Comments on the National Pollution Prevention Plans Regulations and the Declaration of Greenhouse Gases as Priority Air Pollutants Gazetted by the Minister of Environmental Affairs in January 2016

The ERC welcomes the introduction of a requirement for pollution prevention plans for large emitters, and the concomitant declaration of greenhouse gases (GHGs) as priority air pollutants, by the South African government. Identifying GHG as priority pollutants to be controlled, and requiring the reporting and implementation of mitigation measures, are essential elements of climate change policy. The following comments are offered as suggested technical improvements, as well as raising some further questions for consideration regarding the relationship between overall climate mitigation policy and the measures proposed in these regulations.