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Natural Justice critiques the draft National Energy Policy (NEP) 2025 for Kenya, highlighting a contradiction between its clean energy goals and its proposal to continue oil, coal, and nuclear development. The organization argues that these fossil-fuel and nuclear pathways risk creating stranded assets and undermine climate commitments. Key recommendations include the adoption of a dedicated Just Energy Transition chapter, the mandatory use of Community Development Agreements (CDAs), and the alignment of land acquisition practices with World Bank standards. Natural Justice specifically urges the removal of nuclear energy and liquefied natural gas (LNG) from the policy in favor of geothermal, solar, and wind alternatives.

A submission by a coalition of civil society organisations—including Law for Energy Transitions Africa, Natural Justice, The Green Connection, and Project 90 by 2030—providing detailed comments on the draft South African Wholesale Electricity Market (SAWEM) Code and Rules. The submission argues that the draft framework lacks sufficient alignment with constitutional rights and climate obligations, suffers from governance conflicts of interest due to the Market Operator's link to Eskom, and lacks transparency regarding costs and contracts.

The Public Affairs Research Institute (PARI) critiques the Draft Revised White Paper for Local Government, arguing that it relies too heavily on technical and managerial solutions for fundamentally political problems. PARI suggests that the proposed shift to a single-tier municipal system is politically unfeasible and warns that removing functions from weaker municipalities could undermine democratic accountability. The submission advocates for a stronger focus on the affordability of basic services, noting that 40% of households cannot afford them, and calls for a revitalisation of democratic social mobilisation to drive genuine reform. It also recommends formalising the role of traditional leadership through democratically responsive compacts and improving municipal communication to rebuild public trust.

A joint statement by five Canadian environmental and health organizations—Ecojustice, Breast Cancer Action Quebec, the Canadian Association of Physicians for the Environment, the David Suzuki Foundation, and Environmental Defence—providing feedback on the 'Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams'. While the organizations support the proposed risk management measures and their alignment with European Union and Washington State standards, they strongly criticize the proposed implementation timelines, which could allow some facilities to use PFAS-containing foams until 2039.

ClientEarth argues that environmental safeguards are constitutional obligations, not administrative burdens, and that the EU should address implementation bottlenecks—such as lack of staffing and poor digitalisation—rather than deregulating. The document specifically opposes the discontinuation of the SCIP database, the simplification of the EU Deforestation Regulation (EUDR), and the weakening of the Industrial Emissions Directive (IED) or Nature Restoration Regulation (NRR). It emphasizes that robust environmental assessments provide legal certainty and risk mitigation for investors.

The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, submitted comments on the Presidential Climate Commission's (PCC) draft recommendations for South Africa's 2030–2035 Nationally Determined Contribution (NDC) update. The submission emphasizes the need for high mitigation ambition to avoid fossil fuel lock-in, the integration of social justice, and the urgent implementation of adaptation measures in accordance with the Climate Change Act.

A joint statement from five Canadian environmental and health organizations—including Ecojustice and the Canadian Association of Physicians for the Environment—urging the Canadian government to expedite the listing and regulation of per- and polyfluoroalkyl substances (PFAS). The organizations argue that current regulatory criteria underestimate PFAS bioaccumulation and call for the inclusion of fluoropolymers, as well as an accelerated timeline for phasing out PFAS in firefighting foams and consumer products.

The GCHA submission argues that Chile's climate action should be framed through a public health lens to maximize health co-benefits, increase public support, and reduce the disease burden on the healthcare sector. The document recommends aligning emissions targets with a 1.5°C limit, accelerating health-related climate risk assessments, and implementing specific mitigation actions within the healthcare sector, which currently accounts for 6.7% of national emissions. It further suggests phasing out diesel subsidies, accelerating the coal phase-out date to 2030, and deprivatizing water to protect public health. The GCHA emphasizes the need for disaggregated epidemiological data to protect vulnerable groups and suggests using WHO tools to quantify the economic returns of health-promoting climate actions.

Carbon Market Watch argues that the draft appeal and grievance processes for the Article 6.4 mechanism are insufficient and not ready for adoption. The organization recommends a structured consultation period of at least one month and suggests using the Green Climate Fund's Independent Redress Mechanism as a model for accessibility, legitimacy, and rights compatibility. Key criticisms include the imposition of appeal and grievance fees, restrictive eligibility criteria for appellants and grievants, limited language options (English only), and a lack of retaliation safeguards.

The submission argues that mandatory hazard labelling is essential for public health, particularly for women, children, and racialized communities, and advocates for the phaseout of carcinogens, mutagens, and endocrine disruptors in consumer products.

The Life after Coal Campaign and the Fair Finance Coalition Southern Africa argue that the JET-IP is heavily skewed toward private sector interests and large-scale infrastructure, specifically green hydrogen, at the expense of community-led renewable energy and social investment. They highlight critical gaps in policy alignment, the lack of transparency regarding debt and loan agreements, and the failure to adequately address the health impacts of air pollution at the Medupi and Kusile power stations. The authors call for a reprioritization of funding toward transmission grid strengthening and socially owned energy models, while warning that the current approach to decommissioning coal plants, as seen at Komati, lacks the necessary community participation to be considered 'just'.

Natural Justice critiques the South African Oceans Economy Master Plan to 2035, stating it lacks concrete analysis on greenhouse gas mitigation and contradicts global scientific consensus by proposing offshore oil and gas exploration. The commentary highlights a 'troubling absence' of biodiversity considerations and fails to address the needs of small-scale and subsistence fishers. It further argues that the plan's job creation claims lack factual support and that the public participation process was flawed, excluding many marginalized coastal communities.

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.

Natural Justice submitted a series of recommendations to the Kenyan government regarding the Draft Forest Policy 2020. The organization argues that the draft unfairly portrays local communities as the primary drivers of forest degradation while ignoring the impact of multinational corporations and government infrastructure projects. They propose integrating a human-rights based approach, recognizing indigenous land tenure and traditional governance, and ensuring that conservation funding reaches the community level. Additionally, they call for greater transparency in the policy's formulation and the inclusion of independent monitoring to address conflicts of interest within the Kenya Forest Service.

The IISD argues that Canada's current draft framework for assessing non-tax fossil fuel subsidies is too restrictive and lacks transparency. It recommends adopting the World Trade Organization (WTO) definition of subsidies, removing qualifiers like 'specificity' and 'normality', and aligning the 'inefficiency' criteria with Canada's Paris Agreement commitments. The document emphasizes the need for full public disclosure of subsidy data, coordination with Finance Canada on tax-related measures, and the inclusion of provincial and territorial jurisdictions to meet the G7's 2025 phase-out deadline.

The Centre for Environmental Rights (CER) provides written submissions on the March 2018 Final Draft Report of Climate Change Mitigation Policies and Measures (PAMs). The CER supports the examination of policy effectiveness but identifies several gaps, including the need for better alignment between various government climate projects, the exclusion of certain greenhouse gases and externalities in socio-economic analyses, and a lack of rationale for prioritizing coal-to-liquid production through 2050. The CER emphasizes that the report's findings—specifically regarding the electricity sector as the key to decarbonization—should inform the revision of the Integrated Resource Plan for Electricity (IRP 2010).

CIEL argues that the World Bank's Draft Guidance Notes for the ESF are 'severely lacking in substance' and often merely reiterate standards without providing actual implementation guidance. The submission provides specific recommendations across several standards, including labor conditions, pollution prevention, indigenous peoples' rights, and stakeholder engagement. Key demands include the integration of international conventions (such as ILO 169 and UNDRIP), the adoption of a 1.5-degree pathway for greenhouse gas accounting, and the explicit protection of human rights defenders against reprisals. CIEL also emphasizes that the World Bank must ensure Borrowers disclose the existence of the Inspection Panel to affected communities and that project-level grievance mechanisms must be independent, transparent, and rights-compatible.

The Centre for Environmental Rights (CER) supports the objectives of the Climate Change Mitigation Policies and Measures (PAMs) study but argues that its current methodology is too narrow. The CER contends that limiting the analysis to carbon dioxide, methane, and nitrous oxide excludes other critical greenhouse gases and pollutants, such as hydrofluorocarbons, perfluorocarbons, sulphur hexafluoride, black carbon, and hydrochlorofluorocarbons, which could undermine the accuracy of the modelling and miss significant mitigation opportunities.

Stakeholder organizations are urging the CDM Executive Board to intervene in the Barro Blanco Hydroelectric Power Plant Project in Panama due to ongoing human rights concerns, including threats of forced eviction of Ngäbe indigenous communities and failure to obtain free, prior and informed consent. The authors highlight that the project developer, GENISA, was fined $775,200 by Panama's Environment Ministry for non-compliance with its environmental impact assessment, including failures to relocate and compensate affected people. The stakeholders request that the Board notify UN human rights bodies, inquire with Panamanian authorities, and consider withdrawing the project's registration if it violates CDM procedures.

The Centre for Environmental Rights (CER) provides submissions on the first draft of the Nkangala District Municipality (NDM) Air Quality Management Plan (AQMP). The CER identifies significant gaps in technical and financial capacity, a lack of alignment with the Highveld Priority Area (HPA) AQMP, and deficiencies in health impact assessments and monitoring. The submissions call for the NDM to prioritize staffing, ensure transparency in air quality data, and implement stricter dust control regulations.