{"query_echo":{"q":"","filters":{"climate_tags":["greenhouse gas reporting"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'greenhouse gas reporting' for facet 'climate_tags' is not in the controlled vocabulary."}]},"total":{"value":5,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?climate_tags=greenhouse+gas+reporting","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-000755","url":"https://climateinsightsdirectory.org/document/cer-000755","title":"PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2018-06-29","source_url":"https://cer.org.za/wp-content/uploads/2018/07/CER-submissions-on-the-draft-amendments-to-the-Framework-for-AQM_29-June-2018.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 several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.","ai_generated":true,"unit":"cer-000755#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The CER contends that the public consultation process for the 2018 draft Framework was unfair and unreasonable due to a short 30-day comment period for three interrelated documents and a failure to hold meetings in priority areas most impacted by pollution.","ai_generated":true,"unit":"cer-000755#insight-1","date_modified":"2026-08-17"},{"text":"The document asserts that South Africa's National Ambient Air Quality Standards (NAAQS) and Minimum Emission Standards (MES) are too weak and are outdated compared to World Health Organisation (WHO) guidelines, requiring urgent review.","ai_generated":true,"unit":"cer-000755#insight-2","date_modified":"2026-08-17"},{"text":"The CER reports that major polluters Eskom and Sasol have obtained widespread postponements for MES compliance and that Eskom continues to fail to comply even with the more lax standards in its atmospheric emission licences (AELs) without facing enforcement action.","ai_generated":true,"unit":"cer-000755#insight-3","date_modified":"2026-08-17"},{"text":"The draft Framework is criticised for lacking a comprehensive progress review of the 2007 and 2012 Frameworks, often extending expired deadlines or deleting targets without explaining previous failures.","ai_generated":true,"unit":"cer-000755#insight-4","date_modified":"2026-08-17"},{"text":"The CER objects to proposed changes in the draft Framework that would weaken the requirements for MES postponement applications, specifically the removal of requirements to prove that emissions are not causing adverse environmental impacts.","ai_generated":true,"unit":"cer-000755#insight-5","date_modified":"2026-08-17"},{"text":"The submission highlights significant deficiencies in the South African Air Quality Information System (SAAQIS), noting that the new website is a 'shell' lacking critical data, media libraries, and a functional learners' centre.","ai_generated":true,"unit":"cer-000755#insight-6","date_modified":"2026-08-17"},{"text":"The CER argues that greenhouse gas (GHG) reporting is undermined by allowing aggregated company-level reporting instead of mandatory facility-level reporting, which prevents accurate monitoring of emission sources.","ai_generated":true,"unit":"cer-000755#insight-7","date_modified":"2026-08-17"},{"text":"The document notes a critical lack of capacity at the local government level, stating that many municipalities lack the skilled staff and financial resources to implement Air Quality Management Plans (AQMPs) or enforce the Air Quality Act (AQA).","ai_generated":true,"unit":"cer-000755#insight-8","date_modified":"2026-08-17"},{"text":"The CER expresses concern that the government intends to build new coal-fired power stations (such as Thabametsi and Khanyisa) in priority areas where air quality is already poor or deteriorating.","ai_generated":true,"unit":"cer-000755#insight-9","date_modified":"2026-08-17"}],"climate_tags":["air quality","greenhouse gas reporting","coal-fired power stations","environmental justice","climate mitigation"],"geography_discussed":["Vaal Triangle","Highveld","Waterberg-Bojanala","Mpumalanga","Limpopo"],"frame_perspective":[],"analysis_type":["Policy Review","Legal Submission","Compliance Monitoring"]},{"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"]},{"id":"cer-000319","url":"https://climateinsightsdirectory.org/document/cer-000319","title":"anglo-ghg-report-ea3842a6ba3ee0e7.pdf","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2019/12/Anglo-GHG-report.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"This document consists of greenhouse gas (GHG) reporting notes and data tables submitted in March 2019 for Anglo American operations in South Africa. It details the calculation methodologies for fugitive methane and carbon dioxide emissions from coal mining for Anglo Operations (Pty) Ltd and provides emission data for Anglo American Platinum and Anglo American Inyosi Coal for the year 2018.","ai_generated":true,"unit":"cer-000319#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"Anglo American Coal South Africa utilizes the Intergovernmental Panel on Climate Change (IPCC) 2006 Tier 2 methodology to estimate CO2 and CH4 emissions, following the April 2017 Technical Guidelines from the Department of Environmental Affairs.","ai_generated":true,"unit":"cer-000319#insight-1","date_modified":"2026-08-17"},{"text":"Under the applied methodology, fugitive emissions from opencast coal mines are recorded as zero, regardless of the volume of tonnes produced.","ai_generated":true,"unit":"cer-000319#insight-2","date_modified":"2026-08-17"},{"text":"Anglo Operations (Pty) Ltd (AOPL) comprises four specific operations: Greenside Underground, Goedehoop Underground, Khwezela Opencast, and Isibonelo.","ai_generated":true,"unit":"cer-000319#insight-3","date_modified":"2026-08-17"},{"text":"For the 2018 data year, Anglo American Platinum reported total emissions of 495,099 tonnes of CO2, 14.04 tonnes of CH4, and 2.86 tonnes of N2O across its Polokwane Smelter, Waterval Smelter & ACP, Mortimer Smelter, and Rustenburg Base Metals Refinery.","ai_generated":true,"unit":"cer-000319#insight-4","date_modified":"2026-08-17"}],"climate_tags":["greenhouse gas reporting","fugitive emissions","coal mining","methane","carbon dioxide"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["Regulatory Reporting","Emissions Inventory"]},{"id":"cer-000459","url":"https://climateinsightsdirectory.org/document/cer-000459","title":"KM_C654e-20180221122406","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2019/10/Annexure-E-Response-to-CER_Implementation-of-the-GHG-Reporting-and-PPP-Regulations.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Department of Environmental Affairs (DEA) of South Africa responded to concerns raised by the Centre for Environmental Rights (CER) regarding the interpretation and implementation of the National Greenhouse Gas (GHG) Reporting Regulations and the National Pollution Prevention Plan (PPP) Regulations.","ai_generated":true,"unit":"cer-000459#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Department of Environmental Affairs maintains that the mandatory GHG reporting regime is consistent with the guiding principles of the 2011 National Climate Change Response White Paper (NCCRP). The NCCRP proposes mandatory emissions reporting for entities emitting more than 0.1 Mt of GHGs annually or consuming electricity resulting in more than 0.1 Mt of emissions from the electricity sector.","ai_generated":true,"unit":"cer-000459#insight-1","date_modified":"2026-08-17"},{"text":"Current GHG reporting requires registration at the company level with disaggregation at the facility level. The Department argues that company-level reporting is sufficient to meet the programme's objectives and supports the implementation of climate mitigation instruments, including carbon taxes, carbon budgets, and the tracking of Pollution Prevention Plans (PPPs).","ai_generated":true,"unit":"cer-000459#insight-2","date_modified":"2026-08-17"},{"text":"The National Atmospheric Emission Inventory System (NAEIS) is currently being upgraded to enable company-level aggregation and to meet the requirements of the GHG reporting regulations. Because the NAEIS is currently unable to meet these requirements, the Department introduced offline reporting mechanisms via annexures 2 and 3 as a back-up.","ai_generated":true,"unit":"cer-000459#insight-3","date_modified":"2026-08-17"},{"text":"The Department asserts that the current reporting regime improves the transparency, accuracy, completeness, and consistency of future GHG inventories compared to previous methods, which relied on Aggregate Energy Balance data and voluntary company data. This improvement is intended to help South Africa meet UNFCCC reporting obligations through National Communications and Biennial Update Reports.","ai_generated":true,"unit":"cer-000459#insight-4","date_modified":"2026-08-17"},{"text":"As of the date of the letter, 140 data providers have submitted registrations under Annexure 2 of the regulations, covering a total of 595 facilities.","ai_generated":true,"unit":"cer-000459#insight-5","date_modified":"2026-08-17"},{"text":"The first round of pollution prevention plans covers the period from 21 July 2017 to 31 December 2020, with a submission deadline of 21 December 2017. Subsequent plans will cover five-year periods, with the next phase starting 1 January 2021 and the subsequent plan due by 31 May 2021.","ai_generated":true,"unit":"cer-000459#insight-6","date_modified":"2026-08-17"},{"text":"The Department has received pollution prevention plans from 35 companies, including Eskom, Sasol, and ArcelorMittal South Africa. The Department refused to share these plans with the CER, citing Regulation 7 of the National Pollution Prevention Plan Regulations and the need to protect confidential production process information.","ai_generated":true,"unit":"cer-000459#insight-7","date_modified":"2026-08-17"}],"climate_tags":["greenhouse gas reporting","pollution prevention plans","carbon tax","carbon budgets","unfccc","climate mitigation"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["Policy Response","Regulatory Implementation"]}]}