Template for Stakeholder Comments per White Paper Section

The Biodiversity Law Centre and Natural Justice provide detailed feedback on a draft White Paper for biodiversity conservation in South Africa. While supporting the document's transformative goals and Afrocentric approach, they argue for stronger constitutional grounding in 'ecologically sustainable development,' clearer definitions of key terms like 'conservation area' and 'wildlife,' and the explicit inclusion of indigenous peoples and local communities (IPLC). They specifically call for the integration of climate change into the problem statement and the removal of GDP as a metric for biodiversity success, warning that such a measure encourages unsustainable growth.

• The stakeholders argue that the White Paper fails to sufficiently ground its approach in the constitutional requirement for 'ecologically sustainable development,' proposing that all references to sustainable use be preceded by the word 'ecologically'.
• There is a significant concern regarding the lack of clear mechanisms for co-operative governance and conflict resolution between state departments, specifically noting that the Department of Mineral Resources and Energy's current approach is largely incompatible with government climate change commitments.
• The document identifies a critical absence of definitions for essential terms, including 'conservation area', 'integrative approach', and 'wildlife', which creates policy uncertainty.
• The stakeholders emphasize that the White Paper must explicitly recognize the role of Indigenous People and Local Communities (IPLC) in biodiversity stewardship, noting that these groups often possess unique knowledge and maintain a harmonious relationship with nature.
• The stakeholders strongly oppose the use of Gross Domestic Product (GDP) as a metric for biodiversity, arguing that it encourages unsustainable economic growth and fails to account for the depreciation of natural assets.
• The document argues that climate change and biodiversity loss are inextricably linked and should be addressed as a single complex problem in the White Paper's problem statement to avoid maladaptation.
• The stakeholders propose expanding the definition of Ubuntu to move beyond human-to-human relatedness to include the interdependence between humans and the natural environment.
• The stakeholders express concern that the White Paper lacks a detailed implementation plan, specifically regarding the allocation of human and financial resources, which risks leaving the policy as a purely aspirational document.
• The stakeholders object to the description of wildlife ranching as 'vitally important' without qualifying that intensive management practices can be contrary to conservation objectives.

APA

Natural Justice (n.d.). Template for Stakeholder Comments per White Paper Section. https://naturaljustice.org/wp-content/uploads/2022/09/Table-NJ-and-BLC-Comments-on-White-Paper.pdf

Chicago

Natural Justice. Template for Stakeholder Comments per White Paper Section. n.d. https://naturaljustice.org/wp-content/uploads/2022/09/Table-NJ-and-BLC-Comments-on-White-Paper.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=Template for Stakeholder Comments per White Paper Section |url=https://naturaljustice.org/wp-content/uploads/2022/09/Table-NJ-and-BLC-Comments-on-White-Paper.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljusticendtemplate, author = {{Natural Justice}}, title = {{Template for Stakeholder Comments per White Paper Section}}, publisher = {Natural Justice}, url = {https://naturaljustice.org/wp-content/uploads/2022/09/Table-NJ-and-BLC-Comments-on-White-Paper.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }