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Fairness needs to be the foundation for the Government’s next Carbon Budget - Climate Outreach
The document responds to the Department for Energy Security & Net Zero's proposal for the Seventh Carbon Budget, which aims for an 87% emissions reduction by 2038. While acknowledging the growth of the clean energy economy and public support for climate action, it warns that trust in politics is low and that the transition of sectors like transport and housing must not punish ordinary people. It advocates for linking the clean energy transition to everyday concerns such as bills and housing to maintain public backing.
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Document type: Statement
CEO Note: What rewilding victory looks like
The CEO of Mighty Earth reports on rewilding successes, including the planned restoration of grizzly bears to Washington state and a feasibility study for their return to California. The note also celebrates the creation of the 729,000-acre Patagonia Azul Provincial Park in Argentina and calls for Indonesia to shift its 'food and energy estates' project from intact forests to degraded lands to protect biodiversity and climate goals.
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Document type: Statement
CCS Comments on the First National Nature Assessment Zero Order Draft
The Center for Climate and Security (CCS) has submitted comments on the Zero Order Draft of the First National Nature Assessment (NNA1), prepared by the US Global Change Research Program (USGCRP). CCS supports the draft's inclusion of anthropogenic ecosystems, biotic eruptions, and the link between global nature loss and U.S. security. However, CCS recommends that the NNA1 expand its analysis to include unprotected, privately owned nature as a source of hazard aversion and incorporate benefit-cost analyses comparing nature-based solutions with synthetic alternatives. Additionally, CCS urges the inclusion of maladaptation risks to human and national security, citing examples from São Tomé and Príncipe and Vanuatu where climate finance projects failed to account for social inequalities and power dynamics.
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Document type: Statement
Addressing Liquidity Challenges
The paper argues that the corporate concept of solvency is inapplicable to sovereign states, suggesting instead that debt sustainability should be the anchoring concept for liquidity discussions. It identifies three interpretations of liquidity challenges: as a contrast to solvency, as rollover risks, and as a gap in financing for long-term investments. The authors highlight a prevalent "too optimistic" bias in sustainability assessments, which delays necessary debt restructurings. They recommend that debtor countries prioritize creating fiscal space through restructuring and that the international community enhance transparency via multistakeholder forums to align debt sustainability analyses with climate and development investment needs.
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Document type: Research paper
NATURAL JUSTICE AND THE ENVIRONMENTAL LAWYERS COLLECTIVE FOR AFRICA COMMENTS ON ZERO DRAFT STUDY ON THE IMPACT OF CLIMATE CHANGE ON HUMAN AND PEOPLE’S RIGHTS AFRICA
This briefing, submitted by Natural Justice and the Environmental Lawyers Collective for Africa (E.L.C.A), provides commentary on a zero draft study by the African Commission on Human and Peoples’ Rights (ACHPR) regarding the impact of climate change on human and people's rights in Africa. The document evaluates the study's identification of vulnerable groups and rights, critiques its approach to corporate accountability and extractive industries, and offers recommendations to strengthen the protection of indigenous peoples, children, and the environment through legal and monitoring frameworks.
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Document type: Briefing
NATURAL JUSTICE COMMENTARY ON THE NATIONAL NUCLEAR REGULATOR AMENDMENT BILL [B25-2023]
Natural Justice argues that nuclear energy is an economically unviable and environmentally dangerous alternative to renewable energy in South Africa. The commentary contends that the National Nuclear Regulator Amendment Bill encourages investment in a sector characterized by high costs, long lead times, and significant waste management risks. It specifically criticizes the extensive powers granted to the Minister of Mineral Resources and Energy, citing the Department's poor track record in rehabilitating abandoned mines as evidence that it cannot be trusted to manage nuclear decommissioning and waste. The authors advocate for decentralized renewable energy solutions, such as solar and wind, to address load shedding and rural energy access.
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Document type: Statement
COMMENTARY ON THE DRAFT WHITE PAPER ON CONSERVATION AND SUSTAINABLE USE OF SOUTH AFRICA’S BIODIVERSITY 2022
Natural Justice and the Biodiversity Law Centre express strong support for the Draft White Paper on Conservation and Sustainable Use of South Africa’s Biodiversity 2022. They commend the document for moving away from colonial and apartheid-era conservation models toward a vision of 'Living in Harmony with Nature' that integrates human well-being, animal welfare, and the intrinsic value of nature. The organizations highlight the need to address the lack of transformation in the biodiversity sector and the ongoing threats of habitat loss and invasive species in South Africa.
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Document type: Statement
Earthjustice Statement on West Virginia v. EPA Oral Arguments
Earthjustice argues that the Supreme Court may use the 'major questions' doctrine in West Virginia v. EPA to limit the EPA's ability to combat climate change and regulate industrial air pollution, potentially undermining the regulatory authority granted by the Clean Air Act.
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Document type: Statement
CATF Comments on the USAID Climate Strategy 2022-2030
The Clean Air Task Force (CATF) argues that the USAID Climate Strategy 2022-2030 should expand its scope beyond renewable energy to include advanced clean energy technologies such as carbon capture, utilization and storage (CCUS), clean hydrogen, and advanced nuclear. CATF contends these are essential for decarbonizing hard-to-abate sectors like heavy industry and shipping, and for maintaining grid reliability. The organization also urges USAID to explicitly support the Global Methane Pledge by helping partner countries reduce short-lived climate pollutants (SLCPs), specifically in the oil and gas sector, provided such investments do not extend the life of fossil fuel operations. Finally, CATF recommends that USAID better align its climate programming with the broader economic, human development, and COVID-recovery priorities of host countries to ensure long-term sustainability and local ownership.
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Document type: Statement
Financing 1.5°C: What’s Driving ESG-Related Mergers?
Large financial institutions are increasingly acquiring smaller firms specializing in environmental, social, and governance (ESG) expertise to improve their analytical capabilities regarding climate risk. This trend is driven by the need for high-quality data and the ability to integrate forward-looking climate scenarios into risk frameworks, partly spurred by the TCFD recommendations. The author predicts a similar wave of M&A activity will shift toward 'climate alignment'—the process of aligning portfolios with 1.5°C targets—as financial firms seek the proprietary data and technology necessary to meet net-zero commitments.
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Document type: Briefing
Remarks of Ann Weeks, for Clean Air Task Force Virtual Public Hearing on Proposed Revised Cross-State Air Pollution Rule Update for the 2008 Ozone NAAAQS, Fed. Reg. 68,964 (Oct. 30, 2020)
Clean Air Task Force argues that the EPA's proposed ozone reductions are insufficient, urging the agency to address the 2015 ozone standard, expand NOx controls to industrial and transportation sectors, and analyze the environmental justice impacts of power plant emissions and trading programs.
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Document type: Statement
Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020
The Centre for Environmental Rights, on behalf of the Life After Coal campaign and 350Africa.org, provides commentary on the National Treasury's 2020 Draft Technical Paper 'Financing a Sustainable Economy'. The submission argues that the Draft Paper focuses too heavily on voluntary disclosure rather than binding commitments and fails to align with the urgency of the climate crisis or South Africa's international obligations under the Paris Agreement.
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Document type: Statement
Green Climate Fund Replenishment Pledges a Positive Step, But Far More Finance Needed
The World Resources Institute acknowledges the $9.7 billion in pledges to the Green Climate Fund's first replenishment as a positive step, noting that 11 countries at least doubled their previous contributions. However, the statement argues that significantly more finance is required to address the climate emergency, calling for contributions from the United States, Australia, wealthy oil-producing states, and other large emitters to support vulnerable countries.
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Document type: Statement
TOWARDS PROCUREMENT FOR DEVELOPMENT: A COMMENT ON PARI – POSITIONS ON STATE REFORM IN SOUTH AFRICA
The author comments on PARI's position papers regarding state reform in South Africa, arguing that public procurement should be used as a tool for industrial policy and economic transformation. The text distinguishes between 'developmental' procurement, which fosters high-productivity industries and innovation, and 'non-developmental' procurement, which often results in the outsourcing of state services to dependent firms. The author suggests that while South Africa has used procurement to support black business growth, there is an urgent need to transition toward 'Procurement for Innovation' (PPfI) to drive structural transformation and reduce the influence of state-dependent coalitions associated with 'state capture'.
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Document type: Statement
Everyones talking climate so where next?
The author reflects on the impact of Extinction Rebellion's April 2019 protests in London, noting that while they successfully brought climate change to the mainstream, the movement now faces the challenge of maintaining this momentum. The text advocates for the implementation of a Citizens' Assembly to facilitate public policy discussions, while warning that decarbonisation goals—such as reducing meat consumption and flying—may face public resistance. It further emphasizes the need to increase ethnic and socio-economic diversity within climate activism to move beyond 'middle-class white folks' and ensure a 'just transition' that is socially sustainable.
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Document type: Statement
Summary Comments to the Proposals for Amendment of the ICSID Arbitration Rules
The International Institute for Sustainable Development (IISD) critiques the ICSID Secretariat's proposed rule amendments (Working Paper #2), stating they fail to address core concerns of states and stakeholders. The IISD argues that many necessary reforms—such as prohibiting 'double-hatting' of arbitrators, mandating the publication of awards, and expanding the grounds for review of decisions—cannot be achieved through rule changes alone and require amendments to the ICSID Convention itself. The document specifically recommends stricter standards for arbitrator independence, more flexible expedited arbitration rules for developing countries, and the introduction of mechanisms for third-party intervention and joinder to protect the rights of non-party stakeholders.
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Document type: Statement
CATF Statement on New Pennsylvania Methane Regulations
The Clean Air Task Force welcomes Pennsylvania's action to reduce methane emissions from new natural gas equipment, noting the state's position as the second-largest gas producer. The organization advocates for the state to next address emissions from existing equipment and contrasts Pennsylvania's approach with the federal government's policies, which it describes as rolling back safeguards intended to control methane waste and address climate change.
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Document type: Statement
COMMENTS ON NATIONAL PLANNING COMMISSION ECONOMY SERIES: ENERGY DISCUSSION PAPER
The Centre for Environmental Rights (CER) submits that South Africa must urgently transition from coal to renewable energy due to the declining competitiveness of coal, severe health and environmental impacts, and extreme vulnerability to climate change. The CER argues against new coal and nuclear infrastructure, recommends the decommissioning of non-compliant coal plants, and calls for a transformation of Eskom into an organ of state promoting clean energy. It further emphasizes the need for meaningful public consultation in energy planning and warns against the continued operation of high-emission facilities like Sasol's Secunda complex.
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Document type: Statement
Is “Moonlighting” a Problem? The role of ICJ judges in ISDS
The document analyzes the practice of 'moonlighting' by ICJ judges, noting that at least 20 current or former judges have served as arbitrators in at least 90 ISDS cases during their tenure. This represents approximately 10 per cent of all known treaty-based investment cases as of July 2017, which the author argues may undermine the ICJ's reputation for independence.
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Document type: Research paper
Brexit threatens far more than the UK’s future
The author contends that Brexit reflects a global anger toward political elites and the failures of globalisation, rather than a failure of the EU itself. The text highlights specific risks for Ireland, including the potential return of a land border and economic destruction if the UK leaves the single market. It further argues that the EU must reform its governance—specifically the European Council—to increase transparency and accountability to prevent further rises of right-wing populism in states like France. The author suggests that a lack of investment in infrastructure and a 'Green New Deal' contributed to the precariousness that fueled the Leave campaign.
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Document type: Statement