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brunsbuttel-lng-rf-iof-letter-5.10.21-6f7233b0474d9d44.pdf
A coalition of NGOs, including Reclaim Finance and Urgewald, wrote to the CEOs of ten insurance companies (including Allianz, AXA, and Munich Re) demanding they stop insuring the Brunsbüttel LNG terminal in northern Germany. The authors argue that the project, promoted by Gasunie, will lock in greenhouse gas emissions for 30–50 years, contradicting the 1.5°C goal and risking the creation of a stranded asset. They highlight that the project costs €450 million, with up to €100 million from German taxpayers, and faces significant opposition from environmental groups and market analysts.
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Document type: Statement
PRE-BUDGET SUBMISSION
The Institute for Economic Justice (IEJ) critiques the South African National Treasury's approach to debt reduction through expenditure cuts, asserting that such austerity is economically flawed and violates constitutional and international human rights obligations. The report highlights the negative impacts of budget cuts on education and healthcare, noting that the 2021 Budget's non-interest spending is projected to contract at an annual real average rate of 5.2 per cent. To counter this, the IEJ suggests utilizing additional fiscal space from SARS revenue windfalls and IMF funding, implementing progressive taxes such as a wealth tax and social security tax, and launching a GDP-linked stimulus package. The document advocates for a Universal Basic Income Guarantee (UBIG) and the conduct of gendered human rights impact assessments to guide fiscal policy.
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Document type: Report
Making adaptation a global ambition
The author contends that the extreme weather events of 2021 demonstrate that climate risk is transboundary and that current adaptation efforts are insufficient. The text argues for a shift from domestic to transboundary perspectives on risk, noting that adaptation goals under the Paris Agreement remain 'fuzzy' and lack operational mechanisms. It concludes that adaptation has limits and must be pursued in tandem with aggressive mitigation to avoid catastrophic costs and loss of life.
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Document type: Statement
Investing in troubled waters
The report argues that the aquaculture industry faces significant systemic risks due to high fish mortality rates and a dependence on fishmeal and fish oil (FMFO) derived from wild-caught fish. It finds that most investors fail to integrate these material risks into their policies, often relying on inadequate certification schemes. The document highlights the economic cost of fish deaths, the threat to food security in regions like West Africa due to FMFO extraction, and the potential for 'greenwashing' through green bonds. It recommends that investors require full supply chain transparency, the elimination of wild-caught fish in feed by 2025, and the adoption of robust fish-welfare standards.
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Document type: Report
Aperçu de la chaîne d’approvisionnement en farine et huile de poisson de l’Afrique de l’Ouest vers l’Europe
The report examines how the fishmeal and fish oil industry in West Africa, particularly in Mauritania, Senegal, and The Gambia, diverts critical protein sources from local human consumption to feed aquaculture and livestock in Europe and Asia. It highlights the ecological collapse of sardinelle and bonga stocks, the socio-economic marginalization of local fish processors (primarily women), and the role of European feed giants and retailers in driving this demand.
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Document type: Report
The State of Cities Climate Finance Part 1
The report estimates that an average of USD 384 billion was invested annually in urban climate finance during 2017-2018, a figure significantly lower than the estimated annual need of USD 4.5 to 5.4 trillion for low-emission and resilient urban infrastructure. Mitigation efforts, particularly in sustainable transport and green buildings, dominate the landscape, while adaptation finance remains severely underfunded, representing only 9% of tracked project-level data. The analysis highlights a geographic imbalance, with the majority of finance flowing to China and developed economies, while regions like Sub-Saharan Africa and South Asia remain critically underfunded. Key barriers to scaling this finance include low creditworthiness of city governments, a lack of bankable projects, and institutional restrictions on local borrowing.
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Document type: Report
Additional profits of sectors and firms from the EU ETS 2008-2019
Between 2008 and 2019, fifteen CO2-intensive industrial sectors in nineteen EU countries earned estimated additional profits between €30 billion and over €50 billion from the EU ETS. These profits were derived from three primary sources: the overallocation of free emission allowances, the use of cheaper international credits (CERs/ERUs) for compliance, and the passing through of opportunity costs of free allowances into product prices. The iron and steel sector was the largest beneficiary, with profits ranging from €11.9 billion to €16.1 billion. In contrast, the aviation sector experienced a net loss of €151.2 million due to the need to purchase allowances. The report argues that free allocation may no longer be fit for purpose and recommends increasing the share of auctioning combined with targeted investment subsidies or a Carbon Border Adjustment Mechanism (CBAM) to reduce windfall profits and encourage decarbonization.
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Document type: Report
The EU sustainable taxonomy set to fuel greenwashing
Reclaim Finance asserts that the EU sustainable taxonomy's climate mitigation and adaptation criteria have been watered down due to pressure from Member states and industry lobbies. The author claims the current proposal allows for the burning of all forest biomass and creates pathways for fossil gas and nuclear energy to be labeled as sustainable, thereby undermining the EU Sustainable Finance Strategy and contradicting scientific research.
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Document type: Statement
La taxonomie durable de l’UE en passe d’alimenter le greenwashing
Reclaim Finance criticizes the European Commission's 2021 delegated acts for the EU sustainable taxonomy, claiming that political and industrial pressure has overridden scientific criteria. The author asserts that the current framework allows for greenwashing by adopting weak bioenergy standards and leaving the door open for fossil gas and nuclear energy, which the author argues are incompatible with the Paris Agreement goals.
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Document type: Statement
A snapshot analysis of anti-Muslim mobilisation in France after terror attacks
The document analyzes anti-Muslim sentiment in France, noting that terrorist attacks in October 2020 triggered significant spikes in hateful online discourse. Using social media listening tools, the Institute for Strategic Dialogue (ISD) identified key narratives including the alleged 'islamisation' of France, anti-headscarf rhetoric, and the 'great replacement' conspiracy theory. The analysis highlights the role of far-right politicians and media outlets in mainstreaming this discourse, particularly targeting Muslim women.
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Document type: Briefing
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
EUROPE GAS TRACKER REPORT 2021
The report finds that the EU is planning a 35% increase in gas import capacity through pipelines and LNG terminals, costing an estimated €87 billion. This expansion is argued to be unnecessary for security of supply and contradictory to the EU's climate goals, creating a significant risk of stranded assets and emissions lock-in. While public financing from the EIB and EU grants has historically catalyzed these projects, the report notes a shift toward phasing out such support, though private finance and initiatives like the Three Seas Initiative continue to pose risks of further fossil gas entrenchment.
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Document type: Report
LAST CHANCE FOR THE POWERING PAST COAL ALLIANCE
The briefing argues that the Powering Past Coal Alliance (PPCA) has failed to trigger a meaningful global coal exit due to significant loopholes in its declaration and a lack of monitoring. It highlights that many financial institution members continue to invest in coal, and co-chairs Canada and the UK are not leading by example, with Canada developing new coal mines. The document calls for a reform of the PPCA to align with climate science, requiring an immediate stop to new coal projects and a full sector exit by 2030 in OECD/European countries and 2040 globally.
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Document type: Briefing
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
Buen Vivir versus Green Deal : l'émergence d'un concept en Europe
The paper explores the concept of Buen Vivir, rooted in indigenous Latin American paradigms, and its potential as an alternative to the anthropocentric and growth-based models of development prevalent in Europe. It highlights the tension between Buen Vivir and the 'Green Economy' or 'European Green Deal', arguing that while the latter seeks to 'decouple' growth from resource use, Buen Vivir rejects the logic of infinite economic growth entirely. The authors note that while official EU-Latin American diplomatic recognition of Buen Vivir has been limited and largely stagnant since a 2015 resolution, local-level initiatives in European cities—such as Amsterdam—and countries like Spain and Greece are increasingly adopting practices aligned with Buen Vivir, including agroecology, local currencies, and the promotion of the 'commons'.
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Document type: Research paper
Toward a Tradable, Low-Carbon Cement Standard
The paper proposes a tradable performance standard for the U.S. cement industry that sets an emissions intensity benchmark. Producers exceeding the benchmark must surrender credits, while those below it generate tradable credits, creating a financial incentive for decarbonization. The authors recommend a standard covering Scope 1 and Scope 2 emissions per unit of clinker and mineral additives, with stringency increasing annually. To prevent carbon leakage, the standard would apply to both domestic production and imports. The paper emphasizes that this standard must be part of a broader policy suite, including innovation funding and market-demand policies, to address the high costs and technical barriers of deep decarbonization technologies like carbon capture, use, and storage (CCUS).
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Document type: Research paper
EU Power Sector in 2020
In 2020, renewables generated 38% of the EU's electricity, surpassing fossil-fired generation (37%) for the first time. This shift was driven primarily by wind and solar, while coal generation fell by 20% to 13% of the total mix. However, the report notes that the transition remains too slow to meet 2030 and 2050 climate targets, as gas generation remains high and nuclear output saw a record 10% decline.
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Document type: Report
Buen Vivir: un concepto emergente en Europa
The paper explores 'Buen Vivir', an indigenous-rooted concept from Latin America that challenges anthropocentrism and infinite economic growth. It examines the concept's formal introduction into EU-Latin American relations via a 2015 EuroLat resolution and contrasts it with the 'Green Economy' and 'European Green Deal', which the authors argue maintain a growth-centric logic. While governmental adoption in Europe remains limited, the text identifies local 'post-developmentalist' practices in countries like Spain, Greece, and the Netherlands—such as agroecology and the recognition of nature's rights—as aligned with Buen Vivir principles.
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Document type: Research paper
Revision of the State Aid Guidelines for Environmental Protection and Energy and exemption rules
ClientEarth argues that EU State aid rules must be transformed into sustainability instruments that prohibit support for fossil fuels and harmful biomass, while prioritizing energy efficiency and renewable energy. The document calls for the strict application of the 'Energy Efficiency First' principle, the exclusion of low-carbon (fossil gas-based) hydrogen from subsidies, and the removal of aid for high-efficiency combined heat and power (CHP) plants. It further recommends increasing support for energy communities, zero-emission vehicles, and energy efficiency in buildings, while introducing a 'greenwashing test' to ensure the environmental integrity of aid beneficiaries.
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Document type: Statement
The European Power Sector in 2020
In 2020, renewables became the EU's primary electricity source for the first time, generating 38% of electricity. While wind and solar growth remained robust despite the pandemic, the report argues that deployment must nearly triple to meet 2030 Green Deal targets. Coal generation fell by 20% in 2020, though this decline was partially offset by increased gas generation and a record 10% drop in nuclear output. Consequently, Europe's electricity carbon intensity fell to 226 grams of CO2 per kilowatt-hour in 2020, a 29% reduction since 2015.
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Document type: Report