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The EU's Carbon Removals Certification Framework (CRCF) is criticized for failing to mandate 'corresponding adjustments,' allowing both companies and countries to claim the same emissions reductions. This 'double counting' risks displacing necessary climate action and contradicts the EU's own international stance on additionality and the rules of the Paris Agreement's Article 6.

CATF opposes the UK government's consultation on hydrogen blending into gas networks, stating that low-carbon hydrogen is too scarce and expensive to be used for residential heating or minimal GHG reductions in power generation. They recommend prioritising 'no regrets' industrial sectors, such as refineries and ammonia producers, and using electrolytic hydrogen from curtailed electricity for long-duration energy storage instead of grid injection.

The paper outlines a strategic framework for Europe to achieve leadership in clean energy innovation, emphasizing that financial investment alone is insufficient. It proposes four pillars of innovative capacity: building human capital, pushing early-stage technology, creating demand-side market incentives, and securing access to key resources. Using Norway's carbon capture and storage (CCS) leadership as a case study, the author demonstrates how aligning these pillars creates a competitive advantage that is difficult for other regions to imitate. The document concludes that Europe should target sectors where it has natural resource advantages and integrate its policies to create a cohesive ecosystem rather than relying on isolated funding or deployment targets.

The analysis finds that while gas-fired power plants emit 58% less CO2 at the stack than coal, the lifecycle benefit is reduced to 24% when considering upstream emissions. This benefit varies wildly by production basin; gas from northeast Pennsylvania can significantly reduce GHG impacts, while gas from the Permian basin could potentially worsen them by 20% compared to coal. The report concludes that for natural gas to be compatible with net-zero goals, both aggressive upstream methane abatement and downstream carbon capture and storage (CCS) are required, noting that abated coal with CCS actually shows 37% lower emissions than abated gas with CCS due to the latter's persistent upstream methane and liquefaction emissions.

The analysis examines the complexities of assessing the climate impact of U.S. LNG exports, highlighting that lifecycle emissions vary significantly based on the source basin and the level of upstream and downstream mitigation. Using a case study of power generation in Vietnam, the author demonstrates that switching from coal to U.S. gas could either reduce greenhouse gas impacts by 40% or increase them by 20% depending on methane management. While U.S. EPA regulations and the Methane Emissions Reduction Program are expected to curb emissions, the document asserts that further policies and the application of carbon capture and storage are necessary for gas to remain viable in a climate-constrained world.

The Center for International Environmental Law (CIEL) asserts that the UNFCCC and Paris Agreement do not exhaustively define State obligations regarding climate change. Instead, States are bound by concurrent duties under customary international law (such as the prevention of transboundary harm), human rights law, and the law of State responsibility. CIEL argues that the cumulative emission of greenhouse gases, primarily from fossil fuels, constitutes an internationally wrongful act. Consequently, responsible States—particularly industrialized nations—must cease their destructive conduct and provide full reparation for material and moral injuries. The submission emphasizes that these obligations extend to future generations, grounded in the principle of intergenerational equity and the precautionary principle, which mandates prioritizing proven emission reductions over speculative technologies.

The document asserts that because fossil fuels are the primary driver of climate change, States' duties to prevent transboundary harm and protect human rights necessitate a rapid phase-out of oil, gas, and coal. It argues that due diligence requires States to conduct environmental impact assessments (EIAs) that include downstream 'Scope 3' emissions, regardless of where they occur. Furthermore, it contends that State actions increasing fossil fuel reliance are presumptively contrary to international law and that the precautionary principle obliges States to prioritize proven emission reductions over speculative technologies like carbon capture and storage.

The UK has adopted a heavily regulated asset base (RAB) model for its CO2 transport and storage (T&S) infrastructure to mitigate 'cross-chain risks' and attract investment. Under the Transport and Storage Regulatory Investment (TRI) model, private Transport and Storage Companies (T&SCo) operate networks under licenses from Ofgem, with revenues derived from user tariffs and supported by a Revenue Support Agreement (RSA) and a Government Support Package (GSP) for high-impact risks. This contrasts with the Netherlands and Denmark, where infrastructure is more commercially driven or involves direct state equity stakes in storage. The UK intends to transition toward a more competitive market for storage after 2035, while onshore transport is expected to remain regulated.

The report argues that the UK is currently off track to meet its 2030 NDC and sixth carbon budget, necessitating a shift toward 'accountability and implementation'. It advocates for a systems-based approach that complements electrification with carbon capture and storage (CCS), low-carbon hydrogen, nuclear energy, and aggressive methane mitigation. Key recommendations include establishing a Methane Action Plan, creating a 'producer responsibility' policy for CO2 storage, and prioritising low-carbon hydrogen for 'no-regrets' industrial sectors like refining and ammonia production. The document also emphasises the need for international collaboration, particularly with the EU and emerging economies, to scale these technologies and maintain the UK's global climate leadership.

The report warns that 'unabated' coal phase-down strategies—including co-firing, retrofitting with CCS, and using carbon credits—risk extending the life of fossil fuel infrastructure and providing incomplete emission reductions. It urges public development banks to avoid these 'false solutions' to ensure public funds support rapid coal retirement rather than prolonging coal usage.

The report argues that Poland requires a diverse technological portfolio—including wind, solar, nuclear, and carbon capture—to decarbonise its power system by 2050. Modelling of 19 scenarios indicates that relying on a narrow set of technologies increases system costs and infrastructure needs, while a 'base' scenario suggests a rapid transition involving a massive build-out of onshore wind and the introduction of nuclear power to replace coal.

The report argues that Poland, as one of Europe's most carbon-intensive economies, must adopt a diversified technology portfolio to achieve climate neutrality. It recommends a shift from coal (currently 70% of the power mix) toward a combination of renewables, nuclear energy, carbon capture and storage (CCS), clean hydrogen, and superhot rock geothermal energy. The authors emphasize that restricting technology options would significantly increase system costs and infrastructure needs. Key policy recommendations include implementing 'carbon contracts for difference' to advance CCS, prioritizing clean hydrogen for 'no regrets' industrial sectors, and reforming the nuclear industry through standardized, product-based business models. Additionally, the report calls for urgent action to reduce methane emissions from the oil and gas sector and the mapping of thousands of abandoned wells. Public polling indicates strong Polish support for advanced nuclear (63%) and superhot rock energy (66%).

The Electrical Utilities Criteria establish requirements for the certification of electrical utilities and their debt instruments, focusing on a transition to net-zero emissions by 2050. The framework employs an entity-level approach to assess the decarbonisation of the entire electricity value chain, including generation, transmission, and distribution. Certification requires entities to meet a global emission intensity pathway and adhere to specific fossil fuel phase-out benchmarks, which vary between advanced and emerging economies. The criteria prohibit new investments in fossil fuel power generation and mandate a total phase-out of fossil fuel generation by 2040 at the latest. To support grid security, the criteria allow the replacement of coal with fossil gas under strict conditions, provided the entity maintains its emission intensity pathway and has a phase-out plan. Eligible mitigation measures for Use-of-Proceeds (UoP) bonds include retrofitting plants with carbon capture and storage (CCS), carbon capture utilisation and storage (CCUS), or cofiring with low-carbon synthetic fuels and biomass. Certification is available in two tiers: 'align' for those meeting the pathway at the time of certification, and 'transition' for those meeting it by the end of 2030.

The Electrical Utilities Criteria provide a framework for certifying entities and debt instruments based on their emission intensity and transition pathways. It defines specific thresholds for existing and new capacity across various technologies, including fossil fuels and renewables, while integrating cross-cutting requirements for carbon capture, hydrogen, and bioenergy. The criteria also mandate adaptation and resilience risk assessments to ensure long-term operational viability under climate change.

The document defines the technical requirements for electrical utilities to achieve certification, focusing on a transition pathway to net-zero emissions by 2040. It sets specific greenhouse gas (GHG) emission intensity thresholds (gCO2/kWh) for existing and new capacity, mandates the phase-out of unabated fossil fuel plants, and provides guidelines for low-carbon technologies such as CCS/CCUS, hydrogen co-firing, and bioenergy. It also includes requirements for climate adaptation and resilience risk assessments.

The report establishes a framework for certifying electrical utilities and their debt instruments based on their alignment with a 1.5-degree warming scenario. It defines a global emission intensity transition pathway based on IEA Net Zero (NZE) 2023 data, requiring utilities to reduce carbon intensity from 460 gCO2/kWh in 2025 to 0 by 2050. The criteria distinguish between existing capacity, which may be retrofitted with carbon capture or low-carbon co-firing, and new capacity, for which no new fossil fuel investments are eligible. It also sets specific non-combustion emission thresholds for hydropower, geothermal, and bioenergy, and incorporates EU Taxonomy standards for CO2 transport and methane leakages.

The report finds that since the 2021 IEA Net Zero roadmap, at least 20.3 billion barrels of oil equivalent (boe) of new oil and gas discoveries have been announced. In 2023 alone, 20 fields were approved for development, sanctioning 8 billion boe. The analysis highlights a significant disconnect between the industry's push for new reserves—particularly in South America and Africa—and climate goals, noting that current production pathways are significantly higher than 1.5 degree compatible scenarios. It specifically criticizes the use of scope one and two emissions claims to justify projects while ignoring scope three emissions.

The report inventories major energy subsidies in South Africa, detailing fiscal support for oil, gas, electricity, coal, and nuclear energy. It highlights a significant increase in total quantified subsidies, reaching ZAR 118,317 million in FY 2022/2023, driven largely by carbon tax exemptions. The document describes specific mechanisms such as VAT exemptions for fuels, Free Basic Electricity for disadvantaged households, and various grants for state-owned enterprises like PetroSA and Eskom.

The report outlines Colombia's energy transition pathways through 2052, evaluating five scenarios: Actualization, Modernization, Inflexion, Innovation, and Energy Transition (TE). It details the shift from coal and hydrocarbons toward non-conventional renewable energy sources (FNCER), including solar, wind, and hydrogen. The analysis covers demand-side efficiency in residential, industrial, and transport sectors, as well as the strategic role of critical minerals like copper and nickel. Economic evaluations using benefit-cost ratios indicate that while residential and tertiary efficiency measures are highly beneficial, industrial transformation requires significant capital investment and state support due to high private costs.

The Clean Air Task Force (CATF) advocates for the Commodity Futures Trading Commission (CFTC) to implement more rigorous standards for voluntary carbon credit derivatives. CATF suggests adding 'durability' and 'vintage' to the CFTC's proposed commodity characteristics and requiring dynamic baseline analysis, independent third-party verification, and explicit accounting for the risk of carbon reversal to prevent low-quality credits from distorting prices and undermining climate goals.