I believe that industry participation is critical in order to ensure that the proposed Carbon Tax legislation for South Africa is relevant and applicable to operations in the South African market place. The revised draft of the Carbon Tax bill issued for public comment in late December 2017, certainly provides greater definition to areas that were rather rudimentary in the earlier draft/s, however industry needs to ensure that the opportunities presented in the legislative process, allowing stakeholder input are utilised to ensure that the enacted bill accurately reflects the realities of industry in SA. This cannot be left to big business organisations alone, as in a lot of cases, their plant operations are vastly different to those of smaller operators.
A simple example is the development of benchmarks for emissions intensity for each industry, against which an individual operation’s performance in terms of emissions intensity will be measured. If we consider the use of boilers for process steam generation, there will be significant differences between the plant at a large operation; say SASOL or Chevron Refinery; versus a smaller food manufacturing plant for a given fuel type. Thus in seeking to access the Performance Allowance rebate included in the legislation mechanism, an operation’s performance must be referenced to an industry benchmark.
It is thus critical that the industry benchmark be accurately determined, and that the operation participate in the processes to determine the benchmarks applicable to their industry. In addition, the operations should seek to develop higher level monitoring and verification procedures to accurately record their emissions from the site. This will ensure that actual performance is accurately evaluated in the assessment of Performance and a rebate can be achieved where it is due for out-performing industry in reducing its emissions.