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SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL
The Center for International Environmental Law (CIEL), on behalf of several environmental organizations, warns the U.S. Senate Committee on Finance that TTIP may prioritize trade interests over public health. The document highlights the divergence between the EU's hazard-based REACH regulation and the U.S.'s risk-based Toxic Substances Control Act (TSCA), arguing that harmonization or mutual recognition could lead to a 'lowest-common denominator' approach to chemical safety. It specifically opposes investor-state dispute settlement (ISDS) mechanisms, which it claims allow corporations to sue governments over public interest laws, and warns that TTIP could preempt protective sub-federal laws in the U.S. and national laws in EU member states. Finally, it suggests that a restrictive TTIP could discourage other nations, particularly BRIICS countries, from adopting more stringent chemical safety standards.
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Document type: Statement
Flood risk in Australia: whose responsibility is it anyway?
The research identifies a significant lack of mutual understanding regarding roles and responsibilities among flood risk stakeholders in Australia. Findings indicate that insurance providers felt ignored until the 2010–2011 floods, councils felt limited in their risk-reduction options, and the SES felt over-relied upon for response. The paper argues that achieving the shared responsibility vision of the 2009 National Strategy for Disaster Resilience requires better inter-stakeholder understanding and increased personal responsibility from residents.
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Document type: Research paper
From policy to reality: ‘Sustainable’ tropical timber production, trade and procurement
The report argues that 'sustainable' and 'legal' timber policies in producer and consumer countries are often rudimentary technical responses that fail to address systemic governance flaws, corruption, and human rights violations. In Malaysia, the report highlights a lack of transparency in logging license awards and systemic violations of indigenous customary land rights. In Japan, South Korea, and Australia, the report identifies weaknesses in procurement frameworks, such as a reliance on exporter-provided paperwork and a failure to reduce overall tropical timber consumption. It concludes that without fundamental governance reforms and a reduction in consumption, certification schemes and procurement guidelines remain insufficient to prevent deforestation and social injustice.
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Document type: Report
绿色税收助力绿色能源:环境财税改革促进可再生能源技术部署
The document examines how environmental taxes and fiscal reforms can fund renewable energy, analyzing eight international case studies to provide policy recommendations for China. It argues that dedicated (earmarked) tax revenues can increase transparency and investor confidence, and that well-designed EFR measures do not necessarily hinder economic growth. For China, the report suggests transitioning from electricity surcharges toward a system based on natural resource and carbon taxes to ensure long-term funding stability for renewable energy.
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Document type: Executive summary
Green Revenues for Green Energy
The report examines how China can transition from relying on electricity surcharges to using environmental taxes and carbon pricing to fund renewable energy. By analyzing eight international case studies, it argues that EFR measures can be pro-growth if revenues are recycled effectively and that earmarking revenues increases transparency and investor confidence. The document suggests that China should consider a carbon tax and natural resource taxes to provide stable, long-term funding for its renewable energy targets, while implementing governance structures to ensure accountability and avoid the 'stop and go' investment cycles seen in some other jurisdictions.
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Document type: Executive summary
Green Revenues for Green Energy
The report examines how environmental taxes and other market-based instruments can fund renewable energy deployment. Through eight case studies from diverse economies, it argues that EFR can generate a 'double dividend' by reducing pollution while providing stable funding for green energy. It highlights the importance of revenue recycling to maintain economic competitiveness and the role of earmarking in increasing policy transparency and public acceptance. For China, the report suggests transitioning from electricity surcharges to a system based on natural resource and carbon taxes to ensure long-term investment stability.
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Document type: Report
SOCIAL AND ENVIRONMENTAL IMPLICATIONS OF NANOTECHNOLOGY DEVELOPMENT IN ASIA-PACIFIC
The report provides a comprehensive overview of nanotechnology's expansion across Asia-Pacific, detailing national initiatives in countries such as India, China, Japan, and Australia. It highlights a critical gap between rapid commercialization and the lack of specific regulatory frameworks to manage health and environmental risks. The document details potential hazards, including the asbestos-like pathogenicity of carbon nanotubes and the ecotoxicity of silver and zinc oxide nanoparticles. It further analyzes the potential for nanotechnology to displace employment through product multifunctionality and increased durability. Finally, it discusses the role of the Strategic Approach for International Chemical Management (SAICM) in establishing global guidance for the sound management of manufactured nanomaterials.
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Document type: Report
San Giorgio Group Case Study: Jädraås Onshore Windfarm
The Jädraås Onshore Windfarm, the largest in Scandinavian Europe at its May 2013 commissioning, was financed through a total of EUR 360 million in private investment. To overcome limited commercial bank lending capacity during the economic recession, a 'Synthetic Loan' structure was created: the Danish export credit agency (EKF) provided an AAA-rated state-backed guarantee that enabled the pension fund PensionDanmark to provide EUR 120 million in debt. The project's viability was further secured by the Swedish renewable electricity certificate scheme, providing a 15-year revenue stream. Risk was managed through hedging contracts for power and certificates and a 15-year operations and maintenance contract with turbine provider Vestas. The report argues that this model is replicable for other green infrastructure projects if simple structures and risk-coverage mechanisms are employed.
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Document type: Case study
多家公司在马来西亚残余的雨林中进行非法的破坏性砍伐,日企与之贸易往来密切
The report details how Japanese trading companies import timber from Sarawak, Malaysia, where illegal logging and corruption are widespread. It highlights specific cases involving companies like Samling and Rimbunan-Sons, noting that only 5% of Sarawak's primary forest remains. The document criticizes the Japanese government's limited measures compared to the US, EU, and Australia, and urges Japan to mandate supply chain due diligence and ban illegal timber imports to protect global biodiversity and climate stability.
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Document type: Report
Implementing an Agricultural Water Security Market for Southwestern Manitoba
The report outlines a framework for an Agricultural Water Security Market (AWSM) in southwestern Manitoba, designed to mitigate the impact of the expanding oil and gas sector on regional water security. The proposed market would enable companies to achieve 'water neutrality' by purchasing offsets that fund the creation of water retention sites, which in turn support groundwater recharge and provide co-benefits like flood mitigation and nutrient retention. The document analyzes 11 national and international water trading models to inform the AWSM's design, which is intended to start as a voluntary system based on corporate social responsibility before potentially transitioning to a regulated market. It estimates a potential water storage supply of 6,287 cubic decametres against an annual oil and gas demand of 400 to 600 cubic decametres. The report identifies key potential actors, including the Oil Producing Municipalities of Manitoba and Manitoba Conservation and Water Stewardship, and examines the provincial and federal legislative frameworks that could support the market's operation.
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Document type: Report
Biofuels—At What Cost?
The report analyzes the costs and benefits of France's biofuel policies in 2011, finding that while bioethanol provides some emission reductions, conventional biodiesel often leads to net emission increases due to indirect land-use change (ILUC). Financial support for the sector, primarily through blending mandates and excise tax exemptions, is estimated between €782 million and €1.01 billion. The study also notes that biodiesel's reliance on imported feedstocks limits its contribution to energy security compared to bioethanol.
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Document type: Report
Governing Africa’s Mangroves: A Sustainable Future
The policy brief highlights that mangroves are among the world's most threatened vegetation types, with over 20% lost in the last 30 years. It emphasizes that in Africa, mangroves often overlap with fossil fuel deposits and infrastructure projects, leading to degradation. The author advocates for the use of ecosystem valuations, integrated coastal zone management, and the inclusion of local communities in decision-making to reconcile economic growth with biodiversity conservation. Proposed interventions include the adoption of 'no net loss' policies, the use of Strategic Environmental Assessments (SEAs), and the implementation of Payment for Ecosystem Services (PES) and Blue Carbon trading to provide financial incentives for conservation.
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Document type: Policy brief
Potential for International Offsets to Provide a Net Decrease of GHG Emissions
The paper examines the potential for international offsets to provide a net decrease in global GHG emissions, distinguishing between 'surplus reductions' (actual abatement exceeding credits issued) and 'net atmospheric benefit' (reductions beyond country pledges). It argues that achieving a net benefit requires high confidence in additionality, the implementation of measures like pre-issuance discounts or stringent baselines, and accounting rules that prevent double-counting. Analysis of the Clean Development Mechanism (CDM) suggests that industrial gas projects (HFC-23 and N2O) are the most promising candidates for yielding a net decrease, potentially providing 80 to 100 million tonnes CO2e in 2020, provided host countries do not count these reductions toward their own pledges.
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Document type: Research paper
A High-Renewables Tomorrow Today: King Island, Tasmania
King Island, Tasmania, is implementing the King Island Renewable Energy Integration Project (KIREIP) to transition from diesel-heavy power to a high-renewables system. By integrating wind, solar, energy storage, and smart grid technologies, the project aims to reduce annual diesel consumption from 4.5 million liters to 1.6 million liters, targeting a 65 percent renewable energy share. Key innovations include the use of diesel-powered rotary uninterruptible power supply (D-UPS) generators to enable periods of 100-percent-renewable penetration and the installation of Australia's largest battery system at the time. Additionally, the proposed TasWind project seeks to export large-scale wind energy to mainland Australia, though it faces local opposition regarding tourism and land use.
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Document type: Case study
soil carbon markets undermine concerns of small and marginal farmers watch this
The author contends that soil carbon markets are financially and technically unviable due to low carbon prices, measurement challenges, and the high cost of implementation. The text argues that pushing for emission reductions in agriculture burdens small farmers in India, Africa, and Latin America, potentially leading to the takeover of agricultural operations by non-farmers. It advocates for agro-ecological approaches and financial support for adaptation over market-based mitigation burdens.
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Document type: Statement
STATEMENT OF CARROLL MUFFETT PRESIDENT AND CEO CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH AND SIERRA CLUB BEFORE THE U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON ENERGY AND COMMERCE SUB-COMMITTEE ON COMMERCE, MANUFACTURING AND TRADE HEARING ON THE U.S. – E.U. FREE TRADE AGREEMENT: TIPPING OVER THE REGULATORY BARRIERS
The document warns that TTIP may prioritize trade interests over public health by promoting regulatory harmonization and mutual recognition that could lower chemical safety standards in the U.S. and EU. It specifically contrasts the EU's hazard-based REACH regulation with the U.S.'s risk-based TSCA approach, arguing that mutual recognition would effectively erase protections for chemicals restricted in only one jurisdiction. The author also cautions against investor-state dispute settlement (ISDS) mechanisms, which could allow corporations to sue governments over public interest laws, and warns that TTIP could preempt protective sub-federal or sub-regional laws. Finally, the statement suggests that a low-standard TTIP could chill the development of stringent chemical regulations in other regions, such as the BRIICS countries.
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Document type: Statement
STATEMENT OF CARROLL MUFFETT PRESIDENT AND CEO CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH AND SIERRA CLUB BEFORE THE U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON ENERGY AND COMMERCE SUB-COMMITTEE ON COMMERCE, MANUFACTURING AND TRADE HEARING ON THE U.S. – E.U. FREE TRADE AGREEMENT: TIPPING OVER THE REGULATORY BARRIERS
The document warns that TTIP may prioritize trade over public health by promoting regulatory harmonization and mutual recognition that could weaken chemical safety standards. It highlights the divergence between the EU's hazard-based REACH approach and the US's risk-based TSCA approach, arguing that mutual recognition would effectively erase protections unique to one jurisdiction. The author also cautions against investor-state dispute settlement (ISDS) and the preemption of sub-national laws, while noting that TTIP could negatively influence chemical regulations in non-member countries like the BRIICS nations.
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Document type: Statement
The EU-US Free Trade Agreement: Bad Prospects for the Global South
The author contends that the TTIP will harm the Global South through the diversion of trade flows and the imposition of EU-US standards on other nations. Mexico is highlighted as particularly vulnerable, specifically in its garment industry. The text suggests the agreement is a strategic attempt by the US and EU to bolster their diminishing economic influence and sideline the BRICS nations, potentially undermining the multilateral trading system in favor of a non-transparent, power-driven trade regime.
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Document type: Statement
National climate change legislation: The key to more ambitious international agreements
The document argues that strong national climate legislation acts as an enabler for more ambitious international agreements by increasing competitiveness, confidence, and knowledge. It highlights that domestic laws can provide the 'legal force' required for future UNFCCC outcomes and recommends strengthening the role of legislators through capacity building and better engagement with executive negotiators.
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Document type: Research paper
Mapping Options for a Voluntary Peer Review of Fossil-Fuel Subsidy Reform within the G-20
The document explores the use of peer review as a 'soft law' tool to improve transparency, accountability, and mutual learning among G-20 nations regarding fossil-fuel subsidy reform (FFSR). It analyzes existing peer-review models from the OECD, APEC, and WTO, proposing three potential structures for the G-20: country-only, third-party, or hybrid reviews. The author argues that the G-20's relative informality and homogeneity make it a suitable forum for such a mechanism, provided a balance is struck between external accountability and internal trust.
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Document type: Briefing