CONCERNS REGARDING THE INTERPRETATION AND IMPLEMENTATION OF THE NATIONAL GREENHOUSE GAS REPORTING REGULATIONS AND THE NATIONAL POLLUTION PREVENTION PLAN REGULATIONS

A statement from the Life After Coal/Impilo Ngaphandle Kwamalahle campaign (comprising the Centre for Environmental Rights, groundWork, and Earthlife Africa Johannesburg) addressed to the South African Minister of Environmental Affairs. The letter seeks clarification and proposes amendments to the National Greenhouse Gas (GHG) Reporting Regulations and the National Pollution Prevention Plan Regulations, citing ambiguities that could undermine climate reporting and transparency.

• The Life After Coal/Impilo Ngaphandle Kwamalahle campaign argues that the National Greenhouse Gas (GHG) Reporting Regulations are ambiguously worded, potentially allowing data providers to submit a single aggregated report for all facilities rather than the necessary facility-level data.
• There is a significant discrepancy between reporting via the National Atmospheric Emission Inventory System (NAEIS) portal, which requires data at the facility, emissions unit, and stack level, and Annexure 3 of the regulations, which only requires reporting per activity.
• The campaign asserts that company-level reporting instead of facility-level reporting would hinder local authorities from creating GHG emission inventories and prevent South Africa from meeting its reporting obligations under the UNFCCC and the Paris Agreement's enhanced transparency framework.
• The campaign expresses concern that sections 12 and 14 of the GHG Reporting Regulations place undue restrictions on the publication of NAEIS data, arguing that GHG emission data should be public by default, as is the case in the European Union and Australia.
• The campaign requests information on the enforcement of the 3 May 2017 registration deadline for Category A facilities, specifically asking for the number of registered facilities and what actions the Department of Environmental Affairs (DEA) will take against those that failed to comply.
• Regarding the National Pollution Prevention Plan Regulations, the campaign seeks clarification on regulation 4(1), specifically the meaning of the term "reconciled" and whether subsequent plans must be submitted every five months, which appears to conflict with the five-year validity period of the plans.
• The campaign specifically requested copies of the pollution prevention plans for Eskom, Sasol, and ArcelorMittal SA following the 21 December 2017 submission deadline.

APA

Centre for Environmental Rights (2018). CONCERNS REGARDING THE INTERPRETATION AND IMPLEMENTATION OF THE NATIONAL GREENHOUSE GAS REPORTING REGULATIONS AND THE NATIONAL POLLUTION PREVENTION PLAN REGULATIONS. https://cer.org.za/wp-content/uploads/2018/07/Annexure-C-CER-letter-re-GHG-Regulations_19-January-2018.pdf?x21779

Chicago

Centre for Environmental Rights. CONCERNS REGARDING THE INTERPRETATION AND IMPLEMENTATION OF THE NATIONAL GREENHOUSE GAS REPORTING REGULATIONS AND THE NATIONAL POLLUTION PREVENTION PLAN REGULATIONS. 2018. https://cer.org.za/wp-content/uploads/2018/07/Annexure-C-CER-letter-re-GHG-Regulations_19-January-2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=CONCERNS REGARDING THE INTERPRETATION AND IMPLEMENTATION OF THE NATIONAL GREENHOUSE GAS REPORTING REGULATIONS AND THE NATIONAL POLLUTION PREVENTION PLAN REGULATIONS |date=19 January 2018 |url=https://cer.org.za/wp-content/uploads/2018/07/Annexure-C-CER-letter-re-GHG-Regulations_19-January-2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018concerns, author = {{Centre for Environmental Rights}}, title = {{CONCERNS REGARDING THE INTERPRETATION AND IMPLEMENTATION OF THE NATIONAL GREENHOUSE GAS REPORTING REGULATIONS AND THE NATIONAL POLLUTION PREVENTION PLAN REGULATIONS}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = jan, url = {https://cer.org.za/wp-content/uploads/2018/07/Annexure-C-CER-letter-re-GHG-Regulations_19-January-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }