SAFCEI’s Submission into INDC for COP21

3 September 2015

Attention: Ms. Irene Koenze

Department of Environment Affairs and Tourism

South African Government.

Tel: +27 12 399 8837


Submission into the proposed  Intended Nationally Determined Contribution for South Africa (INDC).


The Southern African Faith Communities’ Environment Institute (SAFCEI) aims to promote the care and nurturing of all of God’s creation. We are an institute of people of many faiths, united in our diversity through our common commitment to earthkeeping.  Our aim is to support the faith communities in fulfilling their environmental & socio-economic responsibility.

SAFCEI upholds the core principles of the Earth Charter, including: respect and care for the community of life, ecological integrity, social and economic justice, democracy, non-violence and peace.

We note the devastating impact of global warming and climate change; and the long term negative consequences of the use of nuclear energy and fossil fuels, and their impact particularly on poor and vulnerable communities.  We are committed to working towards achieving a transition to clean energy.

At this critical moment in time, South Africa can play a pivotal role in unblocking the barriers and challenges that have impeded the finalisation of a binding agreement to date.  SAFCEI believes that South Africa’s negotiating experience in overcoming apartheid can be of crucial importance in the upcoming COP21 negotiations.

South Africa’s role as chair of the G77 +China, its participation in BRICS and its leading role in the Africa Group provide an opportunity to push for an ambitious agreement, rather than the minimum to which each country can commit.

South Africa’s INDC needs to express a vision for the future.  The outdated concept of trade-offs between environment and development needs to be replaced with the acknowledgement that future “good” development can only be low carbon development, and that any continuation with business as usual is the most expensive form of development, the negative consequences of which will be borne by society in the future.

The Pope’s Encyclical, and the the Islamic Declaration on Global Climate Change are examples that indicate that faith communities are calling on their followers to respond to climate change, and this provides an opportunity for governments to put forward ambitious targets.

All societal and economic development is based on ecological resources, and successful and sustainable future survival of the human and other species is dependent on the actions we take now.  With Africa, particularly Southern Africa, predicted to be one of the worse affected regions of the globe, we must motivate for ambitious progress at COP21.

Given the predicted impacts on SADC, South Africa cannot hide behind conditional commitments.  Irrespective of the outcome of international agreements, the country will need to adapt, and will have to work with its neighbours to help the region to adapt.   Such adaptation commitments can be put on the international table to show South Africa’s willingness to take responsibility and also to reflect the reality of Africa’s situation.


Specific comments on the INDC

These comments are not necessarily related to specific paragraphs in the text but reflect SAFCEI’s position as related to the INDC proposal as a whole.

SAFCEI supports the highlighted importance of adaptation in the INDC.  It is acknowledged that putting forward South Africa’s historical costs of adaptation (both as part of loss and damage) as well as the cost of adaptation such as working for water etc, is a useful negotiation position.  However, the societal costs are generally borne by poor and vulnerable communities, and these costs are often difficult to quantify.  It might be useful to attempt to quantify the measure that must be put in place to avoid such costs.  SAFCEI supports this initiative and would suggest its refinement in future iterations.

Understanding that the INDC arises from intragovernment department sectoral plans, there is a need for DEA to speak out more strongly in directing different sectoral plans to be amended based on their failure to address climate change effectively.  For example, DEA can call on DoE to complete the IRP and IEP as a matter of urgency because we cannot plan our carbon budgets or trajectories without updated information.

Coal cannot be a fuel resource for the future, and DEA should be stronger in insisting that we cannot continue with coal.  Although the industry often speaks about carbon capture and storage (CCS), this has not proven itself at this point and SAFCEI believes that DEA would be justified in stating that a precautionary approach should be followed – one that does not allow new coal until CCS is commercially proven.

Nuclear Energy is not a cost effective mitigation measure and several studies have shown that renewable energy is the future.  Noting that the nuclear energy deal is not about energy (as shown by the draft IRP2010 prior to policy adjustment which indicated that the best option did not include nuclear energy), SAFCEI therefore believes that nuclear energy should not form part of the INDC.  Rather, the INDC should commit South Africa to the best affordable alternative low carbon technologies and such analysis and cost comparisons (which include externalities) should form part of the mitigation planning ahead of 2020.

In the current economic situation, finances should be directed towards those sectors that can result in the biggest “bang for buck”.  This implies that existing subsidies (direct or indirect) for coal and nuclear must be removed and channelled towards a just energy transition.  Given that water is a scarce resource, there should be an emphasis on climate resilient technologies that reduce our dependence on water.

In the discussion document, there is no mention of the private sector investment in renewables.  This should be reflected as part of how financial flows are contributing to a green economy and transparency is also needed.  The REI4P is widely regarded as successful in putting renewable energy into the grid and has been paid for by private industry.  Additional investment by government into the REI4P could expand renewable energy and lower the carbon intensive portion of the electricity mix.

Government infrastructure plans can lead to lock in of carbon intensive projects such as large road networks, coal mining infrastructure, etc.  Such infrastructure plans need to rather be aligned with a low carbon future.  Adjusting infrastructure plans to align with adaption could lead to avoided costs (eg not putting road infrastructure in flood prone areas or along coastal areas that are likely to be affected by increased storm surges).  As such, the attitude of planners needs to shift from only deviating from business as usual when international funds become available, towards climate adapted development as the new “business as usual”.

The INDC needs to acknowledge the role of the three tiers of government and promote an approach that sees implementation at the local government level.  There should be some commitment in the INDC to work with all tiers of government and that financial flow mechanisms need to enable finance to reach the local level.  This is important, given that 60% of people currently live in cities and South Africa is an urbanising society.

Within the INDC, there is a worrying trend of most commitments being dependent on others agreeing.  This can lead to a stalemate where no one does anything.  Such a conditional commitment is neither in South Africa’s nor the rest of Africa’s interest.  We will have to adapt and the INDC should be firm on this.  The negotiation then becomes about additional proactive adaptation and mitigation actions that can be achieved once the developed countries pay their ecological debt.

It was pointed out that government spends 29% of their budgets on procuring services.  Such procurement, if aligned with climate change goals, becomes a tool for transition.  Such tools need to be mentioned in the INDC as real concrete steps that South Africa will commit to and that will make a real difference to future carbon trajectories.

In the pre-2020 period, there is an opportunity for emphasising communication and training for the low carbon opportunities that could flow from a multilaterally agreed plan which would only come into effect in 2020.  There is a need for preparedness training, and South Africa would demonstrate the seriousness of its commitment if it could point to resources that it is committing to in the INDC for training and public preparedness as part of preparing to implement adaptation and mitigation measures.

As part of our political alignment, the document should clearly indicate South Africa’s commitment to 1.5 degrees, not 2 degrees.  Rather than trying to please everyone with a schizophrenic

approach to the degrees of warming that we support, it would demonstrate leadership if South Africa took a position in line with the Africa position of 1.5 degrees and focused on bringing other parties on board with 1.5.  If there are good reasons for possibly allowing for 2 degrees (for example South Africa’s economic dependence on coal exports in the short term), then such rationale should be transparently available and up for debate and robust interrogation.

South Africa has a paramount aim of addressing systemic poverty and our rationale of labour intensive, economic development that encourages education, training and resilient land management, food security and energy security, can be aligned with the UN Sustainable Development goals.  The INDC needs to reflect such alignment.

South Africa also needs to adopt the moral high ground. We need to acknowledge our historical legacy of contributions to climate change emissions, in comparison to the rest of Africa, and that certain infrastructure decisions have already locked us into a carbon intensive trajectory.  In comparison with the rest of Southern Africa, South Africa needs to own up to its carbon intensity, and lead in additional mitigation action, above that required by most states in Africa.

As South Africa’s energy and transport sector contribute the majority of emissions, spatial planning and infrastructure planning is paramount in addressing climate change.  All infrastructure projects should be reviewed and assessed for their climate resilience.  Electricity sector reform is needed to enable industry to purchase low carbon power, rather than being forced to purchase carbon intensive Eskom power.  Such systemic change details are not necessarily part of the INDC, but the INDC can commit South Africa to systemic change in the transition to low carbon economy, rather than highlighting various projects that are examples of how such systemic changed is actioned.

Acknowledging that such negotiating texts are often closely aligned with international trade, the INDC should seek to commit South Africa to a proactive renewable energy, climate resilient economy that sends firm signals to international investors looking to support such green economic development.  The INDC then becomes a progressive tool for attracting investment in the type of economic development that builds a sustainable, resilient society, rather than our current economic paradigm which attracts investment into exploitative resource extraction that leaves a legacy of destruction for future generations.

Climate Change has been described as a life or death issue.  Our actions in this current time will determine both our species as well as other species survival.  Humans have developed the ability to change the ecological functioning of the planet so far in a destructive manner.  There is a need now to use human ingenuity with compassion to restore the balance of nature that is our life support system.

We believe that faith based communities have a significant role to play in the nurturing and protection of God’s creation. South Africa is a nation of people of faith.  All our faiths speak to the necessity of earthkeeping.

We call on all governments to place environmental justice at the forefront of their agendas, to promote a value based economic system and take steps to safeguard the future of our children and planet Earth.  SAFCEI calls on the South African government to acknowledge our responsibility of earthkeeping and to use the INDC to challenge other nations to join us in an ambitious, visionary commitment to solving the planetary crisis.

We provide this submission in the spirit of constructive engagement, the cornerstone of strengthening our democracy, and look forward to engaging further with the process.



Liziwe McDaid                                                                                   

Programme Coordinator: Energy and Climate Change Programme                                                

Southern African Faith Communities’ Environment Institute

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