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AMICI CURIAE BRIEF (Pendapat Hukum Para Sahabat Pengadilan) State Administrative Lawsuit on Cancellation of Bali Governor's Decree No.660.3 / 3985 / IV-A / DISPMPT About Environmental Permit Development of Steam Power Plant (PLTU) given to PT. PLTU CELUKAN BAWANG ON THE VILLAGE ON THE SUPPORT OF GEROKGAK DISTRICT, REGENCY OF BULELENG
The brief contends that the environmental impact analysis (ANDAL) for the PLTU Celukan Bawang expansion in Bali is legally insufficient under Law no. 32/2009 because it omits a comprehensive climate change assessment. The authors argue that such assessments must include the project's direct and life-cycle greenhouse gas emissions, the project's vulnerability to climate-driven sea level rise and storm surges, and how climate change exacerbates the project's local environmental harms. Drawing on international legal precedents from South Africa, Australia, and the United States, as well as guidance from the European Union and Canada, the brief asserts that climate considerations are essential for meeting Indonesia's Nationally Determined Contribution (NDC) and Paris Agreement commitments. Specifically, the expansion is projected to release over 200 million tons of CO2 over 30 years and faces physical risks due to its low-lying coastal location and the degradation of protective coral reefs.
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Document type: Legal commentary
The potential role of fiscal policy
The report argues that the UK's current vehicle taxation system is insufficient to meet legal air quality limits and the 2040 target for banning new internal combustion engine vehicles. It proposes a three-tiered strategy: mandating charging Clean Air Zones in the short term, replacing the plug-in grant with a time-limited VAT rebate for ULEVs in the medium term, and developing a road-user charging system in the long term to replace eroding fuel duty revenues.
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Document type: Report
Parallel Report on SPAIN concerning air pollution and climate change
The report details the health impacts of coal-fired power plants in Spain, specifically noting thousands of asthma and bronchitis cases in children. It criticizes the Spanish government for using EU derogations to allow higher emissions and for proposing a Royal Decree to hinder plant closures. Additionally, it highlights that Spain's greenhouse gas emissions in 2015 remained 16.6% higher than 1990 levels, with coal plants accounting for 60.3% of emissions from all combustion installations in 2015.
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Document type: Report
How coal works
The document provides a comprehensive overview of the coal industry in the United States, detailing the transition from underground to surface mining and the shift toward low-sulfur coal. It highlights the severe ecological damage caused by mountaintop removal and the public health risks associated with coal combustion, including the emission of sulfur dioxide, mercury, and carbon dioxide. The guide also discusses the economic decline of coal due to the rise of natural gas and renewables, while noting the energy-intensive nature of carbon capture and storage (CCS) technologies.
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Document type: Guide
Bridging the Gap: The Role of Short-Lived Climate Pollutants
The document discusses the role of short-lived climate pollutants (SLCPs) in closing the 'emissions gap'—the difference between current Nationally Determined Contributions (NDCs) and the trajectories needed to keep global temperature rise below 2°C or 1.5°C. It identifies methane, tropospheric ozone, black carbon, and hydrofluorocarbons as primary targets for reduction, noting that while some strategies target single pollutants, most affect multiple. The text emphasizes that SLCP reductions, especially when combined with CO2 reductions, can limit long-term warming.
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Document type: Report
A report by the Centre for Environmental Rights in collaboration with groundWork and the Highveld Environmental Justice Network
The report concludes that the Highveld Priority Area (HPA) has failed to improve air quality over a decade, with ambient air remaining in widespread non-compliance with health-based national ambient air quality standards (NAAQS). This failure is attributed to inadequate government capacity, a lack of financial and human resources at the municipal level, and the failure of major industrial emitters, specifically Eskom and Sasol, to reduce emissions. The report highlights a deteriorating monitoring network, ineffective dust control regulations, and a lack of progress in addressing indoor air pollution in low-income settlements. It argues that the granting of postponements from minimum emission standards (MES) to major polluters has further hindered progress, violating the constitutional rights of residents to an environment not harmful to their health.
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Document type: Report
Politics & Global Warming
The report finds that while a majority of US registered voters believe global warming is happening and human-caused, there is significant political polarization, particularly among conservative Republicans. Despite this, there is broad cross-party support for various clean energy policies, such as renewable energy research and tax rebates for energy-efficient vehicles. However, a gap exists between the willingness of voters to advocate for climate policy and their actual engagement in such activities.
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Document type: Report
WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY
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.
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Document type: Statement
Tracing Who’s Responsible for Temperature Increase and Sea Level Rise
The document details findings from a study published in Climatic Change that attributes specific percentages of global warming and sea level rise to the largest carbon producers. It highlights that the 90 largest producers contributed 57% of the atmospheric carbon dioxide rise since 1880, while 50 investor-owned companies were responsible for roughly 16% of the temperature increase and 11% of sea level rise over the same period. The text argues that these companies knew of the risks as early as 1965 but chose to misinform the public.
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Document type: Fact sheet
Plug-in Electric Vehicles
The document details the differences between battery electric vehicles (BEVs) and plug-in hybrid electric vehicles (PHEVs), noting that BEVs produce less than half the carbon dioxide of conventional internal combustion engine vehicles. It highlights the U.S. market's heavy reliance on California for sales due to the Zero Emission Vehicle (ZEV) program and discusses the economic benefits of PEVs, such as lower fuel and maintenance costs. The text also outlines the current state of charging infrastructure, the downward trend in battery costs, and various federal and state incentives designed to accelerate adoption.
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Document type: Fact sheet
California The CAREless Carpet Industry: CARPET STEWARDSHIP PROGRAM’S RELIANCE ON INCINERATION A CRITIQUE OF THE BURNING UP VALUABLE RESOURCES
The report argues that California's carpet stewardship program, led by the industry-controlled Carpet America Recovery Effort (CARE), has failed to meet recycling goals and instead increased the incineration of carpet waste. It contends that incineration—including Waste-to-Energy (WTE), cement kilns, and Carpet as Alternative Fuel (CAAF)—is a wasteful practice that violates the California Public Resources Code's waste management hierarchy. The document highlights significant environmental and health risks, noting that burning carpets containing PVC releases dioxins and unregulated nanoparticles. Financially, it claims WTE is the most expensive energy generation method in the U.S. and can lead to municipal bankruptcy. From a climate perspective, it cites CalRecycle data showing that WTE incineration adds approximately 26,000 metric tons of CO2, whereas recycling saves about 36,000 metric tons. The authors recommend that CalRecycle reject CARE as the stewardship organization and mandate an industry-funded program with enforceable recycling targets.
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Document type: Report
How tax support for the petroleum industry could contradict Norway’s climate goals
The document analyzes the impact of 'fast depreciation' and 'uplift' tax provisions on the profitability of over 700 licensed but non-producing oil and gas fields in Norway. It finds that these measures significantly increase the internal rate of return (IRR) for investors, making many fields economic that would otherwise be abandoned. At an oil price of USD 50 per barrel, the analysis suggests 95% of new oil investment depends on these supports, which could lead to an additional 8 billion barrels of production and 2.9 billion metric tonnes of CO2 emissions.
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Document type: Briefing
Microsoft Word - GHGs reporting program comparison, United Sates regs with South Africa regs- 2016-7-6
The analysis identifies several gaps in South Africa's draft GHG reporting regulations, including a lack of accuracy calibration for monitoring instruments and ambiguous language regarding facility-level reporting. It recommends that South Africa adopt more stringent requirements similar to the US GHGRP, such as a uniform emissions threshold of 25,000 metric tons of CO2 equivalent, a shorter transitional period for regulated entities, and the explicit inclusion of fluorinated gases in the reporting text to ensure transparency and accountability.
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Document type: Statement
Europe’s dark cloud
The report finds that EU coal-fired power plants were responsible for approximately 22,900 premature deaths in 2013, with health costs estimated between 32.4 and 62.3 billion Euros. A significant portion of these impacts is cross-border; for example, coal plants in Poland and Germany caused over 7,000 premature deaths in other countries. The analysis identifies the 'Toxic 30' plants responsible for 51% of these deaths and the 'Dirty 30' plants contributing nearly half of the EU coal fleet's CO2 emissions. The authors advocate for a full coal phase-out, structural reform of the EU Emissions Trading System, and the implementation of an Emissions Performance Standard to meet Paris Agreement goals.
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Document type: Report
Climate goals and sustainable development
The author contends that using CO2 equivalent (CO2e) as a single metric for emission pledges obscures the distinct atmospheric behaviors and impacts of different substances, potentially hindering both peak warming reduction and sustainable development. By pledging targets for substances separately, countries can address the specific harms of short-lived pollutants—such as methane's contribution to tropospheric ozone, which damages crops and human health—while pursuing long-term CO2 reductions, thereby achieving both climate and development goals.
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Document type: Statement
Meeting Clean Power Plan Michigan
Michigan is positioned to meet its Clean Power Plan target of 21.8 million tons of CO2 (31% below 2012 levels) by 2030. A proposed 'Clean Path Case' involving 30% renewable energy and 1.5% annual electricity savings could drive $13 billion in investment, add 8,300 MW of wind and solar capacity, and provide $4.1 billion in public health benefits by 2030. The brief recommends that the Michigan Agency for Energy develop a mass-based compliance plan and that the legislature expand the Renewable Energy Standard and Energy Efficiency Requirements Standard.
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Document type: Policy brief
CLIMATE: HOW TO WIN
The policy brief asserts that global climate success depends on the 20 largest emitting nations adopting a small set of high-impact policies across four sectors: electricity, buildings, industry, and transportation. It emphasizes that policy design is critical to avoid inefficiencies and suggests the use of 'Best Practice Networks' (BPNs) to provide technical expertise to governments to ensure these policies are effectively implemented.
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Document type: Policy brief
colorado_cpp_letter_3.2.16-46cd48e6eb4f5785.pdf
A coalition of organizations advises Governor John Hickenlooper to maximize investments in energy efficiency to achieve Colorado's 2030 Clean Power Plan compliance limits. The letter argues that efficiency is the cheapest demand-side resource, capable of saving Colorado residents $1.5 billion and avoiding nearly 16 million tons of carbon dioxide. It recommends expanding non-utility programs, such as combined heat and power generation and updated building energy codes, and suggests opting into the Clean Energy Incentive Program (CEIP).
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Document type: Statement
new_mexico_cpp_letter_3.2.16-0d45bfeadce9edc4.pdf
A coalition of organizations wrote to Governor Susana Martinez of New Mexico, arguing that energy efficiency is the lowest-cost method for reducing emissions and meeting Clean Power Plan goals. The authors highlight that implementing specific efficiency policies—such as updated building codes and combined heat and power—could achieve 78 percent of the state's 2030 compliance goal, saving New Mexico residents $645 million and avoiding 3.8 million tons of carbon dioxide.
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Document type: Statement
oklahoma_cpp_letter_3.2.16-f8d5590c50992303.pdf
A coalition of energy and environmental organizations wrote to Governor Mary Fallin of Oklahoma, arguing that energy efficiency is the lowest-cost method for reducing emissions and meeting Clean Power Plan goals. The letter suggests that implementing specific policies—such as updated building codes and combined heat and power—could meet 87% of Oklahoma's 2030 compliance target, saving the state $288 million and avoiding 10.7 million tons of carbon dioxide.
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Document type: Statement