REQUEST FOR STRENGTHENING AND PUBLICATION OF THE NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS, THE NOTICE OF INTENTION TO DECLARE GREENHOUSE GASES PRIORITY POLLUTANTS AND THE POLLUTION PREVENTION PLAN REGULATIONS

The Centre for Environmental Rights, representing several non-governmental and community organisations, urges the South African government to finalise and publish draft regulations for greenhouse gas (GHG) reporting and pollution prevention. The letter argues that these regulations are essential for South Africa to meet its commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC), specifically regarding the introduction of mandatory GHG reporting by 2016. Key demands include shifting reporting from a company level to an individual facility level and ensuring that GHG emission data is made publicly available through the National Atmospheric Emission Inventory System (NAEIS). The authors warn that failing to incorporate these transparency and monitoring measures could render the regulations unconstitutional and hinder the state's ability to track emissions trajectories and identify mitigation opportunities.

• The authors request the immediate publication and implementation of three sets of draft regulations: the National Greenhouse Gas Emission Reporting Regulations, the Notice of Intention to Declare GHGs Priority Pollutants, and the Pollution Prevention Plan Regulations.
• South Africa's Intended Nationally Determined Contribution (INDC) specifically proposed the introduction of mandatory domestic GHG reporting no later than 2016 to enable increased disaggregation of data over time.
• The Centre for Environmental Rights argues that GHG reporting must occur at the individual facility level rather than the company level to ensure accurate verification and effective tracking of the country's largest emitters.
• The document emphasizes that GHG emission data should be publicly accessible via the NAEIS to support transparency and the constitutional right to access information.
• Under the Paris Agreement, South Africa is obligated to communicate ambitious Nationally Determined Contributions (NDCs) every five years and provide a national inventory report of anthropogenic emissions using IPCC-accepted methodologies.
• The authors cite the case of Colenso Power (Pty) Limited as an example of emitters trivializing climate science by claiming there is no legal requirement to assess climate change impacts and asserting that uncertainty still exists regarding the science.
• The letter notes recent administrative actions in South Africa that integrate climate change considerations, including a requirement for a climate change impact assessment for the Thabametsi coal-fired power station and the refusal of a mine authorisation in Limpopo due to threats to climate change resilience.

APA

Centre for Environmental Rights (2016). REQUEST FOR STRENGTHENING AND PUBLICATION OF THE NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS, THE NOTICE OF INTENTION TO DECLARE GREENHOUSE GASES PRIORITY POLLUTANTS AND THE POLLUTION PREVENTION PLAN REGULATIONS. https://cer.org.za/wp-content/uploads/2016/08/Annexure-C-CER-Letter-to-DG-NAQO-GHG-Regulations-5-4-16.pdf?x21779

Chicago

Centre for Environmental Rights. REQUEST FOR STRENGTHENING AND PUBLICATION OF THE NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS, THE NOTICE OF INTENTION TO DECLARE GREENHOUSE GASES PRIORITY POLLUTANTS AND THE POLLUTION PREVENTION PLAN REGULATIONS. 2016. https://cer.org.za/wp-content/uploads/2016/08/Annexure-C-CER-Letter-to-DG-NAQO-GHG-Regulations-5-4-16.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=REQUEST FOR STRENGTHENING AND PUBLICATION OF THE NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS, THE NOTICE OF INTENTION TO DECLARE GREENHOUSE GASES PRIORITY POLLUTANTS AND THE POLLUTION PREVENTION PLAN REGULATIONS |date=5 April 2016 |url=https://cer.org.za/wp-content/uploads/2016/08/Annexure-C-CER-Letter-to-DG-NAQO-GHG-Regulations-5-4-16.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2016request, author = {{Centre for Environmental Rights}}, title = {{REQUEST FOR STRENGTHENING AND PUBLICATION OF THE NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS, THE NOTICE OF INTENTION TO DECLARE GREENHOUSE GASES PRIORITY POLLUTANTS AND THE POLLUTION PREVENTION PLAN REGULATIONS}}, publisher = {Centre for Environmental Rights}, year = {2016}, month = apr, url = {https://cer.org.za/wp-content/uploads/2016/08/Annexure-C-CER-Letter-to-DG-NAQO-GHG-Regulations-5-4-16.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }