Emissions targets welcome, but soft on consequences
• Report from environment department report is vague on penalties
Industry says the recently published draft sectoral emission targets (SETS) report lacks a clear plan for accountability and consequences if targets are missed.
The department of forestry, fisheries & the environment (DFFE) report was recently released for public comment.
These shortcomings aside, industry experts have broadly welcomed the draft as another step in mapping out how SA will reduce greenhouse gas (GHG) emissions to ensure it achieves its global climate change mitigation commitments.
The draft SETS are expected to result in overall reductions of 27-million tonnes of carbon dioxide equivalent emissions by 2030 compared with a business-as-usual scenario.
The largest share of reductions will come from cutting electricity sector emissions from about 196-million tonnes of carbon dioxide equivalent in 2022 to 125-million tonnes by 2030. The energy sector is responsible for 78% of SA’s total GHG emissions, and electricity alone for about 70% of GHG emissions.
The SETs report details the proposed emissions allocation targets, or emissions limits, that have to be adopted and implemented by government departments that oversee certain economic sectors such as the energy sector.
The SETs are meant to support SA in implementing its nationally determined contribution under the Paris Agreement. SA’s most recent undertaking aims to reduce emissions to between 350-million and 420million tonnes of carbon dioxide equivalent by 2030 — about 20%-33% less than emissions at present.
“The importance of SETs is that they allocate emission targets to policy sectors, thereby ensuring that climate change mitigation is mainstreamed in overall government planning, particularly in those sectors whose policy development and implementation has implications for climate change and the country’s objectives to transition to a low-carbon economy and society,” said Peter Mbelengwa, DFFE head of communication.
He said the SETs were one of three “mitigation response policy tools” that formed part of the overall national climate change mitigation system.
The Climate Change Bill spells out that the policy tools include SETs, carbon budgets and GHG mitigation plans.
The bill aims to frame a comprehensive national climate change response, and was passed by parliament at the end
of April and is waiting to be signed into law by President Cyril Ramaphosa.
Under the draft SETs, said Mbelengwa, contributions from carbon budgets have been allocated as part of the SETs attributable to the DFFE.
SEVEN SECTORS
“The carbon budgets, along with other SETs allocated in other policy sectors, when assessing the overall emissions reduction impacts, must ensure that our national emissions profile is within our climate change mitigation targets as required by the Climate Change Bill,” he said.
The SETs are allocated across seven sectors which are overseen by seven government departments. The sectors are agriculture, industry, energy (overseen by the department of mineral resources & energy, or
DMRE), mining (overseen by the DFFE and DMRE), human settlements (departments of human settlements and water & sanitation), transport (department of transport and the DFFE).
According to the draft SETs document, the targets will be assigned to the ministers of these departments, who will be responsible for implementation. Progress will be monitored annually and a final monitoring and evaluation of the SET will take place at the end of a fiveyear period.
Happy Khambule, head of energy and the environment for Business Unity SA (Busa), said SETs could prove to be a hurdle to economic growth. “If the economy starts growing, as we need it to, there is the risk that these sectoral targets may constrain certain sectors in terms of growth.”
The approach taken with these draft SETs, said Khambule, did not allow for a possible upside to economic growth.
The SETs, said James Reeler, senior manager for climate action at the WWF SA, put the onus on the government’s linefunction departments to align with the nationally determined contribution by requiring departments to provide direction on what is needed to meet the prescribed SETs.
“Up until now the only government department that has had any real focus on climate change mitigation and adaptation has been DFFE.”
This means departments such as the DMRE have had no direct responsibility in terms of climate change mitigation and meeting SA’s nationally determined contribution. Both the draft SETs and the bill fail to put in place meaningful consequences for government departments or companies — in the case of carbon budgets — that fail to meet mitigation obligations.
“For government line ministries, the repercussions are fairly vague. They must meet the target, but if they don’t then the consequences are the same as when departments fail to deliver on any of their targets. There are no significant implications other than possibly budgetary ones, which is not a sufficient punitive measure,” said Reeler.
For SA, the elephant in the room is the energy sector.
According to Reeler it was concerning that the 2023 draft version of the Integrated Resource Plan (IRP) had lesser ambitions in terms of renewable energy and emissions reduction than the IRP 2019, which was used in indicating SETs for the energy sector.
“The approach DFFE has used for the SETs is to ask the sectors what they have planned and then see how that fits in [with the overall] SETs,” he said.
BUY-IN
But this was not necessarily the wrong approach, said Andrew Gilder, a director at specialist climate change legal consultancy Climate Legal, which advised government on the drafting of the bill.
For the SETs to work, he said, the DFFE needed buy-in from other line departments. The way the draft SETs report does this is to provide a “relatively soft landing” for departmental and ministerial action. By using the IRP, which is compiled by the DMRE, as the basis for setting SETs for the energy sector, for example, the DFFE was not reaching beyond what the DMRE itself has already indicated can be achieved in that sector.
“The DFFE is clearly trying to put itself in a position where it is not in direct opposition to other departments,” Gilder said.
The problem, said Reeler, was when departments were not sufficiently ambitious in terms of decarbonisation, or when they relied on outdated modelling and assumptions.