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Carbon Market Watch supports the early auctioning of 450 million ETS2 allowances to address a €6.8bn funding gap in the Social Climate Fund for 2027 caused by a one-year delay in the system's start. The organization argues that these revenues should be ringfenced for the Social Climate Fund to help member states implement National Social Climate Plans and protect vulnerable households. Additionally, it supports the requirement that only member states that have transposed the legislation can access auctioning revenues to incentivize timely implementation.

A joint statement by five Canadian environmental and health organizations—Ecojustice, Breast Cancer Action Quebec, the Canadian Association of Physicians for the Environment, the David Suzuki Foundation, and Environmental Defence—providing feedback on the 'Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams'. While the organizations support the proposed risk management measures and their alignment with European Union and Washington State standards, they strongly criticize the proposed implementation timelines, which could allow some facilities to use PFAS-containing foams until 2039.

Carbon Market Watch argues against scrapping the CBAM despite industry complaints about administrative complexity, suggesting instead that the EU quantify actual carbon leakage and circumvention risks before expanding the mechanism to downstream products. The organization emphasizes that complementary EU policies like the Digital Product Passport and international standards can mitigate administrative burdens. It further recommends providing special treatment for Least Developed Countries (LDCs) and Small Island Developing States (SIDS) to align with UNFCCC principles.

Ember argues that the draft FNA methodology focuses too narrowly on "surplus" renewable power rather than the broader goal of decarbonising the electricity system. The organization advocates for renaming flexibility needs to "non-fossil flexibility network needs" to signal a shift away from fossil assets and avoid stranded investments. Ember also calls for greater data transparency, the inclusion of cost-efficiency metrics, and the integration of the FNA into the existing ERAA/NRAA modelling process to better optimize the dispatch between fossil and non-fossil assets.

Carbon Market Watch supports the draft Delegated Act on permanent carbon capture and usage (CCU) within the EU ETS, praising its strict permanence criteria and 'white-list' approach for products. However, it warns that the 'end of life' criteria must account for CO2 release via deterioration and calls for greater transparency in how products are added to or removed from the approved list.

Carbon Market Watch argues that climate neutrality plans (CNPs) for high-emitting installations must be transparent, standardized, and subject to rigorous assessment criteria to prevent them from becoming a mere formality for receiving free emission allowances. The organization advocates for the mandatory use of a common electronic template to ensure comparability across Member States and calls for the public disclosure of these plans under the Aarhus Convention to ensure accountability for big polluters.

Clean Energy Canada and the Canadian Climate Institute advocate for the rapid finalization of the Clean Electricity Regulations (CER) to provide investment certainty for non-emitting generation. They support a flexible performance standard and an emissions pooling approach but warn against excessive flexibility that could incentivize the continued use of natural gas as a baseload resource. The authors recommend a performance standard of no more than 60 tonnes of CO2 per GWh and oppose extending the End of Prescribed Life (EoPL) beyond 20 years to avoid stranded assets and prolonged emissions.

Ember argues that approving 15 reconsidered coal projects would increase Australia's annual coal mine methane emissions by approximately 190 thousand tonnes. The organization emphasizes that meeting the 1.5C warming limit requires a 75% reduction in energy sector methane emissions by 2030, which cannot be achieved through mitigation technology alone without reducing coal production. Ember specifically recommends closing the gassiest thermal coal mines and avoiding new thermal coal mines, while suggesting that metallurgical coal mines only be approved if they employ available mitigation technologies and cooperate with the UNEP’s International Methane Emissions Observatory.

The document argues that the DOE's proposed 4 kgCO2e/kgH2 standard is too weak and should be lowered to 1 kgCO2e/kgH2 to prioritize truly zero-emission hydrogen. It criticizes the GREET model for underestimating methane leakage and grid emissions, warns against the safety and environmental risks of carbon capture and storage (CCS), and demands that the hydrogen hub program incorporate strict environmental justice protections and community engagement.

The document argues that coal mine methane (CMM) is a critical but underreported driver of emissions in New South Wales, accounting for over 90% of the state's energy sector methane emissions. Ember proposes two new pillars for the NSW EPA's Action Plan: 'Inform and Plan' and 'Mitigate'. The 'Inform and Plan' pillar suggests collaborating with international initiatives like the International Methane Emissions Observatory and implementing high-tier IPCC measurement, reporting, and verification (MRV) methodologies to address reporting gaps. The 'Mitigate' pillar recommends a 75% reduction target for methane emissions by 2030, the closure of 'gassy' thermal coal mines, and a commitment to no new coal mines or expansions. The report highlights that current reporting may be significantly underestimated, citing IEA estimates that Australia's reported CMM emissions could be missing 800 thousand tonnes.

A coalition of NGOs urges the European Commission to end overfishing by setting Total Allowable Catches (TACs) strictly within scientific limits and transitioning to low-impact, climate-friendly fisheries. The group highlights significant implementation gaps in the Common Fisheries Policy (CFP), particularly regarding the landing obligation and the failure to meet the 2020 goal of sustainable harvesting for all stocks. They advocate for an ecosystem-based approach that accounts for climate-driven species shifts and the use of remote electronic monitoring to combat illegal discarding.

ClientEarth argues that the European Commission's proposed amendments to the Solvency II Directive are insufficient to manage climate-related risks. The organization recommends requiring insurers to model extreme warming (3°C+) and disorderly transition scenarios over a minimum 30-year period. It further advocates for 'double materiality' in risk management to account for the environmental impact of underwriting and calls for fast-tracking EIOPA's analysis of capital requirements for fossil fuels to mitigate systemic financial risks.

Carbon Market Watch argues that the European Commission's proposal to update the EU ETS is insufficient, specifically citing an inadequate emission reduction target and the failure to implement the polluter pays principle through continued free allowances. The organization advocates for a 70% emission reduction target by 2030, a more aggressive Market Stability Reserve (MSR) intake rate of 36%, and the immediate phase-out of free emission allowances. Further recommendations include expanding the ETS to cover all international shipping voyages and waste incineration, excluding Carbon Capture and Utilization (CCU) due to potential loopholes, and deleting Article 26 of the ETS Directive to allow binding greenhouse gas limits in industrial permits.

ClientEarth critiques the current EU agricultural and fisheries policies for failing to meet sustainability targets and urges the European Commission to adopt a new, comprehensive legislative framework. The organization argues that existing tools like the Common Agricultural Policy (CAP) and Common Fisheries Policy (CFP) are insufficient or poorly implemented. It advocates for an 'umbrella law' that covers the entire food value chain, integrates fundamental rights and access to justice, and utilizes public procurement to drive systemic change toward environmentally positive and healthy food systems.

ClientEarth's feedback on the EU Taxonomy draft delegated regulation emphasizes the need for science-based thresholds, the exclusion of fossil gas and hazardous chemicals, and the prevention of corporate lobbying from watering down environmental standards.

Ember argues that the 4th Projects of Common Interest (PCI) list should be the last to include fossil gas projects, as current infrastructure is sufficient and demand is projected to decrease by 2030. The organization advocates for prioritizing renewable energy sources (RES), energy storage, and smart grid technologies to meet EU emission targets, while suggesting that the responsibility for writing the Ten-Year Network Development Plan (TYNDP) be expanded beyond the two ENTSOs to reduce conflicts of interest.

The Canadian Association of Physicians for the Environment (CAPE) supports Ontario's draft Pollinator Health Action Plan, particularly its focus on protecting pollinators from stressors like pesticide exposure and habitat loss. CAPE emphasizes the link between pollinator health and human food security, citing research that a total loss of animal pollinators could increase annual human deaths from nutrition-related diseases by 1.42 million. While welcoming the plan's strategic outcomes, CAPE recommends adding specific targets, budgets, and timelines, creating an independent scientific advisory body, providing farmer incentives for pollinator-friendly practices, and conducting a cumulative assessment of pesticide exposures in Ontario.

This document is a submission by Synfuels regarding proposed emission standards for combustion installations. The author provides feedback on particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxide limits for both existing and new facilities, arguing for alignment with international standards and consideration of local resource constraints.

ClientEarth's feedback on the EU's Offshore Renewable Energy Strategy emphasizes the need for high environmental standards, public transparency, and regional cooperation. It argues that the strategy must adhere to the 'do no harm' principle and the precautionary principle, ensuring that the deployment of offshore wind and other ocean energies does not compromise biodiversity or ignore the rights of public participation under the Aarhus Convention. The document suggests a regional approach to grid development and targeted financial support for technologies that have not yet reached grid parity, such as wave energy.

ClientEarth supports a combination of regulatory and non-regulatory measures to revise the Renewable Energy Directive (REDII) to align with the European Green Deal. The organization advocates for a 2030 emissions reduction target of at least 65%, the exclusion of non-renewable hydrogen from support, and the removal of biomass from the category of renewable energy sources due to its impact on climate, health, and biodiversity.