Dear Portfolio Committee on Forestry, Fisheries and the Environment

Natural Justice: Lawyers for Communities and the Environment (NJ) is a pan-African non-profit organisation rooted in the struggles of communities across Africa. As a team of pioneering lawyers and legal experts, we specialise in human rights, environmental, climate, land, indigenous peoples', and heritage law in pursuit of social and environmental justice.

Following the Department's briefing to the Committee on 29 September regarding progress under Operation Phakisa's Biodiversity Economy Programme, Natural Justice respectfully wishes to raise the following question and recommendation for the Committee's consideration as it continues its oversight of the programme's implementation.

Question

Given the Committee's repeated concerns regarding transformation, equitable participation, and community benefits within the biodiversity economy, should the Department of Forestry, Fisheries and the Environment (DFFE) be required to report annually on biodiversity economy outcomes using indicators that measure equity, inclusion, ownership, income distribution, and access to decision-making processes?

Recommendation

To strengthen accountability and ensure that biodiversity economy initiatives contribute meaningfully to social and economic transformation, Natural Justice recommends that DFFE incorporate environmental justice indicators into its Annual Performance Plan and annual reporting framework. These indicators should measure, among other things:

Community ownership and control of biodiversity economy initiatives;
Equitable benefit-sharing arrangements;
Gender equity and youth participation;
Land tenure security; and
Access to biodiversity-related economic opportunities for historically marginalised communities.

We therefore petition the Committee to require transparent and publicly accessible reporting on the beneficiaries of biodiversity economy investments. While economic growth remains an important objective, it should not be regarded as a measure of success where structural inequalities in ownership, decision-making power, and access to benefits remain unaddressed. Meaningful transformation requires evidence that biodiversity economy programmes are advancing inclusion, equity, and environmental justice for communities whose livelihoods and wellbeing are intrinsically linked to biodiversity resources.

Yours sincerely,

Natural Justice: Lawyers for Communities and the Environment