LIFE AFTER COAL CAMPAIGN COMMENTS ON THE CLIMATE CHANGE BILL, 2022

The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, represented by the Centre for Environmental Rights, groundWork, and Earthlife Africa, submitted comments on the Climate Change Bill, 2022. The submission argues that the Bill is insufficient to address the climate emergency and lacks the urgency, ambition, and enforcement mechanisms necessary to meet South Africa's international obligations under the Paris Agreement and protect constitutional rights.

• The Campaign argues that the Climate Change Bill, 2022 lacks urgency and contains inadequate or absent timeframes for critical mitigation actions, such as the determination of GHG emissions trajectories and the listing of GHGs and activities.
• The submission contends that the Bill's current emission trajectory is based on the obsolete 2015 Nationally Determined Contribution (NDC), which is deemed 'highly insufficient' and inconsistent with the 2021 updated NDC and the Paris Agreement's goal of limiting warming to 1.5°C or well below 2°C.
• The Campaign highlights a critical lack of enforcement and penalties in the Bill, noting that there is currently no criminal or administrative penalty for exceeding a carbon budget, which renders the carbon budget mechanism ineffective.
• The submission criticizes the Bill's limited access to information, arguing that relying on the Promotion of Access to Information Act (PAIA) and the Protection of Personal Information Act (POPIA) is insufficient and that automatic, real-time public disclosure of climate data should be the default.
• The Campaign asserts that the Bill fails to adequately center the South African Constitution and the Bill of Rights, specifically the right to an environment not harmful to health or well-being, which the Pretoria High Court confirmed is immediately realisable.
• The document emphasizes that fossil fuels are the primary driver of South Africa's emissions—accounting for over 80% of GHGs—yet they are not mentioned in the Bill, which the Campaign argues is a significant omission.
• The submission recommends the establishment of an independent scientific advisory panel to provide evidence-based recommendations to the government, distinct from the political and consensus-based output of the Presidential Climate Commission.
• The Campaign argues that the Bill places an undue burden on municipalities and provinces without providing necessary funding, capacity-building, or technical support for implementing climate response plans.
• The submission suggests that the Bill should be amended to include a 'ratchet mechanism' for sectoral emission targets (SETs) and the national trajectory, ensuring that successive targets always become stricter and never more lenient.

APA

Centre for Environmental Rights (2022). LIFE AFTER COAL CAMPAIGN COMMENTS ON THE CLIMATE CHANGE BILL, 2022. https://cer.org.za/wp-content/uploads/2022/05/Life-After-Coal-comments-Climate-Change-Bill-2022_27_May_2022.pdf?x21779

Chicago

Centre for Environmental Rights. LIFE AFTER COAL CAMPAIGN COMMENTS ON THE CLIMATE CHANGE BILL, 2022. 2022. https://cer.org.za/wp-content/uploads/2022/05/Life-After-Coal-comments-Climate-Change-Bill-2022_27_May_2022.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=LIFE AFTER COAL CAMPAIGN COMMENTS ON THE CLIMATE CHANGE BILL, 2022 |date=27 May 2022 |url=https://cer.org.za/wp-content/uploads/2022/05/Life-After-Coal-comments-Climate-Change-Bill-2022_27_May_2022.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2022life, author = {{Centre for Environmental Rights}}, title = {{LIFE AFTER COAL CAMPAIGN COMMENTS ON THE CLIMATE CHANGE BILL, 2022}}, publisher = {Centre for Environmental Rights}, year = {2022}, month = may, url = {https://cer.org.za/wp-content/uploads/2022/05/Life-After-Coal-comments-Climate-Change-Bill-2022_27_May_2022.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }