Submission to the Presidential Climate Commission on South Africa’s Just Energy Transition - Investment Plan

The Institute for Economic Justice (IEJ) and Climate Finance for Equitable Transitions (CLiFT) argue that the JET-IP's strategy of 'de-risking' private finance is insufficient to mobilise the required R1.5 trillion and exposes South Africa to significant fiscal, legal, and social risks. The authors contend that the plan fails to meet National Determined Contributions (NDCs) due to an over-reliance on private renewable energy and a lack of investment in public transport and energy efficiency. They recommend shifting to a 'rights-based' governance framework and an 'allocative credit policy' that prioritises public investment, local manufacturing, and comprehensive social protections for workers and communities.

• The JET-IP's reliance on a risk-based prudential macroeconomic framework will fail to mobilise the target of R1.5 trillion and will not effectively redirect finance away from dirty industries due to structural impediments like shadow banking and private equity.
• Heavy dependence on private debt and 'de-risking' strategies exposes the South African government to significant financial and regulatory risks, including potential contagion from external jurisdictions and the risk of 'regulatory chill' where the state avoids public interest reforms to prevent investment disputes.
• The JET-IP is unlikely to meet South Africa's National Determined Contributions (NDCs) because it relies on private renewable energy generation that lacks sufficient scale and fails to allocate funding for energy efficiency.
• The transport decarbonisation strategy is criticised for prioritising the export of new energy vehicles (NEVs) and 'techno fixes' over a modal shift toward sustainable public transport, with only 4.7% of transport financing dedicated to public transport.
• Investment in green hydrogen is viewed as highly speculative and risky due to its extreme capital intensity, potential to compete with other decarbonisation goals, and significant water risks in a water-scarce country.
• The 'just' element of the transition is deemed insufficient as the plan prioritises capital-intensive industries over labour-intensive ones, underfunds renewable energy localisation (allocating only R1.6 billion), and lacks comprehensive social protections for affected workers.
• The JET-IP's risk-based governance framework is argued to jeopardise human rights and national law, as it relies on 'good practice' and monitoring rather than a rights-based approach with effective grievance and redress mechanisms.

APA

Baloyi, B., Madhi, Y., Krinsky, J., Isaacs, G., Tan, C., Vastardis, A. Y., & Türkelli, G. E. (2023). Submission to the Presidential Climate Commission on South Africa’s Just Energy Transition - Investment Plan. Institute for Economic Justice. https://iej.org.za/wp-content/uploads/2023/04/IEJ-and-CLiFT-JET-IP-Submission-March-2023.pdf

Chicago

Baloyi, Basani, Yasirah Madhi, Jezri Krinsky, Gilad Isaacs, Celine Tan, Anil Yilmaz Vastardis, and Gamze Erdem Türkelli. Submission to the Presidential Climate Commission on South Africa’s Just Energy Transition - Investment Plan. Institute for Economic Justice, 2023. https://iej.org.za/wp-content/uploads/2023/04/IEJ-and-CLiFT-JET-IP-Submission-March-2023.pdf.

Wikipedia

{{cite report |last1=Baloyi |first1=Basani |last2=Madhi |first2=Yasirah |last3=Krinsky |first3=Jezri |last4=Isaacs |first4=Gilad |last5=Tan |first5=Celine |last6=Vastardis |first6=Anil Yilmaz |last7=Türkelli |first7=Gamze Erdem |title=Submission to the Presidential Climate Commission on South Africa’s Just Energy Transition - Investment Plan |publisher=Institute for Economic Justice |date=March 2023 |url=https://iej.org.za/wp-content/uploads/2023/04/IEJ-and-CLiFT-JET-IP-Submission-March-2023.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{baloyi2023submission, author = {Baloyi, Basani and Madhi, Yasirah and Krinsky, Jezri and Isaacs, Gilad and Tan, Celine and Vastardis, Anil Yilmaz and Türkelli, Gamze Erdem}, title = {{Submission to the Presidential Climate Commission on South Africa’s Just Energy Transition - Investment Plan}}, institution = {Institute for Economic Justice}, year = {2023}, month = mar, url = {https://iej.org.za/wp-content/uploads/2023/04/IEJ-and-CLiFT-JET-IP-Submission-March-2023.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }