OpenLobby.EU
Explore

Trilateral Research

TRI

Trilateral Research Ltd is a research and sociotech development SME based in Ireland and the UK.

Lobbying Activity

Response to Carbon capture utilisation and storage deployment

31 Aug 2023

Trilateral Research Ltd is a UK and Irish SME that conducts research funded through the European Union, including research on climate engineering technologies in the TechEthos project. Our response to the Commissions call for evidence draws on this expertise. Trilateral Research Ltd welcomes the opportunity to provide feedback to the European Commissions call for evidence on an industrial carbon management strategy (the strategy). This initiative is an important and welcome step towards the clarification of the role of carbon capture, utilisation and storage (CCUS) activities in achieving carbon neutrality, and in identifying the measures needed to optimally benefit from these climate technologies. Trilateral Research Ltd sees the following priorities for an EU strategy for industrial carbon management: 1. Defining carbon capture, utilisation and storage activities The EU would benefit from clarifying the definition of CCUS activities. As part of this definition, the framework should specify which activities constitute emission reductions or carbon removal for the purpose of achieving carbon neutrality under the European Climate Law. 2. Clarifying the legal status of carbon removals The EU should clarify the legal status of carbon removals, which would help create legal certainty and enable uptake of carbon removal activities required to achieve carbon neutrality 3. Optimally incentivising the most appropriate carbon management activities First, the strategy should seek to clearly define and quantify the contribution of different CCUS activities in achieving climate neutrality. Then, depending on the expected contribution to neutrality, the EU should develop measures that incentivise the appropriate amount and type of CCUS activities. *** This submission was prepared by the Climate, Environment and Energy cluster of the Research & Innovation team at Trilateral Research Ltd. Our recommendations for an industrial carbon management strategy are further detailed in the attached letter. Requests for further information or clarification can be emailed to julie.vinders@trilateralresearch.com.
Read full response

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Association Européenne des Expositions Scientifiques, Techniques et Industrielles

11 Jan 2023 · Metaverse, AI Act, DSA

Response to Requirements for Artificial Intelligence

6 Aug 2021

Trilateral Research is a UK and IE-based ethical technology development and research company. Our experienced interdisciplinary teams apply rigorous, cutting-edge research when developing and assessing new technologies to ensure they achieve sustainable innovation and measurable impact. We believe that regulation should be a part of the governance framework for AI, as it will help ensure AI systems are safer, more reliable, and better suited for inclusion as part of the fundamental infrastructure of society. Trilateral Research is aware of the potential harms that can come from unregulated use of AI and the pressures to rapidly make use of this new technology. We are also deeply familiar with the philosophy behind the draft regulation and have already adopted practices in line with many elements of the proposed Regulation. Additionally, Trilateral Research has an established history of research and work related to privacy and data protection under GDPR, and we understand that enforcement strategies, and support and guidance, particularly for SMEs, will be very important to the impact of the Act. - We support establishing red lines for AI systems that pose unacceptable levels of risk. We caution against too narrowly defining those prohibited AI systems and recommend that the list of prohibited AI systems be non-exhaustive and a process established for other AI systems to be added in the future. - We support mandatory requirements that are clear, implementable and support the development of secure, trustworthy, and ethical AI for high- risk AI systems. However, mandatory requirements should not place unnecessary or onerous burdens on developers, especially SMEs, because these burdens could discourage proactive measures to support compliance. - We recommend that impact assessment becomes an explicit and mandatory requirement of the risk management system for high-risk AI systems. Such assessment should include, at a minimum, assessment of bias, discrimination, invasion of privacy, misuse of personal data and damaging trust, and could be modeled on privacy and data protection impact assessments required under the GDPR. - We welcome regulatory sandboxes and other support measures for SMEs and small-scale providers. As conditions are set out in implementing acts, we recommend that the selection criteria are strictly, carefully, and transparently defined to avoid the potential for misuse by participants to gain unfair competitive advantages both in regulatory advice and in being first to the market. - We support the creation of an independent, centralised EU body to ensure cooperation, coordination and consistent application of EU law related to AI. Like the European Data Protection Board, the independent, centralised body should be tasked with developing and promulgating guidance on legal concepts and regulatory issues associated with AI, including specific guidance for SMEs. - We recommend strengthening and expanding enforcement mechanisms to better protect fundamental rights and whistleblowers. Stronger measures are needed to ensure that individuals and citizens can adequately and effectively raise concerns about harmful AI systems and be protected from retaliation if such concerns are voiced. These mechanisms could complement other complaint and redress tools, including those under GDPR and within national human rights institutions. - We support the instrumental role that standards will play in regulatory compliance. It is important that any of the European Standard Organisations mirror the ongoing activities taking place in the international arena and strive to reduce duplication of work and effort. This would reduce the onerous burden for SMEs, who may have to navigate through all the forthcoming standards to determine which ones are functional. Furthermore, we recommend the use of standards to meet regulatory requirements as opposed to the use of common specifications.
Read full response