4. Greenhouse Gas (GHG)

4.1.     DECLARATION OF GREENHOUSE GASES AS PRIORITY AIR POLLUTANTS 

  •  The Declaration was published on 21 July 2017

On 21 July 2017, the Minister of Environmental Affairs declared the following greenhouse gases as priority air pollutants:

  • Carbon dioxide (CO2)
  • Methane (CH44)
  • Nitrous oxide (N2O)
  • Hydrofluorocarbons (HFCs)
  • Perfluorocarbons (PFCs)
  • Sulphur hexafluoride (SF6)

A person conducting a production process set out in Annexure A to the Government Notice which involves emission of greenhouse gases more than 0,1 Megatonnes (Mt) annually, reported as carbon dioxide equivalents (CO2-eq), and/or if so directed by the Minister, is required to submit a pollution prevention plan (PPP) to the Minister for approval. PPP must be prepared in accordance with the National Pollution Prevention Plans Regulations 2017 referred to below.

The production processes listed in Annexure A include, amongst others, coal mining, cement production, carbon black production, iron and steel production and ferro-alloys production.

4.2.     NATIONAL POLLUTION PREVENTION PLANS REGULATIONS, 2017

  • To prescribe the requirements for PPPs regarding greenhouse gases declared as priority air pollutants (above mentioned).
  • The first PPP must be submitted to the Minister for approval within five months from the date of promulgation of the Regulations (i.e. on or before 21 December 2017).
  • ITTCC is planning a workshop for members to outline all the relevant GHG Regulations.

Also on 21 July 2017, the Minister published the National Pollution Prevention Plans Regulations 2017. The purpose of the Regulations is to prescribe the requirements for PPPs regarding greenhouse gases declared as priority air pollutants (above mentioned).

In terms of the Regulations, a first PPP must cover the period from the date of promulgation of the Regulations up to 31 December 2020, and the subsequent plan must cover periods of five calendar years each. The first PPP must be submitted to the Minister for approval within five months from the date of promulgation of the Regulations (i.e. on or before 21 December 2017).

The ITTCC is exploring the possibility of an extension to this date. The ITTCC is also planning a workshop for members to outline all the relevant GHG Regulations and reporting requirements, including processes, timing and requirements. We will keep members informed.

 

4.3.   GHG Reporting Regulations

  • The National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004): National Greenhouse Gas Emission Reporting Regulations were gazetted on 3 April 2017.
  • The DEA has granted an extension of the registration period by 30 days.
  • A meeting has been agreed with the DEA to discuss the potential double reporting of greenhouse gases.

The National Environmental Management: Air Quality Act, 2004 (Act No. 39 of 2004): National Greenhouse Gas Emission Reporting Regulations were gazetted on 3 April 2017.

The technical guidelines for measurement, reporting and verification (MRV) of emissions by industry are still a work in progress. BUSA hosted a workshop with the Department on 17 July 2017 to discuss the concerns of business, which still had not been addressed in the version published on the DEA’s website. It seems that in the movement of personnel at the DEA, the comments from business were misplaced and comments would therefore be submitted again.

There remain outstanding concerns regarding the regulations, due the delay of the publication of the Notice/s extending the registration period; and the exclusion of the Waste sector. The guidelines for registration and reporting are also still awaited.

A meeting is being arranged to discuss issues at a policy level with the Deputy Director General (DDG) in August.

 

4.4.   GHG Pathways

  • The initial report has been issued for comments by 10 August 2017.

DNA Economics has been appointed to undertake the development of greenhouse gas (GHG) pathways. The aim of this work is to develop three pathways for South Africa – without measures (WOM), with existing measures (WEM) and with additional measures (WAM).

The initial report has been issued for comment. The report analyses projected pathways for the different sectors until 2015. The pathways are based on data from the Mitigation Potential Analysis (MPA) and data in the public domain.

Members are strongly urged to critically assess both the data and assumptions used for their sectors; comments must be submitted by 10 August 2017.