Comments on the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 21 February 2014 regarding the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. The submission primarily argues that the draft regulations fail to ensure adequate public access to atmospheric emission data and provides recommendations to align the regulations with constitutional rights to information and a healthy environment.

• The CER argues that the period provided for public comment on the Draft NAEIS Regulations was unreasonable and procedurally unfair, noting that stakeholders were only notified of the 21 February 2014 deadline during a workshop on 6 February 2014.
• The CER criticizes Draft Regulation 11 for failing to define "confidential information," which they claim creates a false impression that all emission data may be confidential and allows industries to avoid disclosure.
• To address confidentiality concerns, the CER suggests adopting a model similar to the United States Environmental Protection Agency (EPA), where the default is public access and the submitter must provide upfront, detailed substantiation for any claims of Confidential Business Information (CBI).
• The CER recommends deleting Draft Regulation 12(1)(a) regarding "unfair competition," arguing it is redundant because the Promotion of Access to Information Act (PAIA) already protects the commercial interests of third parties.
• The CER proposes rewording Draft Regulation 12 to establish that placing NAEIS data and information in the public domain should be the default position, rather than a discretionary action by the relevant authority.
• The submission asserts that automatic public access to emission data is necessary to fulfill constitutional rights to a healthy environment and access to information, and to reduce the administrative burden of processing PAIA requests.

APA

Centre for Environmental Rights (2014). Comments on the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-NAEIS-Reporting-Regulations_21-Feb-2014-....pdf?x21779

Chicago

Centre for Environmental Rights. Comments on the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. 2014. https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-NAEIS-Reporting-Regulations_21-Feb-2014-....pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Comments on the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations |date=21 February 2014 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-NAEIS-Reporting-Regulations_21-Feb-2014-....pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2014comments, author = {{Centre for Environmental Rights}}, title = {{Comments on the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations}}, publisher = {Centre for Environmental Rights}, year = {2014}, month = feb, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-submissions-on-NAEIS-Reporting-Regulations_21-Feb-2014-....pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }