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Friends of the Earth warns that the appointment of Ben Black, a former private equity executive, as CEO of the U.S. International Development Finance Corporation (DFC) may shift the agency's focus from sustainable development toward profit-driven investments. The organization expresses concern that this leadership change could lead to increased financing for extractive projects and a weakening of environmental and social safeguards.

The statement highlights the legacy of George Meléndez Wright, the first Latino National Park Service employee of El Salvadoran heritage, who modernized wildlife management at Yosemite National Park and established the National Park Service's Wildlife Division. It notes that despite his contributions—including creating the first wildlife management plans and personally funding surveys—there is no commemoration of his work at Yosemite. The text concludes by criticizing the Trump Administration for government shutdowns, federal labor force reductions, and the erasure of climate change interpretation in national parks.

The document critiques debt-for-nature swaps (DNS) as a 'green trap' that prioritizes creditor profits over biodiversity and sovereignty. It asserts that these mechanisms reinforce a cycle of extractivism and austerity in the Global South, where governments are forced to prioritize debt servicing over social and ecological investments. The author calls for the cancellation of illegitimate debts and a radical overhaul of the global financial architecture based on justice and reparation.

The document critiques debt-for-nature swaps (CDN), asserting they function as a 'green trap' that reinforces financial dependence and extractivism in the Global South. It claims these mechanisms transfer control of national territories and policies to foreign NGOs and private actors while providing minimal conservation funding. The text argues that the current international financial architecture forces indebted nations into a cycle of austerity and extractivism to service debts, and calls for the cancellation of illegitimate debts and the recognition of the North's ecological debt to the South.

The document critiques debt-for-nature swaps (EDN), asserting they are a 'green' facade for an unjust financial system. It argues that these mechanisms reinforce financial dependence, facilitate the privatization of common goods, and shift control of territories to foreign NGOs and private actors. The text highlights a 'vicious circle' where debt repayment forces countries toward extractivism and austerity, while modern EDN structures—often involving 'blue' or 'green' bonds—replace old debts with more opaque loans from international entities.

Friends of the Earth International opposes the Tropical Forest Forever Facility (TFFF), a Brazilian-led initiative designed to mobilize private finance for tropical forest conservation. The organization argues that the TFFF's 'blended finance' model—which prioritizes private investor returns over conservation payments—treats nature as a commodity and risks creating a cycle of debt for tropical forest countries. The paper criticizes the central role of the World Bank and the limited influence of Indigenous Peoples and Local Communities (IPLCs), calling instead for debt cancellation, historical reparations, and community-led forest management based on the intrinsic value of ecosystems.

Natural Justice critiques South Africa's Draft Second NDC, noting that while it introduces tighter 2030 targets and a 2031–2035 carbon budget, it lacks enforceable commitments, funding for adaptation, and a coal phase-out schedule. The submission recommends unconditional emissions reductions, grant-based loss and damage finance, and the integration of human rights indicators and Free, Prior and Informed Consent (FPIC) into climate planning.

The Institute for Policy Integrity disputes a draft U.S. Department of Energy (DOE) report titled “A Critical Review of Impacts of Greenhouse Gas Emissions on the U.S. Climate,” which claims that climate impacts are too small to justify aggressive abatement. The Institute asserts that surveys of economic experts actually show a broad consensus that significant mitigation is warranted and that climate change will cause significant damage, including limited economic growth and increased mortality.

Reclaim Finance asserts that ING's 2025 Climate Update fails to introduce new policies and obscures the bank's ongoing support for fossil fuel developers. The report highlights that ING continues to provide corporate financing for LNG infrastructure and is a major lender to Venture Global. Furthermore, it claims ING misleadingly uses its Science Based Targets initiative (SBTi) validation while ignoring the July 2025 Net-Zero Standard for Financial Institutions, which requires the exclusion of financing for companies developing new coal, oil, or gas projects by 2030.

The document criticizes the US government for granting 'licenses to pollute' to chemical and coal companies, which exposes children to hazardous substances like PFAS, lead, and pesticides. It argues that children are uniquely vulnerable to these toxins and demands the immediate phase-out of organophosphate pesticides, stricter air and water quality standards, and the prohibition of phthalates in consumer products.

The document challenges the common use of the term "baseload" as a justification for favoring specific energy resources, clarifying that "baseload" refers to the minimum constant load of an electric system rather than a specific type of power plant. It argues that describing certain resources as "baseload resources" does not prove they are the most cost-effective or reliable options for meeting that demand, nor does it guarantee grid security during peak demand. The brief aims to distinguish between "baseload," "dispatchable," and "firm" resources to counter rhetoric suggesting that retiring such resources inherently risks grid reliability.

ClientEarth critiques the European Commission's 'Roadmap towards Nature Credits', warning that a market for biodiversity credits could undermine EU environmental law if not strictly separated from regulatory obligations and offsetting. The organization argues that the biodiversity financing gap—estimated at 19 billion euros per year in the EU—should first be addressed by scaling up public funds and redirecting the 48 billion euros in annual harmful subsidies. ClientEarth recommends that any future credit system be strictly outcome-based, exclude 'business-as-usual' practices, and prohibit the use of credits for ecological compensation (offsetting) to avoid 'net loss' of biodiversity. It further highlights the scientific complexity of measuring biodiversity compared to carbon, cautioning against reductionist proxy metrics that could lead to greenwashing.

The submission argues that South Africa's draft second NDC lacks sufficient ambition and fails to reflect the 'highest possible ambition' required by the Paris Agreement. It proposes more stringent emission targets—350 Mt CO2e for 2025-2030 and 248 Mt CO2e for 2031-2035—based on 'fair share' calculations and the best available science. The document highlights legal risks under the South African Constitution, the Climate Change Act, and NEMA, while criticizing the Department of Forestry, Fisheries and the Environment (DFFE) for a non-transparent process that delayed the release of the underlying technical report. It further calls for a stronger focus on phasing out fossil fuels, enhancing climate adaptation for vulnerable groups, and incorporating climate justice principles from the Presidential Climate Commission's recommendations.

The document highlights the environmental and health risks associated with spreading sewage sludge on approximately 70 million acres of U.S. farmland, noting that such sludge often contains per- and polyfluoroalkyl substances (PFAS). It criticizes the EPA for failing to finalize risk assessments for PFOA and PFOS and for underestimating the risks of over 150 other PFAS chemicals detected in sludge. The text cites specific farm failures in Maine and Michigan due to contamination and notes that while some states like Maine have banned the practice, others still encourage it. The author calls for federal regulations, the protection of local government authority to restrict sludge use, and corporate accountability for clean-up.

A coalition of 42 organizations, including Earthjustice and the NRDC, submitted comments on the EPA's Draft Sewage Sludge Risk Assessment for PFOA and PFOS. The coalition argues that the EPA's assessment confirms that these 'forever chemicals' in sewage sludge pose unacceptable risks to human health and the environment, particularly through land application on farms. They claim the EPA's risk calculations are underestimates because they use low-end concentration models and ignore combined exposure effects. The document calls for the prompt finalization of the assessment, the establishment of numerical limitations and management practices under the Clean Water Act, and the expansion of future risk assessments to include other PFAS, synthetic organic fluorine compounds, and microplastics. Additionally, they advocate for stricter pretreatment standards for industrial dischargers to prevent PFAS from entering publicly-owned treatment works.

The CER argues that the Draft Mineral Resources Development Bill 2025 fails to adequately protect mine-affected communities and the environment. Key concerns include the conflict of interest inherent in the 'One Environmental System' (OES), where the Department of Mineral and Petroleum Resources manages both mining promotion and environmental authorisations. The CER criticizes the Bill's narrowing of the definition of 'community' and 'interested and affected persons,' which it claims limits public participation. It further highlights gaps in mine closure and rehabilitation, particularly regarding abandoned mines, and calls for the legal incorporation of the Mining Charter to ensure binding transformation and gender parity targets. The CER proposes introducing the principle of Free, Prior and Informed Consent (FPIC) and improving access to information through mandatory public disclosure of mining authorisations.

The document argues that the Trump EPA's proposal to revoke the 2009 endangerment finding relies on misinterpretations of the Clean Air Act and fringe science. It details how the agency seeks to narrow the definition of 'air pollution' to exclude global harms and challenges the scientific consensus on climate change using a Department of Energy report authored by climate skeptics. The briefing notes that while the proposal specifically targets motor vehicle emission standards for model years 2012 to 2027 and beyond, it also undermines the legal basis for greenhouse gas regulations on power plants and oil and gas facilities.

The World Resources Institute (WRI) has condemned a proposal by the U.S. Environmental Protection Agency (EPA) to reverse its authority to regulate greenhouse gas emissions by overturning the 'endangerment' finding. WRI argues that this move ignores decades of science and will negatively impact public health, household energy costs, and economic stability.

The Canadian Association of Physicians for the Environment (CAPE) argues that British Columbia's current climate strategy is insufficient to meet its 2025 and 2030 targets, primarily due to continued support for fracked gas and liquefied natural gas (LNG) expansion. CAPE highlights significant health risks associated with fracking, including respiratory disease and cancer, noting a critical loss of physicians in northeastern B.C. The submission calls for a moratorium on new fracking and LNG development, a ban on gas connections in new buildings by 2025, and increased investment in active transportation and public transit to address the province's largest emissions source. CAPE also emphasizes the need for equitable electrification and a just transition for fossil fuel workers.

Reclaim Finance argues that the Caisse des Dépôts et Consignations (CDC) lacks credibility in its responsible investment strategy due to its continued support for oil and gas expansion. The organization highlights that the CDC's 2024 responsible investment report fails to end new investments in fossil fuel developers, such as TotalEnergies, and relies on an ineffective shareholder dialogue process. Reclaim Finance urges the CDC to cease new investments in these companies, vote against their management, and implement stricter climate criteria for its external asset managers, who manage 10 billion euros of its portfolio.