Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants & the National Pollution Prevention Plans Regulations

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 8 February 2016 regarding the Draft Declaration of Greenhouse Gases as Priority Pollutants and the Draft National Pollution Prevention Plans (PPP) Regulations. The submission argues for greater alignment between these regulations and South Africa's international commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC), while advocating for increased transparency, public access to data, and more rigorous monitoring and verification of greenhouse gas (GHG) emissions.

• The CER and its clients argue that the Draft Declaration and Draft PPP Regulations must be aligned with South Africa's international obligations, specifically the Paris Agreement and the Intended Nationally Determined Contribution (INDC), to avoid inconsistencies and duplication.
• The submission recommends the unification of data submitted to the National Atmospheric Emission Inventory System (NAEIS) and the data required under the Draft PPP Regulations to improve transparency and verification.
• The CER advocates for public access to pollution prevention plans and annual progress reports via the NAEIS platform, citing constitutional rights to an environment not harmful to health and the right of access to information.
• The submission identifies a lack of clarity regarding the 0.1 megatonnes (Mt) annual GHG emission threshold for submitting a pollution prevention plan, requesting clarification on whether this applies to individual processes or the total emissions of a juristic person across all facilities.
• The CER criticises the definition of 'company' in the Draft PPP Regulations for its reliance on 'carbon budgets', noting that no legislative framework for such budgets currently exists, which could create a compliance loophole.
• The submission proposes that pollution prevention plans should include a specific target GHG emission reduction to be achieved over a five-year period, aligned with the INDC and any allocated carbon budgets.
• The CER recommends that the Minister be granted the power to require additional mitigation measures if a facility fails to reduce emissions according to its plan or if further measures are needed to meet international commitments.

APA

Centre for Environmental Rights (2016). Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants & the National Pollution Prevention Plans Regulations. https://cer.org.za/wp-content/uploads/2016/08/CER-comments-on-the-Declaration-of-GHGs-as-priority-pollutants-the-NPPP-Regulations-_-8-Feb-2016.pdf?x21779

Chicago

Centre for Environmental Rights. Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants & the National Pollution Prevention Plans Regulations. 2016. https://cer.org.za/wp-content/uploads/2016/08/CER-comments-on-the-Declaration-of-GHGs-as-priority-pollutants-the-NPPP-Regulations-_-8-Feb-2016.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants & the National Pollution Prevention Plans Regulations |date=8 February 2016 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-comments-on-the-Declaration-of-GHGs-as-priority-pollutants-the-NPPP-Regulations-_-8-Feb-2016.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2016comments, author = {{Centre for Environmental Rights}}, title = {{Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants \& the National Pollution Prevention Plans Regulations}}, publisher = {Centre for Environmental Rights}, year = {2016}, month = feb, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-comments-on-the-Declaration-of-GHGs-as-priority-pollutants-the-NPPP-Regulations-_-8-Feb-2016.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }