By Oct 2, some 146 countries, representing almost 87 per cent of global greenhouse gas emissions, had submitted their intended national climate action plans to the United Nations ahead of the 2015 Paris Climate Conference, to be held in December. Pakistan was not among the countries that met the deadline despite having a plan.

After several months of painstaking revisions, Irfan Tariq, director general of Pakistan's Ministry of Climate Change, submitted the country’s draft national climate plan to Prime Minister Nawaz Sharif's office and could finally sleep easy.

That was about two weeks ago.

The document – titled the Intended Nationally Determined Contributions (INDC) – outlines Pakistan’s contribution to the global fight against climate change and was due to be submitted to the UN by Oct 1. But despite the ministry’s best efforts, Pakistan missed the UN’s deadline for submission as the team never heard back from the Prime Minister's office.

Tariq laments that if the climate change ministry had been headed by a minister, things would have been different. Senator Mushahidullah Khan resigned as federal minister for climate change in August, after a controversial interview he gave to the BBC.

When Prime Minister Nawaz Sharif spoke in the United Nations General Assembly (UNGA) on Sept 30, says Tariq, he brought up sustainable development goals and the Paris agreement. "But it's one thing to put it in your speech and quite another to unpack it!"

Asia director of the Climate and Development Knowledge Network (CDKN), Ali Tauqeer Sheikh, thought the PM had the perfect opportunity to announce his country's submission that day at the UNGA.

Why the INDCs are important?

  • INDCs give countries a chance to outline their climate actions.
  • Adding up targets in documents makes it possible for the world to track progress towards achieving the collective goal of limiting global warming to below 2 degrees Celsius relative to pre-industrial levels.
  • The INDCs also give developing countries an opportunity to outline their adaptation efforts.

However, commentators argue that poorer countries are being forced to reduce their emissions before they have had a chance to develop their economies.

"It is true that some countries are more responsible for green house gases (GHGs) than others, but at the end of the day, everyone should share the blame," says Hassan Shah, a hydro-geologist and expert in water resources management.

Not promising the moon

The INDC had outlined three options to reduce emissions by 2030 and the PM's office was to select one of these before submitting it to the UN Framework Climate Change Convention (UNFCCC)

  • to reduce emissions by 10pc (5pc unconditionally and 5pc with international support)
  • to reduce emissions by 18pc with additional international support
  • or reduce by 18pc if it is all through international assistance.

The base year that Pakistan is taking is 2012 since emissions data before that is not available.

Christiana Figueres, executive secretary of the UN Framework Climate Change Convention (UNFCCC) to which the submissions are to be made, terms the submissions “unprecedented.” Over 80 pc of the plans, stated the UNFCCC statement, include "quantifiable objectives and also over 80pc include intended actions to adapt to climate change."

But CDKN's Sheikh was not too impressed with Pakistan's INDC and finds it "unambitious and unimaginative". He would have proposed international financing for public transport or upgrading Pakistan's dying railways and urban flood prevention. Bangladesh, he says, had sought international financing for underground transport systems in return for reducing emissions.

But Tariq argues that the government wants to "play safe", and only commit to what was achievable. Pakistan’s emissions are expected to rise with its growing economy, particularly given the government's emphasis on exploiting coal. In any case, he points out that these commitments are "intentions" and not "binding". Countries can still revise or even walk away from their commitments.


"There is no reason to be overly ambitious today just to look good for the agreement without having done our homework to see what is and isn’t possible with or without international support," agrees Kashmala Kakakhel, a development consultant who has been following the INDC's process internationally.


Kakakel found that there was focus on key sectors of energy and agriculture that contribute to 90pc of the country’s emissions, rather than trying to prepare a "generic INDC", and failing to achieve any concrete results.

However, the gap she found was that the Pakistan document just provides a set of "mitigation activities" that it will undertake with "no clear demarcation of which activities will fall under unconditional contribution and which activities can happen if Pakistan is provided external support". In her opinion, unconditional contribution should have documented all renewable energy projects such as the solar park and the hydel power projects currently under construction which will ultimately reduce the emissions.

Even Abid Qayyum Suleri, executive director at the Sustainable Development Policy Institute (SDPI) and a member of the National Economic Advisory Council, sees "huge room for improvement" in the INDCs. He says the plan has not considered the fact that Pakistan’s future energy consumption and emissions are likely to rise for a number of reasons: reduction in international oil prices, new power projects under the China-Pakistan Economic Corridor and Iran-Pakistan gas pipeline, imports of LNG, and army operations in tribal areas of Pakistan bordering Afghanistan which would bring peace and economic development to the region.

"All these game changers would bring new economic growth opportunities coupled with new vulnerabilities for climate change," Suleri says.

In this context, Pakistan needs to review its GHG emission targets for the post-2020 period. "Without having a realistic baseline for post-2020 period, we can never come up with realistic nationally determined contributions," he says.

Dissecting Pakistan's INDCs

Hydrologist Shah is sceptical of the "science behind the calculations of GHG mitigation in the energy sector". He questions whether Pakistan can reduce emissions given government plans to add 25,000 megawatts of power to the national grid by exploiting “5,346 million tonnes of shale oil/gas and burning an additional 55 million tonnes of coal every year” as stated in Pakistan's development plan — Vision 2025. Questions may be raised on how this increased use of fossil fuel in the energy mix was going to mitigate GHGs, he points out.

Even with hydropower, the loss of forests and wetlands that sequester carbon from the atmosphere has not been taken into account. "Without adding such economic externalities, we may, yet again, be fooling ourselves," he warns.

Shah says while there was a lot of talk about reforestation and protection of ecosystems in both the Vision 2025 and the INDC, there was little mention of water resources or wetland restoration. "Both documents propose to enhance storage capacity by three-folds by building additional reservoirs to stop the so called ‘escapages’ to the sea!"

"We use 95pc of our water in the irrigation sector, which wastes 75pc of it. Despite the huge potential for saving water, the INDC has not emphasised improving irrigation efficiency," says Shah.

Vaqar Ahmed, deputy executive director at SDPI, says the targets were not sufficiently backed by clear institutional arrangements. "Who will do what and by when? he asks, adding: "I don't know how you can produce growth and investment forecasts (and required investment for mitigation and adaption) in such a short time period!"

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