Please submit by the 5th of June your comments to the proposed NATIONAL CLIMATE CHANGE ADAPTATION STRATEGY SOUTH AFRICA.

Find below our guideline to easily submit.

SUBMISSION GUIDELINE – To send by the 5th of June


The Director General

Department of Environmental Affairs

Attention: Mr Sibonelo Mbanjwa

Private Bag X447

Pretoria 0001

South Africa


Dear Mr Mbanjwa,

Re: Submission – National Climate Change Adaptation Strategy (NCCAS) South Africa

 As a Conservationist/







Private individual,

Wildlife passionate,

We would like to highlight the importance of more consistently including biodiversity and wildlife in the NCCAS for the role nature has in climate adaptation.

Whales have been indicated among the ocean heroes capable to mitigate Climate change.

Credit: Mother Jones – Environment


  1. As your comprehensive analysis for Climate Change Adaptation reports, Adaptation and Mitigation are and must be strictly connected. It is crucial to include in the NCCAS also elements capable of Reversing the climate crisis. Among the key factors and not sufficiently emphasised in this Draft, is the role of wildlife.   Nature represents a very complex and structured system on which all life on the planet is based. The disappearance of non-human species will exponentially accelerate the process of global warming since they play a key role in mitigating climate imbalance. Wildlife species directly impact on weather, temperature and humidity and ultimately Reverse climate change. Hence not prioritizing the protection and, when necessary, the least invasive possible AID to wildlife and bio-systems, in our strategies, will result, long and short term, in failure.
  2. It is crucial to always consider Mitigation AND Restoration as intrinsically connected to our Adaptation In fact, adapting to life in a changing climate, must involve adjusting to actual or expected future climate instability in ways which will not contribute to further decline. The goal should be to both Reverse the process and reduce the vulnerability of all life to the harmful effects of climate change. It also means making the most of any potential beneficial opportunities associated with managing the process in ways which will not contribute to further decline.
  3. Studies suggest that larger species mostly contribute to Climate mitigation but are also the most threatened and predict that the progressive disappearance of large species will significantly accelerate the climate crisis. Nature, also, acts as our oxygen pump, food and food pollinator, air and water filter, fire and flood preventer and barrier, seed disperser, fertilizer, pesticide, medicine, composter and more.
  4. We are particularly concerned to read in the NCCAS Draft, concepts such as “responsible mining” or “sustainable drilling”. The Kyoto Protocol goes back to 1992 with a commitment from 192 countries to reduce greenhouse gas emissions in order to mitigate climate change, with South Africa being currently one of the worst countries in terms of failing to respect the deadlines in the progressive transition to innovative energy. South Africa is still massively investing in coal mining and renting land in-and offshore areas to companies such as Total, ENI and Shell, for their oil explorations and drilling, also near protected areas and fracking in regions at high desertification risk. These companies are reported to be among the 100 companies responsible for our climate’s imminent collapse. These companies have also failed to initiate any process of transition towards clean energy in the last three decades. Oil explorations are still authorized on our whale breeding routes while whales play a vital role in climate change mitigation. Whales bring nutrients up to the surface of the ocean stimulating organisms that absorb CO2. They also produce a substance rich in iron and nitrogen, which in turn is nourishment for plankton. Plankton absorbs CO2 and when it dies it takes stored carbon to the bottom of the ocean where it remains permanently out of circulation. Scientists have indicated that up to one third of our carbon fossil emissions are absorbed by our oceans and our marine life.
  5. South Africa is a signatory of the United Nations Agenda 2030 Sustainable Development which launched in New York on September the 25-27 2015 and where Goal no. 14 reads “Life below the Water” and Goal no. 15 reads “Life on Land”.
  6. Life and Biodiversity must surely be emphasized and more consistently included in all sections of the NCCAS.


a. Page 06, Strategic Focus,

3.2. Principles and key elements of adaptation and climate resilience

“Human centred”

COMMENT This is problematic and against biodiversity. It should read “Life centred”

Page 06 “Environmental support for climate adaptation: The development and implementation of the NCCAS will promote the protection of ecosystems and biological diversity that are required to support South Africa’s adaptation to climate change”.

COMMENT This seems to be selective to certain eco-systems while biodiversity is, instead, all interconnected.


b. Page 07, Strategic Focus, 3.3. Strategic objectives

Objectives 3 and 4: “Ensure resources and capacity to respond to impacts”.

COMMENT This should include the protection and, when necessary, the least possible invasive AID to wildlife and bio-systems threatened by Climate change. This should include passive AID as, for example, temporarily suspending the use of biological resources.


c. Page 09, Strategic Focus, 3.6. Linkages between strategic objectives, interventions and outcomes

Objective 1: “Reduce human, economic, environment, physical and ecological infrastructure vulnerability and build adaptive capacity”

COMMENT This should include biodiversity and wildlife vulnerability


d. Page 10 Reduce Vulnerability and Build Adaptive Capacity/ Introduction

“Increased resilience and adaptive capacity achieved in human, economic, environment, physical and ecological infrastructure vulnerability”(StrategicOutcome1.1)

COMMENT Include wildlife


e. Page 10 Reduce Vulnerability and Build Adaptive Capacity, 4.2. Scale of interventions

“A common approach that has been used is ecosystem-based agriculture which involves restoring ecosystems and by doing so reducing the vulnerabilities of communities”

COMMENT In order to reduce impacts, we urge the Government to explicitly mention the gradual shift towards vegetable protein plantations, human herding and biological pesticides. Resources or benefits should be allocated to promote such transition and also the gradual removal of abandoned fences, which cause fragmentation and have other negative impacts on communities and wildlife


f. Page 11 Action 1.1.1

“Support the agricultural sector to implement more efficient climate-smart and conservation agriculture practices.”

COMMENT South Africa should move towards a drastic reduction of pesticide and pollutants


g. Page 11, 4.3. Actions

OUTCOME 1.1: “Increased resilience and adaptive capacity achieved in human, economic, environment, physical and ecological infrastructure vulnerability”

COMMENT Include wildlife


h. Page 11, 4.3 Actions, Action 1.1.5

“This will involve identifying vulnerable ecosystems that need further protection from impacts of climate change. Enforced action is required against illegal harvesting of coastal and offshore fish stock, ecosystem-based approaches are also recommended to ensure the recovery of freshwater and marine fish stocks. Monitoring and controlling alien invasive species that benefit from climate change will reduce the risk of biodiversity loss.”

COMMENT Add “Protect eco-systems and wildlife from invasive agents from land alteration to contamination and pollution”.


i. Page 11, 4.3 Action, Action 1.1.10,

“Create a more adaptive electricity system to reduce dependence on a centralised system and increase distributed generation, especially in rural areas.”

COMMENT “Create a more adaptive CLEAN electricity system”


l. Page 12, 4.3 Action, Action 1.1.17

“Develop guidelines on environmentally responsible mining practices that promote climate adaptation.”

COMMENT We find this very problematic and contradictory. Guidelines are not to be considered as a sufficient frame to regulate what will be permitted, restricted and prohibited in actions such as mining, drilling, fracking; these human activities cannot specifically be defined responsible actions in a NCCAS which visions the protection of communities as a priority or, in addition, lives and biodiversity. South Africa has also international commitments to reduce carbon emissions, which it is failing to comply with.


m. Page 12, 4.3 Actions, Actions 1.1.19

“Invest in high-quality, climate resilient, public infrastructure.”

COMMENT “Invest in high-quality, climate resilient and eco-sustainable/ reduced impact / public infrastructure and materials”


n. Page 14, 5. Early Warnings Systems, Disaster Management Warning Systems

“National Fire Danger Rating System (NFDRS)-Prevention of fires”

COMMENT Human negligence is often the cause of destructive wildfire ignitions. Despite this, legislation is slow in framing where and if the public is forbidden to light fires or cigarettes, as for example near extended vegetation or in vehicles/cars


o. Page 40, ANNEX A: Proposed key messaging for CCA Communication and Outreach Programmes / Adapting to build a strong   South Africa has been conceptualised as the key message of the NCCAS.

“Linkages between adaptation and mitigation are increasingly vital”

COMMENT Biodiversity and wildlife are “healers” and hugely contribute to the mitigation of climate unbalance and the restoration of life we, as humans, rely on.


p. Page 42 ANNEX B: Indicators for monitoring and evaluation of the NCCAS Strategic Outcomes / STRATEGIC OUTCOME 9.1: A National M&E System Developed and Implemented by 2015

“Waste Management Plans, Alien Invasive Strategies, Environmental Impact Assessments…”

COMMENT Add biodiversity and wildlife