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The author argues that the EPA must authorize the California Air Resources Board's 2020 At-Berth Rule to stop ships from burning toxic bunker fuel while docking. The document highlights a spike in pollution during the pandemic, noting that cancer-causing diesel pollution at the Port of Los Angeles rose by over 50 percent in 2021. It criticizes a 'backdoor deal' that allows outdated 2007 rules to persist, claiming that EPA approval could eliminate 3,000 pounds of deadly air pollution daily in the region.

The report estimates that the U.S. requires $5.6 trillion in investment through 2035 across GGRF priority categories, with 31% needed in low-income and disadvantaged communities (LIDCs). It identifies significant gaps between current climate finance flows and these needs, citing barriers such as lack of lender capacity, low homeownership rates in minority communities, and distrust of external developers. The authors argue that the GGRF must act as a catalyst for private capital and recommend that philanthropic foundations provide early-stage technical assistance and funding for complementary services, such as home remediation, to ensure the fund's success.

The People’s Collective for Environmental Justice, Communities for Better Environment, East Yard Communities for Environmental Justice, and Sierra Club argue that the South Coast Air Quality Management District (SCAQMD) has violated the Clean Air Act (CAA) by failing to penalize major stationary sources for ozone precursor emissions. The petitioners claim that Rule 317, intended as an alternative fee program for the 1979 one-hour ozone standard, is a "paper exercise" that allows polluters to avoid fees through unrelated credits. Furthermore, they assert that SCAQMD has completely failed to adopt required fee programs for the 1997 and 2008 eight-hour ozone standards. The document emphasizes that these failures disproportionately harm low-income communities and communities of color in the South Coast Air Basin, which is described as having the worst ozone pollution in the United States.

The report highlights the critical role of zero-emission vehicle (ZEV) trucks in reducing greenhouse gas emissions and diesel-related health hazards, such as respiratory disease and premature death. While ZEV truck sales doubled in 2022 and model availability has increased, current trajectories are insufficient to meet climate targets. The authors advocate for a global ZEV truck sales target of at least 45% by 2030, citing California's Advanced Clean Fleet policy as a leading example of state-of-the-art regulation. The document emphasizes that sales standards must be paired with a comprehensive policy portfolio including charging infrastructure, consumer incentives, and equity considerations to ensure a successful transition.

The Private Equity Stakeholder Project and Action NC urge the North Carolina State Treasurer to implement guidelines for housing investments to protect residents from corporate landlord practices. The letter highlights that the North Carolina Retirement System (NCRS) has invested billions in private equity firms like Landmark Partners, Blackstone, Meadow Partners, and Brookfield Asset Management, which are linked to aggressive evictions, poor maintenance, and steep rent hikes in North Carolina and other U.S. cities.

Carbon Market Watch argues that current carbon market mechanisms, such as buffer pools and insurance, are insufficient to guarantee the multi-century permanence required for carbon removals to credibly offset ongoing emissions. The organization recommends extending project proponent monitoring responsibilities to at least 100 years, implementing strict reversal notification timelines (within 30 days), and requiring the automatic cancellation of unused buffer credits. To address equity concerns, it suggests that liability for reversals should shift to acquiring Parties or be funded via top-off fees and a Secretariat-managed satellite monitoring system, rather than falling on host Parties, many of which are developing nations.

The Yurok Tribe, Port Gamble S’Klallam Tribe, and Puyallup Tribe of Indians petition the EPA under TSCA Section 21 to prohibit 6PPD in tires. They argue that 6PPD transforms into 6PPD-quinone (6PPD-q), a highly toxic chemical responsible for 'urban runoff mortality syndrome' in coho salmon and other salmonids. The petition highlights that 6PPD-q is ubiquitous in urban runoff and sediments, threatening species protected under the Endangered Species Act and undermining Tribal cultural and economic interests. It asserts that the EPA must act because the tire industry has not prioritized alternatives and stormwater treatment is insufficient to remove the toxin.

The Private Equity Stakeholder Project (PESP) calls on Blackstone to implement enforceable labor standards across its global portfolio after the US Department of Labor found systemic child labor violations at Blackstone-owned Packers Sanitation Services Inc (PSSI). Despite initial denials, PSSI eventually reached an agreement with the United Food and Commercial Workers Union (UFCW) to protect workers' rights to organize. PESP asserts that child labor is a byproduct of broader issues like low wages and dangerous conditions, and urges Blackstone to adopt the Private Equity Labor Rights Platform and cease union-busting tactics.

The report argues that the U.S. must implement ambitious long-term capacity targets, holistic transmission planning, and strategic infrastructure investments to achieve a net-zero future. It emphasizes the need for coordinated site identification, streamlined permitting, and the development of a domestic supply chain and workforce to support a potential build-out of 250 to 750 GW of offshore wind by 2050.

The report identifies 19 private equity firms investing in 35 oil and gas companies that have received federal drilling permits since 2017. It estimates that U.S. taxpayers could face up to $384 million in cleanup costs for nearly 2,700 wells operated by these private-equity-backed companies across eight states, with Colorado and New Mexico facing the highest liabilities. The authors argue that the private equity business model—characterized by high leverage and quick exits—combined with outdated federal bonding requirements (averaging only $2,122 per well) and bankruptcy laws, allows firms to externalize environmental costs. The document also highlights 'greenwashing' strategies, such as the promotion of 'certified gas,' used to maintain investor support despite ongoing fossil fuel expansion.

The analysis finds that transitioning Maryland's medium- and heavy-duty vehicle fleet to zero-emission vehicles (ZEVs) would yield significant net societal benefits, ranging from $6.6 billion under the ACT rule to over $11.6 billion under the 100 x 40 ZEV scenario by 2050. These benefits are driven by reductions in greenhouse gases, nitrogen oxides, and particulate matter, leading to fewer premature deaths and hospital visits. While ZEVs currently have higher purchase costs, the report projects they will reach lifetime cost parity with combustion vehicles due to lower fuel and maintenance expenses. The transition is expected to have positive macroeconomic effects, including net national job gains and increased GDP, although it requires substantial investment in depot and public charging infrastructure.

The U.S. electric school bus (ESB) market is expanding, driven by the EPA's Clean School Bus Program and state-level mandates. As of December 2022, 895 districts had committed to 5,612 ESBs. While upfront costs remain three to four times higher than diesel buses, ESBs offer lower operational costs, zero tailpipe emissions, and potential grid resilience through bidirectional charging. The market currently features 24 models across Type A, C, and D buses, with a growing emphasis on repowering existing fleets to reduce costs and waste. Successful deployment requires coordinated planning between districts, utilities, and manufacturers to manage charging infrastructure and specialized maintenance training.

The document argues that British Columbia's proposed methane regulations lag behind international best practices, particularly regarding timelines for existing facilities and the lack of a policy for compressor engine exhaust. The coalition recommends accelerating the target for near-zero methane emissions to 2030, implementing stricter standards for pneumatic devices, tanks, and compressor seals by 2025, and adopting a monthly instrument-based leak detection and repair (LDAR) regime.

The document outlines several key EV-related policies. In California, the Advanced Clean Cars II (ACC II) regulation targets light- and medium-duty vehicle OEMs, while the Advanced Clean Trucks (ACT) rule requires OEMs of medium- and heavy-duty vehicles to sell ZEVs or NZEVs as an increasing percentage of sales from 2024 to 2035. The Advanced Clean Fleets (ACF) regulation mandates ZEV adoption for fleets with over 50 trucks, certain private companies, and public agencies. The Clean Miles Standard (CMS) requires ridehailing providers with over 5 million vehicle miles traveled (VMT) per year to reach zero emissions from passenger miles and 90 percent EV-powered VMT by 2030. The Low Carbon Fuel Standard (LCFS) uses a market-based mechanism to cap the carbon intensity of transportation fuels. At the federal level, the Inflation Reduction Act (IRA) of 2022 provides incentives for EV procurement and infrastructure. Additionally, proposed EPA regulations aim to reduce emissions for light-, medium-, and heavy-duty vehicles, with light-duty targets projecting an average of 82 grams/mile of CO2 by model year 2032.

The submission argues that PFAS should be regulated as a class to prevent 'regrettable substitution' and protect vulnerable populations, including Indigenous peoples and firefighters. The authors contend that the current Draft state of PFAS report underestimates the class size and that the proposed Risk Management Scope (RMS) is insufficient because it lacks a commitment to prohibiting non-essential uses. They recommend fast-tracking the listing of PFAS as toxic substances under CEPA Part 1 of Schedule 1, citing widespread contamination in the Canadian Arctic, the Great Lakes, and human blood.

REITs in the US control approximately 38.5 billion sq. ft. of solar-appropriate surface area, capable of generating over 25 percent of electricity used in US commercial buildings. While on-site solar is economically viable for 90 percent of the top 50 REITs by 2025, adoption is hindered by tax credit complexities, IRS recapture rules, and risks associated with tenant turnover and low energy intensity in industrial warehouses. Community solar is proposed as a solution to these barriers, offering additional tax credit bonuses of 10–20 percent when serving low- and moderate-income residents. Currently, only nine US states support rooftop community solar, though some leading REITs like Prologis, Lineage Logistics, Blackstone, Brookfield, and Hartz Mountain have already installed significant capacity.

The briefing argues that insufficient transmission capacity is a major bottleneck for US decarbonization, with new capacity seeking interconnection consisting of 95 percent zero-carbon resources in 2022. It identifies grid-enhancing technologies (GETs) as cost-effective, rapid-deployment solutions that optimize existing transmission, but notes that utility adoption is hindered by risk aversion and regulatory incentives that reward capital expenditures over operational efficiencies. To overcome this, the document outlines four strategies for Public Utility Commissions (PUCs): building knowledge through investigative proceedings, mandating the consideration of GETs in planning processes, implementing performance incentive mechanisms or totex ratemaking, and engaging in Federal Energy Regulatory Commission (FERC) proceedings.

The Private Equity Stakeholder Project alleges that Brookfield Asset Management's portfolio companies, including Westinghouse and Accor Hotels, have employed coercive anti-union tactics, such as misleading videos, surveillance, and the hiring of union avoidance firms, despite Brookfield's public ESG commitments.

The Clean Air Task Force (CATF) supports the BLM's proposed Conservation and Landscape Health rule, arguing that conservation leases are a valid tool for implementing the Federal Land Policy and Management Act (FLPMA) mandates. CATF recommends that the rule be structured to avoid hindering the buildout of electric transmission and renewable energy, specifically suggesting a two-mile buffer around energy corridors where leases are restricted to permittees. The document also advocates for integrating carbon sequestration and climate resilience into the 'fundamentals of land health' and strongly advises against allowing conservation leases to generate marketable carbon offset credits due to a lack of permanence in the proposed 10-year lease terms.

A coalition of environmental organizations argues that mature and old-growth (MOG) forests are critical for carbon sequestration and biodiversity, and must be protected from logging via a national BLM rule. The document details the ecological value of MOG, identifies ongoing logging threats on BLM lands, and argues that such protections are consistent with the Federal Land Policy and Management Act (FLPMA) and Biden administration executive orders.