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Revision of the Industrial Emissions Directive – Targeted Stakeholder Survey
ClientEarth argues that the IED revision must shift from a static, activity-based approach to one that promotes the industrial activity with the least environmental impact for a given service. The organization advocates for expanding the IED's scope to include mining, upstream oil and gas, and aquaculture, while making greenhouse gas (GHG) emission limit values and energy efficiency standards binding, even for installations covered by the EU ETS. Key recommendations include restricting Article 15(4) derogations to a maximum of 48 months, introducing a right to compensation for victims of pollution, and strengthening Aarhus Convention rights through periodic permit renewals every four years and mandatory public participation for all permit updates.
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Document type: Statement
Final Report
The LIFE-A2J-EARL project focused on bridging the 'implementation gap' of EU environmental laws by empowering the judiciary, public administrations, and public interest lawyers. Operating across eight EU Member States, the project produced a comprehensive legal guide, national toolkits, and a digital platform to facilitate access to justice. It delivered 48 training sessions and 12 webinars, reaching over 2,000 participants. Despite delays caused by the COVID-19 pandemic and shifting judicial attitudes in some regions, the project successfully increased stakeholder awareness of the Aarhus Convention and EU case-law. Key outputs included a database of 117 public interest lawyers from 15 countries and a final virtual conference attended by 285 participants.
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Document type: Report
Urban resilience in Bangladesh: Integrating local and national planning processes
The document highlights the critical role of local governments in achieving Bangladesh's national and international climate commitments, noting that while national policies like the Bangladesh Delta Plan 2100 exist, they often lack alignment with local realities. It identifies significant gaps in vertical coordination, technical capacity, and dedicated climate financing for municipalities. The brief recommends the use of resilience planning tools, the establishment of national knowledge management 'cells', and the inclusion of local governments in national consultation processes to ensure budgets and policies are responsive to on-the-ground urban vulnerabilities.
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Document type: Policy brief
Information Disclosure & Grievance Mechanisms of the New Development Bank
The New Development Bank (NDB) emphasizes the use of 'country systems' for project implementation, which shifts the primary responsibility for environmental and social assessments, consultations, and grievance mechanisms to the client. However, the Centre for Environmental Rights (CER) finds that critical project documentation—including risk assessments, management plans, and Country Partnership Plans (CPP)—is not publicly available. While the NDB has its own Information Disclosure Policy (IDP), there is ambiguity regarding its susceptibility to South Africa's Promotion of Access to Information Act (PAIA), as the NDB's Africa Regional Center has indicated it is not subject to such legislation. The report highlights a lack of transparency in the NDB's decision-making processes and recommends that all project and policy information be made accessible via the NDB website to ensure accountability.
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Document type: Briefing
Joint statement of NGOs on the long-term protection of Hungary's lakes and natural environment
The document argues that Hungarian freshwater lakes, including Lake Balaton, Lake Fertő, Tata Old Lake, and Lake Velence, are facing irreversible environmental risks from state and private tourism investments. The NGOs claim that Hungarian national legislation has been used to streamline permitting processes and limit the ability of the public and NGOs to challenge harmful projects, potentially violating EU Habitats and EIA Directives. They specifically request an infringement procedure regarding a complaint about a 60-hectare tourism complex at Lake Fertő.
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Document type: Statement
Improving Public Contracting Processes of Socio-Environmental Studies for Brazil's Land Transportation Projects
The report analyzes the contracting of Technical, Economic, and Environmental Feasibility Studies (EVTEA) and Environmental Impact Assessments (EIA) for federal land transportation projects in the Amazon. It finds a significant lack of transparency in how these studies are selected, assessed, and approved, as well as a lack of clarity in budget allocations. Analysis of EIA budgets for the Ferrogrão railroad and highway BR-364 shows that over 50% of funds are spent on diagnostic analysis, while only 6% are allocated to risk assessment and mitigation measures. The authors recommend defining clearer selection criteria, establishing upfront budget allocations, and introducing a 'pre-viability phase' to shift diagnostic analysis earlier in the project life cycle.
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Document type: Report
Melhorando o Processo de Contratação de Estudos Socioambientais em Projetos de Infraestrutura Terrestre
The report identifies significant transparency gaps in the procurement of Technical, Economic, and Environmental Viability Studies (EVTEA) and Environmental Impact Studies (EIA) for land transport projects in the Amazon. It highlights that a disproportionate amount of EIA budgets is spent on diagnostics rather than impact assessment and mitigation. The authors recommend clarifying selection criteria in tenders, detailing budget allocations for socio-environmental components, and introducing a 'pre-feasibility' phase to shift diagnostic analysis earlier in the project lifecycle.
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Document type: Report
Air quality in Thailand
The document assesses Thailand's air quality challenges, noting that while numerous Acts and Plans exist, enforcement is hampered by a siloed ministerial approach and a prioritization of economic growth over environmental health. It identifies key pollution sources including road transport, coal-fired power plants, industrial zones, and seasonal crop burning. The paper highlights successful past initiatives such as the phase-out of leaded gasoline and two-stroke motorcycles, and suggests the need for an overarching national agency to integrate air quality management across sectors.
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Document type: Research paper
Legal analysis on including the EU Birds, Habitats and Water Framework Directives into the Energy Community Treaty
The analysis asserts that the current environmental acquis of the Energy Community Treaty is inadequate to prevent biodiversity loss and water deterioration caused by energy projects. It recommends the adoption of selected articles from the EU Birds, Habitats, and Water Framework Directives, arguing that such measures would not impose significant additional burdens since many Contracting Parties already have existing obligations under the Bern Convention or EU accession processes. The document details the specific risks posed by various energy sources—including coal, nuclear, wind, and hydropower—and provides a tailored legal framework for implementation within the Energy Community.
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Document type: Research paper
Financing Fairly A CASE STUDY 2021 From Policy to Practice: Is the Industrial Development Corporation a Responsible Investor?
The report argues that the IDC's investment in MC Mining demonstrates a continued funding of unsustainable, climate-risky projects and highlights critical failures in the IDC's Responsible Investment Policy and due diligence processes. It details the environmental and social risks associated with MC Mining's operations in the Soutpansberg area, including threats to the Mapungubwe World Heritage Site and the Vhembe Biosphere Reserve. The document concludes that the IDC's lack of transparency and failure to integrate sustainability and human rights standards into its decision-making expose public funds to significant risks and undermine South Africa's climate goals.
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Document type: Case study
Access to Justice in European Union Law
The document analyzes the legal mechanisms for accessing justice in environmental matters within the EU, focusing on the Aarhus Convention and EU directives. It details the rights to access environmental information, public participation in decision-making, and the ability to challenge acts or omissions that affect the environment. The guide examines standing requirements for individuals and NGOs, the scope and standard of judicial review, and the necessity of effective remedies, including injunctive relief. It also addresses the specific challenges of challenging decisions made by EU institutions.
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Document type: Guide
Mine Closure Policies in South America
The document outlines best practices for mine closure, emphasizing the necessity of early planning and robust financial assurance to prevent the state from inheriting liabilities from abandoned mines. It specifically examines the comprehensive national laws in Chile and Peru, noting that while both align with international standards for physical and chemical stability, they lack significant emphasis on social transition and post-mining land use. The study details the specific legal milestones, financial instruments, and reporting requirements used in both countries to ensure mine sites are safely reclaimed.
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Document type: Case study
Gestión de desechos mineros: Estudio de casos de Ghana y Canadá
The report examines how Ghana and British Columbia manage mine waste, focusing on tailings facilities and waste rock. It outlines a 'plan-do-check-act' model for governance, emphasizing risk-based standards, corporate accountability, and financial guarantees for closure. In Ghana, the focus is on integrating artisanal mining and strengthening corporate accountability. In British Columbia, the framework has evolved following the 2014 Mount Polley dam failure, leading to the creation of a dedicated Mine Audits and Effectiveness Unit and stricter requirements for independent reviews.
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Document type: Case study
Gestion des déchets miniers : Études de cas du Ghana et du Canada
The case study analyzes mine waste governance in Ghana and British Columbia, highlighting the importance of risk-based frameworks, financial assurances, and corporate accountability. It details Ghana's efforts to formalize artisanal mining and British Columbia's regulatory evolution following the 2014 Mount Polley tailings dam failure.
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Document type: Case study
Mine Water Management: Case Studies from Mongolia and Chile
The report outlines a holistic approach to watershed-level water management, emphasizing the need for risk-based planning, stakeholder engagement, and clear legal frameworks. It presents case studies from Mongolia, which utilizes a system of management zones based on water sources, and Antofagasta, Chile, which employs strategic regional planning and technical cost-benefit analyses. Both jurisdictions highlight the challenges of managing water in arid environments where mining competes with community and agricultural needs, particularly under the pressures of climate change.
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Document type: Case study
Gestión del agua de mina: Estudio de casos de Mongolia y Chile
The report advocates for watershed-scale water governance to balance the needs of the mining sector with those of other users and ecosystems. It details a framework based on risk planning, stakeholder collaboration, and continuous monitoring. In Mongolia, the focus is on integrating surface and groundwater management, particularly in the Gobi desert where mining demands may exceed supply by 2021. In Antofagasta, Chile, the study highlights the use of strategic regional plans and cost-benefit analyses for the Loa River basin, while noting the challenge of water rights assigned without expiration dates.
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Document type: Case study
Gestion des eaux minières : Études de cas de la Mongolie et du Chili
The document examines water governance in the mining sectors of Mongolia and Chile, advocating for a holistic, risk-based watershed approach. It details the legal frameworks, data collection strategies, and stakeholder engagement processes used in both jurisdictions to manage water scarcity and pollution risks, particularly in arid environments.
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Document type: Case study
Good Practices Action Plans Lessons learnt Data & Indicators
The ENHANCE project (2017-2020) focused on integrating the EU Eco-Management and Audit Scheme (EMAS) into regional policies to drive the transition to a circular economy. By collaborating across six European regions, the project identified 24 good practices and implemented 31 actions, primarily focusing on regulatory reliefs and promotional incentives. Key achievements include the reduction of financial guarantees for waste companies in Estonia, tax reductions for EMAS organizations in Catalonia, and the integration of EMAS as an award criterion in Austrian green public procurement. The project engaged 375 stakeholders and concluded that stakeholder involvement and clear financial incentives are critical for the successful implementation of environmental policy instruments.
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Document type: Report
Environmental and Social Management Plan for National Center for Hydrology and Meteorology
The ESMP outlines the environmental and social safeguards for the National Center for Hydrology and Meteorology (NCHM) to install two Automated Weather Stations (AWS) in Bhutan's protected areas. With a budget of USD 120,000, the project targets Singye Dzong in the Bumdeling Wildlife Sanctuary and Gangju La in Jigme Dorji National Park. The plan identifies minor risks including construction waste, dust pollution, and occupational health and safety (OHS) concerns. Mitigation measures include strict waste management, site watering, and adherence to detailed OHS and worker accommodation standards. Implementation is managed by NCHM focal persons with monitoring by ESS officers and the BFL Fund Secretariat.
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Document type: Report
Bhutan for Life Environmental and Social Management Plan for BC-02
The ESMP for Biological Corridor 2 (BC-02) in Bhutan outlines mitigation strategies for four 2021 projects: water supply for the Kamichhu range office, a Black-necked Crane observation deck, and maintenance of forest offices in Gangtey-Phobji and Khotokha. The plan focuses on managing waste, ensuring worker health and safety (including COVID-19 protocols), and preventing human-wildlife conflict. It mandates compliance with both Royal Government of Bhutan (RGoB) laws and WWF's Social Safeguards Integrated Policies and Procedures (SIPP), with the latter prevailing in cases of discrepancy regarding non-title land users and community consultation.
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Document type: Report