{"query_echo":{"q":"","filters":{"climate_tags":["environmental transparency"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'environmental transparency' for facet 'climate_tags' is not in the controlled vocabulary."}]},"total":{"value":3,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?climate_tags=environmental+transparency","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"cer-000394","url":"https://climateinsightsdirectory.org/document/cer-000394","title":"INTERNAL APPEAL PURSUANT TO THE PROMOTION OF ACCESS TO INFORMATION ACT 2 OF 2000","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2019-12-13","source_url":"https://cer.org.za/wp-content/uploads/2020/01/Annexure-A-PAIA-Appeal-CER-13-12-19.docx.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER) filed an internal appeal on 13 December 2019 against the Department of Environment, Forestry and Fisheries' decision to redact greenhouse gas (GHG) emission data and pollution prevention plans for several major South African emitters. The CER argues that the Department failed to provide adequate reasons for the redactions and that the information is of fundamental public interest, overriding claims of commercial confidentiality.","ai_generated":true,"unit":"cer-000394#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Centre for Environmental Rights (CER) is appealing a decision by the Department of Environment, Forestry and Fisheries to redact GHG emission data and pollution prevention plans, asserting that such information \"is not, and cannot be, commercially confidential.\"","ai_generated":true,"unit":"cer-000394#insight-1","date_modified":"2026-08-17"},{"text":"The CER's PAIA request sought records from 16 entities, including Eskom Holdings SOC Ltd, Sasol Ltd, ArcelorMittal South Africa Ltd, and Anglo American Plc, specifically requesting GHG emission data reports, pollution prevention plans, and annual progress reports.","ai_generated":true,"unit":"cer-000394#insight-2","date_modified":"2026-08-17"},{"text":"The Department granted partial access but redacted numerical values of unit activities in GHG emission reports, expected GHG emissions in pollution prevention plans, and anticipated emission reductions in annual progress reports for companies such as Eskom, Sasol, and ArcelorMittal.","ai_generated":true,"unit":"cer-000394#insight-3","date_modified":"2026-08-17"},{"text":"The CER argues the Respondent failed to provide adequate reasons for the redactions, stating that simply quoting sections 28 and 36 of PAIA is insufficient to meet the requirements of section 25(3) of the Act.","ai_generated":true,"unit":"cer-000394#insight-4","date_modified":"2026-08-17"},{"text":"The appeal contends that the Department failed to discharge its onus of proof to show that the requested information would likely cause harm to the commercial or financial interests of the third parties.","ai_generated":true,"unit":"cer-000394#insight-5","date_modified":"2026-08-17"},{"text":"The CER points to international precedents in Australia and the United Kingdom where GHG emission and energy consumption data are proactively published or cannot be refused on the basis of commercial confidentiality.","ai_generated":true,"unit":"cer-000394#insight-6","date_modified":"2026-08-17"},{"text":"The CER asserts a 'public interest override' under section 46 of PAIA, arguing that the risk of GHG emissions constitutes a significant public safety and environmental risk that outweighs any commercial harm.","ai_generated":true,"unit":"cer-000394#insight-7","date_modified":"2026-08-17"},{"text":"The CER notes that some companies, including SAPPI, Anglo American, and Mbuyelo Coal, voluntarily provided unredacted reports after the Department's refusal, undermining the claim that the data is commercially sensitive.","ai_generated":true,"unit":"cer-000394#insight-8","date_modified":"2026-08-17"},{"text":"The document highlights South Africa's vulnerability to climate change, noting it is the world's 13th largest GHG emitter and that a 2°C global temperature increase equates to a 3 to 4°C increase for South Africa.","ai_generated":true,"unit":"cer-000394#insight-9","date_modified":"2026-08-17"}],"climate_tags":["greenhouse gas emissions","climate change mitigation","environmental transparency","pollution prevention plans","climate risk disclosure"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["legal appeal","policy challenge"]},{"id":"cer-000633","url":"https://climateinsightsdirectory.org/document/cer-000633","title":"REQUEST FOR ACCESS TO POLLUTION PREVENTION PLANS & GREENHOUSE GAS REPORTING RECORDS","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2018-06-25","source_url":"https://cer.org.za/wp-content/uploads/2018/07/CER-Letter-to-DEA-PPPs-GHG-Reporting-25-6-18.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER) sent a formal request to the South African Department of Environmental Affairs (DEA) on 25 June 2018, demanding access to pollution prevention plans and greenhouse gas (GHG) reporting records. The CER disputes the DEA's claims of confidentiality regarding emissions data from major companies and calls for transparency to ensure the effectiveness of the national mitigation system.","ai_generated":true,"unit":"cer-000633#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Centre for Environmental Rights (CER) requested that the Department of Environmental Affairs (DEA) provide, by 2 July 2018, the number of entities that submitted pollution prevention plans by the 21 June 2018 deadline and a list of the names of those entities.","ai_generated":true,"unit":"cer-000633#insight-1","date_modified":"2026-08-17"},{"text":"The CER disputes the DEA's assertion that pollution prevention plans for ArcelorMittal, Eskom, and Sasol contain confidential information, arguing that withholding this data prejudices constitutional rights and undermines the GHG mitigation system.","ai_generated":true,"unit":"cer-000633#insight-2","date_modified":"2026-08-17"},{"text":"The CER requested specific GHG reporting data by 16 July 2018, including the names of category A data providers who registered and reported emissions, access to emissions and activity data reports submitted by 31 March 2018, and details on enforcement actions against non-compliant providers.","ai_generated":true,"unit":"cer-000633#insight-3","date_modified":"2026-08-17"},{"text":"The CER argues that GHG reporting data should be public, noting that companies like Sasol already provide emissions data in the USA and citing a Supreme Court of Appeal judgment (ArcelorMittal South Africa v Vaal Environmental Justice Alliance) which stated that for corporations operating in South Africa, \"there is no room for secrecy\" regarding the environment.","ai_generated":true,"unit":"cer-000633#insight-4","date_modified":"2026-08-17"}],"climate_tags":["greenhouse gas reporting","pollution prevention plans","climate change mitigation","environmental transparency"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["legal request","policy advocacy"]},{"id":"cer-000455","url":"https://climateinsightsdirectory.org/document/cer-000455","title":"SUBMISSIONS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2015-08-04","source_url":"https://cer.org.za/wp-content/uploads/2018/07/Annexure-E-CER-Comments-on-Draft-GHG-Reporting-Regs-4-8-15.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER), representing groundwork (gW), Earthlife Africa, Johannesburg (ELA), and the South Durban Community Environmental Alliance (SDCEA), submitted formal comments on the draft National Greenhouse Gas (GHG) Emission Reporting Regulations published on 5 June 2015. The CER argues that the draft regulations are insufficient to meet South Africa's international obligations under the UNFCCC and the Kyoto Protocol, citing a lack of detailed facility-level reporting, a failure to identify 'key categories' of emission sources as per IPCC Guidelines, and inadequate provisions for public disclosure of emission data.","ai_generated":true,"unit":"cer-000455#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The draft regulations are criticized for requiring only total GHG emissions per company rather than detailed facility-level data, which the CER argues prevents an accurate understanding of South Africa's emissions and hides facilities with poor track records.","ai_generated":true,"unit":"cer-000455#insight-1","date_modified":"2026-08-17"},{"text":"The CER asserts that the draft regulations fail to identify 'key categories' of emission sources as defined by the IPCC Guidelines, which is essential for prioritizing resources and applying more stringent estimation methodologies to the sectors accounting for approximately 95% of total emissions.","ai_generated":true,"unit":"cer-000455#insight-2","date_modified":"2026-08-17"},{"text":"The submission argues that the draft regulations' confidentiality provisions (Draft Regulation 13) are too vague and could be used by industry to avoid disclosing emission data, contradicting constitutional values of openness and transparency.","ai_generated":true,"unit":"cer-000455#insight-3","date_modified":"2026-08-17"},{"text":"The CER recommends that the default position for GHG emission data in the National Atmospheric Emission Inventory System (NAEIS) should be public disclosure, citing international best practices in the USA, EU, and Australia.","ai_generated":true,"unit":"cer-000455#insight-4","date_modified":"2026-08-17"},{"text":"The CER suggests expanding the definition of 'competent authority' to include municipalities and air quality officers, noting that these local authorities already manage atmospheric emission licensing under the Air Quality Act (AQA).","ai_generated":true,"unit":"cer-000455#insight-5","date_modified":"2026-08-17"},{"text":"The submission objects to the proposed four-year transitional period that would allow data providers to use lower-tier calculation methods, arguing it is unjustifiably long and lacks a rational basis.","ai_generated":true,"unit":"cer-000455#insight-6","date_modified":"2026-08-17"},{"text":"The CER notes that the 'Technical Guidelines for Monitoring, Reporting and Verification' mentioned in Draft Regulation 7(4) were not available on the Department of Environmental Affairs website at the time of submission, limiting the ability to assess calculation methods.","ai_generated":true,"unit":"cer-000455#insight-7","date_modified":"2026-08-17"}],"climate_tags":["greenhouse gas reporting","climate change mitigation","environmental transparency","ghg inventory"],"geography_discussed":["United States","European Union","Australia"],"frame_perspective":[],"analysis_type":["policy analysis","legal submission"]}]}