WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY

The Centre for Environmental Rights (CER) submitted a response to the Department of Environmental Affairs regarding the Climate Change Mitigation Policies and Measures (PAMs) methodology. While supporting the study's objectives, CER argues that the proposed scope of greenhouse gases is too narrow, excluding several gases listed in the 2014 Biennial Update Report (HFCs, PFCs, and SF6) as well as critical pollutants like black carbon and HCFCs. CER recommends extending the scope of the analysis to ensure accuracy and reflect national priority air pollutants.

• The Centre for Environmental Rights (CER) supports the objectives and the proposed approach and methodology of the PAMs study, which aims to estimate the individual and aggregate effects of existing, enhanced, and potential climate change mitigation policies and measures as outlined in the National Climate Change Response White Paper (NCCRWP).
• CER identifies a discrepancy in the scope of greenhouse gases (GHGs) included in the PAMs analysis. While the Briefing Document claims to limit emissions to those in South Africa’s National GHG Inventory from the 2014 first Biennial Update Report to the UNFCCC, it appears to restrict the analysis to only carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). CER notes that the Biennial Report actually includes hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulphur hexafluoride (SF6).
• CER argues that the PAMs analysis excludes two critical pollutants with significant climate impacts: black carbon and hydrochlorofluorocarbons (HCFCs). The CER highlights that reducing black carbon emissions could provide a near-term opportunity to delay global warming, and notes that HCFCs have a high global warming potential and are subject to a phase-out under the Montreal Protocol.
• CER strongly recommends that the scope of GHGs considered in the PAMs analysis be extended and revised, citing the recent declaration of GHGs as national priority air pollutants and the publication of the National GHG Emission Reporting Regulations.

APA

Centre for Environmental Rights (2017). WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY. https://cer.org.za/wp-content/uploads/2018/04/CER-PAMs-Approach-Methodology-Submission-18-August-2017.pdf?x21779

Chicago

Centre for Environmental Rights. WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY. 2017. https://cer.org.za/wp-content/uploads/2018/04/CER-PAMs-Approach-Methodology-Submission-18-August-2017.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY |date=18 August 2017 |url=https://cer.org.za/wp-content/uploads/2018/04/CER-PAMs-Approach-Methodology-Submission-18-August-2017.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017written, author = {{Centre for Environmental Rights}}, title = {{WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = aug, url = {https://cer.org.za/wp-content/uploads/2018/04/CER-PAMs-Approach-Methodology-Submission-18-August-2017.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }