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The Department of Environmental Affairs (DEA) of South Africa responded to concerns raised by the Centre for Environmental Rights (CER) regarding the interpretation and implementation of the National Greenhouse Gas (GHG) Reporting Regulations and the National Pollution Prevention Plan (PPP) Regulations.

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  • The Department of Environmental Affairs maintains that the mandatory GHG reporting regime is consistent with the guiding principles of the 2011 National Climate Change Response White Paper (NCCRP). The NCCRP proposes mandatory emissions reporting for entities emitting more than 0.1 Mt of GHGs annually or consuming electricity resulting in more than 0.1 Mt of emissions from the electricity sector.
  • Current GHG reporting requires registration at the company level with disaggregation at the facility level. The Department argues that company-level reporting is sufficient to meet the programme's objectives and supports the implementation of climate mitigation instruments, including carbon taxes, carbon budgets, and the tracking of Pollution Prevention Plans (PPPs).
  • The National Atmospheric Emission Inventory System (NAEIS) is currently being upgraded to enable company-level aggregation and to meet the requirements of the GHG reporting regulations. Because the NAEIS is currently unable to meet these requirements, the Department introduced offline reporting mechanisms via annexures 2 and 3 as a back-up.
  • The Department asserts that the current reporting regime improves the transparency, accuracy, completeness, and consistency of future GHG inventories compared to previous methods, which relied on Aggregate Energy Balance data and voluntary company data. This improvement is intended to help South Africa meet UNFCCC reporting obligations through National Communications and Biennial Update Reports.
  • As of the date of the letter, 140 data providers have submitted registrations under Annexure 2 of the regulations, covering a total of 595 facilities.
  • The first round of pollution prevention plans covers the period from 21 July 2017 to 31 December 2020, with a submission deadline of 21 December 2017. Subsequent plans will cover five-year periods, with the next phase starting 1 January 2021 and the subsequent plan due by 31 May 2021.
  • The Department has received pollution prevention plans from 35 companies, including Eskom, Sasol, and ArcelorMittal South Africa. The Department refused to share these plans with the CER, citing Regulation 7 of the National Pollution Prevention Plan Regulations and the need to protect confidential production process information.

Cite the original document

APA
Centre for Environmental Rights (n.d.). KM_C654e-20180221122406. https://cer.org.za/wp-content/uploads/2019/10/Annexure-E-Response-to-CER_Implementation-of-the-GHG-Reporting-and-PPP-Regulations.pdf?x21779
Chicago
Centre for Environmental Rights. KM_C654e-20180221122406. n.d. https://cer.org.za/wp-content/uploads/2019/10/Annexure-E-Response-to-CER_Implementation-of-the-GHG-Reporting-and-PPP-Regulations.pdf?x21779.
Wikipedia
{{cite press release |author=Centre for Environmental Rights |title=KM_C654e-20180221122406 |url=https://cer.org.za/wp-content/uploads/2019/10/Annexure-E-Response-to-CER_Implementation-of-the-GHG-Reporting-and-PPP-Regulations.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{centreforenvironmentalrightsndkmc654e20180221122406, author = {{Centre for Environmental Rights}}, title = {{KM\_C654e-20180221122406}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2019/10/Annexure-E-Response-to-CER_Implementation-of-the-GHG-Reporting-and-PPP-Regulations.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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