PRELIMINARY COMMENTS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS

The document argues that the draft Regulations unfairly place the burden of GHG emission calculations on data providers rather than the competent authority. It recommends shifting the data provider's role to reporting activity data at a facility level, expanding the scope of GHGs to include fluorinated gases, and ensuring full public disclosure of emission data to meet South Africa's obligations under the Paris Agreement and its Nationally Determined Contribution (NDC).

• The draft Regulations incorrectly place the responsibility for determining the reporting methodology and calculating GHG emissions on Category A data providers, which the authors argue is "unjust, and unreasonably burdensome".
• The authors recommend that the competent authority, not the data provider, should be responsible for calculating GHG emissions based on activity data provided by the facilities.
• The document highlights a lack of transparency and public access to data, noting that the draft Regulations' definition of "transparency" fails to provide for public access to information.
• The authors argue that the draft Regulations are ambiguous regarding facility-level reporting, potentially allowing data providers to submit a single aggregated report instead of separate reports for each individual facility.
• The current draft Regulations omit the reporting of GHG emissions from refrigeration and air conditioning, specifically hydrofluorocarbons (HFCs) and perfluorocarbons (PFCs), which the authors believe should be a "top priority".
• The authors criticize the proposed 5-year transitional period allowing data providers to use tier 1 methods, stating there is "no rational basis" for such a long period given South Africa's international commitments.
• The document recommends the creation of a "Category C" data provider to include importers, wholesalers, and distributors of fuels and ozone-depleting substance substitutes.
• The authors contend that the confidentiality provisions in draft regulations 12 and 14 are redundant and may be used to improperly withhold information that is of fundamental environmental importance.
• The document points out that the Technical Guidelines, which are essential for implementing the regulations, were not published alongside the draft Regulations, which the authors describe as an "irregularity for administrative justice".

APA

Centre for Environmental Rights (2016). PRELIMINARY COMMENTS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS. https://cer.org.za/wp-content/uploads/2018/07/Annexure-F-CER-Submissions-Draft-GHG-Reporting-Regs-7-7-16.pdf?x21779

Chicago

Centre for Environmental Rights. PRELIMINARY COMMENTS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS. 2016. https://cer.org.za/wp-content/uploads/2018/07/Annexure-F-CER-Submissions-Draft-GHG-Reporting-Regs-7-7-16.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=PRELIMINARY COMMENTS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS |date=7 July 2016 |url=https://cer.org.za/wp-content/uploads/2018/07/Annexure-F-CER-Submissions-Draft-GHG-Reporting-Regs-7-7-16.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2016preliminary, author = {{Centre for Environmental Rights}}, title = {{PRELIMINARY COMMENTS ON THE DRAFT NATIONAL GREENHOUSE GAS EMISSION REPORTING REGULATIONS}}, publisher = {Centre for Environmental Rights}, year = {2016}, month = jul, url = {https://cer.org.za/wp-content/uploads/2018/07/Annexure-F-CER-Submissions-Draft-GHG-Reporting-Regs-7-7-16.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }