After a summary presentation by the lead negotiator of South Africa's delegation to the upcoming 21st session of the Conference of Parties (COP21) in Paris, the Committee heard a large number of submissions, from a diverse array of interested parties, on the draft of South Africa's Intended Nationally Determined Contribution (INDC) to be presented in Paris.
South Africa hosted COP17 in Durban in 2011, at which the Durban Platform for Enhanced Action, intended to place both developed and developing countries under legal obligations to reduce their greenhouse gas emissions, had been launched. COP19 in Warsaw had given birth to INDCs; national plans detailing how a country intended to go about reducing its emissions. The key elements of the South African INDC were that the agreement should:
- be multilateral, rules-based, and legally binding, to keep the temperature increase below 2°C.
- support a transition to low emissions and climate resilience
- give equal priority to mitigation and adaptation measures
- be inclusive, fair and effective.
It was unanimously agreed that climate change was a problem that threatened all of humanity, but that developed countries, and particularly Africa, were the most vulnerable. All the submissions expressed the view that renewable energy needed to be pursued, and nearly all considered the inclusion of nuclear power as a 'green option' in the INDC to be problematic. The expansion of coal power and oil and gas exploration were incompatible with reduction of greenhouse gas emissions. Some submissions pointed carbon offsets as a way of lowering the impact of industry on the environment, but several questioned the efficacy of market mechanisms. The wisdom of making some emissions commitments contingent on international climate finance was the subject of some disagreement.
The global carbon budget until 2050 of about 600 gigatons of CO2 was extensively discussed, and there was some disagreement as to what a fair share of this was for South Africa, due to our status as a developing country on the one hand, and our relatively large emissions volume. Estimates ranged from 7 to 22 gigatons. Also discussed was South Africa's projected peak-plateau-decline trajectory, according to which emissions would be allowed to increase until 2025, after which they would plateau and then decline until 2050.
Some submissions found the mitigation strategies in the INDC to be insufficient, although most were satisfied with the adaptation strategies. Some submissions criticised vague and evasive language in the INDC, such as a reference to unnamed South African experts who had calculated a national carbon budget of 22 gigatons. Government was called on to develop a quantified carbon budget to facilitate planning. Some of the underlying assumptions of the INDC about the relationship between climate change mitigation and adaptation measures on the one hand and economic development on the other were questioned. It was an error to assume, as the INDC did, that the need to address climate change and the need to develop economically were opposed, and that the transition to a low carbon economy would come at the cost of lower economic growth and lower levels of employment. This discourse showed the pervasive and malign influence of the mining-energy complex, whose short-term interests were severely threatened by the prospect of a transformation of the South African economy. Nuclear power was simply too expensive and would crowd out funding for renewable energy. . Subsidies being given to coal and nuclear power should be redirected to renewable energy and energy efficiency.
The Committee was told that it would hear many views on whether the INDC was achievable, and it was important for them to be vigilant of the interests behind the views expressed. Research showed that the INDC was well within the bounds of possibility, both technically and economically. Whether or not it was politically possible was up to government. It would be difficult, and require systemic changes but it was possible, and it was not incompatible with economic growth and unemployment reduction. Electricity generation would have to be completely decarbonised by 2050. This did not mean closing coal power stations, it just meant not building any more. If there was a successful climate change agreement and South Africa continued to build new coal power stations, they would either stand unused or South Africa would be made an international pariah. The Committee was asked to pass legislation compelling industry to make their emissions data public. Without it, it was impossible to have a rational, facts-based conversation about climate change.
The Chairperson thanked civil society as a whole for the submissions. No democratic government could believe that it did not depend on civil society to advise it. He reminded the public that negotiations at COP21 would be difficult and there would be many competing interests. Taking a hard line on a particular point entailed the risk that it may be rejected completely. In particular, he warned that they may not be able to insist on adherence to the Africa Group position of 1.5°C average temperature increase.
The Chairperson, Mr Jackson Mthembu, welcomed the large and diverse gathering, and explained that the purpose of the meeting was to discuss South Africa's position regarding climate change, which would be taken to the 21st session of the Conference of Parties (COP21) to be held in Paris in December 2015. This position would include South Africa's Intended Nationally Determined Contribution (INDC) for reducing greenhouse gas emissions. He stressed the seriousness of the situation, and that if global action was not taken, we would be facing a catastrophe of unexplainable proportions. There would be floods, heat waves and water shortages, and developing countries would bear the brunt of the catastrophe because they were dependent on agriculture. The last time public hearings had taken place on climate change, all parties had agreed that an agreement to reduce greenhouse gas emissions was needed that was legally binding at international level. At the last COP in Lima in 2014, it had been agreed that countries would develop INDCs, to be presented this year in Paris. Mr Mthembu asked the decision-makers present to consider what their descendants might think of them if they failed to act to avert a climate catastrophe. He reminded the gathering of the cross-cutting nature of the problem; it was not confined to any one government department or parliamentary committee. Co-operation within government, between government and civil society, and between nations would be required if the global average temperature increase was to be kept below 2°C above the pre-industrial average.
Mr Mthembu explained that on account of the large numbers of public submissions, it would be impractical to hold the usual question-and-answer session with Committee members, but individual presenters might be invited to present to the Committee if necessary. He then called on the Director General of the Department of Environmental Affairs (DEA) to introduce the Department's presentation.
Department of Environmental Affairs (DEA) Presentation
Ms Nosipho Ngcaba, DEA Director General, explained that the INDC had been made public and they had received comments on it. It had been discussed by Cabinet last week and would be finalised tomorrow. South Africa's position at COP21 would however still be tweaked in line with the outcome of the public hearings. She then handed over to Mr Maesela Kekana to deliver the Department's presentation.
Mr Maesela Kekana, DEA Chief Director: International Climate Change Relations and Negotiations, explained the position South Africa would take to COP21. He said that the objective of the COP was to facilitate international co-operation in response to climate change. The current conference was attempt to arrive at a binding agreement on climate change responsibility. Mr Kekana gave a brief history of climate change, starting from the mid nineteenth century with the rise of industrialisation. This required energy, the production of which led to increase in greenhouse gases in the atmosphere. For now, the concentration of greenhouse gases was still manageable, but if the current pattern of increasing concentration continued, real problems would result. The impact of climate change would be felt on ecosystems, human systems, urban systems, economic systems and social systems.
Mr Kekana said that South Africa had been participating in the COP since its inception, and the South African negotiation team included several veterans. South Africa hosted COP17 in Durban in 2011, at which the failure to adopt the Copenhagen Accord at the preceding conference and certain weaknesses of the Kyoto Protocol of 1997 (for example, that it had not been adopted by the United States of America) had to be redressed. A new round of negotiations had been launched under the Durban Platform for Enhanced Action, which was intended to place both developed and developing countries under legal obligations to reduce their greenhouse gas emissions. COP 18 in Doha had discussed implementation, and COP19 in Warsaw had given birth to INDCs; national plans detailing how a country intended to go about reducing its emissions. South Africa, representing vulnerable regions, had wanted these to be commitments, but had not been able to insist on this in the negotiations. The legal status of the INDCs would be discussed further in Paris. At COP20 in Lima in 2014, South Africa had successfully insisted that any INDC should include details of climate change adaptation measures, not just mitigation measures. 2015 was the fourth and final year of the negotiations begun at Durban: an agreement had to be reached in Paris. The key elements of the South African position were that the agreement should:
- be multilateral, rules-based, and legally binding, to keep the temperature increase below 2°C.
- support a transition to low emissions and climate resilience
- give equal priority to mitigation and adaptation measures
- be inclusive, fair and effective.
South Africa's INDC was organised into four elements: adaptation, mitigation, means of implementation and equity. Mr Kekana discussed the details of each element, as they appeared in the presentation document. He explained that South Africa had made their intention to reduce emissions very clear at Copenhagen, but would need international financial support to fulfil these intentions.
Rev G Shayi submission
Rev G Shayi of Gugulethu said that the climate change events currently occurring were foretold in the Bible; but it also told that God was the loving creator of the universe. He said that there were several international commodity trading firms who purchase carbon offsets, and suggested that buying these was a great way for an individual to combat climate change. He said that the scientific community was unanimous in its agreement about the reality of climate change, although a “cottage industry” of climate change denialists persisted. He said that recycling and a renewable energy policy could help make South Africa more environmentally friendly.
Mr Bobby Peek, groundWork Director, explained that climate change did not just affect the environment, but human beings directly. Climate change might destroy humanity, but the world would continue. Combating climate change was not a generous act done on behalf of nature, but part of our very own struggle for existence. Climate change would affect our health. A study in The Lancet published in 2014 detailed the likely effects on pulmonary and cardiovascular health. South African research also showed a serious impact on our health from coal power emissions, even before climate change effects.
Mr Peek explained that the world's carbon budget until 2050, if the temperature increase was to be kept below 1.5°C, was about 600 gigatons (GT) of CO2. At the current rate, this budget would be consumed by 2030. This meant that fossil fuel power could not continue. South Africa's cut of the global carbon budget was about 10-12GT according to some estimates, or as low as 7GT according to a Chinese calculation, but the DEA had “fiddled the numbers” to allow themselves a bigger budget, as it was clear that South Africa's yearly emissions were going to exceed our allowance.
He went on to describe some of the effects of heavy industry, including industrial plantations, in Kwazulu-Natal and Mpumalanga. There were threats to the water supply in particular. New coal fired power stations continued to be built, which would prevent the country from meeting the targets in its INDC. Mr Peek insisted that market mechanisms for reducing emissions, such as carbon offsets, have not worked. Unless the coal-fired power program was halted, groundWork could not give their mandate to the DEA.
Highveld Environmental Justice Network submission
Ms Promise Mabilo explained that the Highveld had been declared an air quality priority area due to the elevated levels of pollution resulting from the concentration of Eskom's coal-fired power plants and Sasol's operations in the area. The Network believed strongly that, although South Africa needed to address its poverty and energy challenges, the continued reliance on coal power would hinder our ability to meet emissions targets. We needed to invest in renewable energy. The large land areas required for coal power plants and the mines supporting them took away from agricultural land and therefore threatened our food security and water supply and would contribute to poverty. Government had also failed to ensure that industry complied with air quality legislation, undermining all attempts to reduce emissions.
Vaal Environmental Justice Alliance (VEJA) submission
Ms Sebolelo Mafisa from VEJA called on the South African delegation to stand firm at COP21 and to demand a strong, legally binding international commitment to measures that would keep the temperature increase below 1.5°C. They must represent the interests of the poor and disadvantaged, and not allow COP21 to be a political parade. She said that government's failure to regulate big business would inflate South Africa's contribution to climate change. The adaptation strategy needed to incorporate finance for healthcare.
Women in Energy and Climate Change Forum submission
Ms Ndivile Mokoena called for legally binding national and global policies addressing adaptation and mitigation strategies (especially at local level), sustained reduction in greenhouse gas emissions across the globe, and technology transfer from developed countries to develop a low-carbon economy. She wanted the Green Climate Fund to be taken seriously, in order to alleviate poverty, to secure the food supply without relying on genetically modified organisms (GMOs), rehabilitate mine dumps and generally improve human health. She also wanted to see climate change response measures expressed in local government Integrated Development Plans (IDPs).
Soweto Electricity Crisis Committee submission
Ms Martha Mokate's submission was delivered in Tswana and translated in summary by Mr Mthembu. Ms Mokate said that there had been insufficient time for engagement during the development of the INDC. She said that South Africa could not continue to rely on coal power and should be moving toward renewables.
Earthlife Africa submission
Dr Tristen Taylor, Project Coordinator, said that emissions reduction would have to start immediately if South Africa's peak, plateau and decline (PPD) programme in its INDC was going to be adhered to. In order to make a proportional contribution to a less than 2°C increase, South Africa would need to reduce emissions by 5% each year from 2020. Mr Taylor said that South Africa's offering in its INDC was insufficient, even for a developing country. He also expressed concern that the method of ensuring that the South African INDC was adhered to was legally unenforceable. South Africa could not go to COP21 and expect other countries to legally commit to emissions targets if we did not do so ourselves. Fortunately, the legislation would only need to target Eskom and Sasol. But the coal power station building programme was going to preclude the possibility of meeting the emissions targets required to keep the increase below 2°C. The climate change battle would be won or lost based on industrial policy.
South African Waste Pickers' Association (SAWPA) submission
Mr Simon Mbata, SAWPA Chairperson, explained that waster pickers are a primary recycling system in South Africa. Waste is linked to human development, both socially and technologically. Waste had been targeted by the Clean Development Mechanism of the UN Framework Convention on Climate Change (UNFCCC). He said that the value recovered from waste by waste pickers far exceeded the value recovered by waste-to-energy processes, which had the additional disadvantages of destroying the livelihood of waste pickers and contributing to emissions. Recycling and composting were far superior solutions, he said.
South Durban Community Environmental Alliance (SDCEA) submission
Mr Desmond D'Sa, Executive Director of SDCEA, agreed with Ms Mokate that the process of developing the INDC had not been adequately participatory. He said that the UNFCCC had not brought any meaningful change to the lives of the people most immediately affected by climate change. The Durban Platform had done nothing to benefit the poor in South Africa. In fact, things had got worse. Money and market solutions would not be effective; what was needed was a radical change in our means of production. The expansion of coal power and oil and gas exploration were incompatible with reduction of greenhouse gas emissions. Plantations are not an effective way to offset emissions, and they also put pressure on the water supply and threaten biodiversity. He said that the COP had been dominated by polluters, and he did not expect Paris to be any different. He called on the South African delegation to represent the ordinary people of South Africa.
World Wide Fund for Nature (WWF) submission
Ms Louise Naudé, WWF National Climate Change Officer, praised the DEA for moving the INDC in a more concrete direction, with the PPD trajectory, which allowed for a period during which emissions would be allowed to increase, followed by a period during which they would be held steady, followed by a period in which they would decline. However, she called on the government to commit even further, to a quantified national carbon budget. She understood that government was under immense pressure from heavy industry to allow more and more emissions. In addition, this lobby presented itself as if it represented all business, although it was essentially a lobby for the fossil fuel industry, who were the most threatened by the shift toward a low carbon economy. There was also the problem of conflict within government. Different departments have different mandates and they do not always manage to arrive at consensus.
Turning to the INDC itself, Ms Naudé pointed to a reference to studies by “South African experts” calling for a very large carbon budget of 23GT. She asked government to make those studies more transparent, and to stand up for what they really believed an equitable carbon budget for South Africa was. She said the National Climate Change Response White Paper suggested some realistic figures. She recognised the need for some flexibility and suggested that the budget should be between 12.4-16GT. It was not a risk to make a firm commitment, because as a developing country, South Africa could make its mitigation contribution subject to levels of support from the international community. Finally, she praised the adaptation component of the INDC as “world-leading.”
Ms Tasneem Essop, WWF Head: Low Carbon Frameworks, said that although the historical carbon debt of developed countries meant that they were obliged to contribute more to emission reductions and to provide support for developing countries, this should not be used as an excuse for developing countries with large emissions like South Africa to shirk their responsibility. She called on the South African delegation to take strong positions on behalf of developing countries and the poor. The INDCs were extremely weak and she asked for them therefore to promote a review and ramping-up mechanism. She said the target should be for fossil fuels to be phased out completely by 2050. There should be no compromise on loss and damage clauses, which had been sacrificed during negotiations at COP20 in Lima. This must not happen again. The delegation must put pressure on developed nations to fulfil their climate finance pledges, namely the $100 billion by 2020 which they pledged in Copenhagen.
Greenpeace Africa submission
Ms Penny-Jane Cooke, Climate and Energy Campaigner at Greenpeace, said it was imperative that South Africa reconsider its current commitment to the expansion of coal and nuclear power if it was going to meet an equitable emissions target. It should commit to the goal of a zero-carbon economy by 2050 and to 40% renewable energy by 2030. She felt that this level of ambition was lacking in the INDC. The intended mitigation measures lacked quantification, and the carbon budget was far too large. Such evasiveness would undermine any claim to moral authority or spokesmanship for vulnerable countries, and suggested that South Africa was not sincerely committed to the 2°C increase limit, not to mention the Africa Group position of a 1.5°C limit. The INDC also lacked detail for plans to shift investments to renewable energy in a transformative way. Finally, Ms Cooke said that the characterisation of nuclear power as a low carbon option was disingenuous. Although a nuclear plant burns no hydrocarbons, this ignores a large portion of the life-cycle of nuclear fuel, from mining, enrichment, fabrication, transport and waste processing, all of which are carbon intensive. In short, nuclear power was a false option. South Africa was the 11th largest carbon dioxide emitter in the world, having recently overtaken Mexico, as a direct consequence of our reliance on coal power.
Congress of South African Trade Unions (COSATU) submission
Mr Matthew Parks, COSATU Deputy Parliamentary Coordinator, said that he did not see that the needs of organised labour were opposed to the requirement of climate change action.
Ms Hameda Deedat, COSATU Researcher, was disheartened by the lack of changes in the INDC through the consultative process. She was concerned that the submissions would not be taken seriously. She said that they were in support of a just transition to a less carbon-intensive economy. However, she pointed out that the entire discussion was taking place within a capitalist paradigm, and that changes were being suggested to a system that was inherently defective. She said that the INDC was not insistent enough that countries needed to be transparent and accountable. South Africa needed to lobby for global termination of fossil fuel subsidies, and restated COSATU's anti-nuclear stance.
Congress of Traditional Leaders of South Africa (CONTRALESA) submission
Mr Andrew Pheto, CONTRALESA Special Advisor, said that climate change was already having an impact on traditional communities, who rely on agriculture, herding and tourism. He had seen growing seasons shortening, leading to lower yields and putting subsistence farmers, who did not have the kind of irrigation systems used by commercial farmers, at risk. New crop and livestock diseases were emerging. The changing environment required new knowledge and the development of disaster management strategies. Mr Pheto discussed a worrying new trend of old cars from Asian countries (that now had stricter vehicle emissions legislation) being “dumped” in South Africa and distributed throughout Africa. He called for tighter legislation on vehicle emissions and a ban on vehicle dumping. This would also benefit South Africa indirectly, by increasing the demand for platinum group metals used in catalytic converters, that reduce exhaust emissions.
Mr Pheto expressed his support for the adaptation measures contained in South Africa's INDC. On mitigation measures, he also supported the view that developed countries were obliged to provide climate finance.
Stellenbosch University Sustainability Institute submission
Prof Mark Swilling, Sustainability Institute Director, questioned some of the underlying assumptions of the INDC about the relationship between climate change mitigation and adaptation measures on the one hand and economic development on the other. It was an error to assume, as the INDC did, that the need to address climate change and the need to develop economically were opposed, and that the transition to a low carbon economy would come at the cost of lower economic growth and lower levels of employment. This discourse showed the pervasive and malign influence of the mining-energy complex, whose short-term interests were severely threatened by the prospect of a transformation of the South African economy. Historically, great economic and industrial changes have arisen alongside changes in energy and communications technologies. In the present era, renewable energy and the Internet were going to transform the industrial landscape. Prof Swilling saw the beginnings of this transformation in South Africa over the last five years in the Renewable Energy Independent Power Producers Programme (REIPPP). Nuclear power was simply too expensive and would crowd out funding for renewables. It would inevitably exceed its budget and as a large project it carried the risk of encouraging rent-seeking behaviour. Prof Swilling was critical of the concept of making the transformation of our economy contingent on the provision of international finance. It was unreasonable to expect other countries to fund an economic transformation that was in the interests of our own people. If international climate funding was forthcoming, this should be considered a bonus, but we should not rely on it. Finally, although he praised the inclusion of adaptation measures in the South African INDC, he emphasised the importance of adapting cities to be more efficient.
Chemical and Allied Industries Association (CAIA) submission
Ms Deidre Penfold, CAIA Executive Director, explained that the chemical industry contributed about 5% to South Africa's gross domestic product (GDP). She said they recognised the need to transition to a lower carbon economy, and supported a holistic climate change policy to this end. Over the past ten years, greenhouse gas emissions from the chemical industry had declined by more than 60%. She was not sure that the emissions targets and the timeframe of the PPD programme in the INDC were realistic or even possible and called for more realistic goals. She said that the chemical industry did not dispute the projected peak-plateau-decline trajectory for emissions, but called for a revision of the precise quantities based on more recent data. She drew attention to the need to balance the national contribution to the global effort to mitigate climate change with the national imperative to increase economic growth and employment, energy security and socio-economic development.
South African Faith Communities Environment Initiative (SAFCEI) submission
Ms Liziwe McDaid, SAFCEI Energy and Climate Change Programme Coordinator, agreed with Prof Swilling that we could not wait for international climate funding and that the opposition between mitigation and economic growth was a false one. While she understood that negotiation was a matter of give-and-take, she was concerned that the South African position appeared to have slipped to a 2°C limit, despite the fact that the Africa Group position was a 1.5°C limit. She called for co-operation between the Environment and Energy Portfolio Committees in Parliament. Finally, she said that they considered nuclear power and market mechanisms to be false solutions. Subsidies being given to coal and nuclear power should be redirected to renewable energy and energy efficiency.
Bishop Geoff Davies, SAFCEI Executive Director, called on South Africa to do the morally correct thing. The negotiating team needed to show the same leadership that had been shown during our transition to democracy. The three platforms of sustainable development were people, planet and profit; but too much emphasis had hitherto been placed on the last of these, at the expense of the others. He encouraged all to read Pope Francis' encyclical, which said that the world had deified the market. The faith community had added a fourth platform, spirituality or ethics, to guide our decision making. South Africa could not continue to increase its emissions for the next ten years, as the PPD trajectory indicated; we had to start reducing emissions immediately. We needed to use the solar and wind resources that we had.
Project 90 by 2030 submission
Mr Happy Khambule, Project 90 by 2030 Policy & Research Officer, expressed his support for all the submissions that had been heard, with the exception of the Chemical and Allied Industries Association submission, which he said contradicted the principle of the INDC. They did not support any compromise on the goal of a low-carbon future. He agreed with Prof Swilling that the INDC document made false assumptions about the relationship between economic growth and low-carbon development. He called for the replacement of “fair” contributions (to climate change mitigation) with “defensible” contributions, i.e. contributions that can stand up to a high level of national, regional and international scrutiny. He supported the idea of making some mitigation commitments conditional on the provision of international climate finance. Mitigation measures would become more and more expensive in the future, so we needed to aim for emissions to peak before 2025, and to aim for the lower limit of our estimated carbon budget. Past contributions to climate change mitigation should not be included in the body of the INDC document, but could be included in an appendix. He criticised weak and vague language that would harm South Africa's credibility in negotiations.
University of Cape Town Energy Research Centre (ERC) submission
Mr Hilton Trollip, ERC Energy and Climate Change senior researcher, focused on the mitigation component of the INDC. He explained that it was a function of universities to provide government with credible evidence and reasoning to guide their decision making. South Africa's INDC recognised that we are a responsible global citizen and that we would make a fair contribution to climate change mitigation. The university's role was to look at the document and determine whether the contribution it described was fair and would be effective. He stressed that their research showed that it was in South Africa and Africa's interests to hold firm to the 1.5°C limit. Turning to the PPD trajectory, Mr Trollip said the Climate Action Tracker, a respected assessment measure of climate mitigation strategies, had rated South Africa's INDC as “inadequate.” However, if we stuck to the lowest emission projections of our PPD, we could have an adequate or even an exemplary rating.
It was also important to ask whether the South African INDC was achievable. He warned that the Committee would hear many views on this question, and that it was important for them to be vigilant and cognisant of the interests behind the views expressed. The research of the Energy Research Centre, which was open, transparent, and not linked to any interested party to the question, showed that it was well within the bounds of possibility, both technically and economically. Whether or not it was politically possible was up to government. They needed to demand from any contrary claims that they are backed up by equally solid, transparent evidence. It would be difficult, and require systemic changes but it was possible, and it was not incompatible with economic growth and unemployment reduction. Electricity generation would have to be completely decarbonised by 2050. This did not mean closing coal power stations, it just meant not building any more. If there was a successful climate change agreement and South Africa continued to build new coal power stations, they would either stand unused or South Africa would be made an international pariah. Mr Trollip called on the Committee to pass legislation compelling industry to make their emissions data public. Without it, it was impossible to have a rational, facts-based conversation about climate change issues.
Closing statement by Committee Chairperson
Mr Mthembu called attention to the great diversity of interests present and assured them that their submissions would be taken seriously. He reminded the public that negotiations at COP21 would be difficult and there would be many competing interests. Taking a hard line on a particular point entailed the risk it may be rejected completely. In particular, he warned that they may not be able to insist on adherence to the Africa Group position of 1.5°C average temperature increase. But this did not mean the delegation did not share their ideals: retreat was not defeat, it was a strategy. He agreed that legislation was required for emissions reporting. He thanked civil society as a whole for the submissions. No democratic government could believe that it did not depend on civil society to advise it.
The meeting was adjourned until the following day.
- South Durban Community Environmental Alliance (SDCEA) submission
- South African Faith Communities Environment Initiative (SAFCEI) submission
- Consultation on SA’s Intended Nationally Determined Contribution (INDC) submission
- groundWork submission
- Congress of South African Trade Unions (COSATU) submission
- Congress of Traditional Leaders of South Africa (CONTRALESA) submission
- Greenpeace Africa submission
- World Wide Fund for Nature (WWF) submission
- Robert W. Howarth submission 2
- Robert W. Howarth submission
- Project 90 by 2030 submission
- University of Cape Town submission
- Chemical and Allied Industries' Association (CAIA) submission
- Vaal Environmental Justice Alliance (VEJA) submission
- South African Waste Pickers' Association (SAWPA) submission
- Earthlife Africa submission