Currently, the Ministry of Natural Resources and Environment (MNRE) is developing a draft decision on the issuance of a list of sectors and facilities that emit greenhouse gases which must conduct updated greenhouse gas inventory and gather opinions from affected parties.
Livestock facilities are included in the list of facilities that must conduct greenhouse gas inventory. Illustrative image.
The draft regulation specifies the list of sectors and facilities that emit greenhouse gases which must conduct inventory, including sectors related to industry and trade, transportation, construction, natural resources and environment, agriculture, and rural development. The document is expected to have an impact on businesses included in the mentioned sectors.
For the proposed draft, the Vietnam Chamber of Commerce and Industry (VCCI) provided feedback stating that Appendix IV of the Draft on the List of Construction Sector Inventory Facilities stipulates that hospitals are among the facilities that require inventory.
VCCI considers that this regulation is not appropriate because Appendix I on the classification of construction works under Decree 46/2015/ND-CP stipulates that hospitals belong to the category of healthcare works, not commercial buildings.
The construction sector includes 140 facilities (Appendix IV) comprising cement production enterprises and commercial buildings with an annual energy consumption of 1,000 TOE or more, an increase of 36 facilities compared to 2022.
According to the opinions of relevant agencies of the Ministry of Construction, the list in the construction sector does not include apartment buildings, hospitals, and schools since the operation of these types of buildings is not under the management of the construction sector, and the potential greenhouse gas emissions reduction of these buildings is relatively small compared to the total greenhouse gas emissions of the building sector.
Similarly, Appendix III of the Draft on the List of Transport Sector Inventory Facilities includes passenger transport businesses. VCCI also believes that this regulation is not appropriate because businesses in the passenger transport sector are not among the cases that are required to conduct greenhouse gas inventory according to Decree 06/2022.
Therefore, VCCI proposes that the drafting agency review the facilities in the List to ensure compliance with the criteria specified in Article 6 of Decree 06/2022.
Notably, VCCI finds that the addition of livestock farms to the forecasted list is not appropriate.
Explaining this issue, the drafting agency believes that these facilities have emissions of 3,000 tons of CO2 or more.
However, VCCI suggests that the MNRE reconsider that Decree 06/2022 does not include these businesses among the cases requiring greenhouse gas inventory. The addition of these businesses to the list means that they will have to comply with the obligations to conduct inventory and reduce emissions according to Decree 06/2022.
According to feedback from businesses, many livestock facilities are currently facing significant operating costs due to the impacts of the COVID-19 pandemic and requirements to relocate livestock farms to meet environmental protection requirements. This regulation will immediately impose an additional burden on businesses during this time.
According to the proposed draft of the MNRE, the total number of facilities included in the updated greenhouse gas inventory list is 2,893 facilities, an increase of 981 facilities, equivalent to a 51.3% increase compared to 2022, estimated to account for about 34.5% of the national greenhouse gas emissions.
These are facilities with high greenhouse gas emissions in all sectors and areas that need to be strictly managed in terms of greenhouse gas emissions. From 2025, these facilities will have to submit the results of greenhouse gas inventory to specialized agencies under the People’s Committee for review.
