These comments were submitted to the U.S. Environmental Protection Agency on August 7th, 2025.

These comments were submitted to the U.S. Environmental Protection Agency on August 7th, 2025.
The 30th Conference of Parties (COP30) in Belém marks a critical turning point for the United Nations Framework Convention on Climate Change (UNFCCC), as it will be the first COP held after a full turn of the Paris Agreement’s ambition cycle, following the completion of first global stocktake as well as the submission of biennial […]
G7 states and others are considering or implementing carbon border adjustment mechanisms (CBAMs), but the lack of interoperable or harmonized emissions monitoring, reporting, and verification (MRV) rules around which these countries can coordinate their national policies creates risks for trade and investment. Implementing CBAMs without first addressing interoperability could generate trade barriers that impede […]
The review of the Warsaw International Mechanism for Loss and Damage associated with Climate Change Impacts (WIM) occurs every five years and measures the activities and progress made by the WIM to avert, minimize and address loss and damage (L&D). Parties were unable to reach consensus on the 2024 review of the WIM at the […]
The period from the end of the first global stocktake (GST) at COP28 (2023) through to COP30 (2025) is critical. During this time period we will learn the collective level of ambition of new climate targets, whether countries have taken into account the outcomes of COP28 in formulating them, and whether countries have put in […]
This memo has been updated to reflect final House-passed provisions as of June 4th, 2025; results based on the earlier Ways & Means (W&M) Committee draft are included in the appendix for reference. Executive Summary The House-passed 2025 budget reconciliation bill includes major rollbacks to the Inflation Reduction Act’s tech-neutral clean energy tax credits, particularly […]
Positioned at the center of global capital flows, financial institutions are uniquely equipped to shape the pace and scale of the net-zero transition. To stay on track for a 1.5-degree-C pathway, investment must increase nearly fivefold to $7.4 trillion annually by 2030, according to the Climate Policy Initiative. Similarly, the London School of Economics’ Grantham […]
While finalizing research for the Center for Climate and Energy Solutions’ (C2ES) analysis, Navigating the Finance Sector Net-Zero Transition: Levers for Decarbonizing in a Complex Landscape, the financial sector underwent a wave of transformative developments. In the United States, legal challenges to the use of climate and Environmental, Social, and Governance (ESG) factors intensified, and […]
Communities in Kentucky have long supplied a significant portion of the natural resources that powered the U.S. economy, namely coal. Since 1790, Kentucky has supplied more than 11 percent of all coal produced in the United States. As global markets shift toward lower-carbon products, communities throughout Kentucky have the opportunity to turn their skills and […]
Questions for Consideration How are Parties planning to take forward the GST signals that relate to the acceleration of the development and deployment of CDR approaches? How do they intend to reflect this in new NDCs, or future updates of submitted NDCs, including through the provision of information to facilitate clarity, transparency and understanding? How […]