Priority Areas are areas where ambient air quality standards are or may be exceeded; and specific interventions are needed to improve air quality in the area. Section 18 of the Air Quality Act (NEMAQA) makes provision for the DFFE to declare an area a “Priority Area” for the purposes of better managing air quality.
In 2007, the Highveld Priority Area (HPA) was declared in terms of NEMAQA. And in 2012, the first Air Quality Management Plan (AQMP), identifying contributors to poor air quality; identifying potential management actions; setting targets for air pollutant emissions reductions; and publishing monitored air pollutant emissions data, was published. The HPA AQMP was updated in 2025. And in August 2024, the Regulations for Implementing and Enforcing Priority Area Air Quality Management Plans (PA Regulations), were published. The Regulations contain various measures to “operationalise” the goals and targets of the Priority Area AQMPs.
These measures include the identification of certain stakeholders who need to compile an Emissions Reduction and Management Plan (ERMP) for the main purposes of minimizing, preventing and managing emissions. In this way, the stakeholders can contribute towards emission reduction targets as stipulated in the HA AQMP. Stakeholders include holders of Atmospheric Emissions Licences (AELs).
The PA Regulations specify the content of an EMRP, which should include inter alia:
- Identifying which industrial sector the facility falls into, as identified in the AQMP, and the baseline and targeted emissions, as well as emission reduction plans identified in the AQMP for that sector.
- An inventory of emissions sources and recent graphed emissions trends at the facility.
- Current and planned emissions management and reduction measures.
- An estimation of emissions reductions achievable with the implementation of planned measures; and
- Record keeping, monitoring and evaluation.
For example, the 2025 HPA AQMP identifies the following baseline and target emissions for the industrial sector; and the reduction plans proposed for that sector (those applicable to holders of AELs are highlighted in bold):
Table 1: Emission (kt/a) for each emission reduction target for the Industrial sector (Second Generation Highveld Priority Area Air Quality Management Plan, 2025).
| Emission Target | PM10 | PM2.5 | SO2 | NOx | CO | VOC | NH3 |
| Baseline | 168.8 | 83.7 | 1541.2 | 929.5 | 912.8 | 281.6 | 1.0 |
| 2030 (40% Reduction) | 101.3 | 50.2 | 924.7 | 557.7 | 547.7 | 168.9 | 0.6 |
Table 2: Emission Reduction Plan for Industrial Emissions (Second Generation Highveld Priority Area Air Quality Management Plan, 2025).
| Objective | Key Activities | Responsibility |
| Reduce emissions from industries | Compliance with the MES and other atmospheric emission licence conditions | Identified stakeholders in regulation 3(2)(a) and 3(2)(e) of the Regulations for Implementing and Enforcing Priority Area Air Quality Management Plans, 2024. |
| Assessment of compliance monitoring reports | Identified stakeholders in regulation 3(2)(e): DFFE, Provinces, Metros, Districts and Local municipalities | |
| Development and Implementation of emission reduction plans | Identified stakeholders in regulation 3(2)(a) and 3(2)(b). | |
| Monitor and enforce compliance | Identified stakeholders in regulation 3(2)(e): DFFE, Provinces, Metros, Districts and Local municipalities | |
| Identify opportunities and incentive schemes to support industries to implement air quality improvement initiatives. | Identified stakeholders in regulation 3(2)(e): Department of Trade, Industry and Competition (DTIC), DFFE, Provinces, Metros, Districts and Local municipalities | |
| Establish incentive schemes for energy efficiency improvements and fuel switching that directly reduce air emissions. | Identified stakeholders in regulation 3(2)(e): DTIC, DFFE, Provinces, Metros, Districts and Local municipalities |
The first ERMPs are due for submission to the DFFE for approval by September 2025. And then, annual reporting on a facility’s progress against identified reduction plans and targets, is required from 2026 onwards: the ERMP reporting cycle dovetails with the reporting cycle for the National Atmospheric Emissions Inventory System (NAEIS), being January to June 2026. The DFFE will issue a reporting template to stakeholders, it is expected in the last quarter of 2025.
We attended a very informative workshop held by the DFFE on these ERMPs and the annual reporting needed. We made some notes; and also received the DFFE presentation. The PA Regulations, our workshop notes and the DFFE presentations are available on our website:
If you require any assistance with compiling your facility’s ERMP, and / or annual reporting, please feel free to contact us.
Colleen McCreadie | 021 788 9323 | 083 695 1664 colleen@enviroprac.co.za
Lauren Elston | 021 788 9323 | 071 992 2341 lauren@enviroprac.co.za
