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 the post-2020 mitigation system. The CER advocates for the use of the 'low peak plateau decline (PPD) trajectory' for mitigation ambition and strongly opposes the use of 'grandfathering' (historical emissions) to set carbon budgets, as it rewards polluters. The document emphasizes the necessity of public access to facility-level greenhouse gas (GHG) emission data, citing precedents in the EU, USA, and Australia, and objects to the DEA's use of Non-Disclosure Agreements to keep such data confidential. Regarding the carbon tax, the CER argues it should remain a distinct instrument from carbon budgets and should apply to all emissions rather than only those exceeding budgets. Additionally, the CER highlights an Energy Research Centre (ERC) report finding that proposed coal-fired power stations (Thabametsi and Khanyisa) are not least-cost, are unnecessary for demand, and would increase GHG emissions by 205.7Mt CO2eq over 30 years.

• The CER argues that the 'low peak plateau decline (PPD) trajectory range' should be the basis for South Africa's post-2020 mitigation system to align with the 1.5°C target, noting that current NDC commitments are 'highly insufficient'.
• The CER opposes 'grandfathering'—the use of historical emissions to allocate carbon budgets—stating that it 'rewards polluters' and contradicts the 'polluter pays' principle.
• The CER demands public access to GHG emission reporting data at the facility level, rejecting the DEA's claim that such information is commercially sensitive. It cites the EU, USA, and Australia as jurisdictions where such data is publicly available by default.

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} }