Sensible Ambition: Context, how-to-engage and mitigation

This briefing note focusses on highligh2ng key contextual and advocacy considera2ons relating to mitigation in South Africa’s second Nationally Determined Contribution (NDC). It is intended to support and complement NDC related engagement, advocacy and communication from a climate justice perspective.

Reference documents:

Draf Second Nationally Determined Contribution for the RSA1 – issued by the Department of Forestry, Fisheries and the Environment (DFFE)

Draft NDC Recommendation2 – issued by the Presidential Climate Commission (PCC)

THE PROCESSES BEING UNDERTAKEN

• The responsibility for formulating an NDC lies with the DFFE and the minister, and is approved by Cabinet before being finalised and submitted to the United Nations Framework Convention on Climate Change (UNFCCC). The DFFE released a draft NDC for public consultation on 30 July 2025.
• The PCC has been conducting dialogues and stakeholder consultations on the NDC since late 2024. In June 2025 it released a draft NDC recommendation, which is intended to serve as a recommendation in keeping with the PCC’s mandates of advising government on suitable climate change response.
• It is our view that the PCC’s recommendation is generally a reasonably sound document with well-considered and evidence-based motivations for the recommendations contained therein. The PCC secretariat has analysed and commissioned a range of scientific modelling exercises to come to its conclusions on mitigation.
• Commissioners at the PCC are currently divided regarding the mitigation targets in the recommendation come up with certain constituencies favouring the DFFE’s target range, and other commissioners generally aligning with the PCC’s target range or targets that are more ambitious than the recommendation.

ENGAGING ON THE NDC AND KEY DATES

• The DFFE is conducting stakeholder consultations in all of the provinces between 1 and 28 August 2025, as per this schedule. Please contact DFFE directly for further
• The PCC is hosting a national colloquium on the NDC on 26 August 2024 from 09h00 to 16h00. Role players and interested parties are encouraged to attend. The link to register for online participation is hIps://us06web.zoom.us/webinar/register/WN_qAzMgV4iT4LWyf8MefnWA.
• The deadline to submit written comments on the DFFE dra1 is 29 August 2025.

WHAT IS AN NDC?

• A Nationally Determined Contribution (NDC) is a statement of ambition or commitment, and to some degree, a high-level climate action plan submitted by each country under the Paris Agreement.
• The Paris Agreement3 is a global treaty adopted in 2015 where signatory countries commit to limit global warming to well below 2°C, aiming for 1.5°C, through climate action and cooperation. The need to prioritise the 1.5°C target was emphasised at COP 28 in 2023 in what is known as the UAE
• The Paris Agreement stipulates that:
  • “Each Party shall prepare, communicate and maintain successive nationally determined contributions that it intends to achieve. Parties shall pursue domestic mitigation measures, with the aim of achieving the objectives of such contributions.” There are two obligations here: (1) the NDC must be prepared and communicated, and

(2) the countries must pursue domestic mitigation measures (i.e. greenhouse gas (GHG) emissions reductions).

• “Each Party’s successive nationally determined contribution will represent a progression beyond the Party’s then current nationally determined contribution and reflect its highest possible ambition”

Countries are expected to be as ambitious as possible and continuously improve on their last NDC.

• The country’s NDC must reflect “its common but differentiated responsibilities and respective capabilities, in the light of different national ”

This accounts for global climate justice to some extent, recognising that different countries have different developmental needs, capabilities and also different levels of responsibility for past and current emission and global warming. In this way a country like the United States which is responsible for the majority of historical emissions is expected to demonstrate higher ambition then at least developed country with low carbon emissions. South Africa would sit somewhere in the middle of this range being a relatively high emitter with a high carbon intensity economy, but also strong developmental needs and a smaller degree of historical accountability.

KEY CONTEXT AND RECENT DEVELOPMENTS

The 1.5°C target, and where we are currently headed.

• The scientific community, including the United Nations Intergovernmental Panel on Climate Change (IPCC), broadly agrees that limiting warming to 1.5°C over preindustrial levels is important to limit climate impacts as much as possible. Every fraction of a degree over this will have
• Last year 2024 showed a global average temperature increase of 1.55°C and was the hottest year on record. This does not mean that the target from the Paris Agreement has been officially breached, as that target refers to average temperature taken over a number of It does however mean that the 1.5° limit is dangerously close to being breached.
• The IPCC continues to confirm that in order to remain within the 5°C limit, GHGs need to reduce by 43% by 2030 and 60% by 2035 over 2019 levels.
• A 2024 synthesis report4 on NDCs adopted by the United Nations Framework Convention on Climate Change (UNFCCC) shows that if all current NDCs were implemented, GHG’s would reduce by a mere 9% by 2030 and put us on a course of 2.1°C to 2.9°C of warming.
• In terms of real world actions based on existing policies, we are on a pathway to 3.4°C of global warming, according to Climate Action Tracker5
• A United Nations Environment Programme (UNEP) report6 from 2023 highlights that, collectively, governments are planning for 110% more fossil fuel production than is allowed by the 1.5°C
• As can be seen, the collective global poli4cal will, and the general reluctance to commit to steep and decisive fossil fuel phase-out, is sadly lacking and condemning humanity to catastrophic global

The International Court of Justice (ICJ) Advisory Opinion

• In July 2025 the International Court of Justice released an advisory opinion on the obligations of states in rela4on to climate change7. This advisory opinion marks an important milestone in the global recognition of key justice considerations in the international climate change arena.

• Key findings include:
  • The duty to address climate change and mitigate greenhouse gas emissions to prevent global warming exists separately and beyond only the Paris agreement and the UNFCCC. A range of other treaties as well as international customary law also impose these obligations on nations, and failure to do so can give rise to claims of compensation.
  • The Court finds that while the Paris Agreement provides for limiting the global average temperature increase to well below 2°C above pre-industrial levels as a goal and 1.5°C as an additional effort, 5°C has become the scientifically based consensus target, and the parties’ agreed primary temperature goal under the Paris Agreement. The Court adds that this interpretation is consistent with the requirement that mitigation measures be based on the “best available science”.
  • Although the wording of the Paris Agreement suggests that there is a high degree of discretion in what the ambition levels in any NDC can be, it interprets this to find that the discretion is in fact limited. It says that parties are obliged to exercise due diligence and ensure that their NDCs fulfil their obligations under the Paris Agreement and thus, when taken together, are capable of achieving the temperature goal of limiting global warming to 1.5°C above pre-industrial levels. In other words, an NDC that does not align with 1.5°C is falling short of what is

MITIGATION

DFFE draft: weak targets and insufficient ambition

• The essence of the NDC, and what has unsurprisingly turned out to be the most contentious issue, is the actual numerical targets to which South Africa commits itself in terms of GHG emissions
• South Africa, like a number of other nations, expresses its targets as a range rather than a single The thinking behind this is that South Africa will attempt to achieve the upper end of the range without any additional support (such as climate finance from the developed nations), and will attempt to achieve the lower end of the range conditional on receiving such support
• Like all nations, South Africa had an opportunity to revisit and strengthen its 2030 targets, but the DFFE chose not to revise these figures and they remain unchanged in the current The range for 2026 to 2030 is 350 Mt CO2e to 420 Mt CO2e
• Paris agreement par4es are also required, in this round of NDCs, to set a target for the period 2031 to 2035, which has been proposed as being 320 Mt CO2e to 380 Mt CO2e.
• For reference the 9th Greenhouse Gas Inventory Document8 reports that 2022 emissions for South Africa were 478 Mt CO2e (if land use, land use change and forestry – or LULUCF – is excluded) and 435 Mt CO2e if LULUCF is included (because of 43 Mt CO2e of carbon being stored mainly in what are being called “forest lands”). Also for reference, the 2021 NDC update had a range of 398 Mt CO2e to 510 Mt CO2e for 2021 to 2025. 2009 saw the highest emissions ever, at 546 Mt CO2e.
• The DFFE draft vaguely refers to 3 UCT studies from 2025 as forming the technical analyses that have been conducted in order to motivate the proposals in the draft There is very little detail on how the findings of these studies have influenced the draft, and at the date of writing this note, they have not been released for public scrutiny.

How this compares to the PCC draft recommendation

• The PCC’s draft recommenda4on, like that of the DFFE dra1, recommends leaving the 2026 to 2030 target range of 350 Mt CO2e to 420 Mt CO2e unchanged. It does however acknowledge that all efforts should be made to achieve reduc4on values well below the upper end of the
• For the 2031 to 2035 period, however, the PCC mo4vates and recommends a more ambi4ous range of 248 Mt CO2e to 329 Mt CO2

PCC-analysed studies – evidence for sensible ambition

• As an evidence base for formula4ng, and mo4va4ng for, this target, the PCC analysed a number of studies, models and
• The Energy Systems Research Group (ESRG) at UCT was commissioned to conduct a Net Zero Pathways research project by the PCC in 2024. Findings include:
  • Calculations that South Africa’s fair share9 of the remaining carbon budget from 2021 to 2050 would be in a range of 6 Gt CO2e to 9 Gt CO2
  • There are negligible economic benefits of exceeding a national carbon budget of 10 Gt CO2e, and new or elevated risks are
  • It is possible to increase GDP per capita by 120% from 2021 to 2055 and reach net zero by 2050 by imposing a long term GHG budget of 8 Gt CO2
  • There is minimal difference to the economy between pursuing an 8 Gt CO2e and a 10 Gt CO2e budget, and these differences are likely to be eradicated if consideringbenefits from improved air quality and reduced water resource impacts, as well as inves4ng in energy efficiency and accessing concessional finance.
  • A fair share for South Africa 2035 emissions lies in a range of 248 Mt CO2e and 329 Mt CO2e, (the range recommended by the PCC).

• National Business Initiative (NBI) commissioned a study in the early 2020s to explore implications of a net zero Its findings include:
  • South Africa can technically achieve a national budget of 9 Gt CO2 and reach netzero emissions by 2050 if renewable energy is deployed tenfold faster (6-7 gW per annum), coal power is fully retired by the mid-2040s, road and rail mobility is electrified, among other measures.
  • 5 million net job years could be delivered, offsetting losses in coal and other sectors while safeguarding export competitiveness. It also reports that carbon border measures could place 50% of trade value and 1 million jobs at risk without this decarbonisation.
  • A fair share for South Africa 2035 emissions is 310 Mt CO2
• The World Bank Country Climate and Development Report (CCDR) analyses emissions by sector until 2050 within a 9 Gt CO2e na4onal carbon budget. Its findings include:
  • 58% of emissions reduc4ons in South Africa should occur between 2030 and
  • South Africa’s export orientated economic structure is at escala4ng risk due to carbon border It highlights that 75% of South Africa’s current exports to the EU come from sectors at moderate to high trade risk including mining metals agriculture chemicals plastics and rubber.
• The globally regarded Climate Ac4on Tracker10 (CAT) has calculated that a fair share for south Africa of 291 Mt CO2e for
• The Climate Equity Reference Calculator11 (CERC) has calculated that a fair share for South Africa would be between 306 Mt CO2e and 320 Mt CO2e for 2035

Best available science

• The Paris agreement refers to using the best available science, or best available scien4fic knowledge to guide climate action under the agreement
• South Africa’s Climate Change Act states that “the need for climate change mitigation and adaptation responses to be informed by evolving climate change scientific knowledge and decisions which must be based on the best available science, evidence and informa2on”

Comparing the PCC draft recommendation with the DFFE draft NDC

• While the DFFE draft does reference technical analysis, it does not satisfactorily reference any publicly disclosed studies or modelling to justify its 2035 target
• The PCC draft on the other hand goes into depth, referencing a diverse range of studies models and calculators. We are of the opinion that the PCC draft targets are far more thoroughly motivated and can be said to be referencing the best available science that studies climate and economic impacts in the South African context. This includes climate science and the quantified need to reduce greenhouse gas emissions as well as economic considerations such as GDP, employment impacts, economic diversifica4on and economic opportuni4es in decarbonization scenarios.

• Collectively the PCC studies all tend to agree that there is a ‘sweet spot’ economically and that overly diluting ambition with weaker targets does not lead to economic benefit and introduces new These studies show that decarbonizing too quickly would also lead to negative impacts. The PCC draft targets lie within this ‘sweet spot’.

None of the draft targets are adequately safe

• A number of the most recent credible scien4fic es4mates suggest that we have a total global remaining carbon budget of between 170 Gt CO2e and 235 Gt CO2e to have a 50% chance of limi4ng warming to 1.5°C average
• Recent es4mates are that we need to reduce GHG emissions by between 9 and 17% per year.

The benefits of sensible mitigation ambition

• Safety and physical climate risk: South Africa is suscep4ble to droughts and dry spells, heat waves and extreme heat events, flooding, wildfires and increased exposure to tropical cyclones as a result of global warming. These physical impacts in turn translate to increased risks with regard to food sovereignty, water security, infrastructure damage, climate migration, health and The science agrees that every fraction of a degree counts and that failure to limit warming will resulting intensifying impacts and the risk of breaching various tipping points from which there is no return.
• Economy: The studies analysed by the PCC show clearly that inadequate ambi4on (weak targets) do not provide any economic benefit and introduce new Conversely, strong common sensible ambition can lead to diversification in the economy green and climate friendly industrialization cover more employment and safe communities stop
• Transition risks: Carbon border mechanisms have been adopted by the EU and are being considered by other na4ons and trading partners and pose a threat to South Africa’s exports that have a high carbon footprint stop this impact to trade will lead to further economic hardship and unemployment. In addition to such measures undertaken by states and blocs, consumers and markets are increasingly sensitive to the carbon footprint of goods and services. And South African exporters will be disadvantaged due to high carbon footprints. Climate litigation is on the increase, and some 2000+ climate cases worldwide indicate that there is litigation risk call any role players who failed to adequately implement climate change response measures. The ICJ AO underscores this and gives rise to even higher litigation
• Access to climate finance: South Africa has been an aIractive destination for climate finance based on stated commitments and the relative simplicity of decarbonising our coal intensive electricity Grantors and funders have an interest in monitoring and evalua4ng our progress in this regard and inadequate ambition creates the risk that match needed equitable climate finance will be diverted elsewhere it stopped
• Health and environmental co-benefits: strong ambi4on that compels greenhouse gas emissions reduction will also result in reduced air pollution and associated health impact and economic costs. Also lead to the preserva4on of scarce freshwater

Brandon Abdinor, Centre or Environmental Rights 22 August 2025