12/29/23, 2:03 PM Pakistan has a plan for adapting to climate change - will it work?

CLIMATE

Pakistan has a plan for adapting to climate

change – will it work?
The roadmap to a climate-resilient future for Pakistan has been criticised for its top-
down approach, a lack of consultation, and significant omissions

UR EN

Residents of Jaffarabad salvage a solar panel from their flooded home in September 2022. Pakistan’s
National Adaptation Plan sets out how the government intends to equip citizens with the means to

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protect themselves from climate changed-induced disasters, though observers say large parts are
‘identical’ to existing policy. (Image: Fareed Khan / Alamy)

Zofeen Ebrahim
November 22, 2023

O
ne of the last things that Pakistan’s outgoing government did before it was
replaced by a caretaker administration in August was to approve a National
Adaptation Plan (NAP). The plan – which sets out how Pakistan aims to deal
with challenges brought by climate change by coordinating between and creating
institutions – was unveiled on 26 July 2023, by then-climate change minister Sherry
Rehman.

The National Adaptation Plan envisages a climate-resilient Pakistan in which income

inequality and social disparities are addressed. It aims to do this by strengthening the
capacity of local communities to protect themselves and their environment from hazards
by providing green jobs; sustainable infrastructure and services; technology and
innovation; and effective collaboration between the government, private sector and civil
society.

The plan largely assumes availability of foreign funds to realise these strategies, but
experts who spoke with The Third Pole say that it fails to clearly lay out how financing
mechanisms will be utilised.

Nonetheless, the timing of the release of the plan is apt. The climate summit COP28 is
set to begin at the end of November in Dubai, where the Global Stocktake of the world’s
progress in achieving its climate commitments will be presented. This will actively
consider adaptation strategies for communities facing the impacts of climate change, as
well as the needs of local governments.

Meanwhile Pakistan is still, to some degree, dealing with the aftermath of huge floods in
2022. The scale of the disaster was instrumental in Pakistan’s leadership at COP27 in
Egypt, and possibly influenced the summit’s agreement to create a Loss and Damage
Fund. This fund, if operationalised, could be a key route through which international
finance could help support plans like Pakistan’s NAP.

Plan treads well-worn ground, lacks concrete action, say experts

Officials at Pakistan’s Ministry of Climate Change & Environmental Coordination, who
asked not to be named, told The Third Pole they were relieved that the task of preparing a

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National Adaptation Plan – made possible by a USD 3 million grant from the United
Nations Environment Programme – had finally been completed. Pakistan is now one of 40
countries that have created a national adaptation plan, as part of its obligations under
the UN Framework Convention on Climate Change (UNFCCC).

“The very existence of this plan means that we have ticked off the list a major
requirement of the UNFCCC,” said Anam Zeb, an Islamabad-based climate expert who
works at the German Red Cross.

However, she argued that the plan has not substantially brought the debate forward in
Pakistan. Zeb said that large sections of the plan are “almost identical” to Pakistan’s
National Climate Change Policy (NCCP) from 2012; that content on disaster risk
management is almost the same as what that the existing National Disaster Management
Plan 2012-2022 called for; and that measures relating to water management are similar to
what the National Water Policy said in 2018.

Sobia Kapadia, an architect and urban resilience expert at the London School of
Economics Gender, Justice and Security Hub, told The Third Pole that the National
Adaptation Plan also lacks “clear, actionable strategies that address co-ordination issues,
capacity building, resource allocations, community engagement and governance to have
an efficient disaster risk management system”.

“The implementation challenges without defined clarity and mechanisms especially

around governance and finances makes this framework nothing other than what was
done in previous years,” she said. Kapadia argued that the NAP has largely ignored existing
developmental plans, such as “the Planning Commission’s vision 2030; or Sindh
Government’s vision 2025 or even the annual development plans that are linked with
budgets in the fiscal year.” These developmental plans determine how the state allocates
funds and resources, and for the NAP to be successful, she said, “it requires to embed
itself or lead the conversation on developmental plans.”

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Karachi residents quench their thirst at a heat stroke relief camp set up in the city during an
intense heatwave in May 2023 (Image: Owais Aslam Ali / Alamy

Malik Amin Aslam, who was the prime minister’s adviser on climate change from August
2018 to April 2022, told The Third Pole that the plan lacks “out-of-the-box thinking”, and
that it will struggle to benefit from the “rapidly changing global climate financing
framework that is in place”.

Aslam contended that during his tenure under the Pakistan Tehreek-e-Insaf (PTI)
government, the state confronted the climate crisis “without taking a penny from donors”
by focusing on nature-based solutions (NBS) like the 10 Billion Tree Tsunami and the
Pakistan Protected Areas Initiative. Despite nature-based solutions featuring prominently
in the NAP, including as one of its 10 guiding principles, Aslam suggested that this
approach was abandoned after the PTI lost power in 2022, at the “altar of petty political
expediency”. Zia ul Islam, an environment expert formerly of the Pakistan Environmental
Protection Agency, concurred, saying the focus has shifted “from NBS [to] loan-friendly
projects in the NAP.”

Plan critiqued for lack of consultation

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The content of any plan is shaped by the process of its creation, and this has been the
greatest focus of criticism of the National Adaptation Plan from Pakistan’s climate
experts. Imran Khalid, who works with WWF-Pakistan, raised concerns about the role of
World Bank consultants in finalising the NAP, which is prominently mentioned in the
introduction. “Currently, we rely heavily on consultant-led initiatives,” he told The Third
Pole, and that this “may not adequately address the environmental and climate
challenges facing at-risk communities”.

A senior official at the Ministry of Climate Change & Environmental Coordination, speaking
on condition of anonymity, rejected this. “The data and all the material for the chapters
was provided by us, [the World Bank] gave it a proper shape so that it could be submitted
to the UNFCCC.”

Khalid also suggested that the plan, while “substantive”, had been created by a process
that did not reflect the ‘whole-of-society’ approach that the document promised to
espouse. “The broad-based consultative process – taking insights from experienced
professionals, communities, academics, and the broader civil society before finalising
such an important document – is missing,” he said.

Agreeing with Khalid that a more ‘bottom-up’ approach was needed, Rafay Alam, an
environmental lawyer, told The Third Pole: “In an ideal world a ‘national’ adaption plan
would have evolved from the ground (provinces) up instead of top (federation) down.”
This, he explained, is because the main sectors mentioned in the NAP, namely irrigation,
agriculture, land and watershed management, are matters of provincial governance under
the Pakistani constitution.

Alam said he was unsure if the provinces had agreed to the responsibilities assigned to
them under the plan, such as providing funding. “As far as I know, this has not been the
case,” he said, adding that funding for provincial adaptation initiatives requires budget
approvals that are sanctioned by the provincial assemblies. “Since this hasn’t happened
either, the NAP essentially passes the financial responsibility of expensive adaptation
initiatives to provinces that have not made budget allowances for them.”

Zeb argued that what matters most is political will, not how “well written policies or
plans may be”. Zeb said that provincial-level climate change policies, such as those of
Sindh and Khyber Pakhtunkhwa provinces, had not been implemented after being
approved hastily in July 2022, just before the dissolution of the respective assemblies.

Umer Karim, an agriculture and water resources specialist based in Karachi, agreed: “We
have a practice of writing good documents and then shelving them. Let’s hope it’s

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different this time.”

Karim highlighted drainage as another notable omission in the National Adaptation Plan.
“Our agriculture and the entire food system can only survive climate change-related
flooding if we have efficient and regularly maintained storm water evacuation systems.”
Blindness to this issue, he argued, creates additional problems for the environment, as
effluent discharged into the Indus from cities like Sukkur and Rohri pollutes the habitat
of the Indus river dolphin, while sewage from Lahore is released into Ravi River, which
when it reaches Sutlej is used for drinking and agricultural purposes.

Questions of finance
The National Adaptation Plan mentions the creation of a National Climate Change Fund
(NCCF) to provide seed funding for adaptation projects. “How this will be made available
and how will it be designed to ensure that it trickles down to the local level [is something
we don’t know],” said Zeb.

Zia ul Islam said that the capacity of relevant institutions at the provincial level is limited,
both “in terms of logistics and technical understanding, particularly financing”.

Climate finance expert Kashmala Kakakhel argued that the major challenge in
implementing Pakistan’s National Adaptation Plan lies less in financing than improving
existing practices. “We have a fair idea of which geographies and sectors are more prone
to climate impacts; the planning departments of provinces need to start taking more
ownership of how projects are designed and approved. We need to spend our own money
smartly, rather than just waiting for international support to materialise.”

Zofeen Ebrahim
Zofeen was previously Pakistan editor at The Third Pole. She is an
independent journalist based in Karachi and writer at the Thomson
Reuters Foundation, Dawn and the Guardian. She also contributes
regularly to the Inter Press Service.

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