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CATF Statement on Revised EPA Proposal on “Secret Science”
The Clean Air Task Force (CATF) opposes the EPA's "Secret Science" proposal, stating it could exclude foundational public health research and violates the Clean Air Act's mandate to use the latest scientific knowledge.
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Document type: Statement
Comments on the Environmental Protection Agency’s (“EPA”) “Policy Assessment for Review of the National Ambient Air Quality Standards for Particulate Matter, External Review Draft.”
The document provides formal comments on the EPA's External Review Draft of the Policy Assessment for the review of PM2.5 NAAQS. It asserts that the EPA is legally obligated to set standards based solely on health and welfare effects, without considering cost or feasibility, and must protect vulnerable subpopulations. The authors criticize the EPA for disbanding the particulate matter review panel, following a flawed memorandum from former Administrator Pruitt that suggests combining science and policy assessments, and failing to issue a second draft of the Integrated Science Assessment (ISA). Finally, the document argues that current PM2.5 standards are insufficient, citing evidence of mortality risks at levels as low as 8 μg/m3, and recommends lowering the primary annual standard to 8-10 μg/m3 and the 24-hour standard to 25-30 μg/m3.
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Document type: Statement
OPEN LETTER FROM ENVIRONMENTAL ACTIVISTS TO PRESIDENT RAMAPHOSA ON THE SOUTH AFRICA INVESTMENT CONFERENCE, 5 – 7 NOVEMBER 2019
Environmental activists have written an open letter to President Cyril Ramaphosa ahead of the South Africa Investment Conference (5-7 November 2019), arguing that economic growth must not come at the expense of constitutional environmental rights. The authors express concern that the government may weaken water use licence conditions to attract investment, which they argue would be irresponsible given the existing water crisis in Gauteng and the failure of the Department of Human Settlements, Water and Sanitation to enforce regulations in the coal mining sector of Mpumalanga. They specifically oppose further investment in fossil fuels and coal infrastructure, citing the rapid price drop of renewable energy and South Africa's vulnerability as a climate change hot spot.
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Document type: Statement
Status of Coal Ash Disposal Units
The document reports that 95% of regulated coal ash ponds are unlined, allowing toxic chemicals to enter groundwater. It further notes that 67% of reporting impoundments are within five feet of the uppermost aquifer and 92% of coal plants with available data have at least one ash pond leaking above federal safe drinking water levels.
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Document type: Fact sheet
Dirty Fashion Disrupted: Leaders and laggards revealed
The report evaluates the fashion industry's transition to responsible viscose production, noting increased engagement from brands and some progress by producers toward EU Best Available Techniques (BAT) standards. While some European brands are leading in transparency and policy, many others—including several luxury and US-based brands—remain laggards. The document emphasizes that voluntary self-regulation is insufficient and calls for government legislation to ensure industry-wide compliance with environmental standards.
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Document type: Executive summary
Penhalonga Community Environmental Audit Report
The Penhalonga Community Environmental Audit Report describes a community-led 'ground-truthing' process conducted over 16 months to examine company compliance with environmental laws and regulations in Penhalonga, Zimbabwe, a region historically impacted by gold mining.
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Document type: Report
Desvaneciendo Vidas: Un Esquema de la EPA Causaría Que Miles de Personas Fallezcan
Earthjustice criticizes EPA Administrator Andrew Wheeler's attempt to dismantle the Mercury and Air Toxics Standards (MATS) using a flawed cost-benefit analysis. The report claims that MATS saves up to 11,000 lives annually and prevents $90 billion in health-related costs, primarily through the reduction of fine particulate matter (soot). It highlights the influence of coal industry lobbyists, specifically Bob Murray, and provides personal testimonies from residents in Pennsylvania, Arizona, and North Carolina who suffer from health issues linked to power plant emissions.
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Document type: Report
Infraestrutura sustentável na Amazônia
The 'Sustainable Infrastructure in the Amazon' project, running from July 2019 to December 2020, aims to strengthen socio-environmental criteria in the decision-making process for infrastructure projects. It combines economic analysis via a market access tool with regulatory and governance analysis to identify the most effective stages of a project's life cycle for incorporating socio-environmental variables, specifically targeting the feasibility study phase to reduce impacts during implementation.
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Document type: Briefing
Erasing Lives: The EPA’s Crooked Scheme Could Cause Thousands to Lose Their Lives
The report examines the EPA's proposal to withdraw the finding that regulating hazardous emissions from power plants is "appropriate and necessary," which would effectively gut the Mercury & Air Toxics Standards (MATS). It argues that EPA Administrator Andrew Wheeler is using a "rigged" cost-benefit analysis that ignores the health benefits of reducing fine particulate matter (soot) to favor coal industry profits. The document highlights that MATS prevents between 4,000 and 11,000 premature deaths annually and provides personal accounts from affected residents in Pennsylvania, Arizona, and North Carolina.
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Document type: Report
Les approches basées sur le marché peuvent-elles rESOUDRE la perte critique de la biodiversité?
The document critiques biodiversity offsetting markets, asserting that they are conceptually flawed and practically ineffective. It argues that nature cannot be accurately priced or restored to its original state, and that such markets often lead to land grabbing and human rights violations. Instead, the author proposes a return to binding environmental regulations and sustainable practices like agroecology to protect ecosystems.
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Document type: Briefing
¿Los enfoques basados en el mercado son capaces de abordar la pÉrdida CRÍTICA de BIODIVERSIDAD?
The briefing critiques the shift in biodiversity policy from conservation to 'restoration' through financial markets. It argues that biodiversity offsetting—where developers pay to recreate habitats to justify destroying existing ones—is based on the flawed premise that nature can be monetized and replaced. The author cites high failure rates in restoration projects, the inability of markets to price public goods or scarcity, and the risk of land grabbing. Instead of market tools, the document advocates for binding environmental laws and sustainable practices like agroecology to protect biodiversity.
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Document type: Briefing
Can Market-Based Approaches Address Critical Biodiversity Loss?
The document critiques the shift from biodiversity conservation to 'restoration' via financial markets, arguing that biodiversity offsets are conceptually flawed and practically ineffective. It asserts that these mechanisms often lead to net habitat loss and human rights abuses. The author contends that nature cannot be accurately valued monetarily and that the core concepts of 'price signals' and 'additionality' are invalid in this context. As an alternative, the report proposes binding conservation laws to restrict unsustainable economic activities and foster sustainable practices like agroecology.
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Document type: Report
Wheeler’s effort to run over science hits bumps in the road
The author argues that the Trump-era EPA's 'Strengthening Transparency in Regulatory Science' rule (the 'Censored Science Rule') is an attempt to undermine mainstream science to justify deregulation. The document highlights concerns from the EPA's own Science Advisory Board (SAB) regarding the rule's potential to exclude critical human health data and its overall vagueness, which may lead to legal challenges under the Administrative Procedure Act.
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Document type: Legal commentary
Les incendies en Amazonie, un signal d’alarme pour le monde entier
Friends of the Earth International denounces the 2019 Amazon fires, attributing them to the Brazilian government's dismantling of environmental protections to benefit agro-industry and mining. The statement highlights a record increase in fires and deforestation, the persecution of indigenous peoples, and the global climate implications of the destruction of the Amazon rainforest.
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Document type: Statement
Request for 120-Day Comment Period for Phase 2 Coal Combustion Residuals Proposal and for a Public Hearing in Guayama, Puerto Rico
A coalition of 77 public interest groups is urging the EPA to extend the public comment period for the Phase 2 Coal Combustion Residuals (CCR) proposal to 120 days and to hold a public hearing in Guayama, Puerto Rico. The groups argue that the complexity of the rules and the severe local impacts of coal ash waste piles and fill projects in Puerto Rico necessitate greater public accessibility and time for expert review. They highlight that 91 percent of coal plants reporting groundwater data under the 2015 CCR Rule have contaminated groundwater exceeding federal health standards.
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Document type: Statement
Insider Briefing: Coal’s Poisonous Legacy
The document details the systemic contamination of groundwater by coal ash at 91% of monitored U.S. coal plants, highlighting the toxicity of substances like arsenic and lead. It describes legal actions and community advocacy used to challenge the Trump administration's attempts to weaken the 2015 coal ash rule and discusses the implementation of the Coal Ash Pollution Prevention Act (Senate Bill 9) in Illinois to ensure financial assurance and transparency in cleanups.
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Document type: Briefing
Spring Floods Exacerbate Raw Sewage from Factory Farms Washing into Gulf of Mexico
Mighty Earth analyzed EPA and industry data to determine that the top U.S. meat companies discharge nearly 220 million tons of manure and facility waste annually. The analysis highlights that these pollutants, which include toxins and pathogens, are often stored in flood-prone earthen impoundments or discharged directly into waterways. In the Mississippi Watershed, this resulted in an estimated 16 million lbs of direct facility sewage and 128 million tons of manure from livestock and poultry production. The report links these pollution levels and the exacerbation caused by climate-driven flooding to the creation of dead zones in the Gulf of Mexico.
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Document type: Research paper
TRIBUNALES CON ALFOMBRA ROJA
The report examines the Investor-State Dispute Settlement (ISDS) system, detailing ten case studies where corporations used international arbitration to challenge national laws and court rulings related to environmental protection, public health, and indigenous rights. It argues that ISDS creates a 'regulatory chill' where governments avoid passing public interest laws to avoid astronomical fines. The document specifically critiques the European Union's proposed Investment Court System (ICS) and Multilateral Investment Court, claiming these reforms only address procedural issues while maintaining the substantive imbalance that privileges investors over sovereign states and human rights.
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Document type: Report
A FRESH COAT OF PAINT ON THE ANALYSIS OF ALTERNATIVES
The report analyzes a March 2019 General Court ruling (Case T-837/16) to clarify the legal requirements for granting authorisations under the REACH Regulation, specifically regarding the availability of safer alternatives. It emphasizes that the burden of proof rests solely with the applicant to provide 'cogent' and 'reliable' evidence that no suitable alternatives exist. The document argues that the European Commission cannot rely blindly on SEAC's opinions if they lack 'full, consistent and relevant' reasoning. It further asserts that substitution plans are mandatory if alternatives exist but are not currently feasible for the applicant, and that uncertainties regarding alternatives cannot be deferred to future review reports. To implement these findings, the report proposes a detailed checklist for SEAC, updates to the opinion template to shift the focus toward the applicant's burden of proof, and revisions to third-party consultation instructions to clarify that third parties are not required to provide a full analysis of alternatives to raise valid doubts.
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Document type: Report
Ruling on glyphosate renewal: the General Court divided over public authorities' right of standing
The General Court of the EU ruled that the Brussels Region lacked standing to challenge the Commission's renewal of glyphosate authorisation, finding the Region was not 'directly concerned'. This contradicts a previous ruling (T-339/16) where cities were granted standing to challenge Euro 6 emissions standards. The court rejected the Region's arguments that the regulation undermined its local ban on glyphosate or forced it into specific administrative procedures, and it declined to apply the Aarhus Convention to public authorities.
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Document type: Legal commentary