{"query_echo":{"q":"","filters":{"climate_tags":["climate risk disclosure"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'climate risk disclosure' for facet 'climate_tags' is not in the controlled vocabulary."}]},"total":{"value":2,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?climate_tags=climate+risk+disclosure","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"cer-001394","url":"https://climateinsightsdirectory.org/document/cer-001394","title":"Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2020-07-24","source_url":"https://cer.org.za/wp-content/uploads/2022/02/Submissions-on-National-Treasury-Technical-Paper-24.07.20.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Centre for Environmental Rights, on behalf of the Life After Coal campaign and 350Africa.org, provides commentary on the National Treasury's 2020 Draft Technical Paper 'Financing a Sustainable Economy'. The submission argues that the Draft Paper focuses too heavily on voluntary disclosure rather than binding commitments and fails to align with the urgency of the climate crisis or South Africa's international obligations under the Paris Agreement.","ai_generated":true,"unit":"cer-001394#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The authors argue that the Draft Technical Paper's primary focus on voluntary disclosure is insufficient and contradicts its title, 'Financing a Sustainable Economy'. They contend that a voluntary approach lacks oversight and that National Treasury should instead implement binding measures for state and corporate actors to incentivize a shift away from fossil fuel financing.","ai_generated":true,"unit":"cer-001394#insight-1","date_modified":"2026-08-17"},{"text":"The submission highlights a contradiction between the National Treasury's sustainable finance goals and current government energy policy. Specifically, it points to the continued public and private financing of new coal-fired power, such as the 3300MW coal plant and the Limpopo Musina-Makhado Special Economic Zone (MMSEZ) metallurgical complex, as obstacles to a just transition.","ai_generated":true,"unit":"cer-001394#insight-2","date_modified":"2026-08-17"},{"text":"The authors criticize the composition and transparency of the working group that prepared the Draft Paper, noting it consists only of regulatory agencies and industry associations. They argue this excludes critical stakeholders such as trade unions, civil society, academia, and project developers, leading to an 'exclusionary process of engagement'.","ai_generated":true,"unit":"cer-001394#insight-3","date_modified":"2026-08-17"},{"text":"The submission asserts that South Africa's Nationally Determined Contribution (NDC) is 'highly insufficient' and inconsistent with the Paris Agreement's goal of limiting warming to 1.5°C. The authors state that meeting revised targets would require phasing out coal-fired power generation by 2040 at the latest and increasing renewable energy capacity beyond the Integrated Resource Plan (IRP) 2019.","ai_generated":true,"unit":"cer-001394#insight-4","date_modified":"2026-08-17"},{"text":"The authors claim that the Draft Paper's definition of sustainable finance is flawed because it lacks an explicit reference to lowering greenhouse gas emissions and the Paris Agreement. Furthermore, they argue the framework is skewed toward financing mitigation from the perspective of financial sector risk, while neglecting the social costs of adaptation and transition.","ai_generated":true,"unit":"cer-001394#insight-5","date_modified":"2026-08-17"},{"text":"The document criticizes South African Development Finance Institutions (DFIs), specifically the Industrial Development Corporation (IDC) and the Development Bank of Southern Africa (DBSA), for failing to align their investment policies with international social, environmental, and governance standards or to support a just transition.","ai_generated":true,"unit":"cer-001394#insight-6","date_modified":"2026-08-17"}],"climate_tags":["sustainable finance","just transition","coal phase-out","paris agreement","nationally determined contributions (ndc)","climate risk disclosure"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["Policy Commentary","Stakeholder Submission"]},{"id":"cer-000394","url":"https://climateinsightsdirectory.org/document/cer-000394","title":"INTERNAL APPEAL PURSUANT TO THE PROMOTION OF ACCESS TO INFORMATION ACT 2 OF 2000","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2019-12-13","source_url":"https://cer.org.za/wp-content/uploads/2020/01/Annexure-A-PAIA-Appeal-CER-13-12-19.docx.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER) filed an internal appeal on 13 December 2019 against the Department of Environment, Forestry and Fisheries' decision to redact greenhouse gas (GHG) emission data and pollution prevention plans for several major South African emitters. The CER argues that the Department failed to provide adequate reasons for the redactions and that the information is of fundamental public interest, overriding claims of commercial confidentiality.","ai_generated":true,"unit":"cer-000394#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Centre for Environmental Rights (CER) is appealing a decision by the Department of Environment, Forestry and Fisheries to redact GHG emission data and pollution prevention plans, asserting that such information \"is not, and cannot be, commercially confidential.\"","ai_generated":true,"unit":"cer-000394#insight-1","date_modified":"2026-08-17"},{"text":"The CER's PAIA request sought records from 16 entities, including Eskom Holdings SOC Ltd, Sasol Ltd, ArcelorMittal South Africa Ltd, and Anglo American Plc, specifically requesting GHG emission data reports, pollution prevention plans, and annual progress reports.","ai_generated":true,"unit":"cer-000394#insight-2","date_modified":"2026-08-17"},{"text":"The Department granted partial access but redacted numerical values of unit activities in GHG emission reports, expected GHG emissions in pollution prevention plans, and anticipated emission reductions in annual progress reports for companies such as Eskom, Sasol, and ArcelorMittal.","ai_generated":true,"unit":"cer-000394#insight-3","date_modified":"2026-08-17"},{"text":"The CER argues the Respondent failed to provide adequate reasons for the redactions, stating that simply quoting sections 28 and 36 of PAIA is insufficient to meet the requirements of section 25(3) of the Act.","ai_generated":true,"unit":"cer-000394#insight-4","date_modified":"2026-08-17"},{"text":"The appeal contends that the Department failed to discharge its onus of proof to show that the requested information would likely cause harm to the commercial or financial interests of the third parties.","ai_generated":true,"unit":"cer-000394#insight-5","date_modified":"2026-08-17"},{"text":"The CER points to international precedents in Australia and the United Kingdom where GHG emission and energy consumption data are proactively published or cannot be refused on the basis of commercial confidentiality.","ai_generated":true,"unit":"cer-000394#insight-6","date_modified":"2026-08-17"},{"text":"The CER asserts a 'public interest override' under section 46 of PAIA, arguing that the risk of GHG emissions constitutes a significant public safety and environmental risk that outweighs any commercial harm.","ai_generated":true,"unit":"cer-000394#insight-7","date_modified":"2026-08-17"},{"text":"The CER notes that some companies, including SAPPI, Anglo American, and Mbuyelo Coal, voluntarily provided unredacted reports after the Department's refusal, undermining the claim that the data is commercially sensitive.","ai_generated":true,"unit":"cer-000394#insight-8","date_modified":"2026-08-17"},{"text":"The document highlights South Africa's vulnerability to climate change, noting it is the world's 13th largest GHG emitter and that a 2°C global temperature increase equates to a 3 to 4°C increase for South Africa.","ai_generated":true,"unit":"cer-000394#insight-9","date_modified":"2026-08-17"}],"climate_tags":["greenhouse gas emissions","climate change mitigation","environmental transparency","pollution prevention plans","climate risk disclosure"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["legal appeal","policy challenge"]}]}