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
Summary
The Centre for Environmental Rights (CER), representing several non-governmental and community organisations, submitted a formal request to the South African Department of Environmental Affairs on 5 April 2016. The letter urges the strengthening and immediate publication of draft regulations concerning greenhouse gas (GHG) emission reporting, the declaration of GHGs as priority pollutants, and pollution prevention plans, arguing that these are essential for South Africa to meet its commitments under its Intended Nationally Determined Contribution (INDC) and the Paris Agreement.
Key insights
- The CER and its clients 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 Greenhouse Gases Priority Pollutants, and the Pollution Prevention Plan Regulations.
- The CER identifies four primary requirements for the draft regulations to be effective: alignment with national policy and international commitments, public availability of GHG emission data via the NAEIS, reporting at a detailed facility level rather than just company level, and the establishment of robust monitoring, verification, and enforcement mechanisms.
- South Africa's Intended Nationally Determined Contribution (INDC) specifies that GHG emissions should peak between 2020 and 2025, plateau for about a decade, and then decline. It targets an emission range between 398 and 614 Mt CO2–eq for the 2025 to 2030 period and aimed to introduce mandatory domestic GHG reporting by 2016.
- The CER argues that reporting at the company level is insufficient for the state to track progress or report openly under the Paris Agreement, asserting that facility-level reporting is necessary for accurate verification and to encourage compliance.
- The document cites a specific instance of industry resistance to climate science, noting that Colenso Power (Pty) Limited argued in a responding statement that there is no legal requirement to assess climate change impacts and claimed there is "considerable uncertainty around the science of climate change."
- The CER highlights recent administrative actions that integrate climate change considerations, including a ministerial decision requiring a climate change impact assessment for the proposed Thabametsi coal-fired power station and the refusal of a mining authorisation in Limpopo due to concerns over climate change resilience.
Cite the original document
- 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} }
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