Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa

The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted comments on South Africa's Draft Second Nationally Determined Contribution (NDC). The submission argues that the draft's mitigation targets are inadequate and lack ambition, proposing instead more stringent emission limits aligned with the 1.5°C global warming target. The CER also criticizes the lack of transparency in the process, specifically the late release of the underlying technical report, and calls for stronger integration of climate justice, adaptation measures, and a clear commitment to phasing out fossil fuels.

• The CER objects to the transparency of the NDC formulation process, noting that the technical report by the Energy Systems Research Group (ESRG) was released on 28 August 2025, only one day before the submission deadline.
• The CER contends that the draft NDC's mitigation targets—350 Mt CO2e to 420 Mt CO2e for 2026-2030 and 320 Mt CO2e to 380 Mt CO2e for 2031-2035—are unsafe and fail to represent the highest possible ambition or a clear progression.
• The CER proposes alternative mitigation targets of 350 Mt CO2e for 2025 to 2030 and 248 Mt CO2e for 2031 to 2035, while supporting a net zero target by 2050.
• The submission argues that the draft NDC fails to explicitly name the harms caused by fossil fuel production and combustion or the necessity of their rapid phase-out.
• The CER highlights significant economic and legal risks associated with low climate ambition, including potential carbon border adjustment penalties (such as the EU's CBAM) and increased litigation risk following the International Court of Justice's July 2025 advisory opinion.
• The CER expresses concern over delays in climate adaptation planning and the failure of the draft NDC to address climate migration, refugees, and the health impacts of toxic air pollution from fossil fuels.
• The submission recommends that the NDC incorporate the Presidential Climate Commission's (PCC) draft recommendations to support climate justice and a just transition, including restorative, distributive, and procedural justice.

APA

Centre for Environmental Rights (2025). Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa. https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779

Chicago

Centre for Environmental Rights. Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa. 2025. https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa |date=29 August 2025 |url=https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2025written, author = {{Centre for Environmental Rights}}, title = {{Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa}}, publisher = {Centre for Environmental Rights}, year = {2025}, month = aug, url = {https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }