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

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle campaign, has raised concerns to the South African Minister of Environmental Affairs about ambiguities in greenhouse gas (GHG) and pollution prevention reporting. The campaign argues that current regulations allow for aggregated company-level reporting instead of the necessary facility-level data, which undermines the National Greenhouse Gas Inventory and South Africa's international obligations under the UNFCCC and Paris Agreement. They also highlight contradictions in the submission and review timelines for pollution prevention plans and call for greater public transparency of emissions data.

• The National Greenhouse Gas Reporting Regulations contain ambiguities that may allow data providers to submit a single aggregated report for all facilities rather than separate reports for each individual facility.
• Reporting via Annexure 3 is considered problematic because it requires significantly less detail than the National Atmospheric Emission Inventory System (NAEIS) portal, potentially making data un-auditable and lacking transparency regarding specific emission sources.
• Company-level reporting instead of facility-level reporting is argued to hinder local authorities from developing GHG emission inventories and undermine South Africa's reporting obligations under the UNFCCC and the Paris Agreement's enhanced transparency framework.
• The campaign expresses concern that sections 12 and 14 of the regulations place undue restrictions on the publication of NAEIS data, arguing that GHG emission data should be public by default as it is in jurisdictions like Australia and the European Union.
• There is a perceived contradiction in the National Pollution Prevention Plan Regulations regarding the submission of subsequent plans, specifically the phrase "within five months of existing plans being reconciled," which conflicts with the five-year validity and review period.

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} }