Template for Stakeholder Comments per White Paper Section

This document contains written comments and proposed amendments submitted by the Biodiversity Law Centre and Natural Justice regarding a Draft White Paper on the conservation and sustainable use of biodiversity in South Africa. The stakeholders generally support the White Paper's paradigm shift toward transformation and an Afrocentric approach but argue that it lacks critical definitions, detailed implementation plans for funding and cooperative governance, and a sufficiently integrated approach to climate change.

• The stakeholders argue that the White Paper fails to provide a clear framework for cooperative governance and conflict resolution between state departments, specifically noting a potential incompatibility between the Department of Mineral Resources and Energy's approach and the government's climate change commitments.
• There is a strong recommendation to replace all references to "sustainable use" with "ecologically sustainable use" to align the policy with Section 24 of the Constitution, which prioritizes the ecological system.
• The stakeholders identify a critical lack of detail regarding the human and financial resources required for implementation, warning that without a concrete funding plan, the policy goals will remain purely aspirational.
• The document proposes expanding the definition of Ubuntu to move beyond human-to-human interrelatedness to include the relationship between humans and Nature, reflecting an ecocentric African philosophy.
• The stakeholders argue that the White Paper does not sufficiently integrate climate change and biodiversity, suggesting that the two should be treated as a single complex problem to avoid maladaptation.
• The stakeholders oppose the use of Gross Domestic Product (GDP) as a metric for biodiversity, stating that GDP encourages unsustainable growth and fails to account for the depreciation of the natural environment.
• The submission emphasizes the need to recognize the role of Indigenous Peoples and Local Communities (IPLC) in biodiversity stewardship, criticizing "fortress" conservation models that exclude these groups through violence or criminalization.
• The stakeholders request the inclusion of several missing definitions to ensure policy certainty, specifically for the terms "conservation area", "integrative approach", "wildlife", and "reallocation".
• The stakeholders object to the White Paper's description of wildlife ranching as "vitally important" without qualification, arguing that intensive management is 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} }