Analysis in support of the Centre’s comments to the South African Department of Environmental Affairs concerning the Draft National Greenhouse Gas Emission Reporting Regulations

This briefing, submitted by Earthjustice to the Centre for Environmental Rights, provides a comparative analysis between the United States Greenhouse Gas Reporting Program (GHGRP) and South Africa's Draft National Greenhouse Gas Emission Reporting Regulations. It offers specific recommendations to strengthen the South African draft by improving accuracy calibration, clarifying facility-level reporting, expanding the range of covered gases, and reducing flexibility for regulated entities.

• The draft South African regulations lack specifications for accuracy calibration of emissions monitoring instruments, whereas the U.S. GHGRP sets a default accuracy requirement of +/-5% for flow meters.
• Earthjustice recommends that South Africa clarify its regulations to require greenhouse gas (GHG) emissions data for each physical facility rather than allowing aggregated company-level data, noting that facility-level reporting is essential for tracking emissions over time and implementing cap-and-trade programs.
• There is a discrepancy in the South African draft regarding fluorinated gases: the Technical Guidelines for Monitoring indicate they are required, but the cited Air Quality Act only includes carbon dioxide, methane, and nitrous oxide.
• South Africa's draft regulations are criticized for providing excessive flexibility to regulated bodies, including a five-year transitional period and allowing companies to choose their own calculation methods, which may lead to lower reporting levels.
• The U.S. GHGRP maintains a uniform reporting threshold of 25,000 metric tons of CO2 equivalent per year for all industries, while South Africa uses diverse units of measurement across different sectors, creating uncertainty about whether these thresholds represent equivalent emission levels.
• The U.S. GHGRP covers approximately 85-90% of U.S. GHG emissions from over 8,000 facilities and requires reporting for specific source categories regardless of total annual emissions, such as petroleum refineries and cement production.

APA

Centre for Environmental Rights (2016). Analysis in support of the Centre’s comments to the South African Department of Environmental Affairs concerning the Draft National Greenhouse Gas Emission Reporting Regulations. https://cer.org.za/wp-content/uploads/2016/08/Annexure-D-Earthjustice-GHGs-reporting-program-comparison-United-Sates-regs-with-South-Africa-regs-2016-7-6.pdf?x21779

Chicago

Centre for Environmental Rights. Analysis in support of the Centre’s comments to the South African Department of Environmental Affairs concerning the Draft National Greenhouse Gas Emission Reporting Regulations. 2016. https://cer.org.za/wp-content/uploads/2016/08/Annexure-D-Earthjustice-GHGs-reporting-program-comparison-United-Sates-regs-with-South-Africa-regs-2016-7-6.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=Analysis in support of the Centre’s comments to the South African Department of Environmental Affairs concerning the Draft National Greenhouse Gas Emission Reporting Regulations |date=7 July 2016 |url=https://cer.org.za/wp-content/uploads/2016/08/Annexure-D-Earthjustice-GHGs-reporting-program-comparison-United-Sates-regs-with-South-Africa-regs-2016-7-6.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrights2016analysis, author = {{Centre for Environmental Rights}}, title = {{Analysis in support of the Centre’s comments to the South African Department of Environmental Affairs concerning the Draft National Greenhouse Gas Emission Reporting Regulations}}, institution = {Centre for Environmental Rights}, year = {2016}, month = jul, url = {https://cer.org.za/wp-content/uploads/2016/08/Annexure-D-Earthjustice-GHGs-reporting-program-comparison-United-Sates-regs-with-South-Africa-regs-2016-7-6.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }