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ClientEarth US argues that climate change poses significant financial risks to corporations and the US economic system, necessitating bold SEC action to mandate adequate disclosures. In response to the SEC's March 15, 2021 Request for Public Input, the organization proposes seven recommendations intended to improve information quality for investors, promote international reporting consistency, and ensure that new rules are enforceable through regulatory proceedings and private litigation.

The document argues that the EU has failed its legal obligation to harvest all stocks sustainably by 2020, noting that 83% of assessed stocks in the Mediterranean and Black Seas remain overfished and the North-East Atlantic overfishing rate rose to 43% in 2019. The NGOs identify four critical implementation gaps: the need to acknowledge real overfishing levels rather than using misleading metrics, the requirement to manage data-limited stocks according to the precautionary approach, the necessity of using science-based catch limits over 'last resort' remedial measures, and the urgent need to fully implement the landing obligation to prevent illegal discarding. They specifically criticize the Commission for using metrics like landing volumes that distort the status of depleted stocks and for setting Total Allowable Catches (TACs) that frequently exceed scientific advice, particularly for data-limited stocks.

ClientEarth argues that Ofgem's current statutory objectives are outdated and prioritize competition over decarbonisation, hindering long-term climate investments. The submission proposes narrowing Ofgem's principal objective to focus on security of supply and greenhouse gas reduction, introducing sector-specific carbon budgets, and requiring the Department for Business, Energy and Industrial Strategy (BEIS) to issue periodic Strategy and Policy Statements. Additionally, ClientEarth highlights a failure to regulate and verify non-carbon dioxide emissions, specifically methane and sulphur hexafluoride (SF6), and advocates for a consumption-based emissions accounting approach to include extraterritorial emissions from imported energy.

ClientEarth argues that the FCA's proposed disclosure requirements in CP21/17 and CP21/18 are insufficient to provide the granularity needed for informed investment decisions. The briefing recommends mandatory disclosures, the inclusion of Scope 3 emissions, and the alignment of financial accounts with the Paris Agreement and the UK's net-zero target. It specifically calls for expanding the scope of regulated firms and listed entities subject to these rules and introducing robust enforcement to prevent greenwashing.

ClientEarth argues that the draft CEEAG contains political compromises that undermine environmental ambitions, specifically criticizing the continued support for fossil gas, low-carbon hydrogen, and biomass. The organization advocates for the strict integration of the 'Energy Efficiency First' principle, the 'energy solidarity principle', and more rigorous safeguards to prevent 'carbon lock-in'. Key recommendations include limiting hydrogen aid to renewable sources, phasing out support for high-efficient cogeneration and small hydropower, and implementing stricter conditions for the closure of coal activities to ensure they occur by 2030.

A joint statement by five NGOs urging the UK Government to set 2022 fishing opportunities below scientific advice to combat overfishing and enhance marine ecosystem resilience.

The report examines framework climate laws in the UK, France, Mexico, Finland, Sweden, and Victoria (Australia), concluding that while such laws provide a critical political signal and a structured pathway for decarbonisation, most have struggled with implementation. Key failures include a lack of binding interim targets, overcomplexity in governance, and insufficient accountability mechanisms. The report recommends that future laws impose clear, enforceable duties on high-level government decision-makers, integrate independent scientific advisory bodies, and combine long-term goals with frequent short-term progress reporting to avoid 'paper tiger' legislation.

ClientEarth argues that current Solvency II Pillar 1 capital requirements do not adequately capture financial risks from climate change, including transition risks for fossil fuel assets and systemic disruption risks. The document highlights the UK Government's review of Solvency II, which acknowledges that the solvency capital requirement (SCR) and matching adjustment may need amendments to better reflect long-term climate risks and stranded assets. ClientEarth calls on the European Commission to implement similar enhancements to ensure the resilience of EU insurers and maintain a level playing field with the UK.

The document advocates for a comprehensive EU directive on corporate due diligence to prevent environmental harm. It argues against size-based thresholds for companies, citing the seafood and timber industries as examples where small and medium enterprises (SMEs) can cause significant damage. It emphasizes the necessity of a 'life cycle' approach to value chains, particularly for fossil fuels (addressing Scope 3 emissions and methane leakage) and plastics (addressing pellet pollution). Finally, it calls for mandatory, detailed public reporting to ensure corporate accountability, using the automotive sector's emissions and battery supply chains as a case for transparency.

ClientEarth argues against the use of materiality assessments for climate metrics, advocates for mandatory Scope 3 emissions disclosure, and calls for transition plans to include science-based targets aligned with national commitments and a 1.5°C pathway.

ClientEarth argues that Lloyd's of London's 2020 ESG Report fails to align the insurance market with the Paris Agreement goals. The letter highlights gaps in the 'Climate Targets', such as the lack of restrictions on oil and gas (outside tar sands and the Arctic) and the absence of scope 3 emissions targets. ClientEarth asserts that the Society of Lloyd's has a legal duty under PRA Solvency II rules and the 'prudent person principle' to manage climate risks, which include physical risks making assets uninsurable and transition risks leading to stranded assets. The document questions whether the Climate Targets are binding and calls for transparent public disclosure of managing agents' compliance.

ClientEarth and a coalition of organisations are urging the European Commission to proceed without further delay in adopting two key legislative proposals: one to minimise deforestation and forest degradation linked to products on the EU market, and another on sustainable corporate governance. The authors express concern that these proposals, originally scheduled for the second quarter of 2021, have been delayed past the summer recess without official explanation. They argue these initiatives are essential for the European Green Deal, human rights, and biodiversity, noting strong support from the European Parliament, the Council, and public consultations, where over 1.1 million citizens supported the deforestation law and over 80% of respondents supported a due diligence framework.

A coalition of environmental NGOs is calling on the German government to grant NGOs equal access to fisheries quota negotiations and the Special Committee on Fisheries. The letter argues that current transparency is insufficient, as industry members have more access than environmental groups, and proposes the establishment of a formal observer status and proactive documentation publication to align with the Aarhus Convention.

ClientEarth warns that proposed changes to the UK's judicial review process could prevent environmental groups from holding the government accountable and limit the court's ability to reverse unlawful decisions.

A coalition of NGOs and experts supports Birmingham's Clean Air Zone as a critical step to address illegal air pollution, which causes an estimated 900 premature deaths annually in the city. While praising the Council's leadership in implementing the first Class D Clean Air Zone outside London, the authors argue that the zone should be a first step toward a zero-emission transport network and the elimination of pollution hotspots.

The report analyzes Thailand's Community Forest Act B.E. 2562 (2019), noting that while it provides a first-time official umbrella law for community forestry, it is limited to areas outside protected forests. The analysis highlights gaps in customary tenure recognition, complex allocation processes, and a lack of explicit safeguards for marginalized groups. It recommends the development of detailed subsidiary regulations to clarify management plans, benefit-sharing, and market access.

The briefing argues that the EU-Mercosur trade deal was concluded without a complete sustainability impact assessment (SIA), which the European Ombudsman identified as maladministration. It highlights concerns that the agreement could increase deforestation in Mercosur countries, particularly Brazil, and criticizes the European Commission's attempt to seek pre-ratification commitments rather than renegotiating the text. Furthermore, the document opposes any effort by the Commission to 'split' the trade and political components of the agreement to bypass the requirement for unanimity in the Council and ratification by the 27 EU Member State parliaments, asserting that such a move would violate the original 1999 mandate and principles of sincere cooperation.

ClientEarth is supporting five Polish citizens in lawsuits against the Polish government, claiming that the state's failure to address climate change violates personal rights under the Polish Civil Code and human rights under the European Convention of Human Rights. The claimants seek a legally enforceable right to a healthy environment and a commitment from Poland to reduce greenhouse gas emissions by 61% by 2030 and reach net zero by 2043 to align with the Paris Agreement's 1.5 degree goal. The document highlights Poland's heavy reliance on coal, with 70% of electricity coming from coal and significant public subsidies for fossil fuels, as well as the specific climate-related impacts—such as droughts, floods, and wildfires—experienced by the claimants.

ClientEarth contends that the German government's compensation for closing lignite plants is unlawful State aid. The organization argues that the plants would have closed sooner under market conditions, making the aid unnecessary and disproportionate. Furthermore, it asserts that using public funds to cover mine rehabilitation costs breaches the 'polluter pays' principle and EU environmental law. ClientEarth warns that the measure distorts competition and fails to provide significant environmental benefits, especially in light of a German Constitutional Court ruling requiring more ambitious climate targets.

ClientEarth's contribution to the REACH reform IIA emphasizes the need for stricter enforcement of existing rules, the fulfillment of Chemicals Strategy promises without further impact assessments, and the inclusion of specific criteria for PMT, vPvM, and EDC substances.