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GREENHOUSE GAS INVENTORY – DRAFT DECREE ON MITIGATION OF GREENHOUSE GAS EMISSIONS AND PROTECTION OF OZONE LAYER

On July 24, 2020, the Prime Minister has approved Vietnam’s Nationally Determined Contribution (NDC) updated in 2020, which aims to reduce total greenhouse gas emissions (GHG) by 9% toward 2030 compared to business as usual (BAU) with domestic resources and 27% with international support.

Currently, the Ministry of Natural Resources and Environment is developing a Draft Decree on mitigation of greenhouse gas (GHG) emissions and protection of ozone layer in order to regulate details of Article 91, 92 and 139 of the Law on Environmental Protection in 2020.

Subjects of application under the Draft Decree include agencies, organizations, individuals, production facilities and businesses:

  • Involve in greenhouse gas (GHG) emissions activity, emission mitigation and domestic absorption of GHG.
  • Participate in the development of the domestic carbon market; production, import, export and consumption of substances that deplet the ozone and causes the GHG, and all are controlled under the Montreal Protocol on ozone depleting substances.

(Designed by vectorjuic/ Freepik)

Some notable points of the Draft Decree:

  1. Set targets and routes for mitigation of greenhouse gas emissions for 02 phases: phase 1 from now until the end of 2025 and phase 2 from 2026 to the end of 2030. Detailed as below:
  • Phase 1: implement the inventory of greenhouse gas, formulating and implementing a plan to mitigate greenhouse gas emissions.
  • Phase 2: implement the mitigation of greenhouse gas emissions according to the target of mitigating greenhouse gas emissions on the basis of allocated quotas. In case the greenhouse gas emissions facility exceeds the quota or does not use up the allocated quota, it may be exchanged, traded on the domestic carbon market.
  1. Set criteria for determining the group of facilities that must carry out the inventory of greenhouse gas: Facilities with annual greenhouse gas emissions of 3,000 tons of CO2 equivalent or higher or in the following cases:
  • Thermal power station and industrial production facilities with total annual energy consumption of 1,000 tons of oil equivalent (TOE) or more;
  • Cow breeding facilities with the head count of 500 or more; pig breeding facilities with the annual head count exported from 3,000 or more;
  • Trucking companies with the total annual fuel consumption of 1,000 TOE or more;
  • Commercial buildings with the total annual energy consumption of 1,000 TOE or more;
  • Solid waste disposal facilities with the annual operating capacity of 65,000 tons or more.
  1. According to the representative of the Drafting Board, in phase 1 from now to 2025, the enterprise will not take any responsibility other than to report the results of greenhouse gas inventory and inventory activities will be supported by government’s agencies. The government will use national budget for environmental supports to help enterprises in phase 1 of funding for the development of greenhouse gas inventory reports, hiring appraisal consultants.

 

Some comments from representatives of Associations and Businesses:

No.

Comments

1

The representative of Vietnam Steel Association said that this is a new field for the business community, so it is necessary to have appropriate route and feasible proposals. He recommended that there should be appropriate thresholds for the peculiarities of each different industry and transparent and fair mechanisms for all businesses instead of applying the same standards. Especially for the steel industry – the foundation industry, which plays an important role in the economy, but also the one with the emissions must control. According to regulations from 3,000 tons of COemissions must be declared, all enterprises in the steel industry must declare. 

Source: https://thoibaonganhang.vn/giam-phat-thai-khi-nha-kinh-ho-tro-de-doanh-nghiep-thich-ung-116184.html

2

Representative of Vietnam Electricity (EVN), Mr. Tran Tuan Anh said that the development of a plan to reduce greenhouse gas emissions from the facilities will not be able to assess all methods of reducing greenhouse gas emissions in different fields. For example, in the field of energy, reducing greenhouse gas emissions does not come from reducing emissions directly from the facility but indirectly through energy planning, economical use of electricity, promoting renewable energy projects, etc.

Besides, for thermal power station, from the beginning of construction, it has taken into account plans to reduce greenhouse gas emissions, so the development of an annual plan will not be effective.

Source: https://thoibaonganhang.vn/giam-phat-thai-khi-nha-kinh-ho-tro-de-doanh-nghiep-thich-ung-116184.html

3

Representative of Canon Vietnam, Ms. Dao Thi Thu Huyen said that the Draft Decree is not really scientific. Currently, businesses are carrying out a lot of annual statistical reports on energy control of enterprises. Besides, the enterprises also must do five-year target reports on reducing energy use and sending to all relevant authorities.

“So, we have always had data based on how the energy of the business is being used”, Ms. Huyen added: “If we redo the statistics data, then proceed to trading market, this will not bring real value.” 

Source: https://congluan.vn/doanh-nghiep-phai-bao-bao-so-lieu-kiem-ke-khi-nha-kinh-hang-nam-post141856.html

4

Representative of Vietnam Dairy Association, Mr. Tran Quang Trung said that it is incomplete when the Draft Decree regulates that only cow breeding facilities of 500 head count or more must declare the inventory. Mr. Trung wondered on what scientific basis is the number 500 based on? If businesses breed buffaloes, goats, chickens, etc., how much is it regulated to declare?

Source: https://congluan.vn/doanh-nghiep-phai-bao-bao-so-lieu-kiem-ke-khi-nha-kinh-hang-nam-post141856.html

5

Representative of Vietnam Automobile Transport Association, Mr. Nguyen Van Quyen said that it is not reasonable to take the criterion of “consuming 1000 tons of oil or more” must conduct greenhouse gas inventory. Because the transportation industry today has very few centrallized managed models. Enterprises often implement the model of securities and services, so many units do not conduct statistics on the amount of oil consumed annually. Therefore, it is difficult to follow this criterion.

Sourcehttps://congluan.vn/doanh-nghiep-phai-bao-bao-so-lieu-kiem-ke-khi-nha-kinh-hang-nam-post141856.html

 

In order to ensure the reasonableness and feasibility of the Draft Decree, ensuring the rights and interests of associations/ enterprises, the contribution of opinions to the content of the Draft Decree is a necessary and useful information channel.

Accordingly, please kindly help leave your comments via one of the two channels:

  • Channel 1: Direct comments on the website of the Ministry of Natural Resources and Environment, not later than: August 11th, 2021

https://monre.gov.vn/VanBan/Pages/GopYVanBanDuThao.aspx?pID=256

(Photo taken from the website of the Ministry of Natural Resources and Environment, last visited July 15th, 2021)

  • Channel 2: Comments send to the Vietnam Chamber of Commerce and Industry (VCCI). VCCI will summarize to the Drafting Board, no later than August 03rd, 2021.

Please send a letter to the address (can be sent in advance by fax or email):

VCCI Legal Department – No. 9 Dao Duy Anh, Dong Da, Hanoi.

Phone: 024.35770632/024.35742022 – line: 355; Fax: 024.35771459.

Email: xdphapluat@vcci.com.vn/xdphapluat.vcci@gmail.com

Draft download link: http://vibonline.com.vn/wp-content/uploads/2021/07/20210609-Du-thao-Nghi-dinh-ve-Giam-nhe-phat-thai-KNK-va-bao-ve-tang-o-don_Final-1.docx

If you need more information related to GREENHOUSE GAS INVENTORY, please kindly contact ENERTEAM for direct advice and support.

Contact information:

  • Mr.  Quan – Department of Sustainable Development
  • Tel: 028. 3930 2393/ 0389 942 248

 

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