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We Mean Business Coalition response to UN Limiting Overshoot report
The We Mean Business Coalition emphasizes that while global temperatures are likely to exceed 1.5°C, the severity and duration of this overshoot depend on immediate actions by governments and businesses. The Coalition advocates for a priority focus on clean electricity, electrification of transport, buildings, and industry, the reduction of methane and superpollutants, nature restoration, and the strengthening of adaptation and resilience to keep the pathway back to 1.5°C open ahead of COP31.
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Document type: Statement
Fisheries Omnibus MAP Response to the Call for Evidence
ClientEarth responds to the European Commission's Call for Evidence regarding a potential Fisheries Omnibus on Multiannual Plans (MAPs). The organisation argues that the priority should be the effective implementation and enforcement of existing tools rather than the deletion or weakening of key safeguards, such as the provisions on most vulnerable stocks (MVS) in the Western Mediterranean MAP and the 5% rule in the Northern MAPs. It asserts that failing to rebuild depleted stocks perpetuates 'choke risks' and that the only sustainable solution is to prioritise the recovery of stocks below sustainable levels. The document also suggests that the upcoming EU Ocean Act and the revision of the Multiannual Financial Framework (MFF) should be used to strengthen coherence in ocean policies and redirect harmful subsidies toward climate and biodiversity targets.
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Document type: Statement
Ember’s response to India’s draft National Electricity Policy- 2026
Ember's response to India's draft National Electricity Policy 2026 argues for a shift from sequential to co-optimised generation and transmission planning to resolve bottlenecks and stranded assets. The brief recommends deploying grid-enhancing technologies to manage the rise of inverter-based resources, unbundling state transmission utilities to increase private sector participation, and reforming DISCOM procurement to avoid over-reliance on long-term coal contracts. It also calls for a robust data-sharing and cybersecurity framework to manage the increasing volume of electricity data from distributed energy resources.
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Document type: Policy brief
WMBC Response to EU Parliament Vote on EUDR
The We Mean Business Coalition criticizes the European Parliament's decision to delay the Deforestation Regulation (EUDR) by another year and exclude printed products from its scope. The Coalition argues that this creates market uncertainty, disadvantages companies that have already invested in compliance systems, and erodes the EU's credibility in addressing deforestation and nature loss.
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Document type: Statement
IISD Response to the United Kingdom Consultation on the Rosebank Field Development
The IISD response asserts that Equinor's application for the Rosebank field development ignores critical Department for Energy Security and Net Zero (DESNZ) guidance regarding downstream Scope 3 emissions. The document argues that the project is incompatible with the Paris Agreement's 1.5°C target, as no new oil and gas fields are needed or permissible in such scenarios. Furthermore, the IISD claims the project offers minimal economic benefit, potentially resulting in a net loss to the UK Treasury and providing negligible contributions to energy security.
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Document type: Report
RÉACTION DES ONG IVOIRIENNES A LA RÉPONSE DE MONDELEZ SUR LA MISE EN ŒUVRE DU REGLEMENT SUR LA DEFORESTATION DE L’UNION EUROPENNE (RDUE)
Thirty-five Ivorian NGOs have issued a statement opposing Mondelez's call for a 12-month postponement of the EU Deforestation Regulation (EUDR). The NGOs argue that delays would prolong environmental and social degradation in Côte d'Ivoire, where deforestation rates exceed 80%. They reject Mondelez's claims that lack of planter identification and administrative inefficiency justify a delay, asserting instead that the EUDR provides the necessary impetus to finalize long-delayed mapping and identification processes and strengthen government systems.
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Document type: Statement
Reaction of Ivorian NGOs to Mondelez's response on the implementation of the EU Deforestation Regulation (EUDR)
A coalition of 35 Ivorian NGOs has rejected Mondelez's request for a 12-month delay in the implementation of the European Union Deforestation Regulation (EUDR). The NGOs argue that postponing the regulation would prolong environmental and social harm, specifically noting that Côte d’Ivoire has lost over 80% of its forests. They contend that challenges cited by Mondelez—such as lack of farmer identification and mapping—should be addressed through action rather than used as pretexts for delay, asserting that the EUDR provides a unique opportunity to create a more transparent and sustainable cocoa sector.
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Document type: Statement
Transition plan requirements consultation
ClientEarth advocates for the UK government to mandate the development, disclosure, and implementation of transition plans aligned with the Paris Agreement. The organization argues that a 'comply or explain' framework is insufficient and that mandatory requirements are necessary to prevent 'greenwashing' and 'say-do gaps'. It specifically highlights the need for pension schemes to manage systemic climate risk through Paris-aligned anchors and robust stewardship. ClientEarth further asserts that legal risks for directors are often overstated due to the 'dishonesty standard' in English law, and that alignment with the 1.5°C goal is essential for the UK to fulfill its international obligations following the 2025 ICJ Advisory Opinion.
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Document type: Statement
Carbon Market Watch’s input on the UK Government’s proposed framework for voluntary carbon and nature markets
Carbon Market Watch (CMW) opposes the UK government's proposed reliance on market-based mechanisms and the VCMI Scope 3 Action Code of Practice, arguing that allowing carbon credits to 'close scope 3 emissions gaps' effectively legitimises offsetting and risks rewarding 'climate laggards'. CMW advocates for a 'contribution' or 'beyond value chain mitigation' (BVCM) model over offsetting and insetting, and suggests that the UK's Environmental Reporting Guidelines (ERG) should mandate, rather than encourage, the disclosure of carbon credit information. The document also recommends 'temperature-alignment claims' (specifically referencing 1.5°C) as a more precise alternative to 'Paris alignment' claims.
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Document type: Statement
When banks manipulate numbers: a response to BPCE
Reclaim Finance disputes claims by Banque Populaire Caisse d’Epargne (BPCE) that it is reducing fossil fuel financing, asserting that BPCE's reporting excludes critical activities like gas liquefaction and bond underwriting. The document argues that BPCE's renewable energy targets are insufficient for a 1.5°C pathway and that the bank applies a double standard by aggregating financing types when reporting renewable investments but rejecting the same method for fossil fuel reporting.
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Document type: Statement
Why sound planning for floods and wildfires isn’t junk science
The Canadian Climate Institute responds to claims that its 'Close to Home' report relies on 'guesswork,' asserting that its risk modelling uses data from The Co-operators and SwissRe and focuses on near-term risks. The Institute argues that failing to account for flood and wildfire exposure in housing development could increase private and public costs by $3 billion annually. It emphasizes that better land-use planning and risk information empower market participants to make informed decisions, addressing a market failure where insurance and property values misprice risk. The document notes that 2024 saw record insured losses of over $8.9 billion in Canada due to severe weather, including events in Quebec, Toronto, and Jasper, and maintains that climate change is increasing the area burned by wildfires.
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Document type: Statement
Ember’s response to the draft guidelines for Virtual Power Purchase Agreements in India
Ember expresses two primary concerns regarding India's draft VPPA framework: its potential to undermine power system flexibility and its role as a potentially misleading accounting mechanism for corporate clean energy claims. The organization argues that VPPAs may encourage continued investment in 'plain vanilla' solar without storage, exacerbating midday surpluses and grid balancing challenges. Ember also contends that VPPAs allow industrial consumers to claim 100% renewable energy usage through Renewable Energy Certificates (RECs) without physically consuming clean power or contributing to grid stability, potentially diverting investment away from genuine 24/7 clean energy solutions.
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Document type: Statement
Ember’s response to the public consultation on European Resource Adequacy Assessment
Ember's response to the ERAA 2025 consultation highlights significant discrepancies between ENTSO-E's proposed commodity prices and market futures, noting that fossil fuel prices are underestimated while CO2 prices are overestimated. The document argues that the ERAA underestimates battery storage and demand flexibility potential, fails to account for battery CAPEX reductions, and underestimates wind and solar capacities in several European countries compared to National Energy and Climate Plans (NECPs) and industry forecasts.
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Document type: Report
Corporate transition plans and legal liability
ClientEarth argues that the 'recklessness standard' in English law already protects companies from liability for honest but incorrect forward-looking statements in transition plans. It contends that detailed transition planning reduces risks related to greenwashing, breach of duty, and human rights harms, and opposes the introduction of 'safe-harbours' which would undermine market integrity.
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Document type: Statement
Earthjustice Statement on Lease Sale in the Arctic National Wildlife Refuge
Earthjustice welcomes the lack of bids for oil-and-gas drilling leases in the Arctic National Wildlife Refuge, citing the area's ecological value and sacred status to the Gwich’in people, while pledging continued legal opposition to future leasing attempts.
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Document type: Statement
Response to DESNZ Consultation on Scope 3 Emissions Guidance
The IISD response to the DESNZ consultation argues for more rigorous standards in assessing Scope 3 emissions for offshore oil projects, specifically calling for the separate reporting of Category 11 emissions, the use of zero-emission baselines, and the assessment of significance based on 1.5°C science-based scenarios rather than as a proportion of global emissions.
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Document type: Report
Earthjustice Statement on Nomination of Chris Wright to Lead Energy Department
Earthjustice President Abigail Dillen condemned the nomination of Chris Wright to lead the Department of Energy, stating that appointing a "fossil fuel executive and noted climate denier" threatens climate goals. The organization pledged to use legal action and other tools to ensure the continuation of the clean energy transition.
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Document type: Statement
CP24/12: Consultation on the new Public Offers and Admission to Trading Regulations regime
ClientEarth's response to CP24/12 advocates for mandatory climate disclosures aligned with TCFD and ISSB standards, specifically calling for an 'atmospheric viability test' for mineral companies to prevent stranded asset risk. The organization argues against voluntary sustainability-labelled debt disclosures, urging for contractually binding commitments to prevent greenwashing, and cautions against reducing issuer liability for forward-looking climate statements.
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Document type: Statement
Open consultation on Integrating Greenhouse Gas Removals in the UK Emissions Trading Scheme
Carbon Market Watch strongly opposes integrating greenhouse gas removals (GGRs) into the UK ETS, asserting that emissions and removals are not equivalent and that such a move would cause mitigation deterrence. The organization argues that GGRs are a weaker form of mitigation and that their inclusion could lead to an overreliance on cheap, unsustainable options. If integration were to occur, they insist on maintaining the gross cap, issuing allowances ex-post, and implementing a strict permanence framework. They specifically oppose the inclusion of woodland units due to their lack of permanence and the 'carbon debt' they create. Instead, they recommend 'indirect inclusion' where ETS revenues fund GGR projects, or the creation of a separate Removals Trading Scheme.
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Document type: Statement
We Mean Business Coalition response to G7 energy ministers’ communique
The We Mean Business Coalition welcomes the G7's commitment to include the phase-out of fossil fuels and the scaling up of clean energy in their Nationally Determined Contributions (NDCs). The Coalition argues that these signals provide the regulatory clarity necessary for businesses to invest in low-carbon systems and decarbonise their models. However, it notes that financial flows, including public investments and subsidies, must still be aligned with these goals, urging the G7 Finance Ministers to ensure coherence in their upcoming May meeting.
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Document type: Statement