SUBMISSIONS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS

The Centre for Environmental Rights (CER), representing groundwork (gW), Earthlife Africa, Johannesburg (ELA), and the South Durban Community Environmental Alliance (SDCEA), submitted formal comments on the draft National Greenhouse Gas (GHG) Emission Reporting Regulations published on 5 June 2015. The CER argues that the draft regulations are insufficient to meet South Africa's international obligations under the UNFCCC and the Kyoto Protocol, citing a lack of detailed facility-level reporting, a failure to identify 'key categories' of emission sources as per IPCC Guidelines, and inadequate provisions for public disclosure of emission data.

• The draft regulations are criticized for requiring only total GHG emissions per company rather than detailed facility-level data, which the CER argues prevents an accurate understanding of South Africa's emissions and hides facilities with poor track records.
• The CER asserts that the draft regulations fail to identify 'key categories' of emission sources as defined by the IPCC Guidelines, which is essential for prioritizing resources and applying more stringent estimation methodologies to the sectors accounting for approximately 95% of total emissions.
• The submission argues that the draft regulations' confidentiality provisions (Draft Regulation 13) are too vague and could be used by industry to avoid disclosing emission data, contradicting constitutional values of openness and transparency.
• The CER recommends that the default position for GHG emission data in the National Atmospheric Emission Inventory System (NAEIS) should be public disclosure, citing international best practices in the USA, EU, and Australia.
• The CER suggests expanding the definition of 'competent authority' to include municipalities and air quality officers, noting that these local authorities already manage atmospheric emission licensing under the Air Quality Act (AQA).
• The submission objects to the proposed four-year transitional period that would allow data providers to use lower-tier calculation methods, arguing it is unjustifiably long and lacks a rational basis.
• The CER notes that the 'Technical Guidelines for Monitoring, Reporting and Verification' mentioned in Draft Regulation 7(4) were not available on the Department of Environmental Affairs website at the time of submission, limiting the ability to assess calculation methods.

APA

Centre for Environmental Rights (2015). SUBMISSIONS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS. https://cer.org.za/wp-content/uploads/2018/07/Annexure-E-CER-Comments-on-Draft-GHG-Reporting-Regs-4-8-15.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS. 2015. https://cer.org.za/wp-content/uploads/2018/07/Annexure-E-CER-Comments-on-Draft-GHG-Reporting-Regs-4-8-15.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS |date=4 August 2015 |url=https://cer.org.za/wp-content/uploads/2018/07/Annexure-E-CER-Comments-on-Draft-GHG-Reporting-Regs-4-8-15.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2015submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS}}, publisher = {Centre for Environmental Rights}, year = {2015}, month = aug, url = {https://cer.org.za/wp-content/uploads/2018/07/Annexure-E-CER-Comments-on-Draft-GHG-Reporting-Regs-4-8-15.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }