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Examining the Current Policy Landscape of Carbon Management in Europe
The document examines the resurgence of carbon capture and storage (CCS) in Europe as a critical tool for decarbonizing heavy industries and achieving Paris Agreement targets. It analyzes EU-level policies like the TEN-E Regulation and the EU Emissions Trading System (EU ETS), alongside financing tools such as the Innovation Fund and Connecting Europe Facility (CEF). The paper highlights a strategic shift toward 'carbon management hubs' to achieve economies of scale and reviews national progress in Norway, the UK, the Netherlands, Denmark, Sweden, and Germany, concluding that existing policy levers may be insufficient for the required scale-up.
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Document type: Policy brief
Zéro Emission Nette et la COP26
The document critiques the 'net zero' framework promoted by the UK presidency and the 'Race to Zero' initiative for COP26. It asserts that net zero ignores historical responsibility, relies on physically impossible natural carbon sinks, and serves as a 'Trojan horse' for dangerous geoengineering. The author distinguishes between 'removals' and 'offsets', arguing that the latter maintain the status quo and divert investment from systemic transformation. Friends of the Earth International demands a shift toward 'real zero' (absolute emissions reductions), the exclusion of polluting companies from COP26, and the fulfillment of climate finance obligations by Northern countries to support the Global South.
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Document type: Briefing
Recommendations to the EU on the setting of fishing opportunities for 2022
The document argues that the EU has failed its legal obligation to end overfishing by 2020 and calls for 2022 Total Allowable Catches (TACs) to be set strictly within scientific advice. It emphasizes the need for a precautionary approach, better implementation of the Landing Obligation, and the prioritization of depleted stocks over short-term economic profit. The authors also urge the EU to ensure that negotiations with third parties, such as the UK and Norway, adhere to the sustainability objectives of the Common Fisheries Policy.
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Document type: Statement
20210512_joint-ngo-ec-letter-misleading-info-re-overfishing-4c87338e489b830f.pdf
The document challenges the European Commission's claim that 99% of fish bought by consumers come from sustainable sources, arguing this figure focuses on landing volumes rather than the number of stocks. It cites STECF data showing that 43% of North East Atlantic and 83% of Mediterranean stocks are overfished, and notes that the number of stocks outside safe biological limits in 2019 (17) is the same as in 2013.
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Document type: Statement
Understanding the cost of the Drax BECCS plant to UK consumers
Ember estimates that Drax's proposed BECCS plant would cost UK energy bill-payers £31.7 billion over a 25-year lifetime, adding approximately £16 annually to each household's energy bill. The report warns that the project's ability to provide negative emissions is highly uncertain due to the carbon neutrality assumptions of woody biomass, which may instead result in net emissions in worst-case scenarios. It argues that relying on BECCS for the UK's net-zero targets constitutes a serious policy risk and recommends tightening biomass regulations and exploring alternative negative emission sources.
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Document type: Report
TOXIC ASSETS
The report argues that the oil and gas industry is in an inevitable decline, leaving behind millions of unplugged wells that pose severe risks to public health and the environment. It highlights how inadequate bonding requirements and bankruptcy laws in the US and Canada enable companies to offload decommissioning costs onto taxpayers. The document warns that unconventional drilling, such as fracking and deepwater projects, is significantly more expensive to close than conventional wells, creating material financial risks for investors and governments. It concludes that a just transition requires strict enforcement of the 'polluter pays' principle and the closure of legal loopholes to ensure companies, rather than the public, fund the remediation of toxic assets.
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Document type: Report
Report to inform appropriate assessment of fishing operations on the Dogger Bank SACs
The report argues that the UK, the Netherlands, and Germany are in breach of the EU Habitats Directive by failing to implement effective management measures for the Dogger Bank SACs. It concludes that most bottom-contacting fishing gears cause significant harm to the H1110 sandbank habitat and should be halted to restore the site's integrity.
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Document type: Report
ClientEarth’s feedback to the European Commission’s Methane Strategy Roadmap
ClientEarth urges the European Commission to implement strict, mandatory regulations on methane emissions across the fossil fuel and agriculture sectors. The organization argues that the EU, as the world's largest importer of fossil gas, has the commercial power to mandate low-emission supply chains. Key recommendations include expanding the EU Emissions Trading System (ETS) to cover methane, introducing a Carbon Border Adjustment Mechanism (CBAM) for methane-emitting imports, and reforming the Common Agricultural Policy (CAP) to end subsidies for intensive livestock production. ClientEarth also highlights the health risks of indoor gas appliances and the need to counter industry misinformation by replacing the term 'natural gas' with 'fossil gas'.
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Document type: Statement
Reply to the Commission on the state of progress in implementing the CFP through the setting of fishing opportunities
The document argues that the EU missed its 2020 deadline to end overfishing of all stocks and identifies four critical gaps in the implementation of the Common Fisheries Policy (CFP). It highlights that 38% of analysed stocks in the Northeast Atlantic remain overfished and criticizes the Commission for omitting data-limited stocks from reporting and failing to strictly adhere to scientific advice when setting total allowable catches (TACs). The authors emphasize that ending overfishing is essential for the European Green Deal and the EU Biodiversity Strategy, and they call for the adoption of remote electronic monitoring (REM) to ensure compliance with the landing obligation.
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Document type: Statement
Recommendations to the parties managing shared fish stocks in the Northeast Atlantic
The document urges the EU, UK, and other Northeast Atlantic coastal states to establish a joint fisheries management framework based on scientific advice and the Maximum Sustainable Yield (MSY) to end overfishing. It recommends multilateral collaboration, the adoption of a precautionary approach as defined by the UNFSA, and the use of peer-reviewed data from independent institutions like ICES. Specific priorities include recovering North Sea cod stocks and resolving allocation issues for large pelagic stocks such as mackerel, herring, and blue whiting, while ensuring transparency in accordance with the Aarhus Convention.
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Document type: Statement
Let's get the numbers right: What proportion of fish stocks are sustainably managed in the EU?
The document critiques the European Commission's (DG MARE) use of a 99% sustainability figure for fish landings, arguing it masks ongoing overfishing by excluding shared stocks and those without specific scientific advice. It contends that focusing on landing volumes rather than the number of individual stocks ignores depleted species and fails to meet the legal requirements of the Common Fisheries Policy (CFP). The author recommends shifting reporting to stock numbers and including all harvested stocks to ensure transparency and ecosystem-based management.
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Document type: Statement
Taking stock - are TACs set to achieve MSY?
The report finds that progress toward ending overfishing by 2020 has been too slow, with a majority of agreed TACs for 2019 still exceeding scientific advice. It highlights a systemic lack of ambition for stocks subject to precautionary advice and those classified as bycatch, while identifying specific Member States—including France, Ireland, and Spain—as frequent advocates for unsustainable catch limits. The document also criticizes the lack of transparency in the TAC-setting process and the potential for misleading reporting by the European Commission.
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Document type: Report
Danmarks gennemførelse af EU-kravet om at alle fiskefangster skal landes
The report concludes that Denmark has failed to implement the necessary control measures required by EU law to ensure all fish catches are landed and reported. Evidence from last-haul inspections shows significant discrepancies between actual catches of undersized fish and those reported in logbooks, particularly in the Baltic and North Seas. The document highlights that traditional surveillance is ineffective and advocates for Remote Electronic Monitoring (REM) as the only viable tool to deter illegal discarding and 'high-grading'. It also criticizes the European Commission for passivity in enforcing the landing obligation across member states, which undermines the 'level-playing-field' for fishers.
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Document type: Report
The control of the Landing Obligation in Denmark
The report finds that Denmark has failed to establish necessary control measures to ensure compliance with the EU landing obligation, noting that the Danish Fisheries Agency detected only three infringements per year in 2017 and 2018. Evidence from last-haul inspections indicates widespread illegal discarding of fish below the Minimum Conservation Reference Size (MCRS), with cod under MCRS making up 13% in the Baltic and 6% in the North Sea, compared to less than 1% reported in logbooks. The document also highlights 'high-grading' (discarding legal but smaller fish) as a persistent issue, supported by trials from 2008-2015. It concludes that traditional surveillance is ineffective and identifies closed-circuit television (CCTV) and Remote Electronic Monitoring (REM) as the only effective tools for enforcement. Furthermore, it criticizes the European Commission for failing to police Member State compliance and for setting Total Allowable Catches (TAC) based on the flawed assumption that no unaccounted discards occur.
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Document type: Report
Joint NGO response to the Commission consultation on the setting of fishing opportunities for 2020
The document argues that the European Commission has made insufficient progress in implementing the Common Fisheries Policy (CFP), noting that 41 percent of analysed stocks remain overfished. The NGOs call for 2020 TAC proposals to strictly follow scientific advice, improve the implementation of the Landing Obligation (LO) through better monitoring like CCTV, and increase transparency in the TAC setting process.
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Document type: Statement
Political agreement on Western Waters Multi-Annual Plan undermines Common Fisheries Policy (CFP) commitments
A group of NGOs urges MEPs to reject the political agreement on the Western Waters Multi-Annual Plan, claiming it fails to ensure sustainable management for all stocks, allows fishing mortality above sustainable levels, and lacks necessary ecosystem-based management measures.
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Document type: Statement
Input to the EU Fisheries Council Meeting, 17-18 December 2018
The document urges EU Fisheries Ministers to set 2019 Total Allowable Catches (TACs) within scientifically advised levels to meet the Common Fisheries Policy (CFP) goals by 2020. It recommends that TACs not exceed Maximum Sustainable Yield (MSY) or precautionary approach limits, calls for the correct implementation of the landing obligation through robust catch documentation like CCTV, and demands greater transparency in the TAC-setting process through public justification of any limits set above scientific advice.
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Document type: Statement
Joint NGO recommendations on fishing opportunities for 2019 Northeast Atlantic and North Sea stocks
The document outlines NGO recommendations for 2019 fishing opportunities in the Northeast Atlantic and North Sea, urging the Council to set Total Allowable Catches (TACs) within scientifically advised levels to meet the Common Fisheries Policy's Maximum Sustainable Yield (MSY) objectives by 2020. It specifically addresses the risks of 'TAC rollovers', the implementation of the landing obligation, and the dangers of removing TACs or introducing 'bycatch TACs' for stocks with zero catch advice. The NGOs also call for increased transparency in the Council's decision-making process and the alignment of management areas with scientific assessment units.
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Document type: Statement
Outstanding issues regarding landing obligation exemptions requested for the 2019 discard plans
ClientEarth and Seas At Risk recommend that the European Commission reject or strictly condition landing obligation exemptions that lack sufficient scientific evidence. They argue that 'temporary' exemptions should be limited to one year and tied to binding roadmaps for improving selectivity and survivability. The authors highlight a decline in the quality of data submitted for de minimis exemptions and warn that failing to account for dead discards in 'high survival' exemptions could increase fishing mortality and jeopardize Maximum Sustainable Yield (MSY) objectives.
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Document type: Statement
ClientEarth's response to the Commission's Communication concerning a consultation on fishing opportunities for 2019 under the CFP
ClientEarth evaluates the European Commission's communication on 2019 fishing opportunities, welcoming the move toward FMSY targets and the use of ICES landings advice for the Baltic and North Sea. However, the organization expresses significant concerns regarding the use of FMSY ranges in multiannual plans, the lack of transparency in reporting, and the potential for lowering ambitions for stocks categorized as 'bycatch'. It specifically warns against the removal of Total Allowable Catches (TACs) and the use of socio-economic arguments to delay the 2020 MSY deadline.
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Document type: Statement