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EPA’s Proposed Emissions Standards for Natural Gas Production and Transmission
The document argues that the EPA's proposed air pollution standards for the natural gas sector are essential for protecting public health and the environment, particularly through the implementation of 'green completion' technology to capture methane and smog-forming emissions from fracked wells. The authors contend that these standards are cost-effective, as the sale of recovered gas offsets compliance costs, and that they will not hinder domestic production, citing examples from Colorado and Wyoming. The letter specifically rejects proposed industry loopholes from the American Petroleum Institute (API), such as VOC percentage thresholds and implementation delays, which the authors claim would exempt millions of tons of pollution and undermine the standards' effectiveness.
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Document type: Statement
Natural Gas: Palliative, Not a Cure
The author contends that natural gas acts as a 'palliative' rather than a cure for climate change, noting that while it emits less CO2 per kilowatt-hour than coal, its long-term use without carbon capture and sequestration (CCS) is imprudent due to carbon inertia. The text emphasizes the urgent need to eliminate methane leaks from gas, oil, and coal production, which are potent greenhouse gas sources. Furthermore, it warns against over-reliance on the 'shale gale' and the assumption that shale gas will remain cheap in the long term, urging a shift toward zero-carbon energy technologies.
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Document type: Statement
Open letter regarding opposition to a new generation of nuclear power stations in the UK
The document argues that nuclear power is an unsuitable solution for the UK's energy and climate goals due to long construction times, lifecycle greenhouse gas emissions, high costs, and safety risks. The signatories advocate for redirecting investment toward energy efficiency, renewable energy, and other low-carbon technologies.
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Document type: Statement
Nuclear Plant Safety Risks
The Union of Concerned Scientists (UCS) asserts that US nuclear plant risk assessments are merely probability assessments that ignore catastrophic consequences and rely on unrealistic assumptions. The report details how the lack of minimum standards leads to inconsistent results between identical plants and argues that the NRC is using these flawed calculations to justify cutting safety inspections and tests to reduce costs for plant owners.
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Document type: Report
The EU energy transition needs to look beyond LCOE
The document critiques the over-reliance on Levelised Cost of Electricity (LCOE) in EU energy policy, noting that while it provides a project-level cost snapshot, it fails to account for system-wide needs, dispatchability, and the full cost to ratepayers. It advocates for a systems-level approach that integrates diverse generation, storage, and demand-response technologies to ensure a reliable, low-carbon grid.
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Document type: Fact sheet
2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf
The Refinery Managers’ Environmental Forum (RMEF) submitted comments on August 21, 2009, regarding proposed regulations under the National Environmental Management: Air Quality Act (NEMAQA) in South Africa. The RMEF argues that the proposed minimum emission standards are technically and economically unachievable for existing refineries, particularly the requirement for existing plants to meet new plant standards within eight years. They advocate for a 'bubble approach' to measure total site impact rather than point-source monitoring and request specific adjustments to particulate matter (PM) and volatile organic compound (VOC) limits to align with Best Available Techniques (BAT) and economic viability.
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Document type: Statement
SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2”
The Centre for Environmental Rights (CER) submitted comments on the revised draft Air Quality Management Plan (AQMP) for the Nkangala District Municipality (NDM). The CER argues that the plan is overly ambitious given the NDM's lack of capacity and resources, fails to align with the Highveld Priority Area (HPA) AQMP, and contains significant technical errors in its air quality modelling and data.
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Document type: Statement
THE MYTH OF “CLEAN COAL”
The document asserts that "clean coal" is impossible, as the entire coal cycle—from mining to combustion—causes severe damage to health, water, and the climate. It critiques three specific technologies: High Efficiency, Low Emissions (HELE) plants, which only reduce CO2 by up to 20% while increasing costs; Circulating Fluidised Bed (CFB) systems, which increase solid waste and N2O emissions; and Carbon Capture and Storage (CCS), which remains unproven in South Africa and faces high costs and geological transport challenges. The text highlights that Eskom and Sasol are primary coal users in South Africa, and that wind and solar power are cleaner, cheaper alternatives.
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Document type: Fact sheet
Comprehensive land-use planning: A rights-based approach
The document advocates for a land-use planning framework that separates terrestrial carbon sequestration from industrial emission reductions due to the temporary nature of the former. It emphasizes that mitigation must prioritize food sovereignty, legally enforce the land rights of indigenous peoples and local communities, and avoid using land-sector targets to offset continued fossil fuel emissions. The paper critiques current Kyoto Protocol accounting as overly complex and prone to loopholes, suggesting instead the use of direct indicators like hectares of forest maintained. Specific recommendations include addressing high meat consumption and synthetic fertilizer use in developed countries to achieve permanent emission reductions in agriculture.
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Document type: Research paper
GROUNDED IN CLIMATE SCIENCE?
The report evaluates the Greenhouse Gas Protocol's Land Sector and Removals Standard (LSRS), a framework for corporate accounting of land-based emissions and carbon removals. While praising the mandate for separate accounting of emissions and removals, the authors identify critical weaknesses: the voluntary nature of removals reporting and a provision that may allow the SBTi's FLAG Guidance—which permits netting—to take precedence. The analysis also criticizes the inclusion of enhanced oil and gas recovery, the lack of mandatory measurement-based quantification, and loopholes in 'physical traceability' via non-proportional mass balance. The report concludes with recommendations to make removals reporting mandatory, exclude fossil fuel recovery, and assert the LSRS's primacy over other target-setting frameworks.
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Document type: Report
Spent Nuclear Fuel Management Recommendations
The document asserts that the Nuclear Regulatory Commission (NRC) is compromising safety by exempting licensees from critical regulations and approving thin-wall stainless steel storage canisters that do not meet the Nuclear Waste Policy Act (NWPA) or ASME N3 standards. It claims these canisters are prone to hydrogen gas explosions, galvanic corrosion, and structural failure, particularly those from Holtec, which are allegedly scraped and gouged during installation. The author argues that proposed legislation, such as the Nuclear Waste Policy Act of 2019, would further degrade safety by eliminating environmental impact and transparency requirements. The document recommends freezing Decommissioning Trust Funds and transitioning to thick-wall metal casks, noting that such designs survived the 2011 Fukushima disaster.
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Document type: Statement