WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT

The Centre for Environmental Rights (CER) provides written submissions on the March 2018 Final Draft Report of Climate Change Mitigation Policies and Measures (PAMs). The CER supports the examination of policy effectiveness but identifies several gaps, including the need for better alignment between various government climate projects, the exclusion of certain greenhouse gases and externalities in socio-economic analyses, and a lack of rationale for prioritizing coal-to-liquid production through 2050. The CER emphasizes that the report's findings—specifically regarding the electricity sector as the key to decarbonization—should inform the revision of the Integrated Resource Plan for Electricity (IRP 2010).

• The CER requests clarity on how the PAMs project aligns with other government initiatives, such as the Mitigation Potential Analysis (MPA) and the GHG Pathways Project, noting that the overall strategy to coordinate these studies remains unclear.
• The CER argues that the PAMs project must be aligned with energy policy decisions, specifically criticizing the outdated IRP 2010 and the appointment of Thabametsi and Khanyisa as preferred bidders for coal-fired power. A study by the Energy Research Centre (ERC) suggests these two plants would increase GHG emissions by 155-177 million tonnes of CO2 equivalent by 2050 and could make planned mitigation measures redundant.
• While the Draft Report expanded its GHG delineation to include CO2, CH4, N2O, HFCs, and PFCs, the CER notes that black carbon and hydrochlorofluorocarbons (HCFCs) are still excluded, as are emissions from underground coal fires.
• The CER criticizes the socio-economic analysis for being too narrow and failing to account for negative externalities such as water and air pollution. They cite a 2017 groundWork study linking air pollution from Eskom's coal-fired stations to 2,239 attributable deaths annually, costing South Africa over USD 2.3 billion per year.
• The CER disputes the Draft Report's assumption that coal-to-liquid (CTL) production—specifically Sasol's Secunda plant—should be prioritized through 2050, arguing there is no rational basis for the world's largest point-source emitter of CO2 to continue unabated.
• The CER identifies several missing or unclear elements in the assessment of individual policies, including the lack of socio-economic benefits in the Green Transport Strategy, uncertainty regarding rebound effects in the National Energy Efficiency Strategy, and the omission of various carbon-sink policies in the AFOLU sector.
• The Draft Report concludes that the electricity sector is the primary driver for decarbonizing the South African economy, primarily through switching from coal to renewables and gas. The CER asserts these findings should be used to revise the IRP 2010.

APA

Centre for Environmental Rights (2018). WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT. https://cer.org.za/wp-content/uploads/2018/04/CER-Comments-on-PAMs-Draft-Report-6-April-2018.pdf?x21779

Chicago

Centre for Environmental Rights. WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT. 2018. https://cer.org.za/wp-content/uploads/2018/04/CER-Comments-on-PAMs-Draft-Report-6-April-2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT |date=6 April 2018 |url=https://cer.org.za/wp-content/uploads/2018/04/CER-Comments-on-PAMs-Draft-Report-6-April-2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018written, author = {{Centre for Environmental Rights}}, title = {{WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = apr, url = {https://cer.org.za/wp-content/uploads/2018/04/CER-Comments-on-PAMs-Draft-Report-6-April-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }