SUBMISSIONS ON THE OPERATIONALISATION OF THE POST 2020 MITIGATION SYSTEM

The Centre for Environmental Rights (CER) submitted comments to the South African Department of Environmental Affairs (DEA) on June 15, 2018, regarding the operationalisation of the post-2020 mitigation system. The CER advocates for greater transparency in greenhouse gas (GHG) reporting, opposes the use of historical emissions for carbon budgeting, and argues against the inclusion of new coal-fired power stations in national energy plans.

• The CER demands public access to GHG emission reporting data and pollution prevention plans, arguing that reporting must be conducted per facility rather than at an aggregated company level to ensure transparency.
• The CER strongly objects to the DEA using Non-Disclosure Agreements to withhold emission data, citing that in the EU, USA, and Australia, GHG reporting data is generally made available to the public by default.
• Regarding the post-2020 mitigation system, the CER recommends using the low peak plateau decline (PPD) trajectory range to set South Africa's mitigation ambition, noting that current Nationally Determined Contribution (NDC) commitments are "highly insufficient".
• The CER opposes 'grandfathering'—the use of historical emissions to allocate carbon budgets—stating that this approach rewards polluters and contradicts the "polluter pays" principle.
• The CER rejects the proposal to link carbon taxes to carbon budgets, arguing that the tax should apply to all emissions and that separate fines should be used to penalize entities that exceed their carbon budgets.
• The CER opposes flexibility mechanisms such as carbon offsets and carbon trading, asserting that these would render the post-2020 mitigation system ineffective in reducing emissions.
• Referencing an Energy Research Centre (ERC) report, the CER states that the Thabametsi (557MW) and Khanyisa (300MW) coal IPPs would increase GHG emissions by 205.7Mt CO2eq over 30 years and cost South Africa an additional R19.68 billion compared to a least-cost energy system.

APA

Centre for Environmental Rights (2018). SUBMISSIONS ON THE OPERATIONALISATION OF THE POST 2020 MITIGATION SYSTEM. https://cer.org.za/wp-content/uploads/2018/07/CER-SUBMISSIONS-DEA-OPERATIONALISATION-OF-POST-2020-MITIGATION-SYSTEM_15-June-2018.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON THE OPERATIONALISATION OF THE POST 2020 MITIGATION SYSTEM. 2018. https://cer.org.za/wp-content/uploads/2018/07/CER-SUBMISSIONS-DEA-OPERATIONALISATION-OF-POST-2020-MITIGATION-SYSTEM_15-June-2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE OPERATIONALISATION OF THE POST 2020 MITIGATION SYSTEM |date=15 June 2018 |url=https://cer.org.za/wp-content/uploads/2018/07/CER-SUBMISSIONS-DEA-OPERATIONALISATION-OF-POST-2020-MITIGATION-SYSTEM_15-June-2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON THE OPERATIONALISATION OF THE POST 2020 MITIGATION SYSTEM}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = jun, url = {https://cer.org.za/wp-content/uploads/2018/07/CER-SUBMISSIONS-DEA-OPERATIONALISATION-OF-POST-2020-MITIGATION-SYSTEM_15-June-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }