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Additional comments to the declaration of greenhouse gases as priority pollutants

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The Centre for Environmental Rights submitted additional comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases as priority pollutants, specifically requesting clearer distinctions in the classification of land use and land use change.

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  • The Centre for Environmental Rights argues that Annexure 1 of the Declaration fails to differentiate between 'land use' and 'land use change', and does not distinguish between timber plantations and natural forests.
  • The Centre proposes that 'Land use' should be a heading encompassing cropland, settlements, plantation forestry, and mining, while 'Land use change' should cover the conversion of agricultural land to settlement or mining, and the loss of natural systems such as grasslands, wetlands, and forests.

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APA
Centre for Environmental Rights (2014). Additional comments to the declaration of greenhouse gases as priority pollutants. https://cer.org.za/wp-content/uploads/2016/08/CER-additional-comments-on-draft-declaration-of-GHGs-as-priority-pollutant-_14-April-2014.pdf?x21779
Chicago
Centre for Environmental Rights. Additional comments to the declaration of greenhouse gases as priority pollutants. 2014. https://cer.org.za/wp-content/uploads/2016/08/CER-additional-comments-on-draft-declaration-of-GHGs-as-priority-pollutant-_14-April-2014.pdf?x21779.
Wikipedia
{{cite press release |author=Centre for Environmental Rights |title=Additional comments to the declaration of greenhouse gases as priority pollutants |date=14 April 2014 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-additional-comments-on-draft-declaration-of-GHGs-as-priority-pollutant-_14-April-2014.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{centreforenvironmentalrights2014additional, author = {{Centre for Environmental Rights}}, title = {{Additional comments to the declaration of greenhouse gases as priority pollutants}}, publisher = {Centre for Environmental Rights}, year = {2014}, month = apr, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-additional-comments-on-draft-declaration-of-GHGs-as-priority-pollutant-_14-April-2014.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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