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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
Time and tide wait for no man: pioneers and laggards in the deployment of CCS
The study analyzes the impact of partial CCS deployment in Europe by 2030, categorizing countries as pioneers or laggards based on their R&D projects and national roadmaps. Using a dispatch model, the authors find that the economic outcomes of pioneering are heterogeneous: while electricity suppliers in Poland, the UK, and the Netherlands may see increased producer surpluses, consumers in the UK could face higher wholesale prices due to the high cost of gas-fired CCS. Conversely, Romania is projected to experience lower wholesale prices and increased domestic production. The results suggest that being a pioneer does not automatically guarantee an advantage, as benefits are unevenly distributed between producers and consumers.
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Document type: Research paper
Green Investment Schemes: The AAU market between 2008 and 2012
The document examines the AAU market from 2008 to 2012, focusing on how Central and Eastern European (CEE) countries used Green Investment Schemes (GIS) to transform 'hot air'—surplus emission rights resulting from economic downturns—into funding for climate mitigation. It analyzes the strategies of seller countries like Estonia and the Czech Republic, which were successful due to transparent monitoring, and buyer countries like Japan and Spain, which used these deals for technology exports. The report highlights a significant price drop in AAUs by 2012 and discusses the potential for GIS to inform future fund-based mechanisms like NAMAs in developing countries.
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Document type: Research paper
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
Biofuels—At What Cost?
The document updates the 2011 subsidy estimates for EU biofuels, reducing the total estimated support from €9,272–€10,653 million to €5,515–€6,896 million. This correction stems from an overestimation of the volume of biofuels eligible for fuel excise tax exemptions. While budgetary support figures for bioethanol and biodiesel were lowered, other support elements, such as market transfers, remain unchanged. The report also details the calculation methodologies for excise tax exemptions and market price support via blending mandates.
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Document type: Report
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
Migranci muszą stać się eko-obywatelami świata
The document critiques the French model of assimilation and 'Jacobinism', arguing that migration should be managed at a European rather than national level to ensure equality and break nationalist trends. The author advocates for 'co-integration' and a cosmopolitan policy that acknowledges the historical impact of colonialism and the rising phenomenon of ecological migration caused by global warming.
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Document type: Statement
cop18-surplus-decision-russian
The document discusses the outcome of the COP18 meeting in Doha concerning the approximately 13 billion tonnes of CO2-equivalent surplus assigned amount units (AAUs) from the Kyoto Protocol's first commitment period (2008-2012). It identifies Russia, Ukraine, and Poland as the largest holders of these surpluses and notes that without restrictions, these units could allow countries to meet their second commitment period (2013-2020) targets without taking further action. The text outlines the various proposals from the African Group, AOSIS, Brazil, the G-77 and China, and Switzerland, as well as the internal EU compromise reached between countries seeking strict limits (Germany, UK, Denmark) and Poland.
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Document type: Briefing
Keskkonnatasude mõjuanalüüs
The report analyzes the effectiveness of Estonia's environmental fee system, focusing on resource use and pollution charges. It finds that while emissions have decreased, this is primarily due to EU regulatory compliance rather than the fees themselves. The document notes that resource productivity in Estonia remains low compared to the EU average and suggests that future fee structures should be more predictable and integrated with support measures for eco-innovation to better incentivize resource efficiency.
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Document type: Executive summary
G-77 and China Proposal on the Carry-over Rules of Kyoto Surplus Units from the First Commitment Period
The document highlights a massive surplus of 13.1 billion tonnes of CO2 from the first Kyoto commitment period (CP1), far exceeding estimated demand. It notes that weak emissions pledges and lenient offset rules are likely to create an additional 3.6 billion tonne surplus by 2020. In response, the G-77 and China, incorporating views from the African Group, AOSIS, and Brazil, proposed restrictions on the use of CP1 Assigned Amount Unit (AAU) surpluses in the second commitment period (CP2).
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Document type: Policy brief
Open letter regarding the use of offsets in the EU ETS
The letter expresses concern that carbon offsets are undermining EU climate goals by stifling domestic emission reductions and supporting projects that lack environmental integrity. It specifically highlights the negative impacts of coal-fired power plants and large hydro projects in the Clean Development Mechanism (CDM), as well as the lack of transparency in Track 1 Joint Implementation (JI).
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Document type: Statement
The Social Consequences of Imposed Austerity: The Case of Education
The author contends that austerity policies in Europe, especially in post-socialist states, have led to substantial budget cuts in higher education and a push toward the commodification of learning. The text highlights that these measures often shift costs to students through tuition fees and prioritize market-driven research over humanities and fundamental sciences, thereby undermining social equality and the goals of the Europe 2020 strategy.
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Document type: Research paper
Model Mining Development Agreement – Transparency Template
The document analyzes the International Bar Association's Model Mining Development Agreement (MMDA 1.0), providing a template and narrative to ensure mining contracts promote sustainable development, transparency, and equitable resource distribution. It details key contractual areas including land tenure, royalties, taxation, and community obligations, while emphasizing the use of international standards like the IFC Performance Standards and EITI. Additionally, the report investigates the existence of similar model agreements for the oil and gas sector, concluding that no internationally accepted model currently exists despite the availability of various national form contracts.
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Document type: Report
Low-Greenhouse-Gas Consumption Strategies and Impacts on Developing Countries
The research paper examines how shifts in consumer behaviour in high-income countries to reduce GHG emissions—such as buying fewer goods and shifting to services—can disproportionately harm the GDP of lower-income countries and Least Developed Countries (LDCs) due to their reliance on trade. Using a multi-regional input-output (MRIO) model based on the WRAP scenario, the authors find that while such shifts benefit the domestic economy of the consuming country, they can lead to significant GDP losses in poor exporting nations. The paper suggests alternative strategies to align climate mitigation with development goals, such as preferentially sourcing products from low-GHG, low-income regions or improving production efficiency in developing countries.
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Document type: Research paper
Letting Others Lead
The policy brief examines the 'letting others lead' approach of European states toward the regulation of commercial military services. It contends that the perceived restrictiveness of European frameworks is an illusion, as core military tasks are routinely outsourced and regulations are often interpreted permissively or bypassed. This lack of internal rigor leads European states to relegate regulatory initiative to allies (such as the US and UK), multi-stakeholder codes of conduct, and industry self-regulation, which further fragments the global regulatory landscape and reduces accountability.
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Document type: Policy brief
Silent and Irresponsible European Approaches to Commercial Military Services
The policy brief examines the growing but under-reported reliance on private companies for military services across Europe. It contends that unlike the US and UK, European states maintain 'hybrid' arrangements where the state remains closely linked to market actors, which masks the extent of commercialization and prevents public democratic debate. The author identifies four drivers of this trend—technological, economic, strategic, and public management processes—and argues that the resulting lack of clear accountability benefits security professionals who prefer to avoid public scrutiny.
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Document type: Policy brief
East-West regional dimensions in European climate policy
The document analyzes how the European Union has integrated New Member States (NMS) into its climate framework through various effort-sharing mechanisms. It highlights the systemic economic and energy divergences between the EU15 and NMS, such as higher energy intensity and coal dependence in the East. The report examines the evolution of target distribution from the Kyoto Protocol and the EU ETS Phase II to the 2008 Climate and Energy Package, concluding that while centralized governance and GDP-based redistribution have improved fairness and ambition, they have often come at the cost of economic efficiency and domestic sovereignty over energy mixes.
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Document type: Report
The Full Protection and Security Standard Comes of Age: Yet another challenge for states in investment treaty arbitration?
The paper examines how the 'full protection and security' (FPS) standard has evolved from a narrow focus on physical security to a broader interpretation including legal and commercial security. It analyzes conflicting arbitral rulings on whether FPS is an independent treaty standard or reflects the customary international law minimum standard of treatment for aliens. The author highlights the risks for developing states, noting a 46% success rate for investors in FPS claims over 21 years, and suggests that states should explicitly define the scope of FPS in treaties to avoid expansive interpretations by tribunals.
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Document type: Research paper
Sea-Level Rise The Impacts and Economic Costs of Sea-Level Rise on Coastal Zones in the EU and the Costs and Benefits of Adaptation
The document uses the Dynamic Interactive Vulnerability Assessment (DIVA) Model to project that under a medium-to-high emissions scenario (A1B(I)), annual damage costs in the EU could reach €25 billion by the 2080s, with 250,000 people flooded annually. It argues that a combination of mitigation (to limit long-term rise) and adaptation (such as dikes and beach nourishment) is the most effective response, noting that adaptation can reduce annual damage costs by up to 90% with a high benefit-to-cost ratio.
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Document type: Policy brief