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Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020

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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.

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  • 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.
  • 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.
  • 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'.
  • 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.
  • 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.
  • 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.

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APA
Centre for Environmental Rights (2020). Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020. https://cer.org.za/wp-content/uploads/2022/02/Submissions-on-National-Treasury-Technical-Paper-24.07.20.pdf?x21779
Chicago
Centre for Environmental Rights. Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020. 2020. https://cer.org.za/wp-content/uploads/2022/02/Submissions-on-National-Treasury-Technical-Paper-24.07.20.pdf?x21779.
Wikipedia
{{cite press release |author=Centre for Environmental Rights |title=Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020 |date=24 July 2020 |url=https://cer.org.za/wp-content/uploads/2022/02/Submissions-on-National-Treasury-Technical-Paper-24.07.20.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{centreforenvironmentalrights2020commentary, author = {{Centre for Environmental Rights}}, title = {{Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020}}, publisher = {Centre for Environmental Rights}, year = {2020}, month = jul, url = {https://cer.org.za/wp-content/uploads/2022/02/Submissions-on-National-Treasury-Technical-Paper-24.07.20.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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