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KM_C654e-20180221122406
The Department of Environmental Affairs (DEA) of South Africa responded to concerns raised by the Centre for Environmental Rights (CER) regarding the interpretation and implementation of the National Greenhouse Gas (GHG) Reporting Regulations and the National Pollution Prevention Plan (PPP) Regulations.
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Document type: Statement
GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2007): RICHARDS BAY
This responding statement, submitted by groundWork to the Department of Forestry, Fisheries and the Environment (DFFE), argues for the dismissal of Karpowership SA (PTY) Ltd’s appeal against the refusal of an Environmental Authorisation (EA) for a gas-to-power project in Richards Bay. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more cost-effective, renewable energy alternatives.
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Document type: Statement
Carbon Market Watch’s response to the inception impact assessment of the carbon leakage list for the period 2021-2030
Carbon Market Watch criticizes the EU ETS's free allocation of pollution permits, claiming it has generated over 25 billion euros in windfall profits and stalled industrial emissions cuts. The organization argues that the current approach fails to align with Paris climate goals and recommends a more rigorous impact assessment for the 2021-2030 carbon leakage list. Key recommendations include accounting for international climate policies (such as the Chinese and Californian ETS), focusing on direct emissions, and applying the precautionary principle to ensure only sectors at very high risk of carbon leakage receive free allowances.
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Document type: Statement
Carbon Market Watch reply to the European Commissionʼs Inception Impact Assessment for updated rules to the EU ETS aviation coverage
Carbon Market Watch urges the European Commission to adopt the most ambitious options for the EU ETS aviation coverage, specifically advocating for full coverage of emissions and 100% auctioning of allowances from the regulation's adoption. The organization criticizes CORSIA as an ineffective climate strategy and warns that replacing EU ETS coverage with CORSIA would reduce climate ambition and revenue. Additionally, the document calls for the regulation of non-CO2 effects, which are estimated to multiply the global warming impact of aviation CO2 by 2-4 times.
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Document type: Statement
Response to SBTi Call for evidence on the effectiveness of Environmental Attribute Certificates in climate targets
The submission argues that environmental attribute certificates, specifically REDD+ carbon credits and energy certificates like RECs and GOs, are unsuitable for corporate decarbonisation targets. It highlights systemic issues in the voluntary carbon market, including over-crediting and flawed methodologies in REDD+ projects, and asserts that energy certificates are financial instruments that do not represent physical electricity delivery. The document advocates for a strict separation of these certificates from gross emission reduction targets, citing the EU Corporate Sustainability Reporting Directive (CSRD) as a regulatory precedent.
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Document type: Statement
Net Zero Review response
Ember argues that the UK can achieve clean power by 2030 to combat inflation and energy price volatility. The organization identifies planning delays as a primary barrier and criticizes the economic efficiency and sustainability of biomass and BECCS subsidies.
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Document type: Statement
Safeguard Mechanism Consultation - Response for Coal Mine Methane
Ember argues that Australia's Safeguard Mechanism must address the significant underestimation of coal mine methane (CMM) emissions, which it claims are 30-40% higher than reported. The response advocates for a faster baseline decline rate for the coal sector, the adoption of a 20-year Global Warming Potential (GWP) for methane, and a strict industry benchmark of 1-3kg of methane per tonne of coal. Ember specifically calls for a ban on new coal mines and expansions, noting that if 75% of proposed mines proceed, fugitive methane emissions could increase 1.5 times by 2030. The document also suggests that thermal coal mines should be phased out more aggressively than metallurgical coal mines due to the latter's role in steel production.
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Document type: Report
IISD Experimental Lakes Area’s Response to Ontario’s Commitments to Freshwater Protection in Preserving and Protecting our Environment for Future Generations: A Made-in-Ontario Environment Plan
The IISD Experimental Lakes Area (IISD-ELA) responds to Ontario's Environment Plan by urging the government to integrate more rigorous scientific evidence, expanded monitoring, and new technologies into its freshwater protection strategies. Key recommendations include extending air pollutant monitoring to water bodies, researching the impacts of salinity and plastics, setting a specific 18.4 per cent phosphorus reduction target for Lake of the Woods, and utilizing the Internet of Things for real-time sewage flow monitoring.
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Document type: Statement
IISD’s Response to Manitoba’s Proposed New Water Rights Regulations to Protect Wetlands and Make Drainage More Sustainable in the Province
IISD argues that proposed drainage regulations in Manitoba would undermine the goal of no net loss of wetland benefits by enabling the drainage of permanent wetlands (Classes 3, 4, and 5) through payment or purchase options. The organization recommends legislating full protection for Class 4 and 5 wetlands, enhancing protections for Class 3 wetlands, and requiring drainage licenses for all new subsurface tile drainage. Additionally, IISD calls for public online access to drainage permit applications, mandatory downstream landowner approvals for culvert changes that increase flow, and the completion of a provincial wetland inventory to support monitoring and evaluation.
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Document type: Statement
Analyses et commentaires des banques en réaction au rapport Actifs fossiles : les nouveaux subprimes ?
The document details the reactions of eleven major European banks to a report on fossil fuel asset exposure. It provides specific 2019 data on fossil assets and equity for each bank, calculating a risk ratio. While some banks like BNP Paribas, Société Générale, and BPCE provided detailed rebuttals or highlighted their transition policies and green financing, others, such as Deutsche Bank and Santander, declined to respond. The banks generally contest the report's methodology, arguing that it ignores portfolio selectivity, client transition strategies, and the broader solvency of banking groups.
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Document type: Report