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ClientEarth argues that Ofgem's current statutory objectives are outdated and prioritize competition over decarbonisation, hindering long-term climate investments. The submission proposes narrowing Ofgem's principal objective to focus on security of supply and greenhouse gas reduction, introducing sector-specific carbon budgets, and requiring the Department for Business, Energy and Industrial Strategy (BEIS) to issue periodic Strategy and Policy Statements. Additionally, ClientEarth highlights a failure to regulate and verify non-carbon dioxide emissions, specifically methane and sulphur hexafluoride (SF6), and advocates for a consumption-based emissions accounting approach to include extraterritorial emissions from imported energy.

ClientEarth argues that the BEIS proposals for climate-related financial disclosures are inadequate and recommends a mandatory approach aligned with the full TCFD framework and Paris Agreement goals, supported by stronger regulatory enforcement and auditor assurance.

The document argues that U.S. nuclear policy is currently operating in an "information vacuum," with the Nuclear Regulatory Commission (NRC) often prioritizing licensee cost-savings over public safety and environmental data. It highlights systemic risks in "fast-track" decommissioning, the vulnerability of thin-walled spent fuel canisters to corrosion and failure, and the lack of scientific evidence supporting 80-year license extensions for aging plants. The authors further caution against the deployment of small modular reactors (SMRs) and the establishment of consolidated interim storage facilities (CISFs) without comprehensive risk and cost analyses. The briefing concludes with ten recommendations to policymakers, including mandating ASME N3 standards for waste containers, requiring "hot cells" for repackaging damaged fuel, and reforming NRC oversight to reduce regulatory capture.

The European Union has introduced the Paris Aligned Benchmark (PAB) and the Climate Transition Benchmark (CTB) to standardize green financial indices. However, Reclaim Finance argues these benchmarks are inadequate because they focus on carbon intensity rather than absolute emissions reductions and fail to exclude companies developing new fossil fuel projects. The briefing highlights the risk of greenwashing in passive index management, where assets under management exceed $10 trillion, and calls for stricter criteria, including absolute emission targets and a phased exit from fossil fuels by 2040 in OECD countries and 2050 globally.

The document warns that basing Total Allowable Catches (TACs) on total catch advice leads to overfishing when the Landing Obligation (LO) is not followed. It proposes three solutions: strict enforcement via Remote Electronic Monitoring, setting TACs below advised levels to account for illegal discards, or making quota top-ups conditional on proven compliance.

The document is a formal request by 87 public interest groups asking the U.S. EPA to provide in-person public hearings and extend the public comment period to 120 days for two proposed rules: the 'Part A' rule on Coal Combustion Residuals (CCR) closure deadlines and the revision of Effluent Limitations Guidelines (ELG) for steam electric power plants. The groups argue that the current 60-day window is insufficient due to holiday schedules and the complexity of the rules. They further contend that the EPA's proposed call-in sessions are an inadequate substitute for in-person hearings, which allow affected communities to present visual evidence and direct testimony regarding the toxic impact of coal ash on groundwater and surface waters.

ClientEarth argues that HM Treasury (HMT) is an obstacle to ambitious climate policy and lacks transparency in its coordination with other departments. The submission calls for a 'Climate Cabinet' and a parallel climate budget to ensure legal targets are met. In the financial sector, ClientEarth highlights a widespread failure among pension funds and asset managers to treat climate change as a material financial risk, noting a 'herd mentality' that stifles innovation. It criticises the Financial Conduct Authority (FCA) for a lack of enforcement regarding climate risk disclosures and warns of 'greenwash' in sustainable financial products. The document recommends mandatory TCFD reporting for large asset owners by 2022 and the regulation of investment consultants by the FCA.

The Canadian Association of Physicians for the Environment and other organizations are calling for an independent review of the PMRA's glyphosate re-evaluation decision (RVD2017-01). They argue that internal Monsanto documents, revealed during California litigation, show the company ghostwrote scientific studies and suppressed evidence of cancer risks—studies that the PMRA relied upon for its determination that glyphosate is unlikely to pose a human cancer risk. The authors also claim the PMRA failed to consider evidence regarding monarch decline, microbiomes, and the inefficiency of buffer zones as risk management strategies.

The Institute for Policy Integrity opposes the Department of the Interior's intent to roll back the 2016 Blowout Preventer Systems and Well Control Rule, asserting that the agency must analyze the lost societal benefits—including safety, environmental risk reduction, and reduced fatalities—before proceeding with the repeal.

The Canadian Association of Physicians for the Environment and supporting organizations argue that the proposed asbestos regulations contain critical gaps, specifically regarding legacy asbestos, mining residues, and industry exclusions. They recommend a comprehensive National Asbestos Strategy that includes a total ban on exports, the elimination of a 7-year exclusion for the chlor-alkali industry, and harmonized federal-provincial-territorial standards for end-of-life asbestos management.

The FRC is criticized for an 'oversight and enforcement gap' regarding climate-related financial risk, evidenced by its handling of complaints against oil and gas companies and its resistance to TCFD recommendations. These failures are compounded by structural weaknesses in the FRC's governance, transparency, and accountability, including a lack of a clear legislative basis and limited accountability to Parliament and the public.

The document argues that the PMRA has failed to meet legal requirements under the Pest Control Products Act (PCPA) to assess cumulative pesticide risks since 2006. While welcoming the proposed framework, the signatories recommend that cumulative assessments be integrated into individual pesticide registration and re-evaluation decisions, rather than occurring after them. They call for a precautionary approach to grouping pesticides by common mechanisms of toxicity, the inclusion of epidemiological data for outcomes like cancer and endocrine disruption, and the expansion of the framework to cover cumulative environmental risks. Additionally, the authors contest the PMRA's characterization of the 'PCPA factor' as a policy rather than a scientific uncertainty factor and urge for improved monitoring of human and environmental pesticide exposures.

The Centre for Environmental Rights (CER) argues that the draft mid-term review (MTR) of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP) is methodologically flawed, outdated, and fails to demonstrate progress toward its goals. The CER highlights widespread non-compliance with national ambient air quality standards (NAAQS), a deteriorating monitoring network, and significant data gaps in industrial emissions reporting. It specifically criticizes the lack of functional monitoring stations and the failure of key industrial facilities to reduce emissions, concluding that the overall objective of achieving NAAQS compliance in the HPA is not being met.

The report, authored by Dr. H.C. Clark, argues that the proposed natural gas storage in Gallery 2 is unsafe due to significant geological instabilities, including a history of massive roof collapses and the presence of major fault systems. Dr. Clark contends that the Federal Energy Regulatory Commission (FERC) and Arlington Storage Company have ignored critical historical data and failed to provide adequate geomechanical modeling or monitoring plans to address these site-specific risks.

The petition argues that current EPA regulations for the National Contingency Plan (NCP) Product Schedule are inadequate because they lack safety criteria and permit the withholding of ingredient information as confidential business information (CBI). Using the Deepwater Horizon disaster as a case study, the petitioners claim that the lack of data on chronic sub-lethal impacts, bio-accumulation, and subsea behavior led to environmental unknowns and hindered medical responses. They request that the EPA implement a more robust testing suite—including algal species and various water pressures and temperatures—and make full ingredient disclosure a condition for listing on the schedule.

For two decades, Detroit Edison tested a critical safety system at Fermi Unit 2 using an outdated 'answer key,' failing to verify if the system met current safety standards. Despite numerous audits and inspections by both the company and the NRC, the error persisted from 1986 to 2006.

The Clean Air Task Force argues that the EPA's proposed particulate matter (PM2.5) standards fail to provide an adequate margin of safety, potentially resulting in 10,000 more avoidable deaths per year than a more stringent 12 ug/m3 annual standard. The testimony asserts that protective standards are achievable through affordable technologies, specifically targeting sulfur dioxide (SO2) from power plants and carbon emissions from diesel fleets. It criticizes the Clean Air Interstate Rule (CAIR) for providing reductions that are "too little, too late" and for creating regulatory barriers that discourage states from pursuing additional cost-effective power plant reductions. The document advocates for a national SO2 cap of 2 million tons per year and the full funding of the Diesel Emission Reduction Act of 2005 to facilitate the retrofit of existing diesel engines.

The document criticizes a 2002 White House directive that allows "intermittent, low levels" of experimental GM genes in the food supply. It contends that the USDA, FDA, and EPA are implementing policies that lack mandatory safety testing, clear contamination limits, or rigorous oversight. The author highlights the risks of allergenicity, toxicity, and pharmaceutical contamination, noting that US exports and food aid spread these contaminants globally. The briefing calls for a return to a "zero tolerance" policy to protect human health and prevent the environmental amplification of GM traits.

The document challenges the PMRA's re-evaluation of glyphosate, claiming it relies heavily on outdated, confidential industry data while ignoring recent peer-reviewed literature and the exponential increase in glyphosate-based herbicide (GBH) use. It highlights significant gaps in the assessment of toxicological dangers, occupational risks, and food and water contamination, specifically citing concerns over carcinogenicity and endocrine disruption. The authors argue that the PMRA's findings contradict the precautionary spirit of the Pest Control Products Act and the Canadian Environmental Protection Act, calling for a suspension of the registration renewal and a transparent, independent re-evaluation of full herbicide formulations rather than just the active ingredient.

The document argues that hydraulic fracturing in South Africa's Karoo Basin is likely to induce seismicity and that current proposed regulations are insufficient. It recommends the implementation of a risk-based Traffic Light Protocol (TLP) and a transparent, multi-tiered earthquake monitoring system to mitigate risks of building damage and public harm.