LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted comments on the Draft 8th National Greenhouse Gas Inventory Report (NGHGIR) on 31 August 2022. The submission argues that the draft significantly undercounts methane emissions due to the omission of fugitive emissions from the oil and gas industry, pipeline transport, and abandoned mines, and criticizes the use of outdated global warming potential (GWP) metrics and low emission factors for coal mining.

• The Draft 8th NGHGIR uses a methane global warming potential (GWP) of 21 times that of CO2 based on the 1996 IPCC Second Assessment Report, which the Campaign argues grossly understates the actual impact compared to a 20-year horizon GWP of 84.
• The report fails to estimate fugitive methane emissions from oil and natural gas industries, despite a commitment in the 7th NGHGIR (2017) to include them in the next submission.
• Methane emissions from pipeline transport (Item 1A3ei) have not been estimated, despite a network totaling 2,618 km, including the ROMPCO pipeline from Mozambique to Sasol’s Secunda plant and networks operated by Sasol Gas and PetroSA.
• The Draft 8th NGHGIR has not estimated methane emissions from abandoned mines (IPCC Category 1B1ai2), despite these being identified as necessary in the 7th NGHGIR.
• The emission factors used for coal mining and handling are criticized as being extremely low, with underground mining factors at 1/24th of the IPCC default and surface mining factors set to zero.
• The Campaign expresses concern that the lack of baseline methane estimates occurs while the Gas Master Plan envisions increasing gas usage from 2.6% to 15.7% of South Africa's total energy mix.
• The submission recommends that the Department of Forestry, Fisheries and the Environment increase transparency by making GHG emission reports and pollution prevention plans automatically available online.

APA

Centre for Environmental Rights (2022). LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT. https://cer.org.za/wp-content/uploads/2022/09/Life_After_Coal_Comments_-_Draft_8th_National_Greenhouse_Gas_Inventory_Report_31_August_20221-1.pdf?x21779

Chicago

Centre for Environmental Rights. LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT. 2022. https://cer.org.za/wp-content/uploads/2022/09/Life_After_Coal_Comments_-_Draft_8th_National_Greenhouse_Gas_Inventory_Report_31_August_20221-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT |date=31 August 2022 |url=https://cer.org.za/wp-content/uploads/2022/09/Life_After_Coal_Comments_-_Draft_8th_National_Greenhouse_Gas_Inventory_Report_31_August_20221-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2022life, author = {{Centre for Environmental Rights}}, title = {{LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT}}, publisher = {Centre for Environmental Rights}, year = {2022}, month = aug, url = {https://cer.org.za/wp-content/uploads/2022/09/Life_After_Coal_Comments_-_Draft_8th_National_Greenhouse_Gas_Inventory_Report_31_August_20221-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }