Ignoring Climate Change Will Cost Pakistan Dearly

This article is part of a series titled “Is there a way forward for Pakistan?” Read more about the series here.

In this article, I will present an overview of the state of knowledge, institutions, policies, plans, and strategies that deal with climate change at both national and provincial levels in Pakistan. It is imperative to first understand what the global climate discourse is, and how far Pakistan’s policies and action plans are aligned with the global parlance, particularly the science as summed up in the IPCC reports and action orientation as adopted in the Paris Agreement. A stronger alignment of climate action with global discourse is important for Pakistan in order to benefit from international scientific research, technology, and international climate finance.

Let’s first have a summary of the global trends in climate science and its bearing on Pakistan’s climate policies and actions. This will be followed by an assessment of Pakistan’s climate-related institutions and their mandates. Finally, I will present a review of policies ad plans through the prism of Pakistan’s commitments, made in its NDC, or the Nationally Determined Contributions. The article underlines the need for Pakistan to upgrade its policy landscape and regulatory architecture to meet the Paris Agreement. 

1. State of the Existing Knowledge  

This is not a comprehensive or exhaustive review of the existing literature, but a bird’s eye view of some of the more prominent studies and policy documents that have informed and shaped the climate discourse in the country. 

Genesis of Climate Policies:

No other scientific source has informed and influenced the global climate discourse, including Pakistan’s national climate policies, than the Fourth Assessment Report by Intergovernmental Panel on Climate Change (IPCC) released in 2007. This report, known as AR-4 attributed, for the first time, global changes in climate change to anthropogenic factors (IPCC, 2007). Soon after the AR-4 was released, Pakistan Planning Commission set up a Task Force on Climate Change (TFCC) in 2008 to investigate the impact of climate change on the country’s agriculture, economy, energy, and water. The TFCC was the first serious effort in Pakistan to understand the effects of climate change and to devise an adaptation strategy for Pakistan based on IPCC reports. It provided a comprehensive framework for addressing issues that Pakistan faced due to changing climate (GOP, 2010).

Subsequent policies in Pakistan are indebted to the structure and contents of the TFCC report, particularly the National Climate Change Policy 2012 (GOP 2012), Framework for the Implementation of Climate Change Policy 2013 (GOP 2013), and the Nationally Determined Contributions 2016 (GOP 2016). All these documents were developed prior to the special reports by IPCC, released after the Paris Agreement (IPCC 2018, IPCC 2019, IPCC 2019b).  The Special Report on Global Warming of 1.5°C needs a specific mention as it examined various pathways to limit warming to 1.5°C, what it would take to achieve them, and their consequences. It explained that global anthropogenic carbon dioxide (CO2) emissions would need to decrease by about 45% from 2010 levels by 2030, reaching net zero by around 2050. The report also acknowledged that limiting warming to 1.5°C would require the use of “negative emissions technologies” (NETs), often known as carbon sequestration, in order to bring warming back down if global temperatures do overshoot 1.5°C, large-scale use of NETs will be required. Two subsequent reports issued by IPCC on the request of the secretariat of the climate change convention, known as the United Nations Framework Convention on Climate Chante (UNFCCC) have only added to the urgency for accelerating climate actions and efforts in all sectors. 

The Mainstreaming Challenge: 

With these reports, global and national efforts have decisively moved towards climate resilient and low carbon development, reflected in the global discourse on resilient development through net zero emissions and decarbonization. This new global knowledge was adopted by the international community as Paris Agreement. As we will see now, most national climate and sectoral policies in Pakistan have not been systematically aligned with Pakistan’s commitments made under the Paris Agreement. The mainstreaming of climate change, therefore, continues to be a serious national and provincial level challenge. A new set of policy reforms and regulatory mechanisms will be needed to comply with the recommendations of AR-6. 

Most of Pakistan’s federal policies and guiding documents have not embedded climate change. Except for the National Water Policy, climate change continues to be a standalone concern in Pakistan’s national policy milieu, barely getting more than a passing reference. The provincial documents rarely mention climate change, betraying the state of existing knowledge, research and human resource capacities. Punjab Growth Strategy 2015 (GOPb 2015) did not even mention climate change and its revised version that covers 2019-2023 (GOPb 2019) has also not systematically addressed climate change. Likewise, Sindh Poverty Reduction Strategy 2020 (GOS 2017), KP Integrated Development Strategy 2014-2018 (GOKP 2014), and Balochistan Comprehensive Development Strategy 2013-2020 (GOB 2013) that are supposedly provincial planning documents, do not have any reference to climate change. These documents have not acknowledged the existence of the National Climate Change Policy (NCCP), the Framework for the Implementation of Climate Change Policy (FICCP), or the actions committed by Pakistan in its ‘Intended’ Nationally Determined Contributions (NDC) submitted to UNFCC secretariat. All these documents were presumably developed after seeking comments from the provincial or engaging them in consultative processes.   

There are no regular annual reports on the state of climate change or the environment at national or provincial levels, nor there is a repository where the reports could be accessed. Except for the Sindh State of Environment & Development which was printed 20 years ago (IUCN 2004), there are no national or provincial reports on the state of the environment or climate change printed by any national or provincial government. The first report released by the Ministry of Climate Change (MoCC) was the Environment and Climate Change Outlook of Pakistan (MOCC and UNEP 2014), followed by the Annual National Report on Environment of Pakistan in 2016 (MOCC 2016). There were no subsequent annual reports. Likewise, MOCC has not released any periodic status reports on the implementation of NCCP, FICCP, or NDC implementation. This is a void that has not been filled by think tanks, universities, UN agencies, bilateral donors or multilateral development banks. 

Most of Pakistan’s federal policies and guiding documents have not embedded climate change. Except for the National Water Policy, climate change continues to be a standalone concern in Pakistan’s national policy milieu, barely getting more than a passing reference.

From among the multilateral development banks, the World Bank’s flagship study, Pakistan Strategic Country Environmental Assessment Report in 2006 estimated that environmental degradation was costing Pakistan’s economy 6 percent of GDP. Two years later, the Asian Development Bank (ADB) released its Country Environmental Analysis in 2008 (ADB, 2008), followed by a comprehensive compilation on the Climate Change Profile of Pakistan (ADB, 2017). The World Bank has also recently released Opportunities for a Clean & Green Pakistan: A Country Environmental Analysis (World Bank, 2019). Whereas the ADB profile provided a summary of ADB initiatives and ADB’s climate risk screening approach, the World Bank report focused, among others, on strengthening regulatory frameworks for air quality, toxic waste, industrial policy, and water quality. The most comprehensive and seminal report in this regard is CCDR, or the Climate Change and Development Report (World Bank, 2022). The CCDR has pointed out that the combined risks of extreme climate-related events, environmental degradation, and air pollution are projected to reduce Pakistan’s GDP by at least 18 to 20% by 2050. 

Economic Cost of Climate Change:

There are no systematic or scientific studies to measure the economic cost of climate change, not there are any mechanisms in place to collect data and release periodic reports and projections. The cost of climate-induced disasters in Pakistan started primarily with the Preliminary Damage and Needs Assessment in 2011, following the super floods (GOP, ADB, World Bank. 2011). Earlier in 2014, a study by ADB had estimated that the economic cost of climate change would increase over time for South Asia and become the equivalent of 1.8 per cent GDP by 2050 (Mahfooz Ahmed, et.al, 2014). The World Bank in 2018 undertook an assessment of how climate change will adversely affect the standard of living in South Asian countries (Mani 2018). There are no key sectoral studies for agriculture, water, hydroelectricity, or water-induced disasters. The cost of development was projected by (Markandya, 2018), arguing that Pakistan would find it not possible to meet its growth or SDG targets.

Except for the climate public expenditure review by UNDP (UNDP, 2017) showing that Pakistan was spending about 8 per cent of its budget on activities related to climate change, there are no other studies regularly estimating the economic cost of climate change. The NEEDS study had projected resources needed for adaptation (UNDP 2011) and mitigation (UNDP 2011a). The CCDR has presented estimates of climate costs to various sectors but as for the Government of Pakistan, Pakistan Planning Commission in October 2022 released its Post-Disaster Needs Assessment (PDNA) report presenting sectoral estimates of damages and losses in various sectors because of 2022 Super Floods (GOP, Planning Commission, 2022). Providing an analysis of the impact of a disaster on a country’s social, economic, and physical infrastructure, the PDNA has committed to resilient reconstruction. It has included a resilient recovery strategy that outlined the steps needed to rebuild and recover from the disaster. Except for initial efforts by UNDP (GOP 2017) or CCDR (2022) mentioned earlier, there are no systematic efforts to mainstream climate change into public economic and financial management. 

Climate Modelling Gaps:

Pakistan’s capacity for climate projections is limited and underutilised, especially for climate, hydrological, economical, and agricultural modeling capacity. In fact, the capacity has stagnated over the years and now the National Institute of Oceanography (NIO) has ceased to monitor seawater rise. Global Change Impact Study Center (GCISC) is the research arm of the MOCC charged to undertake scientific research and provide information on climate change and its impacts in Pakistan. Established in 2002, it initially undertook some studies of climate impact on agriculture and water but it no longer undertakes studies to measure or project the climate impacts on various sectors. SUPARCO has used its satellite imagery to monitor change in forest cover and Pakistan Met Department (PMD) has used outputs of Global Climate Models (GCMs) for downscaling at a regional scale using Regional Climate Models (RCMs) on its supercomputing facilities. Only a handful of universities or research centres have developed computational resources to perform simulations. The capacity in water and climate modelling is probably stronger at universities than at government research institutions. The government’s research centres, however, are not connected with academia and there are hardly any protocols for data sharing, models, computational resources, and capacity coordination. The policy interventions are needed to enhance data sharing and reuse, support improved scientific and technical data management and good practices by promoting Open Science and FAIR (findability, accessibility, interoperability, and reusability) data principles. 

Sectoral Research Gaps:

Environmental Issues: Many environmental issues have received some attention, even if there is hardly any time-series data on these issues by federal and provincial governments. There are mostly case studies on air and water quality, pollution, industrial discharges and generally dealing with specific water bodies. Note for example, studies on drinking water (Daud, MK, Nafees, M, Ali S, et. al (2017), water shortage, and pollution from a public health perspective (Nabi, Ghulam; Ali, Murad; Khan, Suliman & Kumar, Sunjeet. (2019), or on water pollution as a risk to public health (Sleet, Phaebe (2019). There has been some monitoring of pollution load in water bodies, particularly river Ravi and transboundary nullas by WWF and PCRWR. The data on groundwater abstraction by WASAs in several cities is typically fragmented, dated, and generally not accessible.    

Extreme Weather Events: Compared to floods, most extreme weather events like tropical storms, heatwaves, droughts, flashfloods, landslides, and climate-induced migration have received modest attention from research and policy communities.  Heatwave in Karachi in 2013 get some traction from the Ministry of Climate Change, and released a report prepared by a technical committee (GOP, 2015). The government of Sindh developed a Heatwave Management Plan for Karachi (GOS, 2016) and the NDMA released a toolkit for South Asian Cities (GOP, 2016). There have been very few studies on droughts that both Balochistan and Sindh have been in grip of for many years (SDNA 2019). Nutrition and stunting have emerged as major challenges, particularly in Sindh and Balochistan, but there have not been any provincial-level studies (SUN, 2018).  

Air Quality: There has been a growing interest on the issue of air pollution. Starting with a World Bank report (Sanchez and Ernesto, 2014) that focused on cleaning Pakistan’s air, some other scholars (Greenstone, et. al 2019). In reality, most provincial governments stopped monitoring air quality some years ago. Pakistan is regarded as one of the most polluted countries in the world, with air pollution shortening the average Pakistani’s life expectancy by 4.3 years relative to what it would have been if the World Health Organization (WHO) guideline was met. All of Pakistan’s 212 million people live in areas where the annual average particulate pollution level exceeds the WHO guideline, and 99% live in areas where it exceeds Pakistan’s own air quality standard. Some areas of Pakistan fare much worse than average, with air pollution shortening lives by almost seven years in the most polluted areas. The current PM2.5 concentration in Pakistan is 3.5 times above the recommended WHO limit for 24-hour air quality guidelines value. The cities with the highest levels of pollution are Faisalabad, Lahore, Peshawar, and Karachi. Indoor air pollution is also a significant problem in Pakistan due to harmful gases from cooking fuels such as wood, crop wastes, charcoal, coal, and dung, dampness, mold smoke, and chemicals from cleaning materials. 

While Pakistan has air and water quality standards, confusion prevails regarding national and provincial policies. Further, while the standards require some tightening and upgrading, the key challenge is stronger monitoring, data generation, and enforcement.

Water: Water and agriculture and particularly the Indus basin are well-researched, and serve as the backbone of Pakistan’s agricultural economy and food security. John Briscoe’s Pakistan’s Economy Running Dry (Briscoe, et el, 2005) and a report by Friends of Democratic Pakistan have provided a solid foundation for subsequent work on Pakistan: Getting More form Water (William Young, et. el, 2018) and a study on managing groundwater resources (Lytton 2021). In a specific climate change context, impacts of climate risks on water and agriculture, based on revised Indus basin modelling (Winston, et. el, 2013) and the vulnerability of Pakistan’s water sector (MOCC & UNDP 2016) are important primers. Young has provided an elaborate bibliography of substantial work in various fields touching on pricing, productivity and governance. While there have been some significant technical studies on the water sector by the World Bank and others, its nexus with agriculture, resilient infrastructure, and urban vulnerabilities have not as yet been systematically undertaken at the national level, particularly in the context of institutional capacities needed to undertake near- and long-term actions.  

Perhaps no other aspect of the Indus basin has received as much attention as the Upper Indus Basin (UIB), and the receding glaciers. Some aspects that have received special attention include how climate change is impacting the glacial mass, and propelling their melting (Immerzeel, Walter W., et.al. (2010), approaches to GLOF risk reduction (Arshad, Naz & Ruhi. 2015), or the flood hazards in Hindukush, Karakoram and Himalayan ranges of Pakistan (Arshad, Naz and Ruhi (2012). 

Pakistan Council of Research in Water Resources (PCRWR) is the research arm of the Ministry of Water Resources (MoWR). It is mandated to conduct research on water resources and provide guidance to the government on water management policies. It also monitors water quality and provides information to the public about safe drinking water. Several studies by PCRWR on groundwater, particularly the investigation and mapping in the Lower Indus (Iqbal, N, & Ashraf, M, 2020) and Upper Indus (Khan, A.D., et.el, 2016), and (GOP (2016a) are particularly important for their policy uptake. Perhaps no other institution has drawn more attention to Pakistan’s growing water scarcity by linking it to the growing population and declining per capita availability than PCRWR (Ashraf, 2020). 

Seawater: There is no scientific data collection of seawater intrusion or increasing frequency of tropical storms in the country. Most studies on seawater intrusion are based on international scientific literature and come mostly from academic institutions (Sial, A.A., 2018; Rabbani, M.M, et. al 2008) and government institutions. Some researchers have assessed the impact of seawater intrusion on soil, water, and the environment on the Indus delta using remote sensing tools (Siyal, Altaf Ali, 2018). In a similar vein, IUCN study on environmental degradation because of seawater intrusion (IUCN, 2003) and the Bux Mullh survey to study how it was adding to social inequality and shrinking livelihoods (Bux Mullah, Hussain, (2009) have not been updated.

2. State of Institutional Capacities

Pakistan was perhaps the first country in the world that established a ministry dedicated exclusively to climate change. The decision was primarily driven by internal political compulsions rather than any earnest commitment to national climate action. A constitutional amendment in 2012 relegated the environment to the provinces as a subject, and dissolved the Ministry of Environment. In reality, the climate ministry has still not begun to inform the national development agenda, policy planning, or sectoral policies and priorities at national and provincial levels. This is reflected in the state of research or technical and scientific knowledge, institutions, and national and provincial policies and action plans.

To begin with, the NCCP was approved before SDGs, Sendai Framework or the Paris Agreement were signed. Several issues and concerns that have come to dominate national and global discourse are not fully reflected in the policy. A 5-yearly review was proposed in the policy and a revised NCCP, released in 2021 (GOP, 2021) has not fully filled these gaps and it has, instead, simply added some more desirable actions in a long list of immediate, medium, and long-term policy actions. 

As the focal point ministry, MOCC is not only the architect and custodian of the national climate change strategies and policies but it is also responsible for climate planning, mainstreaming, and global reporting on Multilateral Environmental Agreements (MEAs). It is mandated to develop plans and frameworks for  MEA implementation. Additionally, MOCC is responsible for the formulation, revisions, and finalization of the NDCs for submission to the UNFCC secretariat. 

Projects by Pakistan’s bilateral and multilateral development partners, covering such as carbon taxation, national income accounting, blue carbon, modelling (CGI), and energy transition towards decarbonization did not formally follow the climate portfolio in agriculture, water, disaster risks, and urban planning at federal and provincial levels, as defined by climate policies or action plans. No systematic analysis has as yet been undertaken of these projects and their contribution to climate readiness in terms of adaptation or mitigation.

This coordinating role requires strong scientific and technical knowledge and the ability to lead and coordinate federal ministries and provincial departments. In reality, the ministry’s technical capacity has always remained weak. Most of the technical units established were supported by donor agencies and vanished almost always soon after their interest waned. This technical weakness is reflected in the ministry’s inability to work closely with provinces to develop their respective climate policies and action plans, engage with the sectoral ministries and departments to embed climate change in their policies and plans or develop national adaptation and mitigation plans, even if finances form the donors were made available several years ago. The NCCP has presented a long list of desirable actions, including policy measures, but has not actually made any efforts on its own or jointly with concerned sectoral ministries or departments. Most of NCCP and FINCCP targets were not explicitly covered by NDC. There were only scant references to the NCCP and the Framework in the NDC. No mechanisms for climate actions were set by other ministries and departments or for technical inputs from the ministry. No registry was set up to track, document, and showcase climate actions under NCCP or NDC. Except for a partial review by the Climate Change Commission that was set up by the Lahore High Court in 2015 for the province of Punjab, there has not been any systematic stocktaking to determine if federal and provincial governments accomplished the NCCP. 

Some areas of Pakistan fare much worse than average, with air pollution shortening lives by almost seven years in the most polluted areas. The current PM2.5 concentration in Pakistan is 3.5 times above the recommended WHO limit for 24-hour air quality guidelines value.

Except for KP no other province has notified its climate policy nor embedded climate change in their sectoral policies. Most national and provincial policies have not undertaken any cross-referencing to climate change. While some policies have begun to refer to climate change, perhaps not a single one has cross-referenced with NCCP. Except for National Water Policy that was approved in 2018, most other policies that were developed after 2013 such as the Alternative and Renewable Energy Policy 2019) or National Electric Vehicles Policy (2020) have not always been based on the NCCP recommendations. 

MEAs: Pakistan’s initial environmental legislation called Pakistan Environmental Protection Act (PEPA) had to be changed after the 18th Amendment. It had listed 14 MEAs that Pakistan had signed. Even if Pakistan has signed and ratified several other MEAs since then, including the Paris Agreement, the list has not been amended since 1997 when it was first adopted by PEPA. MOCC hosts a unit that manages nine of the original 14 MEAs listed in PEPA, leaving the remaining ones for Pak Environment Protection Agency or EPA to manage. This has created duplication, confusion, and competition on their implementation between the ministry and EPA. Further, there is no coordinating mechanism with the provinces even if many MEAs have a bearing on climate action. Also, there are no coordinating mechanisms in place for several trade-related MEAs that are not covered by any federal or provincial legislation. International trade agreements are increasingly imposing restrictions based on environmental conventions and protocols. For instance, to qualify for the Generalised Scheme of Preference Plus (GSP+) status for preferential trade with EU, countries have to adhere to the Montreal Protocol, the Basel Convention, Stockholm Convention, Convention on International Trade in Endangered Species, Convention on Biological Diversity, Cartagena Protocol, Kyoto Protocol, and UNFCCC. Failure to adhere to these, or any other conventions required for international trade, could potentially result in significant economic losses for Pakistan.

Climate Finance: MOCC represents the Government of Pakistan at several international climate finance institutions, including the Adaptation Fund (AF), Global Environment Facility (GEF), and the Green Climate Fund (GCF). Pakistan is a recipient of several projects from these facilities but since Pakistan has not secured accreditation, Pakistan has secured international climate finance through internationally accredited agencies such as ADB, FAO, UNEP, UNDP. Direct access to concessional financing from GCF and AF will be possible only after securing accreditation. Except for applying for Clean Technology Fund membership in 2013, the Government of Pakistan is not a recipient of Climate Investment Funds (CIFs), managed by the World Bank on behalf of all MDBs. A climate finance unit was established at MOCC, but it has stayed somewhat dormant, if not dysfunctional. In desperation, the finance ministry as well as the Planning Commission are in the process of setting up their own units as are several provincial governments such as KP, Punjab, and Sindh.

Policy Planning: Mainstreaming climate change continues to be a challenge, as it still has to find a place in the country’s policy planning mechanisms. Planning documents that are used as templates by all public sector projects at provincial and national levels (PC-1, PC-2, PC-3, and PC-4 as well as the templates and formats for the development of Concept Notes, Pre-Feasibility, Feasibility studies) have not been climate-proofed. They have been used with some slight changes since the early 1960s when they were first introduced. At the national level, the MOCC is seldom present in the (public sector development programme or PSDP forum that reviews projects at their design and revision stages, even if formally MOCC is a member of the forum. MOCC is also not a member of ECNEC (Executive Committee of the National Economic Council) chaired by the Planning Commission or the National Economic Council (NEC), a forum chaired by the Prime Minister that approves all economic plans and major projects. Climate Change is absent also from all major economic decision-making tools such as GDP measurement, national income accounting, green growth and specific allocations in the annual budget allocations, and provincial Annual Development Plans (ADPs). 

The Economic Survey of Pakistan in recent years has however begun to include a section on climate vulnerability, and the State Bank of Pakistan and the SECP have begun to introduce policies, rules, and other interventions for green investments such as green bonds, and low-emissions fuels and technologies. 

As already pointed out no secretariat at MOCC was notified for NDC implementation, nor a formal inter-departmental or inter-provincial coordinating mechanism was established. The expectation perhaps was that the Climate Change Authority (CCA) will be set up and oversee the implementation of NDC. CCA, together with Climate Change Fund (CCF) and Climate Change Council (CCC) were to be set up under the Climate Change Act that was notified in 2017. CCA, CCF and CCC have not as yet become operational. Given the utmost priority granted to climate change, the Prime Minister’s Committee on Climate Change, for all practical purposes replaced Climate Change Council (CCC) for high-level political decisions during the PTI government. The present government has however operationalised the Pakistan Climate Change Council and begun to convene its meetings.

3. State of Climate Policy Commitments

The NDC Ambition: 

The NDC in 2016 ambitions were very modest and cautious. It deferred climate actions to a future date. It was done primarily to protect the country’s right to development, even if it entailed increased emissions for some decades. The underlying assumption was that an increase in carbon emissions was essential for economic growth and that carbon emissions and economic development cannot be delinked. Further, it was envisioned that the high growth rate will continue with BAU, and even accelerate because of the projected high economic growth rate. In all, the NDC recommended 57 actions of varying nature in the realm of policy. 

The NDC was developed against an overly high optimism of economic growth in Pakistan driven by CPEC and availability of international finance available after the Paris Agreement. Three assumptions were the driving force: 

1. The economic growth rate will be as high as 9 per cent, and there will not be any downward trends. 
2. Pakistan will continue with the BAU and therefore the emissions will grow rapidly, and the share of RE will continue to be nominal
3. International finances will be available generously, without national-level mitigation measures, policy and institutional reforms, and actions.  

Pakistan’s NDC in 2016 did not align with the global discourse on global increase in temperature or carbon during the century, and the need to peak by or before the mid-century, traversing on the road to low carbon development. Projections presented in the NDC were linear, simply projecting that the emissions will continue to grow in the energy and agriculture sectors, and to a lower extent in industrial processes and waste. A combination of relatively weak scientific capacity and under-utilisation of whatever capacity existed the NDC did not build on climate modelling and present Pakistan’s case in a global temperature change context, or changes in local settings. A stronger scientific basis would have allowed the NDC to present 1.5C or 2C or higher degree scenarios for Pakistan’s economy, ecosystems, and society. 

Since sound modelling is an evolving tool where additional parameters can be included, the NDC did not attempt synergy and trade-off between actions in various sectors such as climate, land, energy, water, and other sectors. These include economic growth rate or changes in ratios of energy mix over the years, cropping patterns, migration, and urban planning, or standard of living. 

Economic costs of climate change were all mostly about the losses that Pakistan had already incurred, and not based on any projected increase in the frequency of extreme climate events. What will be the loss to Pakistan’s GDP over the years, under various climate scenarios? There was no economic or business case presented in the NDC for investments in adaptation or mitigation. The NDC presented static figures of the crop, livestock losses, houses damaged by floods during 2010 and 2014 or people killed by 2015 heatwave, without giving any estimates on increased costs of development, infrastructure upgradation, or reduction in crop yields and productivity. Finally, NDC presented losses based primarily on floods and not the losses based on other extreme events or the slow-onset of climate change. It is against this backdrop the abatement costs presented in NDC were also flat, linear and absolute and this reflects a gap to build an economic case for investment to mitigate climate risks. 

It must be pointed out that in recent years, federal ministries and provincial departments negotiated at least 23-climate related projects, in addition to a large number of water and agricultural-related schemes. Most of these projects were initiated, negotiated, and implemented without any direct involvement or knowledge of MOCC. In reality, the ministry and its policy documents have constituted a very small percentage of the total range of climate change-related investments in the country. Not surprisingly, many development partners have undertaken activities – but without always referring to NCCP or the NDC. The existence of such a mechanism would have helped meet national climate change objectives and targets. 

A large number of projects contributed to Pakistan’s climate policies as well as NDC targets without always engaging with MOCC or cross-referencing national policies. Several projects help improve Pakistan’s energy mix in favor of renewable energy. Four hydroelectricity projects are contributing towards 5,61,227 tonnes of Carbon sequestration covering carbon emissions targets of Pakistan.

Instead of refining and revising the assessments because of more frequent extreme weather events and sluggish economic growth rate, the Updated NDC submitted to the UNFCC secretariat in December 2021, built the case based on scenarios presented in the first submission. The life of the Updated NDC will be four years and the revised NDC will be submitted to UNFCC Secretariat in 2025, even if the countries are encouraged to submit their revisions every year prior to the conference of the Parties. Some key areas requiring a closer look are presented below:

Adaptation: 

No actions related to adaptation were envisioned for the first four years (2016-2020). The development of a National Adaptation Plan (NAP) was envisioned during near-term (2020-2025), in order to create a framework for guiding the mainstreaming of medium and long-term climate change concerns into national sectoral policies, strategies, and programmes for a coordinated approach between different tiers of government. 

The medium- to long-term actions (up to 2030) recommended a long list of goals, without any targets where the progress and accomplishments could be measured or showcased. These were only broad statements, without precise targets or specific actions or their prioritization. The provinces, in collaboration with the World Bank and Pakistan’s other development partners, have already taken action on several of the proposed recommendations, even if the projects and interventions are seldom specifically referenced to the NDC as we will see below in Section II.

Mitigation: 

As per Pakistan’s NDC, total GHG emissions are projected to increase by 300% between the period of 2015-2030. The Energy sector maintains a clear dominance in the existing as well as future emissions profile of the country. NDC analysis predicted emissions from the energy sector to rise by a staggering 380% over the period of 2015-2030. This exponential emissions growth dwarfs the trajectories of all other sectors, the second highest increase is projected from Agriculture at 161% over the same period. Hence, the most efficient mitigation pathway for Pakistan would be to focus on the Energy sector, which in turn has underlying drivers spanning multiple sectors. Data from Climate Watch for the year 2017 indicated that the bulk of emissions from the Energy sector in Pakistan is driven by Electricity/Heating (55.9 Mt CO2e) and Transport (53.84 Mt CO2e). Decarbonising these sectors will ensure a green and sustainable growth pathway for Pakistan.   

NDC had ranked carbon sequestration is a low-priority area. The carbon sequestration potential of areas listed under high priority – increased grid efficiency, increased coal efficiency, and large-scale and distributed grid-connected solar, wind, and hydro-energy – was not fully recognised by the NDC. Further, the carbon sequestration potential of afforestation programmes and ecosystem-based approaches, including mangrove plantations, that subsequently became central planks of the national priorities, may result in missed opportunities as carbon sequestration continues as a low priority consideration in project planning. 

In the energy demand and energy supply sectors, no specific targets were set in NDC. In the energy demand sector, the NDC presented several high and medium-priority areas and almost all of these areas required policy and institutional reforms and economic instruments and incentives to engage the provinces. No technical studies were undertaken to define an integrated reform agenda. 

Predictably, the national and provincial ministries and departments have undertaken many actions and many mitigation-related projects that were not envisioned in the NDC. Since 2016, when the NDC was approved, significant projects were initiated that for all practical purposes go beyond the NDC.

The high-level political announcements committing to phase out coal and announcing no-more coal power plants fundamentally increased the country’s ambition. By committing to increasing the share of hydropower to 50 per cent of total energy generation, the Pakistan government demonstrated a desire to increase the ratio of renewables in the energy mix (solar, wind, hydropower, and transportation), shelving some new coal-fired power plants and to substantially increase the ratio of the electric vehicle fleet, starting with two, three-wheelers and commercial transportation. Some initial policy measures were undertaken for the promotion of EVs. The articulation and progress on low carbon development, RE, and decarbonisation have exceeded the narrative presented in the NDC, even if the country began to backtrack soon after making the announcements. 

List of Sources Cited 

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Ali Tauqeer Sheikh

The writer is a climate change specialist, focusing on low-carbon and resilient development. 

He is presently a senior Climate Change Advisor at the World Bank in Islamabad.  Sheikh serves on many national commissions and international committees, including the country’s apex climate change body, Pakistan Climate Change Council.