South African Climate Action Network submission on South Africa’s proposed updated Nationally Determined Contribution – 2021
On behalf of its 12 member organizations, the South African Climate Action Network (SACAN) has made a written submission in response to South Africa’s proposed updated Nationally Determined Contribution (NDC).
- Enhanced but insufficient: We recognize that the 2021 updated draft of South Africa’s First NDC is enhanced over the 2015 version. This is welcome but remains insufficient in responding to what science needs. We remain unconvinced that this is the best that South Africa can do.
- Strengthen linkages with LEDS 2050 goal: The updated draft is devoid of explicit linkage with South Africa’s Low Emissions Development Strategy (LEDS). In line with the LEDS, the updated NDC should reiterate South Africa’s commitment to move towards a goal of net zero carbon emissions by 2050.
- Revisit mitigation target: It is imperative that the proposed mitigation target range goes deeper than the current formulation. Our analysis indicates that we should aim for GHG emissions to be no higher than 288.4 Mt CO2-eq in 2030. We also believe that the lower level of the target range needs to be done away with in its entirety.
- Emphasize accountability for ensuring implementation: The updated draft should clarify the assumptions and methodological approaches that will be used to account for implementation to ensure transparency and accountability of climate action through relevant policies. To this end, we suggest that the updated draft goes beyond high level target to identify the institutional mechanisms that will ensure NDC implementation.
- Provide details to attract international finance: The document provides a very general and broad brush picture of climate action in South Africa, especially in relation to adaptation. The details about investment needs are not backed up by commensurate details about the activities and interventions required for adaptation. This is not a useful approach to attract international support.
Take systemic, not incremental approach: The updated draft takes an incremental approach for addressing climate change. The lack of imagination in tackling the exponential pace at which the risks from and our exposure to climate change are increasing is visible in the checklist approach undertaken in drafting the updated NDC. This raises concerns about South Africa’s ability to provide leadership for addressing climate change.