Comments regarding the declaration of greenhouse gases as priority air pollutants

The Centre for Environmental Rights, representing several environmental justice organisations and community groups, submitted comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases (GHGs) as priority air pollutants. The submission specifically argues that natural ecosystems should be excluded from the requirement to submit pollution prevention plans.

• The Centre for Environmental Rights argues that the Declaration should be amended to explicitly exclude natural ecosystems from its application. This is because natural areas such as forests, grasslands, and wetlands are not 'land use activities' and typically function as carbon dioxide equivalent (CO2eq) sinks rather than net emitters when maintained in a natural state.
• Under Regulation 3 and Annexure 1 of the Declaration, any person conducting an activity that emits greenhouse gases declared as priority air pollutants in excess of 0.1 Megatonnes (109kg) or more annually (measured as CO2-eq) is required to submit a pollution prevention plan.
• The submission highlights the ecological importance of natural systems, noting that established forests are among the largest CO2eq sinks of all biomes, absorbing 2.4 billion metric tons (Pg) of carbon per year.

APA

Centre for Environmental Rights (2014). Comments regarding the declaration of greenhouse gases as priority air pollutants. https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-draft-declaration-of-GHGs-as-priority-pollutants_10-April-2014_final.pdf?x21779

Chicago

Centre for Environmental Rights. Comments regarding the declaration of greenhouse gases as priority air pollutants. 2014. https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-draft-declaration-of-GHGs-as-priority-pollutants_10-April-2014_final.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Comments regarding the declaration of greenhouse gases as priority air pollutants |date=10 April 2014 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-draft-declaration-of-GHGs-as-priority-pollutants_10-April-2014_final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2014comments, author = {{Centre for Environmental Rights}}, title = {{Comments regarding the declaration of greenhouse gases as priority air pollutants}}, publisher = {Centre for Environmental Rights}, year = {2014}, month = apr, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-draft-declaration-of-GHGs-as-priority-pollutants_10-April-2014_final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }