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FACT SHEET: NEGOTIATING A SOUTH AFRICAN RENEWABLE ENERGY MASTERPLAN (SAREM)
The Institute for Economic Justice (IEJ) critiques the SAREM draft for lacking definitions of 'decent work', failing to provide a robust framework for monitoring local content compliance, and ignoring the potential for a local recycling industry. The document argues that the current market-led approach risks a 'race to the bottom' on price, which undermines local manufacturing. To counter this, the IEJ recommends aggressive local content requirements (LCRs) of 50% for future public procurement, the use of import tariffs to protect nascent industry, and the provision of low-cost public debt to offset the higher costs of locally produced components. It further advocates for a Technology Transfer System (TTS) to build local technical capacity and the establishment of municipal-level recycling depots for solar PV modules to prevent environmental damage and create jobs.
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Document type: Fact sheet
TEN PRIORITIES FOR THE 2022 MEDIUM TERM BUDGET POLICY STATEMENT
The Institute for Economic Justice (IEJ) proposes a shift away from fiscal consolidation toward a macroeconomic framework that prioritizes social infrastructure, public services, and a just energy transition. Key recommendations include expanding the Social Relief of Distress (SRD) grant into a Universal Basic Income Guarantee (UBIG), increasing public infrastructure investment to R900 billion, and restructuring Eskom's R400 billion debt to facilitate renewable energy investment. The IEJ also advocates for progressive taxation, including reversing the Corporate Income Tax reduction and utilizing windfall taxes to fund industrial policy and social protection.
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Document type: Policy brief
Ensuring that COP27 is Truly an ‘African COP’
The document outlines Africa's objectives for COP27, focusing on the African Group of Negotiators' (AGN) demands for increased climate finance and the recognition of the continent's special circumstances. It highlights a tension between the African Union's (AU) support for natural gas as a transition fuel and the goals of renewable energy activists. The brief also details the roles of specific 'climate champion' countries and the impact of global geopolitical tensions, such as the US-China standoff and the Russia-Ukraine war, on climate negotiations.
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Document type: Policy brief
REGULATION OF UPSTREAM GAS AND PETROLEUM ACTIVITIES CERTAIN ISSUES ARISING IN RELATION TO PASA’S ROLE
The Centre for Environmental Rights (CER) issued a statement to the Petroleum Agency of South Africa (PASA) raising concerns regarding transparency, environmental compliance, and climate impact assessments for onshore gas and petroleum activities. The CER highlights a lack of public information on rights holders and questions the legality of specific projects and the use of hydraulic fracturing.
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Document type: Statement
City of Ekurhuleni Municipality v New Star Technology CC and Zhibing Yuan
A summary of a High Court of South Africa judgment where the City of Ekurhuleni Municipality successfully obtained an interdict against New Star Technology CC and Zhibing Yuan for operating a waste recycling facility without required environmental authorisations.
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Document type: Case study
Landscape of Climate Finance in Africa
Africa requires USD 277 billion annually to meet its 2030 climate goals, yet annual flows stand at only USD 30 billion. While the region shows a better balance between adaptation and mitigation than other global regions, private sector contribution remains low at 14%. The report recommends increasing concessional finance for hard-to-abate sectors, improving data tracking through 'climate tagging', and enhancing sub-national investment capabilities to bridge the financing gap.
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Document type: Report
COMMENT ON THE PROPOSED CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY OF 3000 MW FROM GAS
The document argues that the procurement of 3,000 MW of gas power is irrational, unlawful, and environmentally harmful. It claims the process was 'tailor-made' for an existing Eskom project, lacked adequate public consultation, and ignores the availability of cheaper, cleaner renewable energy alternatives. The authors assert that gas is not a 'bridging fuel' due to high methane leakage and that such infrastructure risks becoming a stranded asset, thereby threatening South Africa's climate commitments and constitutional rights to a healthy environment.
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Document type: Statement
COMMENTARY ON THE DRAFT WHITE PAPER ON CONSERVATION AND SUSTAINABLE USE OF SOUTH AFRICA’S BIODIVERSITY 2022
Natural Justice and the Biodiversity Law Centre express strong support for the Draft White Paper on Conservation and Sustainable Use of South Africa’s Biodiversity 2022. They commend the document for moving away from colonial and apartheid-era conservation models toward a vision of 'Living in Harmony with Nature' that integrates human well-being, animal welfare, and the intrinsic value of nature. The organizations highlight the need to address the lack of transformation in the biodiversity sector and the ongoing threats of habitat loss and invasive species in South Africa.
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Document type: Statement
Statement on Treasury and Presidency Proposed SRD Grant Replacements
The Institute for Economic Justice (IEJ) criticizes proposals by South Africa's National Treasury and Presidency to replace the R350 Covid-19 SRD grant. The IEJ argues that Treasury's plan is designed to maximize exclusion through complex categorizations and conditionalities, such as job-seeking requirements, which ignore structural unemployment. The statement warns that these changes could reduce the number of beneficiaries from the current level to approximately 5.5 million, effectively removing support for millions of poor citizens. The IEJ also condemns the government's failure to engage with civil society coalitions in the development of these policies.
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Document type: Statement
MEMO ON TREASURY AND PRESIDENCY PROPOSALS TO REPLACE THE SRD GRANT
The Institute for Economic Justice (IEJ) argues that proposals by the National Treasury (NT) and the Presidency to replace the R350 SRD grant with targeted grants are regressive, unconstitutional, and administratively unworkable. The IEJ contends that these proposals prioritize cost-cutting and the exclusion of poor citizens over the primary goal of combating hunger and poverty. Specifically, the IEJ critiques the 'jobseekers grant' for relying on the false premise that structural unemployment can be solved through job-search facilitation, and the 'household grant' for potentially deepening gender power imbalances and reducing the number of beneficiaries. The memo further challenges the National Treasury's claims of unaffordability, asserting that NT ignores the net cost of grants, available tax surpluses, and progressive financing options like a wealth tax or Social Security Tax. The IEJ advocates for a universal basic income indexed to the Food Poverty Line, arguing that income support should be a survivalist tool rather than a lever for labor market activation.
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Document type: Briefing
SUPPLEMENTARY SUBMISSION ON THE PROPOSED REGULATIONS FOR IMPLEMENTING AND ENFORCING PRIORITY AREA AIR QUALITY MANAGEMENT PLANS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT, 2004
The Centre for Environmental Rights (CER) submitted recommendations to the South African government to strengthen draft regulations for air quality management plans. Following a High Court ruling that poor air quality in the Highveld Priority Area (HPA) violates constitutional rights, the CER advocates for stricter enforcement, including a moratorium on new coal infrastructure, biennial plan reviews, bi-annual public reporting, and the mandatory adoption of 2020 minimum emission standards by 2025.
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Document type: Statement
SOUTH AFRICA’S PARTICIPATION IN THE JUST ENERGY TRANSITION PARTNERSHIP (“JETP”): CIVIL SOCIETY PARTICIPATION AND INPUT
The Life after Coal Campaign (LAC) and Fair Finance Southern Africa (FFSA) call for greater transparency and civil society inclusion in South Africa's Just Energy Transition Partnership (JETP). They demand clarity on financial offers from the International Partners Group, the composition of JETP working groups, and the accessibility of the JETP Investment Plan. The coalitions argue that climate finance must prioritize 'justice elements'—including gender-responsive interventions and community-led projects—while strictly excluding funding for new coal, gas, or nuclear energy. They further emphasize the need for robust governance to track finance flows and ensure that the transition does not impose austerity on low-income users.
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Document type: Statement
REQUEST FOR INFORMATION: KARPOWERSHIP SOUTH AFRICA
The Centre for Environmental Rights, on behalf of Fair Finance Southern Africa (FFSA), has requested information from Investec Group concerning a US$ 140 million loan provided by a syndicate of four banks to Karpowership. The letter highlights that Karpowership SA's proposed floating gas-to-power projects in Coega, Richards Bay, and Saldanha face significant opposition due to environmental impacts and the risk of prolonging fossil fuel reliance. FFSA argues that the projects would emit substantial methane, potentially totaling 80 to 142 million tonnes CO2e over 20 years, and may become stranded assets. The request asks Investec to clarify if the loan finances South African operations and how this aligns with its membership in the Net Zero Banking Alliance and its own net-zero carbon emission claims.
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Document type: Statement
REQUEST FOR INFORMATION: KARPOWERSHIP SOUTH AFRICA
The Centre for Environmental Rights, on behalf of Fair Finance Southern Africa (FFSA), is questioning Türkiye İş Bankası A.Ş. (Isbank) about a US$ 140 million loan provided to Karpowership in March 2020. The letter argues that the Karpowership SA projects—consisting of three vessels with a total capacity of 1,220 MW in Coega, Richards Bay, and Saldanha—pose significant environmental and social risks. Specifically, it highlights the refusal of environmental authorisations by the Department of Forestry, Fisheries and the Environment (DFFE) due to "procedural irregularities" and the potential for the projects to emit "80 to 142 million tonnes CO2e of greenhouse gas" over 20 years. The authors contend that these projects prolong reliance on fossil fuels and may become "stranded assets" as renewable energy becomes cheaper. The letter asks Isbank to clarify if the loan was intended to finance these South African operations and how this aligns with its membership in the Net Zero Banking Alliance.
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Document type: Statement
REQUEST FOR INFORMATION: KARPOWERSHIP SOUTH AFRICA
The Centre for Environmental Rights, on behalf of Fair Finance Southern Africa (FFSA), is questioning the Mauritius Commercial Bank (MCB) about a US$ 140 million loan provided to Karpowership. The letter highlights environmental and legal concerns regarding Karpowership SA's projects in Coega, Richards Bay, and Saldanha, including the refusal of environmental authorisations by the DFFE and the potential for high methane emissions. FFSA seeks to clarify if MCB's financing ultimately supports these South African operations and how the bank assesses the associated material and climate risks.
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Document type: Statement
REQUEST FOR INFORMATION: KARPOWERSHIP SOUTH AFRICA
The document is a formal request for information sent to Standard Chartered Bank by the Centre for Environmental Rights on behalf of Fair Finance Southern Africa, seeking clarification on the bank's role in financing Karpowership SA's floating gas-to-power projects in South Africa.
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Document type: Statement
CLIMATE INSURANCE-LINKED RESILIENT INFRASTRUCTURE FINANCING INSTRUMENT ANALYSIS
CILRIF is a novel financial instrument developed by the UNCDF and partners to address the lack of affordable, long-term climate insurance and resilient infrastructure funding for cities in emerging markets. It operates through two linked facilities: an insurance facility providing 10-15 year coverage with premiums that decrease as cities meet resilience milestones, and a financing facility providing below-market rate loans for adaptation projects. The instrument uses a hybrid parametric and indemnity insurance model to provide immediate post-disaster liquidity while rewarding risk reduction. A financial model for 40 cities suggests that resilience interventions, such as drainage systems for flood risk or cooling networks for heat risk, can reduce annual premiums by 5% to 10% per intervention. The pilot phase targets Makati, Durban, and Freetown, with a goal of mobilizing USD 1 billion in commercial and concessional investment.
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Document type: Report
GREEN GUARANTEE COMPANY INSTRUMENT ANALYSIS
The Green Guarantee Company (GGC) is designed to unlock private institutional capital for climate projects in emerging and frontier markets by providing full hard-currency guarantees for bonds and loans of USD 50-200 million with maturities of 5-20 years. To address technical barriers, the GGC includes a USD 10 million technical assistance (TA) facility to build issuer capabilities and support certification against the Climate Bond Standard (CBS). The instrument will pilot in South Africa before expanding to other large emitters like Brazil, India, and Indonesia, and eventually to more vulnerable least developed countries. Financial modeling suggests the GGC can catalyze up to USD 10.6 billion in climate debt over 20 years, achieving operating breakeven within 3 to 7 years across various scenarios. Expected impacts include the addition of 7.97 GW of renewable energy capacity and the avoidance of approximately 75 Mt of carbon dioxide equivalent.
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Document type: Report
Increasing Subnational Pension Funds’ Climate Investments
The report identifies subnational pension funds as a significant source of untapped capital for urban climate action, estimating at least USD 9.5 trillion in assets across Brazil, Canada, Germany, the Netherlands, South Africa, the UK, and the US. It details structural barriers such as low risk appetite and limited fund size, as well as external barriers like a lack of bankable project pipelines and ticket size mismatches. To overcome these, the document recommends the use of financial instruments such as blended finance, green bonds, and supply-side aggregation (pooling), while urging funds to make net zero commitments and build internal capacity.
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Document type: Report
Landscape of Climate Finance in Africa
The report finds a massive gap between Africa's annual climate finance needs (USD 277 billion) and actual flows (USD 29.5 billion). While international public finance dominates, private sector contribution is low at 14%. Finance is heavily concentrated in a few countries and sectors, with energy receiving the most investment, while agriculture, forestry, and other land use (AFOLU) remains underfunded. The report recommends scaling up concessional finance, improving data tracking, and catalyzing private investment to meet 2030 goals.
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Document type: Report