Some comments on the SA carbon budget system proposals (from an EGSA member)


It is encouraging that there is some movement – see below from DEFF, though I hadn’t previously seen (underlined):


“the Department is [also] preparing the carbon budget allocation methodology to be applied for "the mandatory carbon budget system which is anticipated to commence with the second phase of the carbon tax on 1 January 2023.

The methodology will be consulted with stakeholders and finalized within the current financial year, namely before the end of March 2021.”


It is implicit in the Carbon Tax Act – that Carbon Budgets will in effect be voluntary until the second phase of the Carbon Tax from 1 Jan 2023, since there is no provision for imposing penalties for exceeding Carbon Budgets in the first phase of the Carbon Tax (and the Climate Change Bill requires that penalties be applied by way of the Carbon Tax); so now it’s official.


Also: “Please also take note that, once the proposed Climate Change Act becomes effective, Regulations for Carbon Budget and Mitigation Plans will be developed, accompanied by the carbon budget methodology and requirements for content of mitigation plans in preparation for implementation beyond the pilot period transitional arrangement proposed above.”


NOTE: the methodology for setting Carbon Budgets will not set the emissions pathway/trajectory from which they will be derived, and we have not been told how such a benchmark emissions trajectory will be set, nor is there any guarantee that it will improve substantially on what we have in current policy (the PPD Range); logically this would be the same process that sets a ceiling on emissions for the Nationally Determined Contribution (NDC under the Paris Agreement), regarding which Minister Creecy on 1 June indicated a formal process would soon be initiated…



Dear Stakeholder,


Please find a link on the submission of subsequent pollution prevention plans in terms of the National Environment Management: Air Quality Act, 2004 (Act No. 39 of 2004): National Pollution Prevention Plans Regulations as published in Government Gazette No. 40996 of July 2017 and the proposed process to manage carbon budgets for the period 01 January 2021 to 31 December 2022.




Mashudu Mundalamo



Mashudu Mundalamo


Chief Directorate: Climate Change Mitigation

Directorate: Climate Change Mitigation Policy, Regulation and Planning

Department of Environmental Affairs

Private Bag X447, Pretoria, 0001

Environment House, 473 Steve Biko, Arcadia, 0083

Tel: 012 399 9164 Cell: 082 373 9013

Fax: 086 239 0058 E-mail: