Author: Dustin Lawrence – Low Carbon Engineer at GCX Carbon & Energy
The release of the National Greenhouse Gas Reporting Regulations (NGER) earlier this year was intended to introduce a single national GHG reporting system that would enable the implementation of the long mooted Carbon Tax. In addition to this, the reporting system is part of South Africa’s Intended Nationally Determined Contribution under the Paris Climate Accord.
But do you know how to report and if you need to report? This guide aims to at least put you on the right track.
Firstly do you need to report?
This depends on two main factors, namely the type of operations conducted at your company/facilities and the size of the operations. The regulations contain a full list of operations/activities and the thresholds for reporting. These activities are based on IPCC (Intergovernmental Panel on Climate Change) guidance. A full list of operations and thresholds are included as Annexure 1 to the regulations.
Important to note is that the thresholds are based on a data provider level (Group/company level). For example:
- A company operates 1 boiler at one of their facilities that has a design capacity of 2MW and another boiler at another facility that has a design capacity of 9MW. The NGER state that the threshold for this activity is 10MW and thus the company must report emissions from these boilers (11MW total Capacity).
What activities are covered by the regulations?
Companies are only required to report on emissions that occur directly on sites under their operational control. The following sources need to be reported on should they exceed the threshold:
- Fuel Combustion Activities – This includes any activities that combust fuel to generate energy. Included in this category is any domestic transportation other than onsite or offsite road transportation
- Fugitive emissions from fuel extraction – Includes fugitive emissions from coal mining and oil and gas operations
- Industrial Process Emissions – This covers any GHG emissions that are emitted as a result of industrial processes
- Waste Treatment – This includes Solid Waste treatment/landfilling as well as waste water treatment
When do I need to report?
The regulations state that Data Providers are required to report by the 31st of March each year. Again it is important to note that data providers were also required to have been registered on the National Atmospheric Emissions Inventory System (NAEIS) within 30 days of the regulations coming into effect (3 April 2017). So if you haven’t registered yet, you should get on it.
What period should I report on?
The reporting period stated in the regulation is a standard 12 month Calendar year (January to December). This may mean that some companies already reporting GHG emissions for periods other than this will need to change either their data collection methods or collect data monthly.
How do I calculate my emissions?
The regulations come with a companion guide called the “Technical Guidelines for Monitoring, Reporting and Verification of Greenhouse Gas Emissions by Industry”. The guidelines closely follow the IPCC guidance and detail how to calculate emissions. The guidelines also provide country specific emission factors to ensure standardisation in reporting.
How to report?
While the regulations and guidance document provides a reporting template for data providers, the regulations state that emissions are to be reported on NAEIS. NAEIS was the National Environmental Department’s online portal for reporting emissions other than GHG’s and was set up initially to deal with air quality type emissions. At the time of writing it was not known if the GHG module of NAEIS is fully operational.
Why do I need to Report?
In the global context, it will allow South Africa to accurately quantify its GHG emissions and plot a way forward to reduce emissions in line with the expected outcomes of the Paris Climate Accord. Secondly, it is law, and companies will be liable for a fine of up to R10 million should they not comply with the regulations.
GCX has extensive experience in carbon reporting under GHG Protocol, CDP and other standards. Our team is ready to assist you with any queries you may have on this subject.
- Regulations: https://www.environment.gov.za/sites/default/files/legislations/nemaqa39of2004_nationalgreenhousegasemissionreporting_gn40762.pdf
- Technical Guidelines: https://www.environment.gov.za/sites/default/files/legislations/technicalguidelinesformrvofemissionsbyindustry.pdf
- IPCC Guidance: http://www.ipcc-nggip.iges.or.jp/public/2006gl/