NATURAL JUSTICE COMMENTS ON THE DRAFT CLIMATE CHANGE BILL (MAY 2022)

Natural Justice submitted comments on the draft Climate Change Bill (B9-2022) to the South African Portfolio Committee on Environment, Forestry and Fisheries on 27 May 2022. The organization argues that the Bill lacks the urgency required to address the climate crisis, fails to set ambitious emission reduction targets, and provides insufficient protections for constitutional rights and vulnerable communities.

• The draft Bill is criticized for a lack of urgency, specifically regarding implementation timelines. Natural Justice notes that the Bill omits deadlines for the promulgation of carbon budgets and sectoral emissions targets, and provides an "unreasonably long 5-year period" for provincial and local governments to create climate change response implementation plans.
• The Bill fails to establish ambitious, science-based emission reduction targets for 2030 or mid-century and does not explicitly reference the Paris Agreement's goal of limiting temperature increases to 1.5°C. Natural Justice points out that the interim trajectory in Schedule 3 appears to rely on 2015 Nationally Determined Contributions (NDCs) rather than the updated 2021 NDCs.
• There are significant concerns regarding transparency and the public's right to information. The document suggests the creation of a web-based climate change information portal, citing the Kenya Climate Change Knowledge Portal (KCCKP) as a successful model, to ensure data is accessible to all citizens regardless of language or literacy levels.
• The Bill is viewed as having inadequate enforcement mechanisms. It currently provides for only one offence—the failure to submit a GHG mitigation plan—but lacks penalties for failing to implement that plan or for exceeding an allocated carbon budget.
• Natural Justice argues that the Bill ignores nature-based solutions, specifically failing to recognize forest protection and restoration as tools for carbon sequestration and flood reduction, despite the Paris Agreement's recognition of forests in mitigation and adaptation.
• The document highlights a lack of support for a Just Energy Transition (JET). It advocates for the phasing out of fossil fuels and notes that a transition to wind and solar could result in a net gain of jobs, citing a RES4Africa study that calculated 862,000 direct, indirect, and induced jobs from wind and solar PV between 2020 and 2030.
• The Bill is criticized for placing heavy burdens on local and provincial governments without providing the necessary funding, training, or capacity-building measures required to implement climate response plans.

APA

Natural Justice (2022). NATURAL JUSTICE COMMENTS ON THE DRAFT CLIMATE CHANGE BILL (MAY 2022). https://naturaljustice.org/wp-content/uploads/2022/06/Natural-Justice-Climate-Change-Bill-B9-2022.pdf

Chicago

Natural Justice. NATURAL JUSTICE COMMENTS ON THE DRAFT CLIMATE CHANGE BILL (MAY 2022). 2022. https://naturaljustice.org/wp-content/uploads/2022/06/Natural-Justice-Climate-Change-Bill-B9-2022.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=NATURAL JUSTICE COMMENTS ON THE DRAFT CLIMATE CHANGE BILL (MAY 2022) |date=27 May 2022 |url=https://naturaljustice.org/wp-content/uploads/2022/06/Natural-Justice-Climate-Change-Bill-B9-2022.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljustice2022natural, author = {{Natural Justice}}, title = {{NATURAL JUSTICE COMMENTS ON THE DRAFT CLIMATE CHANGE BILL (MAY 2022)}}, publisher = {Natural Justice}, year = {2022}, month = may, url = {https://naturaljustice.org/wp-content/uploads/2022/06/Natural-Justice-Climate-Change-Bill-B9-2022.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }