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endocrine-disruptors-criteria
The Center for International Environmental Law (CIEL) criticizes the European Commission's June 2016 draft legal acts for Plant Protection Products and Biocidal Products Regulations. CIEL argues the proposed criteria for identifying endocrine disrupting chemicals (EDCs) are too restrictive because they only include substances 'known to' cause adverse effects, excluding 'presumed' and 'suspected' EDCs. The document claims this high burden of proof, potentially influenced by industry lobbying and US trade concerns, fails the precautionary principle and could exclude hundreds of harmful chemicals. CIEL specifically opposes the 'negligible risk' allowance in the Plant Protection Products Regulation, advocating instead for a hazard-based approach similar to that used for carcinogenic, mutagenic, or toxic to reproduction (CMR) substances.
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Document type: Statement
Voluntary Methane Reduction Efforts Will Still Fall Short of Methane Reduction Goal
The Clean Air Task Force asserts that the EPA's Methane Challenge Program, which relies on voluntary industry commitments, cannot achieve the U.S. target of a 40-45% reduction in oil and gas methane emissions by 2025. While 41 companies joined as founding members, the program lacks participation from oil and gas exploration and production companies, which are responsible for 73% of the industry's methane emissions. Although 37 Local Distribution Companies representing nearly 60% of natural gas utility customers are participating, the author maintains that voluntary measures are no substitute for strong, nation-wide regulations of existing pollution sources.
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Document type: Statement
Bilan de l’Accord de Paris des Amis de la Terre International
Friends of the Earth International concludes that the Paris Agreement fails the 'People's Climate Test' due to its lack of binding emission targets, insufficient financial commitments for developing nations, and the absence of concrete mechanisms for loss and damage. The organization criticizes the agreement for not mentioning renewable energy or the phase-out of fossil fuels, while leaving the door open to 'false solutions' like geo-engineering and carbon markets.
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Document type: Statement
Statement of CIEL President Carroll Muffett: Secretary Kerry’s speech to UNFCCC COP 21
CIEL President Carroll Muffett critiques Secretary Kerry's COP 21 speech, stating that the US pledge to double grant-based adaptation assistance to over $800 million by 2020 is insufficient compared to the $100 billion annual pledge by developed countries. Muffett argues that US domestic politics have hindered ambitious international climate engagement and rejects the notion that the Paris outcomes are merely a "preamble," emphasizing the urgent human rights tragedies already caused by climate change.
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Document type: Statement
Ensuring a Robust Accountability Framework at the AIIB
The Center for International Environmental Law and other organizations advocate for the AIIB to implement a transparent, independent, and accessible accountability framework. They specifically call for an Oversight Mechanism aligned with UN Guiding Principles on Business and Human Rights and caution against over-reliance on potentially weak Country and Corporate Systems for grievance redress.
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Document type: Statement
Meeting our global responsibility: the United Nations Sustainable Development Goals
The author critiques the Millennium Development Goals (MDGs) for focusing on income poverty and development aid rather than structural inequality and the link between social and environmental dimensions. While noting progress in poverty reduction and water access, the text highlights that global inequality is rising and environmental degradation is accelerating due to the consumption patterns of an expanding global middle class. The author asserts that industrialised countries, particularly the European Union, must assume global responsibility by meeting the 0.7% GNI official development assistance target and drastically reducing their per capita CO2 emissions to allow the Global South scope for sustainable development.
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Document type: Statement
who benefits from gm crops?
The report argues that USAID and the Bill and Melinda Gates Foundation are aggressively promoting GM crops in Africa by influencing biosafety legislation and bypassing national regulations through Regional Economic Communities (RECs). It highlights the contrast between the 'precautionary approach' of the Cartagena Protocol and the 'promotional approach' of US-funded programs like the Agricultural Biotechnology Support Programme (ABSP) and the Programme for Biosafety Systems (PBS). The document uses case studies from South Africa, Kenya, and Malawi to illustrate how GM adoption can lead to corporate consolidation and increased food insecurity, while criticizing philanthropic projects like Water Efficient Maize for Africa (WEMA) as 'Trojan horses' for private agribusiness interests.
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Document type: Report
Toxic Partnership Revealed
The policy brief analyzes a leaked 'chemicals annex' of the TTIP, asserting that the proposed regulatory cooperation framework would allow the chemical industry to delay the implementation of health-protective laws. It highlights a stark divide between the EU's proactive chemical regulations and the US's outdated legislation, warning that TTIP could erase these protections through harmonization and mutual recognition. The document outlines six primary concerns shared by over 110 civil society organizations, including the potential to block sub-federal regulatory action in US states and EU Member States, limit public access to toxic chemical information, and derail EU leadership on emerging issues like endocrine disruptors and nanomaterials.
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Document type: Policy brief
Views on suggested changes to the Modalities and Procedures (M&Ps) for the Clean Development Mechanism (CDM)
The statement argues that the CDM currently functions as a zero-sum offsetting mechanism that may increase global emissions due to non-additional credits. It recommends a shift toward achieving 'net atmospheric benefits' and proposes rigorous reforms to additionality assessments, the exclusion of high-emission technologies like coal, and the establishment of formal grievance mechanisms and enhanced civil society participation. The author also calls for greater transparency from Designated National Authorities (DNAs) and a restructured CDM Executive Board to prevent conflicts of interest.
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Document type: Statement
Setting the record straight on TTIP: Yes let's
The authors critique the American Chemistry Council (ACC) and the European Chemical Industry Council (Cefic) for submitting draft legal text to TTIP negotiators that they claim would stall the reduction of carcinogens and endocrine disruptors. They argue that the industry's proposals for 'mutual recognition' of notifications and registrations would undermine the EU's REACH principle of 'no-data, no-market'. The text further asserts that the US Trade Advisory System is imbalanced, with industry groups comprising 85% of its members, granting them privileged access to negotiations compared to public interest groups.
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Document type: Statement
Energy security should have more weight in low carbon scenarios
The briefing critiques the EU's Energy Roadmap 2050 for providing only a "superficial treatment" of energy security, primarily limiting its analysis to import dependency and grid stability. The authors argue that energy security is a complex concept encompassing not only security of supply but also security of demand, economic and political risks, and environmental threats. They highlight that the roadmap relies on implicit assumptions—such as the guaranteed expansion of transmission infrastructure and the resolution of nuclear security issues—which may conceal potential challenges in the transition to a low-carbon system. The document advocates for a shift from purely quantitative metrics to a framework that includes qualitative assessments and considers the perspectives of various actors, including households and industries.
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Document type: Briefing
a case for pro-poor carbon projects
The author critiques the Clean Development Mechanism (CDM) for being corporately controlled and failing to deliver promised benefits to poor communities, particularly in India. The text argues that carbon trading should function as reparation for environmental damage, benefiting the underprivileged rather than subsidizing industry. To demonstrate an alternative, the author highlights LAYA's micro-scale projects involving energy-efficient woodstoves and clean drinking water, which share surplus resources with the community, and notes the Fair Climate Network's goal to facilitate 50 similar projects.
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Document type: Statement
Turbulences Ahead: Market Based Measures to reduce Aviation Emissions
The policy brief examines the climate impact of aviation, which contributes between 5% and 14% of global climate emissions. It critiques the reliance on offsetting, arguing that only a cap-and-trade system with a strict cap can deliver real in-sector reductions. The document analyzes ICAO's proposed measures, including a 'basket of measures' and various market-based options, while warning that low-quality offsets from mechanisms like the CDM and JI undermine environmental integrity. It also details the EU's attempt to include international flights in the EU-ETS and the subsequent 'stop the clock' derogation to allow ICAO to find a global solution.
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Document type: Policy brief
Crunch time for aviation emissions
The document critiques the International Civil Aviation Organization's (ICAO) progress toward a market-based measure (MBM) for international aviation emissions. It argues that the industry's preference for 100% offsetting fails to incentivize actual emission reductions within the sector and warns that low-quality offsets could exacerbate climate impacts. The author advocates for a cap-and-trade scheme with a stringent cap and strict quality restrictions on eligible offset credits to ensure environmental integrity.
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Document type: Statement
Stopping the clock on emissions from air travel: what's the buzz?
The document discusses the tension between the EU's unilateral inclusion of international aviation in its Emissions Trading Scheme (EU ETS) and the need for a global agreement via ICAO. It warns against the use of low-quality offset credits, specifically industrial gas offsets and non-additional CDM credits, arguing that any global mechanism must prioritize real, permanent, and verified emissions reductions over supplementary offsets.
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Document type: Statement
Wolf in Sheep’s Clothing?
The report critiques the concept of 'sustainable intensification,' asserting that it serves as a cover for conventional intensive agriculture and the expansion of genetically modified (GM) crops. It highlights how funding from entities like the Gates Foundation and the UK government prioritizes biotechnology over agro-ecological methods. The document argues that GM crops have not delivered promised yield increases or affordable climate adaptation, and instead increase seed costs and chemical dependency. It contrasts this approach with agro-ecology and 'food sovereignty,' which emphasize small-scale farmers' knowledge and traditional practices as more sustainable and productive alternatives.
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Document type: Executive summary
Reality Check: Honest Assessments of Our Energy Future
The authors assert that 80 percent of global energy needs could be met by renewables by 2050, as stated by the IPCC. They critique a New York Times op-ed by Robert Bryce, arguing that his claims regarding the environmental impact and land requirements of wind and solar are based on faulty calculations. The text highlights that a 33 percent renewable electricity mandate in the US would require approximately 800 square miles of land, which is less than one third of the forest area destroyed by mountaintop removal coal mining. The authors advocate for a diverse energy platform including renewables, natural gas, and nuclear power, evaluated through honest life-cycle criteria.
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Document type: Statement
Nuclear Nonsense
Amory B. Lovins critiques Stewart Brand's advocacy for nuclear power, asserting that nuclear energy is economically uncompetitive and slower to deploy than decentralized renewables and efficiency measures. Lovins argues that nuclear power's high capital costs and financial risks make it a poor investment for climate protection, noting that it saves significantly less carbon per dollar and is deployed much slower than alternatives. He refutes claims regarding the necessity of 'baseload' power, the land-use footprint of renewables, and the need for a diverse energy portfolio that includes nuclear power, concluding that the technology's failure to attract private equity in the U.S. demonstrates its lack of market viability.
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Document type: Statement
Summary of the Harmful Provisions in the Energy Bill
The document lists 22 provisions of a U.S. energy bill that the authors claim fail to address global warming or oil dependence. Key criticisms include the provision of billions in subsidies to the nuclear and coal industries, the weakening of the Clean Water Act and Safe Drinking Water Act, and the reduction of state authority over liquefied natural gas (LNG) facilities and transmission lines.
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Document type: Statement
Bush Mandate Centralizes Regulatory Power, Endangers Public
The report analyzes the impact of Executive Order 13422, which modifies the regulatory process by placing political appointees as gatekeepers in federal agencies and expanding the review of non-binding guidance documents by the Office of Information and Regulatory Affairs (OIRA). It contends that the order shifts the focus of regulation toward addressing 'market failures' and aggregate cost-benefit analyses, potentially delaying critical safety and health protections and increasing political interference in science-based regulatory processes.
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Document type: Report