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The document argues that the DOE's proposed 4 kgCO2e/kgH2 standard is too weak and should be lowered to 1 kgCO2e/kgH2 to prioritize truly zero-emission hydrogen. It criticizes the GREET model for underestimating methane leakage and grid emissions, warns against the safety and environmental risks of carbon capture and storage (CCS), and demands that the hydrogen hub program incorporate strict environmental justice protections and community engagement.

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted comments on the Draft 8th National Greenhouse Gas Inventory Report (NGHGIR) on 31 August 2022. The submission argues that the draft significantly undercounts methane emissions due to the omission of fugitive emissions from the oil and gas industry, pipeline transport, and abandoned mines, and criticizes the use of outdated global warming potential (GWP) metrics and low emission factors for coal mining.

Ember expresses concern that the mainstream model of BECCS—adding carbon capture to biomass power plants—may not generate negative emissions because burning wood for power is increasingly viewed as a net emitter of CO2. The submission highlights the high risk associated with the Drax power station project, noting it could cost UK energy bill payers over £30bn while potentially failing to deliver negative emissions. Ember recommends that the UK’s Biomass Strategy 2022 prioritize scientific research and independent monitoring of supply chains over the premature promotion of BECCS projects.

Carbon Market Watch criticises a proposal by fifteen Members of the European Parliament to incentivise CCS and CCU within the EU carbon market. The organisation distinguishes between carbon removals, which physically remove greenhouse gases from the atmosphere, and CCS/CCU, which typically only capture emissions from industrial sources. It warns that promoting CCS/CCU could lead to greenwashing, stranded assets, and delayed emissions, particularly in the power sector. The document specifically highlights the risks of BECCS and waste-to-energy CCS, citing deforestation linked to the Drax power plant. It concludes that the EU carbon market must focus on reducing emissions at the source and that public funding should only support mature, transparently assessed carbon removal technologies.

The report examines how the EU sustainable taxonomy, originally designed to be science-based, has been influenced by industry lobbying to potentially include fossil gas and nuclear energy. It argues that gas is not a sustainable transition fuel due to methane leaks and carbon lock-in, and that nuclear energy fails the 'do no significant harm' (DNSH) principle due to waste and safety risks. The document details the scale of lobbying efforts, identifying hundreds of meetings between EU officials and industry representatives, and criticizes the EU Commission for deferring decisions on these technologies to future legislation and relying on flawed technical reports.

Ember argues that the viability of BECCS as a negative emissions mechanism is undermined by the fact that burning biomass may be net carbon emitting rather than carbon neutral. The document highlights the lack of UK policy measures to ensure carbon-saving biomass production and warns that the land requirements for energy crops could lead to significant food, water, and biodiversity impacts. Furthermore, Ember contends that public subsidies for BECCS are expensive and potentially less effective than investing in rapid decarbonisation or natural forest restoration.

ClientEarth and ECOS submit that the European Chemicals Agency's (ECHA) proposed exemption for 'biodegradable' microplastics lacks sufficient scientific evidence to ensure degradation in real-world environmental conditions. They argue that current laboratory tests at 20°C do not reliably predict biodegradation at lower average temperatures found in nature, such as 12°C in soil and fresh water or 9°C in marine environments. The organizations recommend that no exemption be granted at this stage to maintain incentives for improving testing criteria. Alternatively, they propose a more rigorous framework requiring each polymer and substance in a microplastic mixture to be evaluated separately, with specific ultimate degradation thresholds of ≥ 90% relative to reference materials within defined timeframes for water and soil.

The Centre for Environmental Rights asserts that "clean coal" technology is a misnomer used by vested interests to sustain the coal industry despite its severe environmental and health impacts. The letter argues that coal-fired power is unsustainable and that South Africa must transition to wind and solar power to meet global climate targets and avoid stranding its workforce.

A formal submission by the Vaal Environmental Justice Alliance (VEJA) and groundWork (gW) objecting to ArcelorMittal South Africa's (AMSA) application for postponements and alternative emission standards at its Vanderbijlpark Works facility.

The Freshwater Research Centre (FRC) reviewed the MCWAP Phase 2A Draft Environmental Impact Assessment Report (DEIR) and found it inadequate in its assessment of operational phase impacts on rivers and wetlands. Key criticisms include the failure to account for cumulative climate change risks, the lack of consultation with neighbouring states in the Limpopo River Basin, and the use of a risk matrix that does not assess the significance of impacts as required by NEMA. The FRC highlights significant risks regarding the transfer of poor-quality water and invasive species, such as Water Hyacinth, from the donor Crocodile (West) River and Hartbeespoort Dam to the recipient Matlabas and Mokolo River catchments.

The policy brief examines the risks of including the LULUCF sector in the EU's 2030 climate framework, specifically the danger that carbon sinks could be used to reduce the decarbonization efforts of sectors like transport and manufacturing. It identifies four primary reasons why LULUCF is unfit for integration with other climate instruments: high data uncertainty (32% compared to 1% for fossil fuels), incomplete accounting methods that allow for over-crediting, the non-permanence of biological carbon stores, and the need for carbon removals to be additional to, rather than replacements for, emission reductions. The author highlights specific accounting flaws, such as 'Gross-net accounting' and 'forest management reference levels' (FMRL), which may allow Member States to generate unearned credits. Additionally, the brief criticizes the assumption of biomass carbon neutrality, noting that emissions from burning wood are often unaccounted for in the EU ETS or ESD. The document recommends that LULUCF be maintained in a separate pillar, that land-use offsets be prohibited, and that biomass sustainability criteria be strictly enforced.

The Clean Air Task Force (CATF) supports the readoption of California's Low Carbon Fuel Standard (LCFS) through 2020 but argues against reducing the indirect land use change (ILUC) emissions score for corn ethanol. CATF contends that current modeling, specifically the CA GTAP-BIO model, underestimates emissions by ignoring water scarcity, failing to differentiate between commercial and non-commercial forests, and using flawed yield price elasticity assumptions. The document also highlights the negative impact of corn ethanol on global food security and proposes liquid ammonia as a scalable, low-carbon fuel alternative for the post-2020 period.

The document argues that Dr. Charles R. Frank Jr.'s analysis of electricity technology costs is based on outdated and methodologically flawed assumptions. Amory Lovins asserts that updating nine key variables—including capital costs and capacity factors for solar and wind power—would reverse Frank's conclusions. Lovins specifically critiques the use of national average costs, which he claims are inflated by atypical projects and do not reflect modern competitive practice.

The author argues that Dr. Charles R. Frank, Jr.'s analysis incorrectly concludes that nuclear and gas combined-cycle plants are more beneficial than wind and solar. By replacing Frank's data with empirical figures from the EIA and DOE, the author asserts that the priority for carbon savings actually shifts to hydro, wind, gas combined-cycle, nuclear, and solar. The critique highlights significant underestimations of renewable productivity and overestimations of gas and nuclear costs and reliability.

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a formal reply on 24 March 2014 challenging Eskom's applications for postponement from the Minimum Emission Standards (MES). The CER disputes Eskom's claims that its power stations have a marginal impact on air quality and health, arguing that Eskom's Atmospheric Impact Reports (AIRs) are anecdotal, use insufficient modeling domains, and fail to quantify the health risks associated with secondary PM2.5 formation and mercury emissions.

The Centre for Environmental Rights (CER) argues that Eskom's requests to postpone compliance with the National Environmental Management: Air Quality Act (AQA) should be denied due to flawed atmospheric modelling, exaggerated compliance costs, and significant risks to human health. The CER contends that Eskom fails to meet the legal requirements for postponement, particularly regarding the impact on declared Priority Areas. Furthermore, the document critiques Eskom's proposal for emission offsets as lacking a legal basis and sufficient data, while highlighting that granting these postponements would lead to substantial increases in SO2, NOx, and PM10 emissions through 2020.

The Centre for Environmental Rights (CER), representing various community and environmental groups, submitted formal objections to Eskom's application to vary the Atmospheric Emission Licence (AEL) for the Kriel Power Station. The CER argues that the requested increase in particulate matter (PM) emissions would exacerbate poor air quality in the Highveld Priority Area, cause significant health impacts, and result from Eskom's own poor planning rather than a genuine emergency.

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted comments on August 23, 2013, regarding uMoya-NILU Consulting's Plan of Study (PoS). The PoS was designed to support Eskom's applications for exemptions and postponements of Minimum Emission Standards (MES) for its power stations. The CER argues that the PoS is too narrow in scope, fails to include critical pollutants like PM2.5, uses inappropriate modelling software for near-field impacts, and lacks a mechanism to verify model outputs against real-world ambient measurements.

The author argues that geologic carbon storage and hydraulic fracturing can safely coexist in the U.S., asserting that a Princeton study erroneously ignored the vertical separation (depth) between storage reservoirs and shale gas formations. The text emphasizes that multiple impermeable layers often separate these activities and that regulatory oversight and 3D geologic studies can mitigate risks. Additionally, it notes that U.S. storage capacity is vast, including offshore sites and depleted petroleum formations, meaning shale gas activity will not impede carbon capture and storage development.

Carbon Market Watch criticizes the proposed revisions to the CDM coal crediting methodology (ACM0013), stating that they do not sufficiently address technical flaws such as data quality and project emissions. The organization warns that 45 coal projects in the pipeline, primarily in India and China, risk locking in over 400 million tCO2 in annual emissions, which contradicts the 2°C warming objective. It specifically highlights that six already registered projects will bypass the new rules and could generate 89 million credits based on a flawed methodology.