mansfield Power Station
A formal statement submitted by the Environmental Integrity Project, Sierra Club, and Earthjustice urging the Pennsylvania Department of Environmental Protection (DEP) to deny FirstEnergy Generation LLC's application for a minor permit modification. The application seeks to allow the disposal of 2.5 to 2.7 million tons of coal combustion waste annually from the Bruce Mansfield Power Station at the Hatfield’s Ferry Power Station Coal Combustion By-Product (CCB) Landfill.
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S LETHABO POWER STATION ATMOSPHERIC EMISSION LICENCE FDDM-MET-2011-08-P1 ISSUED ON 1 APRIL 2015
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, and the Vaal Environmental Justice Alliance, filed an appeal on May 28, 2015, against the atmospheric emission licence (AEL) FDDM-MET-2011-08-P1 issued to Eskom's Lethabo Power Station. The appeal argues that the Fezile Dabi District Municipality failed to consider critical health impacts and ambient air quality standards when varying the AEL to incorporate the National Air Quality Officer's (NAQO) decisions to postpone compliance with Minimum Emission Standards (MES).
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF ESKOM’S CAMDEN POWER STATION ATMOSPHERIC EMISSION LICENCE MSUKALIGWA/ESKOM H SOC LTD/CPS/0012/2015/F02 ISSUED ON 31 MARCH 2015
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network, filed an appeal on May 20, 2015, against the atmospheric emission licence (AEL) issued to Eskom's Camden Power Station. The appeal argues that the Gert Sibande District Municipality failed to consider the severe health impacts and poor air quality of the Highveld Priority Area (HPA) when granting emission limit postponements that allow pollutants to exceed national minimum emission standards (MES).
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S HENDRINA POWER STATION ATMOSPHERIC EMISSION LICENCE 17/4/AEL/MP312/11/16 ISSUED ON 31 MARCH 2015
This document is a formal appeal submitted by the Centre for Environmental Rights (CER) on behalf of groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network. The appeal challenges the variation of the Atmospheric Emission Licence (AEL) for Eskom's Hendrina Power Station, issued by the Nkangala District Municipality on 31 March 2015. The appellants argue that the AEL improperly incorporates postponements of Minimum Emission Standards (MES) granted by the National Air Quality Officer, thereby permitting pollution levels that exceed national standards in a declared priority area with already compromised air quality.
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Document type: Report
SUBMISSIONS ON THE DRAFT AIR QUALITY MANAGEMENT BY-LAW
The Centre for Environmental Rights (CER) provides detailed legal submissions on a draft Air Quality Management By-law, advocating for stronger public participation, mandatory rather than discretionary emission standards, and the removal of 'rectification' provisions for unlawful activities.
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Document type: Statement
REDD: A Collection of Conflicts, Contradictions and Lies
The publication examines 24 REDD projects or programmes, concluding that their structural characteristics often harm forest communities and fail to reduce overall global emissions because they function as offsets.
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Document type: Report
South Africa: Toxic air is now legal
The statement criticizes the South African government for granting air quality standard postponements to Eskom, Sasol, and Engen on 24 February 2014. It asserts that these postponements effectively legalize toxic air, contradicting Section 24 of the constitution and a 1995 promise by President Mandela. The document highlights the severe health impacts of Eskom's pollution, estimating 20,000 premature deaths and an economic cost of R230 billion, while arguing that industries have had sufficient time since 2004 to implement pollution control technologies.
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Document type: Statement
EU’s announcement for Paris climate deal fails to address loopholes that could slash announced target in half
Carbon Market Watch argues that the EU's commitment to reduce domestic greenhouse gas emissions by at least 40% by 2030 is undermined by a lack of transparency. Specifically, the organization warns that a surplus of 4-6.5 billion emission permits could reduce effective reductions to 17%-26%, and vague accounting for land-use removals could further lower the target by up to 5%.
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Document type: Statement
Die Mär vom freien Handel
The author contends that modern trade agreements like TTIP, CETA, and TiSA are not about 'free trade' but are tools for corporations to secure interests through secret negotiations. The text argues that these agreements erode national sovereignty, prioritize capital protection over ecological and social rights via private arbitration courts, and threaten public services through privatization. Using NAFTA and a US-Peru agreement as examples, the author claims that promises of growth and jobs often fail to materialize for citizens, benefiting only large corporations.
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Document type: Statement
Wspólnie przeciwko zasiekom
The author critiques the European Union's current approach to migration, characterizing it as based on myths that criminalize migrants and ignore the systemic links between environmental degradation and displacement. The text argues that North Africa's future depends on moving away from neoliberal models and resource extraction—such as shale gas in Algeria—toward ecological sustainability and democratic stability. It calls for the recognition of 'ecological refugees' and a reduction of the Global North's ecological footprint to address the root causes of migration.
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Document type: Statement
World Bank Environmental and Social Framework First Draft for Consultation July 30, 2014
Natural Justice submits that the World Bank's Draft Environmental and Social Framework (ESF) fails to align with modern human rights standards, specifically criticizing the 'opt-out clause' in ESS7. This clause allows borrowers to waive ESS7 protections for indigenous peoples if they claim identifying such groups would risk 'ethnic tension' or 'civil strife,' or if it conflicts with national constitutions. Natural Justice contends this nullifies essential protections like Free, Prior and Informed Consent (FPIC), promotes a regressive view of indigenous identity, and sets a dangerous precedent for other international financial institutions.
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Document type: Statement
CITES-Authorized Trade in DRC Timber Continues at Unsustainable Levels
The document criticizes the CITES permit system for failing to prevent the illegal trade of Afrormosia timber from the Democratic Republic of Congo, noting that the 2015 export quota remains high despite incomplete inventories and widespread permit falsification. It highlights a gap in the CITES Secretariat's verification process, which only confirms if a permit was issued by the DRC Management Authority rather than the legality of the wood itself. The authors call on EU and US officials to use independent monitoring reports to assess legality rather than relying on CITES paperwork.
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Document type: Statement
Joint Media Statement by Civil Society Coalition on the MPRDA: Minister Ramatlhodi chooses a dangerous path
A coalition of civil society organisations condemns the South African Minister of Mineral Resources for prioritising corporate interests over the rights and health of mining-affected communities. The statement highlights widespread protests across multiple provinces due to pollution, socio-economic hardship, and the exclusion of communities from the legislative process regarding the Mineral and Petroleum Resources Development Act (MPRDA). The coalition warns that rushing the Amendment Bill without genuine consultation will lead to further instability and constitutional challenges, while also noting the impact of illicit financial flows by multinational mining companies.
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Document type: Statement