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Feedback to call for evidence - ETS1 review
Carbon Market Watch argues that the EU ETS1 fails to drive industrial decarbonisation due to the continued allocation of free emission allowances, which it claims undermines the carbon price signal for sectors like steel, cement, and chemicals. The submission calls for the complete phase-out of free allocations and indirect cost compensation, suggesting that any remaining benefits be tied to decarbonisation milestones. It further advocates for expanding the ETS scope to cover all departing flights from 2027, including non-CO2 effects and flights to third countries, and extending maritime coverage to 100% of extra-EEA routes and all small ships by 2027. Regarding market stability, the document suggests maintaining existing Market Stability Reserve (MSR) and Linear Reduction Factor (LRF) rules until 2035 to preserve investment signals. Finally, it strongly opposes the integration of carbon removals into the EU ETS to avoid mitigation deterrence and the risk of using removals as a substitute for actual emission reductions.
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Document type: Statement
Brewing resilience
The report details the EECCLiRe project's efforts to build climate resilience among Indonesian coffee smallholders through ecosystem-based adaptation (EbA). Key interventions included the use of climate field schools (CFS) to integrate scientific climate data with traditional knowledge, the promotion of agroforestry to protect heat-sensitive Arabica coffee, and the installation of plastic biodigesters to provide clean energy and organic fertilizer. The document also examines the role of ecolabels and geographical indication (GI) labels in supporting EbA by providing financial incentives, while noting challenges such as power imbalances with intermediaries and the need for context-specific, gender-responsive programming.
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Document type: Report
AFRICA’S FORGOTTEN FISHES
Africa's freshwater ecosystems host at least 3,281 fish species, most of which are endemic, supporting millions of people through fisheries and providing critical ecosystem services. However, approximately 26% of these species are threatened with extinction due to damming, pollution, over-abstraction of water, invasive species, and climate change. The report highlights the critical role of the African Great Lakes and major river basins, the economic potential of the aquarium and recreational angling trades, and the urgent need for integrated management through initiatives like the Freshwater Challenge and the use of eDNA monitoring.
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Document type: Report
The Spirit of Asilomar Entreaty Against Biological Weapons
The document outlines an entreaty endorsed by over 100 experts at 'The Spirit of Asilomar' conference, condemning the development and use of biological weapons. It argues that the most effective way to deter biological weapons is to accelerate the equitable global deployment of tools for attribution, early detection, and rapid countermeasure manufacturing. The text highlights ongoing threats from state actors, specifically Russia and North Korea, as well as non-state actors, and emphasizes that increasing global access to vaccines and countermeasures in developing countries reduces the attractiveness of biological weapons.
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Document type: Statement
South Africa's G20 Moment: Leading a Justice-Driven Energy Transition through Critical Minerals
African Civil Society Organisations have urged the South African G20 Presidency to champion a justice-driven energy transition by focusing on critical minerals. They call for the support of the African Green Minerals Strategy to move the Global South up the value chain, the implementation of people-centred governance including Free, Prior, and Informed Consent (FPIC), and the transformation of global industrial financing and technology transfer. The group advocates for public investment in infrastructure to address energy poverty for 650 million Africans and the creation of a Global Critical Energy Transition Minerals Skills Compact for women and youth.
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Document type: Statement
Nature-Based Solutions For Climate Resilient Infrastructure Planning In The Philippines
The document identifies priority areas for Nature-based Solutions (NbS) in the Philippines to protect infrastructure and populations from climate impacts, noting that a small percentage of land area can provide resilience for millions of people and a significant portion of the road network. It emphasizes that many of these priority areas lie outside existing protected networks, requiring new regulatory approaches, while also highlighting 'win-win' opportunities within protected areas. The report advocates for integrating NbS data into national planning frameworks like the Infrastructure Flagship Program and the Philippine Development Plan, supported by capacity building and centralized data platforms.
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Document type: Executive summary
UK Regulatory Roadmap: Blueprint for Emissions Reductions in the Energy Sector
The report argues that the UK must implement mandatory methane regulations to maintain international leadership and comply with EU import requirements. It recommends a layered approach combining prescriptive measures (such as quarterly leak detection and repair), a phased transition to OGMP 2.0 Level 5 measurement, monitoring, reporting, and verification (MMRV), and the establishment of an emissions intensity standard for both domestic and imported fossil fuels.
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Document type: Report
Design Choices for Debt Sustainability
The document proposes a shift from rigid fiscal rules to a 'constrained discretion regime' for emerging markets facing rising debt costs. It recommends implementing flexible debt anchors, embedding them within a broader fiscal policy regime with independent oversight, and increasing transparency to maintain market confidence.
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Document type: Report
Planning for the future
The report emphasizes that grid capacity is now a primary driver for data centre investment in Europe. To avoid downgraded forecasts and remain competitive in the global AI race, the author recommends that governments treat grids as strategic infrastructure. Key proposals include the creation of priority AI zones outside congested capital cities, joint spatial planning to locate demand nodes near clean energy sources, and the implementation of non-firm grid connection options to reduce queues. Additionally, the document calls for increased research into data centre flexibility and improved data availability regarding demand profiles and grid capacity maps to inform planning and policy.
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Document type: Report
Grids for data centres: ambitious grid planning can win Europe’s AI race
The report argues that proactive grid planning is essential for Europe to meet its goal of tripling data centre capacity and capturing the economic benefits of AI. It highlights a shift in investment from traditional hubs (FLAP-D markets) to regions with lower grid congestion, such as the Nordics and Southern Europe. The analysis suggests that innovative connection agreements, data centre flexibility, and strategic spatial planning can significantly reduce connection wait times and infrastructure costs.
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Document type: Report
Simple solutions are enough to unlock the potential
The report argues that implementing straightforward regulatory changes could unlock at least 8 GW of hybrid power potential in Türkiye. Key recommendations include removing the 100 MW capacity cap, eliminating the requirement for hybrid projects to be physically adjacent to the primary plant site, and establishing clear numerical targets and transparent data reporting for hybrid installations.
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Document type: Report
Bölüm 4: Politika Önerileri
The report argues that simple regulatory adjustments could quickly realize at least 8 GW of hybrid power potential in Türkiye. Key recommendations include removing the requirement for hybrid projects to be physically integrated with the primary plant site, eliminating capacity limits on additional power based on primary source size, and treating hybrid plants as a separate process from new connection capacity allocations. Additionally, the document calls for the establishment of clear numerical targets for hybrid plants within the 2053 goals and improved transparency and accessibility of capacity data for these facilities.
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Document type: Report
Recommendations for strengthening the NECP process
The document argues that the current NECP process suffers from incomplete Member State reporting, outdated reporting categories, and poor data accessibility. It recommends that the European Commission enforce full reporting through 2050, expand the reporting template to include electrification rates, energy storage, demand-side flexibility, and grid planning, and mandate digital submissions to create a single, publicly available data source.
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Document type: Report
Protéger les terres et les eaux dans la région du Traité no 9
The document highlights the ecological importance of the Hudson Bay and James Bay lowlands as a critical global carbon sink and the threats posed by the 'Ring of Fire' mining projects. It details the advocacy of the Friends of the Attawapiskat River, who argue that respecting treaty rights and obtaining free, prior, and informed consent (FPIC) are essential for achieving climate and conservation goals. The study critiques Ontario's mining laws and the lack of provincial implementation of the UN Declaration on the Rights of Indigenous Peoples (UNDRIP), recommending the establishment of Indigenous Protected and Conserved Areas (IPCAs) and a moratorium on mining permits until Indigenous sovereignty and environmental protections are guaranteed.
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Document type: Case study
Private Equity, Public Harm
The report 'Private Equity, Public Harm' estimates that private equity-backed fossil fuel infrastructure in the U.S. generates annual health costs between $11.3 billion and $15.1 billion, causing approximately 1,000 premature deaths and 1,500 emergency room visits yearly. Using the EPA's COBRA tool, the analysis identifies significant impacts from pollutants such as SO₂, NOₓ, VOCs, and PM2.5, noting that several individual private equity firms are responsible for over $1 billion in annual health impacts. The document calls for mandatory disclosures of fossil fuel exposure and emissions, a complete transition to a fossil-free portfolio by 2030, and the integration of environmental justice mechanisms to protect impacted communities.
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Document type: Report
Advancing a Fair and Funded Transition Away from Fossil Fuels
The document argues that despite the COP 28 agreement to transition away from fossil fuels, production and consumption continue to rise. It proposes that COP 30 adopt differentiated timelines for phasing out fossil fuels based on national wealth and historical responsibility, and calls for an immediate end to new fossil fuel exploration and expansion. Key financial recommendations include ending public financing for fossil fuels, reforming subsidies, and establishing the Belém Action Mechanism for Just Transition to coordinate climate finance.
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Document type: Briefing
agliabilityshieldletter25-85c40a66c8eaff21.pdf
A group of state Attorneys General requests that the U.S. Department of Justice recommend legislation to shield energy companies from climate-related liability and restrict federal funding for states pursuing climate lawsuits. The authors argue that such "climate lawfare" undermines national security and economic prosperity by targeting traditional energy resources like oil, natural gas, and coal.
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Document type: Statement
Energy Transitions and Ecological Security Risks
The document outlines how the shift to renewable energy creates socio-ecological risks through expanded critical mineral mining and the rise of oil and gas decommissioning. It highlights environmental degradation, such as water pollution in China and orphan wells in the US, and explains how these issues can escalate into regional conflicts or local violence, as seen in Papua New Guinea. The author argues that current approaches often separate human rights from environmental impacts and recommends integrating these perspectives, increasing data transparency on site locations and health impacts, and sharing decommissioning best practices between experienced and novice nations.
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Document type: Briefing
Threads of Transformation: Fashion, Energy & Women at the Intersection of Climate Action
The global fashion industry contributes 2-8% of global carbon emissions and uses approximately one trillion kWh of electricity annually, with emissions projected to rise by over 60% by 2030 if trends persist. The sector relies heavily on fossil fuel-based synthetic fabrics and inefficient energy sources, while most major brands lack transparent renewable energy targets for their supply chains. Women make up 60% of the workforce but face disproportionate burdens from climate change, energy access inequalities, and systemic gender disparities in wages and leadership.
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Document type: Executive summary
Unlock Agriculture’s Climate Action Potential for Climate and Food System Resilience
The document argues that the EU agriculture and food system has substantial potential for emission reductions, with estimates ranging from 44% to 60% by 2040, provided structural changes and shifts to healthier diets are implemented. The authors oppose the use of international carbon offsets and 'technical tweaks' to the industrial model, instead advocating for a binding sector-specific emission target and a transition toward organic farming, paludiculture, and reduced reliance on synthetic fertilizers and pesticides. They emphasize that climate change already causes €28.3 billion in annual losses for farmers, making a systemic transition essential for long-term viability. The letter calls for the EU's next long-term budget to support farmers in this transition and for the entire agri-food value chain, including processors and retailers, to be held accountable.
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Document type: Statement