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COMMENTS ON DRAFT SA WHOLESALE ELECTRICITY MARKET CODE & RULES
A submission by a coalition of civil society organisations—including Law for Energy Transitions Africa, Natural Justice, The Green Connection, and Project 90 by 2030—providing detailed comments on the draft South African Wholesale Electricity Market (SAWEM) Code and Rules. The submission argues that the draft framework lacks sufficient alignment with constitutional rights and climate obligations, suffers from governance conflicts of interest due to the Market Operator's link to Eskom, and lacks transparency regarding costs and contracts.
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Document type: Statement
Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams
A joint statement by five Canadian environmental and health organizations—Ecojustice, Breast Cancer Action Quebec, the Canadian Association of Physicians for the Environment, the David Suzuki Foundation, and Environmental Defence—providing feedback on the 'Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams'. While the organizations support the proposed risk management measures and their alignment with European Union and Washington State standards, they strongly criticize the proposed implementation timelines, which could allow some facilities to use PFAS-containing foams until 2039.
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Document type: Statement
SUBMISSION ON DRAFT RECOMMENDATION FOR SOUTH AFRICA’S 2030 – 2035 NDC UPDATE
The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, submitted comments on the Presidential Climate Commission's (PCC) draft recommendations for South Africa's 2030–2035 Nationally Determined Contribution (NDC) update. The submission emphasizes the need for high mitigation ambition to avoid fossil fuel lock-in, the integration of social justice, and the urgent implementation of adaptation measures in accordance with the Climate Change Act.
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Document type: Statement
Proposed PFAS Listing Order (Canada Gazette, Pt. 1, Vol. 159, No. 10, March 8, 2025)
A joint statement from five Canadian environmental and health organizations—including Ecojustice and the Canadian Association of Physicians for the Environment—urging the Canadian government to expedite the listing and regulation of per- and polyfluoroalkyl substances (PFAS). The organizations argue that current regulatory criteria underestimate PFAS bioaccumulation and call for the inclusion of fluoropolymers, as well as an accelerated timeline for phasing out PFAS in firefighting foams and consumer products.
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Document type: Statement
Notice of intent – Proposed new requirements for consumer chemical products under the Canada Consumer Product Safety Act
A joint submission by Environmental Defence, the Canadian Association of Physicians for the Environment (CAPE), Breast Cancer Action Quebec, and the Women’s Healthy Environments Network regarding proposed new requirements for consumer chemical products under the Canada Consumer Product Safety Act (CCPSA). The organizations advocate for mandatory hazard labelling, the phaseout of carcinogens and reproductive toxicants, and the inclusion of endocrine-disrupting chemicals in regulatory criteria to protect public health and address socioeconomic inequities.
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Document type: Statement
Just Energy Transition Investment Plan (JET-IP) and Draft Electricity Recommendations: Comments on behalf of the Life after Coal Campaign and the Fair Finance Coalition Southern Africa
This statement, submitted by the Life after Coal Campaign (LAC) and the Fair Finance Coalition Southern Africa (FFCSA) to the Presidential Climate Commission, provides critical comments on South Africa's Just Energy Transition Investment Plan (JET-IP). The authors argue that the plan is overly skewed toward private sector interests and large-scale infrastructure, specifically green hydrogen, while neglecting social ownership models, local manufacturing, and the urgent needs of coal-affected communities.
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Document type: Statement
COMENTÁRIOS DA NATURAL JUSTICE SOBRE O ANTEPROJECTO DA LEI DE FLORETAS: VERSÃO SUBMETIDAA CONSULTA PUBLICA
Natural Justice provides a critical analysis of Mozambique's draft Forest Act, arguing that the document functions as an economic instrument for exploitation rather than a tool for environmental protection. The organization highlights significant gaps in the draft, including the lack of distinction between native and planted forests, the absence of sustainable forest management concepts, and insufficient protections for community rights and biodiversity.
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Document type: Statement
Commentary on National Treasury’s Draft Technical Paper: Financing a Sustainable Economy 2020
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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Document type: Statement
Submissions on the Draft Forest Policy 2020
This document consists of formal submissions by Natural Justice to the Kenyan Ministry of Environment and Forestry regarding the Draft Forest Policy 2020. The submissions argue for a shift away from 'fortress conservation' and the current Community Forest Association (CFA) model toward a human-rights-based approach that recognizes the ancestral rights and conservation roles of indigenous and local communities.
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Document type: Statement
WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT
The Centre for Environmental Rights (CER) provides written submissions on the March 2018 Final Draft Report of Climate Change Mitigation Policies and Measures (PAMs). The CER supports the examination of policy effectiveness but identifies several gaps, including the need for better alignment between various government climate projects, the exclusion of certain greenhouse gases and externalities in socio-economic analyses, and a lack of rationale for prioritizing coal-to-liquid production through 2050. The CER emphasizes that the report's findings—specifically regarding the electricity sector as the key to decarbonization—should inform the revision of the Integrated Resource Plan for Electricity (IRP 2010).
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Document type: Statement
Submission from the Center for International Environmental Law (CIEL) on the Draft Guidance Notes for the Environmental and Social Standards of the World Bank ESF
The Center for International Environmental Law (CIEL) submitted comments on December 20, 2017, regarding the World Bank's Draft Guidance Notes for the Environmental and Social Standards (ESS) of the Environmental and Social Framework (ESF). CIEL argues that the Guidance Notes are "severely lacking in substance" and often merely reiterate the standards or use vague language rather than providing the detailed implementation guidance necessary to prevent harm to people and the environment.
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Document type: Statement
SUBMISSIONS ON THE DRAFT NKANGALA AIR QUALITY MANAGEMENT PLAN
The Centre for Environmental Rights (CER) provides submissions on the first draft of the Nkangala District Municipality (NDM) Air Quality Management Plan (AQMP). The CER identifies significant gaps in technical and financial capacity, a lack of alignment with the Highveld Priority Area (HPA) AQMP, and deficiencies in health impact assessments and monitoring. The submissions call for the NDM to prioritize staffing, ensure transparency in air quality data, and implement stricter dust control regulations.
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Document type: Statement
CIVIL SOCIETY SUBMISSION TO THE GREEN CLIMATE FUND ON ACCREDITATION, SAFEGUARDS AND FIDUCIARY STANDARDS
This 2014 submission from a coalition of civil society organizations provides critical feedback to the Green Climate Fund (GCF) on its proposed accreditation system, fiduciary standards, and environmental, social, and gender safeguards. The authors argue that the current framework relies too heavily on the IFC Performance Standards, which they claim do not represent international best practice, and that safeguards lack the detail and mandatory rigor applied to fiduciary standards. The submission advocates for a "do no harm" approach, the adoption of an exclusion list for high-risk activities, and a differentiated accreditation process based on the risk level of proposed projects.
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Document type: Statement
SUBMISSIONS REGARDING THE REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT
The Centre for Environmental Rights (CER), representing groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on August 22, 2012, regarding the review of the National Framework for Air Quality Management. The submission criticizes the lack of a systematic review of the 2007 Framework, the absence of a current State of the Air Report, and significant gaps in air quality monitoring and public access to information. The CER advocates for more stringent emission standards, mandatory reporting for data holders, and a more inclusive, transparent review process.
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Document type: Statement
Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy
A joint submission by various civil society organizations to the International Finance Corporation (IFC) criticizing its Social and Environmental Sustainability Policy, Performance Standards, and Disclosure Policy. The document argues that the IFC relies too heavily on unverified client data, fails to protect human rights—particularly those of indigenous peoples and women—and lacks transparency in its dealings with financial intermediaries and the extractive industry.
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Document type: Statement
Joint Submission on Responsible Exit On Consultation on the proposed IFC/MIGA Approach to Remedial Action
A joint submission by 24 civil society organizations, including the Center for International Environmental Law, criticizing the International Finance Corporation's (IFC) proposed Approach to Responsible Exit. The submission argues that the IFC's current framework fails to ensure remedy for harms caused by its investments and lacks transparency, urging the institution to make remedy a prerequisite for exit and to implement rigorous pre-divestment due diligence and community consultation.
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Document type: Statement
Comments on Draft South African Framework on Article 6
A statement submitted on 13 December 2024 by a coalition of civil society organizations, including Natural Justice and SAFCEI, providing critical comments on South Africa's Draft Article 6 Framework. The coalition argues that carbon markets are fundamentally flawed and risk enabling human rights abuses, land grabs, and the evasion of actual emission reductions.
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Document type: Statement
sa-oceans-economy-master-plan_natural-justice-submission-af4b0b03e99406bb.pdf
This document is a commentary by Natural Justice regarding the 'South Africa’s Oceans Economy Master Plan to 2035 Draft 3 v1'. The submission criticizes the Masterplan for failing to align with international climate obligations, neglecting marine biodiversity, and lacking meaningful consultation with coastal and indigenous communities. Natural Justice argues that the plan prioritizes economic growth and carbon-intensive industries, such as offshore oil and gas exploration, over environmental sustainability and the rights of small-scale fishers.
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Document type: Statement