Transcript Implementation of South African Climate change Mitigation Policy by

Hilton Trollip
Energy Research Centre, University of Cape Town
21 February 2017, Cape Town
Meeting: Parliamentary Committee on Environmental Affairs
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Outline
 There has been much research on what is possible
Techno-economics …Peak, Plateau, Decline
 South Africa has made commitments – Nationally Determined
Contribution (NDC)
 Being implemented in terms of UNFCCC Paris Agreement
 GovSA has implementation policy – Climate Change Response
White Paper (CCRWP)




Reporting regulations
Carbon budgets
Carbon tax
…
 There are challenges in implementing policy (which is usual)
 The focus of this presentation is progress, challenges, and
prospects
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What do we mean by mitigation policy ?
UNFCCC DEFINITIONS
 Mitigation measure: - what emitters can theoretcially do
Technologies, processes, and practices that contribute to mitigation, for
example renewable energy technologies, waste minimization processes
and public transport commuting practices.
 Mitigation policy: - what government does to control/ influence
emitters and others than can infleunce mitigation
A course of action taken and/or mandated by a government, to enhance
mitigation.
Examples: …support mechanisms for renewable energy supplies, carbon or energy taxes, and
fuel efficiency standards for automobiles
 Mitigation policy is what government does to make
emitters undertake mitigation measures, and cause
others to make low-emissions interventions
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What CAN government do ?
Government operates within the constitution and is not omnipotent
 Support policies
 Information



Statistics / data systems
Research
Pilots / demonstrations / procurement
 Regulation
 Standards
 Limits
 Economic policies
 Taxes, subsidies, sector plans
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What is GovSA doing
 Climate Change Response White Paper, …NDC
 Peak Plateau Decline (PPD) trajectory range

specified in its NDC for the years 2025 and 2030
 emissions will be in a range between 398 and 614 Mt CO2–eq.
 South Africa intends using 5-year periods of
implementation


the first 2016-2020 to develop and demonstrate the
policies, and;
then the periods 2021-2025 and 2026-2030 for its NDC
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Findings
 There have been significant achievements
 Mainly associated with pro-active preparation for UNFCCC
processes

2009 - Copenhagen commitments


Emissions limit on IRP2020
  Renewable energy Independent Power Producer Programme
2011 - Climate Change Response White Paper (CCRWP) in time for
Durban COP17
 BUT, these processes probably rushed policy development
 Since 2011 policy has got bogged down in implementation
challenges
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Selected Findings
– Emissions Reporting Regulations
 The Climate Change Response Green Paper and the Climate
Change Response White Paper (CCRWP) states that:
 “emissions reporting regulations and data system is the foundation
of the mitigation response”
 “reporting of emissions data will be made mandatory for entities
(companies and installations)’
 facility (equivalent to installation) reporting is common in many
jurisdictions, and made available in the public domain
 According to the CCRWP it was to be operational by 2013
 The reporting regulations aren’t yet operational (February 2017)
 There are concerns over what will be reported when the regulations
come into effect
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Findings - Reporting regulations
From ITTCC report on their website: http://www.ittcc.org.za/projects-2/
“At the meeting between business and the DEA on 24 April 2015
 Business Unity South Africa (BUSA) agreed with the Director General
(DG) that data will be collected at company rather than facility level”
“Meeting organised by BUSA on 20 August2015, to discuss the Carbon
Budget Design and other issues
 “The meeting was held between company CEOs, government and
Eskom on 20 August 2015; The DEA acknowledged that this would be a
learning process, they have not decided how the next five years are
going to work because they do not have the necessary information. The
DEA advised that the reason for this is because they do not have a firm
grip on the baseline for the emissions”
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Selected Findings
– Emissions Reporting Regulations
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Selected Findings
– Emissions Reporting Regulations
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Example – USA EPA facility level reporting
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Example – USA EPA facility level reporting
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Example – USA EPA facility level reporting
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Example – USA EPA facility level reporting
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Example – USA EPA facility level reporting
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Findings - Reporting regulations
From “Guide for
designing Mandatory
Greenhouse Gas
reporting
programmes
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Findings - Reporting regulations
From “Guide for designing Mandatory
Greenhouse Gas reporting
programmes
• We have not identified research or
programme specifications that
systematically attend to these
crucial elements of designing a
complex system
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Reporting regulations & Carbon
Budget Design
 Findings from research related to previous slide
1.
There is frustration on business’s side on lack of clarity and
incompleteness in design of policies such as the reporting
regulations, DEROs, carbon budgets carbon tax.
 There appears to be little disagreement on lack of
technical/quantitative analysis capacity at the DEA
2. Business is now assisting in a “learning by doing mode”
 This DOES place those who are to be regulated in a position
of ‘assisting’ the regulator design the regulatory system.
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Findings - Carbon budgets
 The carbon budgets were first mentioned in the CCRWP
Notably there was no mention of them in the CCRGP or in
the consultation process for the white paper.
 Carbon budgets slated in Climate Change Response White
Paper to be allocated and adopted by 2013
 Carbon budgets not yet operational
 ‘Voluntary carbon budgets’ being implemented
 No public domain information on who and allocations
 Being implemented by emitters in conjunction with DEA


Raises questions of information asymmetry
Raises questions over balanced representation of interests
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Pollution prevention plans
 Being implemented in carbon budgets voluntary
scheme
 Similar concerns as reporting regulations and carbon
budgets
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Findings - general
 With the failure, so far, to implement the core policies
defined in the NCCRWP, it is clear that the two year
time frames outlined in the NCCRWP to implement
these policies was unrealistic.
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Findings - general
 The NCCRWP contains a raft of partially developed
and complex policies with partially developed
understanding and analysis of linkages and
dependencies.
 This presents a significant technical implementation
challenge to an under-capacitated Department of
Environmental Affairs
 This makes the policies vulnerable to pushback by
interests that could be negatively impacted by effective
implementation of policies.
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Findings - general
 Some large decisions (such as adopting carbon budgets in
the NCCRWP) and seemingly small (but potentially
significant) policy decisions (e.g. company level reporting)
are being made by bureaucrats alone, or in conjunction
with interest groups without the benefit of necessary
consultations and/or transparent, published policy analysis
 There is an attempt to design and operationalise policies in
conjunction with interests that these policies seek to
regulate (e.g. carbon budgets) without adequate public
domain policy analysis nor robust design
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Findings - general
 What would appear to be obvious sequencing, has not
been happening such as,
 feasibility analysis and design of policies before adopting
them,
 assessing dependencies and linkages,
 prioritising the reporting regulations and data-system
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Findings - general
 Policies are adopted before feasibility has been
assessed and when their designs are far from complete,
and attempts are made to implement the raft of underdeveloped policies all at once, without the
acknowledged foundation in place.
 As a stark example, it has been found impossible (so
far) to implement the acknowledged foundation
Reporting Regulations policy merely have officially
and formally reported and recorded emissions data
 Voluntary data simply cannot provide the same
functions as official data
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Other government departments
 Inter-governmental cooperation ?
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Intra-government cooperation
The NCCRWP states:
 Under the leadership of the relevant national sector
government department, each significantly emitting
economic sector or sub-sector will be required to formulate
mitigation and lower-carbon development strategies. These
strategies will specify a suite of mitigation programmes and
measures appropriate to that sector or sub-sector.

For e.g. DTI 2016/2017 Industrial Policy Action Plan does not do this
 Last week in parliament reported that DEA has requested
DOE to include carbon budgets in IRP
 Lack of support for NCCRWP
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Opportunities provided by COP21
 “Each Party shall prepare, communicate and maintain
successive nationally determined contributions that it
intends to achieve.
 “Parties shall pursue domestic mitigation measures, with
the aim of achieving the objectives of such contributions
 “Each Party shall regularly provide the following
information… Information necessary to track progress
made in implementing and achieving its nationally
determined contribution
 “Information submitted by each Party under paragraphs 7
and 9 of this Article shall undergo a technical expert
review
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Conclusions
 Pro-active interactions with UNFCCC processes
associated with progress until 2011
Since then
 Many challenges with implementation: policy design,
technical, capacity, political economy
 Paris agreement provides windows of opportunities to
progress mitigation implementation ?
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Findings: content of reporting
regulations
 Industry Task Team on climate change (ITCC)
 Reports that decision to report at company level made at
meeting between BUSA and DEA
 This is despite public facility level reporting being the
foundation of mitigation policy in many marketeconomy democracies
 This is despite there being no public domain research or
policy analysis on this key issue
 It might considerable limit the performance of the
mitigation policy – this is an unknown
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Thank you !
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