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Air of Injustice: How Air Pollution Affects the Health of Hispanics and Latinos
The report details how Hispanic Americans are disproportionately exposed to air pollution, with 71 percent living in counties violating federal air quality standards as of 2002. It identifies specific health risks including asthma, stunted lung growth, and low birth weight, exacerbated by poverty and lack of health insurance. The document also notes risks from mercury contamination in fish and the potential for global warming to induce crop failures and famines. Finally, it argues that the EPA has failed to implement Executive Order 12898 because it has not identified impacted populations or developed criteria for determining disproportionate risk.
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Document type: Report
Technical Realities
The Union of Concerned Scientists concludes that the Block 2004 GMD system is ineffective against real attacks due to a lack of realistic testing and vulnerability to simple countermeasures. The report critiques the Missile Defense Agency's (MDA) claims of high effectiveness, noting that the system's radars cannot discriminate warheads from decoys and that the deployment schedule is driven by political rather than technical milestones.
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Document type: Report
Reforming the Automobile Fuel Economy Standards Program
Amory B. Lovins, CEO of RMI, submits comments to NHTSA challenging the technical basis of its proposed rulemaking on automobile fuel economy standards. He argues that NHTSA incorrectly relies on retrospective correlations between vehicle weight and safety, which fail to account for modern materials like advanced polymer composites and high-strength steels. Lovins asserts that these materials can create vehicles that are simultaneously large, lightweight, and safe, thereby eliminating the perceived tradeoff between fuel economy and crashworthiness. He recommends that CAFE standards be performance-based, technology-forcing, and based on size metrics rather than mass to avoid incentivizing a 'mass arms race' and to maintain the global competitiveness of U.S. automakers.
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Document type: Statement
Separate Comments on the U.S.-Morocco Free Trade Agreement
The Center for International Environmental Law (CIEL) argues that the U.S.-Morocco Free Trade Agreement's investment chapter grants foreign investors excessive rights that exceed those of domestic U.S. investors, violating the Trade Act of 2002. CIEL highlights the risks of the investor-state dispute mechanism, the lack of a general environmental exception, and the use of subjective standards like 'fair and equitable treatment' which could undermine public interest regulations and democratic governance.
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Document type: Statement
Eighteen of Americas most prominent environmental organizations express deep concerns about the Bush Administrations approach towards implementing the Stockholm Convention on Persistent Organic Poll
A coalition of eighteen environmental organizations argues that the Bush Administration's proposed FIFRA amendments fail to effectively implement the Stockholm Convention on Persistent Organic Pollutants (POPs). The groups claim the proposal denies the EPA effective authority to ban additional POPs pesticides, introduces burdensome cost-benefit requirements that contradict the treaty's precautionary principle, and attempts to limit Congressional regulatory power through an unfounded constitutional interpretation. They recommend that implementing legislation adopt a health-based standard of "reasonable certainty of no harm," use international ban decisions as the default for domestic regulation, and ensure the U.S. regulatory process parallels the international decision-making process.
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Document type: Statement
Analysis of Department of Justice Letter Regarding the Constitutionality of Mandatory Notice and Comment Provisions Proposed in Implementing Legislation for the Stockholm Convention on Persistent Organic Pollutants (POPs)
The Center for International Environmental Law (CIEL) argues that the Bush Administration's claims regarding the unconstitutionality of notice and comment provisions in S. 1486 have no basis in U.S. law. The DOJ asserted that requiring the Executive Branch to consult with stakeholders during international negotiations violates the separation of powers. CIEL counters that such provisions do not dictate negotiation outcomes and that Congress has the authority to regulate the domestic acquisition of information. Furthermore, CIEL rejects the 'international nondelegation doctrine' invoked by the Administration, noting that U.S. law frequently contains contingent delegations based on international decisions, such as in the Clean Air Act and the Chemical Weapons Convention Implementation Act.
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Document type: Briefing
New Views of Trade and Sustainable Development: Using Sen’s Conception of Development to Re-examine the Debates
The document critiques the common assumption that economic growth (GDP) is equivalent to development, proposing instead that development should be viewed as the expansion of individual freedoms and capabilities. It argues that trade liberalization only contributes to sustainable development when accompanied by strong domestic institutions—such as education, health, and environmental management—that provide the instrumental freedoms necessary for individuals to act as agents of change. The author suggests that WTO-mandated reforms should move away from 'cookie-cutter' strategies toward tailored packages that protect the policy space needed for developing countries to build these essential domestic institutions.
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Document type: Research paper
Separate Comments of TEPAC Members on the U.S.-Central American Free Trade Agreement (CAFTA)
The authors argue that CAFTA's investment chapter grants foreign investors greater substantive rights than U.S. investors, violating the Trade Act of 2002. They specifically criticize the lack of an appellate review mechanism, the absence of a general environmental exception, and the use of subjective standards like "fair and equitable treatment" which they claim could undermine democratic governance and environmental protections.
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Document type: Statement
Separate Comments of TEPAC Members on the Investment Chapter of the U.S.- Australia Free Trade Agreement
The authors argue that while the U.S.-Australia FTA's lack of an investor-state dispute mechanism is positive, the substantive investment provisions still grant foreign investors rights exceeding those of domestic investors under U.S. law. They highlight risks to environmental regulation, the lack of a general environmental exception, and the subjective nature of 'fair and equitable treatment' standards.
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Document type: Statement
International genetically modified crops a decade of failure [1994 - 2004]
The report claims that the first ten years of GM crop commercialization were a 'resounding failure', noting that promises of cheaper, higher-quality food and the solution to global hunger have not materialized. It highlights the dominance of Monsanto, the failure of the first GM tomato, and the rise of global opposition due to concerns over genetic contamination, biodiversity loss, and corporate control of seeds.
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Document type: Report
A los Ministros de Comercio
The Alliance for Responsible Trade (ART) warns Trade Ministers that proposed intellectual property rules in the Free Trade Area of the Americas (FTAA) could limit governments' ability to provide affordable essential medicines and undermine national sustainable development projects by exceeding TRIPS agreement standards. The coalition also calls for greater transparency in the negotiation process, requesting the publication of clear texts and the holding of national and regional public hearings to ensure substantive civil society dialogue.
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Document type: Statement
Draft U.S. Model Bilateral Investment Treaty-Draft Comments from the Department of State Subcommittee on Investment
The Center for International Environmental Law (CIEL) has formally critiqued a draft report from the Department of State Subcommittee on Investment, claiming it unfairly favors the investment community. CIEL identifies specific inaccuracies, such as the false claim that environmental and labor groups oppose any limitation on governmental authority to regulate, and notes a lack of mention regarding transparency and public participation in dispute settlement. The organization urges a revision of the report to ensure it is balanced and neutral before finalization.
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Document type: Statement
Sending humans to Mars won't save Earth
The statement by Scientists for Global Responsibility (SGR) criticises the US government's proposal for a manned mission to Mars, citing an estimated cost of $1 trillion. SGR argues that these funds would be better spent on global aid—such as providing clean water, eliminating hunger, and achieving universal literacy—and on mitigating climate change. The document further links space exploration goals to military interests and highlights the rising costs of climate-related disasters and biodiversity loss.
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Document type: Statement
Text of an SGR letter sent to the Prime Minister, The Right Honourable Tony Blair, MP, on 6 November 2003
The letter from Scientists for Global Responsibility (SGR) argues that genetic modification of crops is driven by corporate profit and lacks sufficient safety evidence. SGR claims that the UK government is overly supportive of the GM industry and ignores scientific warnings about environmental damage and health risks, such as the creation of superweeds and gene transfer in the human gut.
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Document type: Statement
Doce razones para excluir a las grandes represas hidroeléctricas de las iniciativas renovables
The report presents twelve reasons why large hydroelectric projects are incompatible with the goals of renewable energy initiatives. It contends that these projects fail to alleviate poverty, divert funding from cleaner decentralized technologies, and often suffer from underestimated costs and overestimated benefits. The text highlights severe social and environmental impacts, including the forced displacement of 40 to 80 million people and the emission of greenhouse gases from reservoirs. It further argues that large dams increase vulnerability to climate change, are inflexible and costly to build, and are not truly renewable due to sedimentation.
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Document type: Report
The Case Against GM Crops
The paper contends that genetic modification is an imprecise technology that creates unpredictable biological outcomes and potential health hazards, such as new allergens or toxins. It claims GM crops harm biodiversity, contaminate non-GM and organic farms, and result in lower yields and higher costs for farmers. Furthermore, it criticizes the consolidation of the seed market by a few biotechnology companies and the lack of corporate liability for environmental or health damages.
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Document type: Research paper
Necessity and Proportionality in the WTO
The document argues that shifting from a strict 'necessity' test to a 'proportionality' test in WTO dispute settlements would transfer the power to balance trade interests against public policy goals from domestic democratic institutions to WTO panels and the Appellate Body. It specifically warns that proposed changes to the General Agreement on Trade in Services (GATS) could allow the WTO to outlaw domestic measures it deems 'out of balance' with their objectives, potentially undermining protections for the environment, human health, and consumers.
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Document type: Research paper
Al grano: impacto del maíz transgénico en España
The report examines the impact of transgenic maize, specifically the Bt 176 variety, in Spain. It argues that the Spanish government has failed to implement adequate monitoring and prevention plans, leading to genetic contamination of organic crops and the development of pest resistance. The document claims that transgenic maize does not provide the promised yield increases and poses risks to non-target species and human health through antibiotic resistance markers. It concludes that Spain is uniquely permissive within the EU and calls for a halt to transgenic cultivation until a comprehensive legal and safety framework is established.
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Document type: Report
The impact of GM corn in Spain
The report examines the deployment of Bt 176 GM corn in Spain, highlighting a lack of independent monitoring and the failure of the Spanish government to enforce mandatory 'Prevention Plans'. It documents cases of genetic contamination in organic crops in Navarra and presents evidence from the ITG-A suggesting that corn borers are developing resistance to the Bt toxin. The document further argues that GM corn does not provide superior yields compared to conventional varieties and poses risks to non-target species and human health via antibiotic-resistance genes.
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Document type: Report
U.S.-Chile and U.S.-Singapore Free Trade Agreements are Wrong Models for the Environment
The Center for International Environmental Law and other signatories argue that the U.S.-Chile and U.S.-Singapore FTAs undermine environmental protection through flawed investment rules and weak environmental provisions. They specifically highlight the failure to meet the 'no greater rights' standard for foreign investors, the absence of a citizen submission process, and the lack of an independent environmental cooperation institution, contrasting these agreements unfavorably with the U.S.-Jordan FTA and NAFTA.
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Document type: Statement