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The Clean Air Task Force (CATF) contends that the Department of Energy's (DOE) "Restoring Reliability: Coal Recommissioning And Modernization" funding opportunity redirects up to $350 million from carbon capture pilot programs to maintain aging coal plants without requiring carbon capture installation. CATF argues that targeting plants scheduled for retirement before 2032 makes carbon capture infeasible due to the 3-7 year construction timeline and the 12-20 year operational period needed to recover capital costs. Furthermore, the document states that allocating $350 million across up to five plants is too diluted, as a single large-scale retrofit often exceeds $500 million. CATF recommends that the DOE limit eligibility to plants expected to operate beyond 2040 and mandate explicit capture performance requirements to meet the Infrastructure Investment and Jobs Act (IIJA) mandate for two coal-based carbon capture demonstrations.

Ember's submission to the Independent Review of Greenhouse Gas Removals warns against overreliance on Power BECCS, citing significant delays at the Drax power station, technological uncertainty, and high costs to consumers. The document highlights that Drax's BECCS project has been delayed to the early 2030s despite substantial public subsidies and that the technology's carbon neutrality is scientifically contested. Ember notes a 60.1% decrease in estimated residual emissions to be balanced by engineered removals between the 6th and 7th Carbon Budgets. It further argues that Power BECCS creates a dangerous dependence on imported biomass, with over 99% of Drax's 2024 wood pellets being imported, primarily from North America. The report recommends winding down Drax subsidies after 2031 and prioritising decarbonisation of easier-to-abate sectors like power, buildings, and transport.

The report critiques the reliance on Levelized Cost of Electricity (LCOE) for power system planning, noting that while useful for tracking historical technology costs, it fails to account for system-wide needs, generation profiles, and integration costs. It highlights that clean firm technologies can reduce overall system costs despite higher LCOEs. The authors recommend moving toward comprehensive system-level analyses that model temporal and spatial constraints to optimize decarbonization pathways.

Carbon Market Watch evaluates the ICVCM's recent decisions on cookstove methodologies, praising the rejection of legacy Kyoto Protocol methodologies and the conditional approval of the Gold Standard Metered methodology, while arguing that other approved methodologies like GS-TPDDTEC and VM0050 still contain loopholes regarding adoption and usage rates.

The Clean Air Task Force asserts that assigning negative emissions rates to biomethane, such as those used in the California Low Carbon Fuel Standard, would allow hydrogen producers to meet 45V tax credit thresholds by blending small amounts of biomethane with fossil natural gas instead of investing in carbon capture. The author contends this would reward environmentally harmful practices, create market distortions, and promote 'dirty' hydrogen production through steam methane reforming (SMR) without carbon capture.

The briefing contrasts two competing approaches to corporate renewable electricity accounting: 24/7 hourly matching and the 'avoided emissions' model proposed by the Emissions First Partnership (EFP). It argues that 24/7 matching provides a necessary demand signal for grid decarbonisation and storage technologies, whereas the EFP proposal is a "repackaging of the controversial offsetting model" that allows companies to claim emissions reductions without actually decarbonising the grids they use. The document urges the GHG Protocol and the Science Based Targets initiative (SBTi) to adopt granular, hourly, and local accounting standards to prevent corporate lock-in of fossil fuel infrastructure and to ensure genuine progress toward the 1.5°C temperature limit.

The Clean Air Task Force asserts that the 40BSAF-GREET model used by the US Treasury fails to meet statutory requirements for section 45Z because its indirect land use change (ILUC) values are significantly lower than those in the CORSIA and EPA RFS frameworks. The author calls for updated ILUC numbers to comply with the Clean Air Act.

Ember argues that the Boggabri coal mine's fugitive emissions are severely under-reported, using a self-led estimate that is 95 times lower than NSW state guidance. The submission warns that the proposed Modification 10, which involves mining deeper coal seams between 2033 and 2040, could result in Scope 1 emissions being 9 million tonnes higher than reported if state-recommended factors were used. Ember highlights a lack of assessment regarding how increased mining depth affects methane release and calls for a peer-reviewed assessment of pre-mine drainage mitigation before approval.

Dr. W. Payton Gardner's review concludes that the PHC and GMR for the Bull Mountain Mine contain significant omissions and non-conservative assumptions. The review highlights a failure to quantitatively analyze impacts on over 50 local springs and shallow groundwater wells, a groundwater model that ignores fracture flow processes and incorrectly assumes 'healing' in mudstone layers, and a mitigation strategy relying on the UB2A sandstone aquifer that is likely insufficient in both volume and water quality.

The briefing examines the discrepancy between methane emissions reported by the oil and gas industry and those found through independent measurements. It highlights that industry-led estimation methodologies, such as the API Compendium, often fail to account for 'super-emitter' events, leading to reports that may be 94% lower than independent estimates. The author calls for regulators to mandate measured rather than estimated data to verify climate claims and ensure the effectiveness of the Global Methane Pledge.

Ember's feedback on the JETP CIPP highlights critical gaps in the plan, particularly the exclusion of captive power emissions, which may lead to 2030 emissions exceeding the 290 MT CO2 target. The organization recommends increasing solar targets, reassessing wind deployment locations, and questioning the sustainability and viability of bioenergy. Ember also criticizes the coal retirement timeline, noting that the CIPP's plan to retire only 1.7 GW by 2040 contradicts the Indonesian government's more ambitious goals and the IEA's 1.5 degree scenario. Additionally, the document calls for greater transparency in GFANZ financing, comprehensive risk assessments regarding US political stability, and urgent policy reforms to end coal subsidies and prohibit new coal plants in the industrial sector.

The report examines the GWP* metric, which focuses on changes in methane emissions over time rather than absolute levels. It argues that this methodology allows high-polluting companies and countries to present minor reductions as negative emissions, thereby escaping accountability and undermining the Paris Agreement's 1.5°C goal. Through case studies of Tyson, Fonterra, and New Zealand, the document demonstrates how GWP* can make significant emitters appear climate neutral. It further details lobbying efforts by the animal agriculture industry in the US, UK, Ireland, and New Zealand to adopt this metric.

Carbon Market Watch argues for stricter transparency, monitoring, and liability frameworks for carbon removal activities under the Article 6.4 mechanism. The organization proposes that all removal-based credits be publicly tagged, monitoring periods be extended to a minimum of 100 years, and a clear distinction be made between 'avoidable' and 'unavoidable' reversals to ensure project proponents bear appropriate financial liability. It further suggests the implementation of a minimum default risk rating for buffer pool contributions and the ability to permanently ban proponents who violate human rights or cause repeated avoidable reversals.

The Environmental Commenters (EDF, CATF, NRDC, Sierra Club, and Earthworks) argue that current source-level reporting systematically underreports methane emissions. They recommend integrating top-down empirical data (satellite, aerial, and tower measurements) to validate bottom-up inventories. Key technical recommendations include establishing a 100 kg/hr threshold for 'large release events,' requiring continuous metering for a sample of pneumatic controllers to prevent data manipulation, and updating gathering pipeline emission factors using recent aerial studies rather than outdated distribution pipeline data. The group also emphasizes the need for rigorous reporting during ownership transfers to prevent 'transferred emissions' from escaping oversight and calls for extended reporting requirements for offshore facilities and plugged wells.

Ember critiques the TYNDP 2024 storylines for having low electrification levels and unrealistic fossil fuel price projections. The organization argues that the 'Green Ambition' (GA) and 'Distributed Energy' (DE) scenarios are not fully self-consistent and fail to align with 1.5C pathways. Ember recommends introducing a higher-ambition scenario with at least 90% emissions reduction by 2040 and urges the removal of fossil methane from heating and transport by 2050.

The report evaluates the CCIA for the Tetra4 Cluster 2 gas field expansion, which includes up to 400 test wells and 300 production wells. The author argues that the CCIA fails to meet South African legal requirements for a full life-cycle emissions assessment, specifically citing the omission of Scope 3 emissions from the final impact determination and several errors in Scope 1 calculations. Key technical failures identified include the use of outdated global warming potential (GWP) values, unrealistic flaring efficiency assumptions, and the omission of methane emissions from well drilling and operational gas production. Additionally, the report finds that the CCIA provides an unsupported claim that the project's LNG will replace more GHG-emitting fuels, while failing to account for the transport of 40% of the produced LNG.

The report critiques Tetra4's Cluster 2 gas expansion, citing significant data gaps in structural geology and hydrogeology. The author argues that the company's groundwater flow models and contamination simulations for methane and total dissolved solids (TDS) are unreliable because they ignore the complex nature of fractured-rock aquifers. Furthermore, the report contends that the proposed monitoring network is inadequate, relying on repurposed water-supply wells rather than strategically placed monitoring wells, and lacks essential analytical testing for carcinogens and radioisotopes.

The Center for International Environmental Law (CIEL) presents a critical overview of Carbon Capture and Storage (CCS), asserting that the technology overpromises on emission reductions while introducing significant safety risks and high costs. The document highlights the 'energy penalty'—the extra energy required to power capture equipment—and notes that most existing projects are used for enhanced oil recovery (EOR), which can increase overall emissions. It warns that a large-scale CCS buildout in the United States would require an unrealistic and dangerous expansion of pipeline infrastructure. Furthermore, the text argues that CCS is unnecessary for 'hard to abate' industrial sectors, where electrification and demand reduction are more viable, and critiques 'blue hydrogen' as a means to prolong fossil fuel dependence. The document concludes that global capture capacity is negligible compared to total emissions and that public subsidies, such as the US 45Q tax credit, inappropriately support the fossil fuel economy.

Ember's analysis finds that the Whitehaven coal mine in Cumbria is likely to emit 15 times more methane over its lifetime than estimated by the developer, West Cumbria Mining Limited (WCML). The report argues that WCML understated methane content by using core samples instead of official National Atmospheric Emissions Inventory (NAEI) factors and overstated mitigation potential by claiming a 95% destruction rate, whereas the IEA suggests 69% is realistic for such mines. These discrepancies could lead to the mine producing 12 kilotonnes of methane in 2030, significantly impacting the UK's goals under the Global Methane Pledge.

The Clean Air Task Force, The NorthBridge Group, and Green Strategies, Inc. argue that current greenhouse gas accounting rules are outdated and fail to incentivize the diverse portfolio of carbon-free energy (CFE) resources needed for full grid decarbonization by 2035. They recommend adopting a 'bottom-up' book and claim approach for energy attribute certificates (EACs) to prevent double counting and suggest a 'Carbon Facts' label to track both attributional emissions (associated with electricity use) and consequential avoided emissions (actual carbon reductions). The authors specifically urge CEQ to define the 50% hourly match goal by 2030 as either a minimum of 50% CFE in every hour or a high annual average of at least 80% hourly time-matching to ensure the development of firm CFE and storage resources.