SUBMISSION ON DRAFT RECOMMENDATION FOR SOUTH AFRICA’S 2030 – 2035 NDC UPDATE

The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, submitted comments on the Presidential Climate Commission's (PCC) draft recommendations for South Africa's 2030–2035 Nationally Determined Contribution (NDC) update. The submission emphasizes the need for high mitigation ambition to avoid fossil fuel lock-in, the integration of social justice, and the urgent implementation of adaptation measures in accordance with the Climate Change Act.

• The submission asserts that the formulation of the NDC is subject to the Climate Change Act, specifically Section 7(1), which requires organs of state to harmonize policies and decisions to ensure climate risks are considered and the Act's principles are upheld.
• There is significant concern regarding governance and regulatory delays in climate adaptation, particularly the deferral of key provisions in the Climate Change Act related to national, sectoral, municipal, and provincial implementation planning.
• The document highlights severe climate risks in southern Africa, noting that maize yields could drop by up to 75% in extreme warming scenarios and that a recent regional drought left over 60 million people in need of food assistance or short of food.
• The CER argues that the NDC must address climate migration and refugees, noting that regional droughts have already pushed hundreds of thousands or millions of people to move, often ending up in urban informal settlements.
• The submission warns that weakening mitigation ambition increases the risk of 'fossil fuel lock-in'—such as delayed coal decommissioning and the use of gas-to-power—which could lead to stranded assets, higher electricity prices, and increased CBAM-type risks.
• Regarding specific emission targets, the CER recommends that the 2030 target range be reduced to align with ESRG modelling (325 MtCO2e and 373 MtCO2e) and strongly opposes any weakening of the 2035 range (248 MtCO2e to 329 MtCO2e).
• The CER criticizes the current Integrated Resource Plan (IRP 2024) formulation process for having inadequate public consultation and making generation choices that are not based on least-cost considerations or climate soundness.
• To secure climate finance, the submission suggests the NDC should highlight the need for grants and highly concessional loans, and proposes raising funds through increased carbon taxes and loss and damage taxes on heavy emitters.

APA

Centre for Environmental Rights (2025). SUBMISSION ON DRAFT RECOMMENDATION FOR SOUTH AFRICA’S 2030 – 2035 NDC UPDATE. https://cer.org.za/wp-content/uploads/2025/09/PCC-NDC-Draft-Recommendation-Life-After-Coal-comments-June-2025.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSION ON DRAFT RECOMMENDATION FOR SOUTH AFRICA’S 2030 – 2035 NDC UPDATE. 2025. https://cer.org.za/wp-content/uploads/2025/09/PCC-NDC-Draft-Recommendation-Life-After-Coal-comments-June-2025.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSION ON DRAFT RECOMMENDATION FOR SOUTH AFRICA’S 2030 – 2035 NDC UPDATE |date=23 June 2025 |url=https://cer.org.za/wp-content/uploads/2025/09/PCC-NDC-Draft-Recommendation-Life-After-Coal-comments-June-2025.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2025submission, author = {{Centre for Environmental Rights}}, title = {{SUBMISSION ON DRAFT RECOMMENDATION FOR SOUTH AFRICA’S 2030 – 2035 NDC UPDATE}}, publisher = {Centre for Environmental Rights}, year = {2025}, month = jun, url = {https://cer.org.za/wp-content/uploads/2025/09/PCC-NDC-Draft-Recommendation-Life-After-Coal-comments-June-2025.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }