SEA comments on the Climate Change Bill

On the 8th of June 2018, the Department of Environmental Affairs published the Climate Change Bill for comment.

It’s stated objectives are the following:

On 8 August 2018, SEA submitted comments on the Bill. In summary,  

1. SEA sees the Bill as an important step to giving much-needed traction to climate change to enable
long-term accountability of the state as a whole, distinguished by the three spheres of government.
2. However, in order to achieve the goals of reducing emissions, a realistic view of the role of the
electricity sector must be included such that the penalisation of local government, the private sector
and the general public, who are held hostage through the coal burden and the monopolisation of the
sector, can be put in perspective. SEA trusts that the carbon budgets which are yet to be formulated
will be just and based on feasibility.
3. Regulatory reform and transformation of the electricity sector is thus key to reducing GHG emissions,
and should precede the Act.
4. The Bill requires a strong institutional set up to ensure that it is given the power that is required to be
successfully implemented. All spheres of government should be engaged strongly. There is currently a
successful climate change forum that is convened by DEA which should be incorporated into the
Ministerial Committee. Public participation is also crucial.
5. It is critical that the Bill create an enabling environment for positive movement during the transition
to a low-carbon development and thus also speak to empowering local government and business,
vulnerable small and medium enterprises in particular, in order for compliance/transition to be
6. Municipalities require funding which is easily accessible, and skills to implement the Bill, and this
limitation must be taken into account.
7. Environmental legislation is difficult to implement by its nature and the more so in a poorly
performing economy and so the Bill should be far more specific about implementation structures.

The full response can be found here.