A Critical Analysis of Pakistan’s 2021 National Climate Change Policy: Ambition vs. Implementation

Pakistan’s 2021 National Climate Change Policy (NCCP) articulates an ambitious goal: to steer the country toward “climate compatible development” – i.e. resilient, low-carbon growth. It lists 14 broad objectives (from sustaining growth while addressing climate impacts to building resilient infrastructure, protecting food/water security, and enhancing capacity). The policy spans adaptation (water, agriculture, health, forestry, coastal and mountain ecosystems, disaster preparedness) and mitigation (energy, transport, industry, waste, carbon sequestration) across multiple sectors. Institutional mechanisms are envisaged: climate-change cells in federal/provincial ministries, inter-ministerial coordination bodies, and dedicated NCCP implementation committees at federal and provincial levels.==

NCCP Vision, Objectives and Focus

Vision/Goal: The 2021 NCCP’s overarching goal is “to ensure that climate change is mainstreamed in the economically and socially vulnerable sectors” and to guide Pakistan towards climate‐compatible development. This echoes federal commitments (e.g. achieving 60% clean energy by 2030) .

Objectives: The policy lists 14 objectives: from pursuing sustainable growth that addresses climate challenges, to integrating climate concerns into all national policies, focusing on pro‐ poor and gender‐sensitive adaptation, building climate‐resilient infrastructure, and tracking impacts on water/food/energy security . It explicitly calls to “minimize risks” from extreme events (floods, droughts, storms), promote climate‐resilient agriculture, transition to lower‐ carbon development, strengthen coordination mechanisms, and foster public-private investment in adaptation/mitigation .

Sectoral Focus: The NCCP addresses adaptation in water, agriculture/livestock, health, forestry, biodiversity, mountain/rangeland/coastal areas and disaster preparedness (Table of Contents ). Mitigation measures cover energy (generation and efficiency), transport (road, aviation, rail, inland), urban planning/waste, industries, and forestry/carbon sequestration . It also includes cross‐cutting pillars: capacity building, institutional strengthening, awareness raising, international cooperation, finance, and technology transfer.

Institutional Roles: The policy envisions a climate governance structure: climate change cells in each federal/provincial ministry; inter-ministerial “Climate Change Councils” and a National Climate Change Council (as per the 2017 Act); and implementation committees. The federal committee is chaired by the Climate Minister and includes federal secretaries (P&D, Planning, Water, etc.), the NDMA Chairman, heads of meteorological and energy entities, provincial planning secretaries, and civil society representatives . Provincial committees (chaired by Environment Ministers) similarly include planning, irrigation, PDMA, and forest secretaries. In theory, these bodies are to “meet biannually” to oversee policy roll‐out.

Vague or Non-Actionable Provisions

While comprehensive on paper, the NCCP contains many broadly‐worded provisions that lack detail. Experts note the policy often fails to spell out how goals will be achieved. For instance, it urges “promoting nature-based solutions and long-term sustainability” and “tracking climate impacts on water/food/energy security” , but does not specify responsibility or resources for these tasks. A recent policy review found the NCCP “falls short on other elements imperative for a comprehensive climate change policy” – specifically target-setting, prioritization, and designation of implementing agencies . The policy is “unclear and confusing in prioritizing actions and identifying relevant authorities” . It lacks mechanisms to coordinate with sectoral plans (e.g. water or irrigation laws) or to mainstream climate into decentralized governance . Concrete examples underscore these gaps. The document calls for “protecting glaciers” as part of water strategy, but critics point out this is not practically feasible under current conditions . It advocates wide-ranging reforms (electric vehicles, carbon sequestration forests, etc.) without explaining which ministry will lead or how to finance them. No budgets or funding sources are specified, and the Act under which the policy sits requires climate plans but gives no new funds. In short, many provisions read like aspirations rather than actionable plans.

Key Goals: Adaptation, Mitigation and Resilience

Adaptation: Reducing vulnerability to extreme weather and securing livelihoods. This includes water management (expanding storage, conservation, and integrated planning), climate-resilient agriculture (drought/flood-tolerant crops, risk management), health safeguards (disease surveillance, heat-wave preparedness), and ecosystem protection (forests, rangelands, wetlands). Specifically, objectives call to “minimize risks from more frequent/intense floods, droughts” and “develop climate-resilient agriculture and food systems” . Disaster preparedness measures (early warnings, emergency planning) are also explicit.

Mitigation: Shifting to a low‐carbon economy. Goals include transitioning to cleaner energy and transport, improving energy efficiency, and promoting carbon sinks. For example, the NCCP’s stated aim to “promote the country’s transition to cleaner, lower-emission and less carbonintensive development” translates into detailed measures on renewable power, electric vehicles, public transit, industrial emissions, and afforestation. The policy ties these to Pakistan’s NDC targets (50% GHG reduction by 2030 with support) and SDGs.

Resilience: Strengthening institutions, infrastructure and communities to withstand climate shocks. Objectives include building climate-resilient infrastructure (flood defenses, roads, buildings), enhancing coordination (inter-ministerial and inter-provincial climate mechanisms ), and empowering stakeholders (awareness, skills) . The policy emphasizes mainstreaming climate into vulnerable sectors and planning (e.g. integrating climate in development plans), and creating incentives (like green finance) . In practice this means aiming for resilient irrigation systems, flood barriers, resilient housing, and ecosystem-based adaptation (mangroves, forests) – though, as noted, concrete action plans are sparse. These goals map directly to Pakistan’s climate challenges: the NCCP targets flood/drought risk (adaptation), air quality and energy choices (mitigation), and institutional preparedness (resilience). However, as discussed below, implementation has lagged in many areas.

Implementation Status and Gaps

By mid-2025, the NCCP remains largely aspirational. Federal Achievements: The Ministry of Climate Change cites some landmark initiatives (the Ten Billion Tree Tsunami, Clean Green Pakistan index, urban resilience pilot projects, etc. ). Several development projects reference the policy (e.g. World Bank/ ADB loans require climate screenings). However, few public reports evaluate how the NCCP’s specific goals have been met. No official progress report exists, and federal budgets for climate actions are limited.

Provincial and Local Action: Crucially, climate policy implementation has not been uniform across provinces or down to the local level. The 18th Amendment devolved many environment and development functions to provinces, but coordination mechanisms have not kept pace . A 2024 review notes “a significant gap between the formulation of climate policies and their effective implementation” in Pakistan . Provinces most exposed to climate risk (e.g. Punjab’s hot south, Sindh’s coast) often lack the technical expertise and budget to act on adaptation plans . For example, although the federal NCCP envisaged Provincial Implementation Committees, in practice these bodies have rarely convened or delivered concrete plans. A recent policy study found no provincial climate councils to interface with federal strategy, and an “unclear” provincial mandate for climate action.

Delays and Shortcomings: Many NCCP measures remain unimplemented or stalled. Water storage projects, called for in policy, are slow and costly to build – leaving flood-prone areas dependent on inadequate canals. Provincial flood protection schemes in Punjab have suffered from maintenance issues. Early-warning systems and evacuation planning are still rudimentary outside big cities. Meanwhile, some mitigation goals have progressed through parallel initiatives (e.g. renewables auctions, CNG vehicles), but these often align with economic interests rather than NCCP targets. Notably, Pakistan’s updated NDC notes that its ambitious mitigation commitments are “contingent on receiving international funding” , reflecting that domestic budgets fall short. In sum, despite the NCCP’s comprehensive vision, implementation has been inconsistent. Coordination gaps (as discussed below), funding shortfalls, and the COVID-era political upheavals have all contributed to lagging follow-through. In places like Punjab, many national goals (e.g. communitybased adaptation, nature-based flood solutions) remain confined to pilot projects rather than scaled programs.

Case Study: Flood-Risk Management in South Punjab (DG Khan / Rajanpur)

South Punjab (especially DG Khan and Rajanpur districts) is a climate hotspot: historically arid, it saw catastrophic flooding in 2022 that affected hundreds of thousands . A closer look at this region illustrates the NCCP implementation gap at ground level.

Local Implementation of National Goals: The NCCP emphasizes flood risk reduction and water management (Objectives 5–7). Yet locally, most flood mitigation infrastructure is planned by the Irrigation Department and Federal Flood Commission, not through climate adaptation programs. Embankment construction is piecemeal, and drains are often blocked by silt. After 2022, NDMA/PDMA launched relief and some reconstruction, but there was no “climate proofing” plan in place. For example, new houses were rebuilt without raised foundations, and cropland drainage remains poor. The NCCP’s calls for community‐driven planning and nature-based solutions have not been systematically applied here. (Researchers found only ad-hoc efforts and called for more inclusive planning.)

Community Engagement: Local communities are very aware of flood risks; indigenous knowledge (hill-torrent warning signs, traditional embankments) is widespread. However, formal community training and preparedness are limited. NDMA reports on monsoon 2024 highlight “community-based disaster risk management initiatives” as a best practice , but in 2022 most awareness came via news reports and NGO outreach, not structured programs. After floods, community leaders helped identify needs for aid, but they often lacked formal channels to demand disaster funding. NDMA now recommends in future “tailored trainings for communities” at the Union Council level – but these have yet to be implemented in South Punjab.

Inter-Agency Coordination: In principle, NDMA (federal) and PDMA-Punjab (provincial) share flood responsibilities, with input from the Federal Flood Commission (FFC) and local district authorities (DDMAs). In practice, coordination is fragmented. For 2022 floods, NDMA directed provincial rescue, while FFC’s monsoon plan focused on canals. The climate ministry had no direct role in disaster response. Punjab’s PDMA lacked climate expertise, viewing floods as a oneoff emergency rather than a climate adaptation issue. A policy study notes there is “no alignment” between national disaster plans and flood-risk management plans , and limited trust between federal climate planners and local officials . For example, climate policy makers (FGR group) wanted technical inputs, while provincial implementers (PPI group) saw the NCCP as federally driven and peripheral to local development . Thus, when floods hit DG Khan/ Rajanpur, much of the response was reactive relief. Only since 2022 have federal and provincial bodies begun revising local flood strategies with NDMA guidance, but these plans still lack strong community or climate‐science inputs.

Obstacles Encountered: Key challenges in South Punjab include limited data and early warning, weak infrastructure, and scarce resources. Meteorological and hydrological monitoring in Rajanpur/DG Khan is sparse, so while Punjab’s monsoon plan existed, villages often only had hours (or less) to evacuate. The 2024 NDMA review notes the “lack of an end-toend early warning system” was a critical factor in slow response . Funding is another constraint: local governments have tiny budgets; without earmarked climate funds, PDMA spends mostly on immediate relief (food, tents) rather than long-term risk reduction. Technical capacity is also low – district officers have little training in flood modeling or climate science. Social factors (poverty, remoteness, poor road access) exacerbate impacts and slow aid delivery. In 2022, hundreds of thousands in these districts were left homeless and had to “wait for aid and relief under the open sky” , highlighting how resilience is still weak on the ground.

Institutional Coordination: MoCC, NDMA, PDMA, EPA and Local Government

Pakistan’s climate response involves multiple agencies, but coordination among them has proved challenging. The Ministry of Climate Change (MoCC) is the federal focal point, drafting policy and international pledges. The NDMA (National Disaster Mgmt Authority) (under the Prime Minister’s Office) leads disaster planning and emergency response. Each province has a PDMA for disasters, a Provincial EPA for environment, and sectoral departments (irrigation, planning, health, etc.). Municipal governments (e.g. city corporations) handle local services, but climate change is not explicitly in their mandates.

Key coordination issues include:

- Overlapping Mandates: Climate adaptation measures often straddle agencies. For flood control, irrigation and NDMA/PDMA both plan interventions. But there is no formal mechanism linking the federal climate council with NDMA/PDMA plans . The NCCP established high-level committees including NDMA and Pak EPA , but these meet only sporadically. Provincial climate cells (per the 2017 Act) were envisioned to coordinate local climate action, yet they are mostly dormant.

- Decentralization Ambiguity: Since 2010’s 18th Amendment, environment and local development became provincial subjects. The climate policy does not reconcile this fully. As one review notes, “institutions at the provincial levels are independent”, creating “ambiguity in the operationalisation and mainstreaming of NCCP actions at sub-national levels” . Provinces have their own climate policies (Sindh, KP, etc.), but these often differ in scope and resources. Punjab is only now developing its provincial climate strategy. Without clear federal-provincial workflows, many initiatives stall.

- Limited Local Government Role: City and district governments have not been integrated into climate governance. For example, after 2022 floods, funding was channeled through NDMA/PDMA, not local councils. Municipalities still lack explicit climate or DRR roles. No framework exists to involve Union Councils in climate planning (despite the NCCP’s nod to local strategies ). Recent analysis found that district-level actors and community groups were largely absent from NCCP consultations , reflecting a top-down approach.

The result: agencies often “talk past” each other. Environmental regulators (EPA) issue pollution permits but have little say in adaptation, while disaster authorities focus on response rather than prevention. The 2023 policy study summed up the problem: the NCCP “lacks an inter-coordination mechanism” with core sectors (water, agriculture, irrigation) . In practice, NDMA/PDMA risk management and MoCC climate policy operate in parallel, with insufficient cross-communication. The 2024 NDMA monsoon report, while noting improved inter-agency collaboration, still emphasizes the need for sustained joint action.

Stakeholder Capacity (Technical, Financial, Human)

Implementation is further hampered by capacity constraints at all levels. Studies highlight persistent technical and institutional gaps:

Technical Expertise: Many government bodies lack staff trained in climate science or adaptation planning. Provincial departments rarely have climate experts, and climate change remains a new area for most bureaucrats . In districts like Rajanpur, disaster teams have limited GIS or hydrology skills needed for flood modeling. The NIPA policy review notes “the lack of trained professionals in governmental and non-governmental organizations” impedes climate programs . MoCC and academia have expertise, but translating that into practical support (e.g. modeling local flood scenarios) has been slow.

Financial Resources: Public budgets for climate action are constrained. No dedicated line item for NCCP activities exists; adaptation funds come from general PSDP or donor projects. Pakistan is heavily dependent on international climate finance: its NDC’s 50% emissions-cut target by 2030 explicitly relies on foreign assistance . This external dependency creates planning uncertainty (if aid falters, projects stall). Many provinces simply lack funds to co-finance adaptation projects. For example, even where hazards are mapped, investing in infrastructure (e.g. flood channels, rainwater harvesting) competes with other development priorities. The lack of domestic disaster risk financing (e.g. no national disaster fund for prevention) means most spending is reactive relief. As one gap analysis notes, “heavy reliance on international funding” makes Pakistan’s climate actions “vulnerable to shifts in international financing commitments”.

Human Resources and Coordination Capacity: Beyond specialists, the broader pool of planners and local officials has limited climate knowledge. Training efforts have begun (e.g. workshops on climate budgeting ), but need scaling. Civil society and communities also lack platforms. According to interviews in the policy study, local NGOs and women’s groups were largely absent from the NCCP process . Within government, high turnover and weak continuity (recent political changes in 2022–24) have disrupted coordination. The cumulative effect is that “weak technical capacity at provincial level” and low cross-sector awareness have created implementation bottlenecks.

Conclusions and Recommendations

Pakistan’s NCCP 2021 is a comprehensive policy document, but its execution has fallen short. The gap between national vision and local action, especially for flood risk in South Punjab, stems from unclear mandates, funding shortfalls, weak coordination, and limited capacity. To bridge this gap, we recommend:

Clarify and Strengthen Mandates: Provincial climate change cells/committees must be activated with clear authority. The federal government should issue guidelines mandating provincial integration of NCCP goals into provincial plans (e.g. Punjab’s climate strategy) and district disaster management plans. The roles of NDMA/PDMA vis-à-vis MoCC should be delineated in a joint framework (e.g. a MoU linking the National Disaster Management Plan with the NCCP). Establish permanent multi-stakeholder forums at provincial and district levels – including climate, irrigation, health, and local government – to align efforts. For example, NDMA could formally include MoCC staff in its Provincial Steering Committees.

Ensure Sustainable Funding: The government should create dedicated climate/adaptation budget lines at federal and provincial levels. A “Climate Adaptation Fund” could pool domestic resources and international grants for projects (similar to the Benazir Income Support climate cash transfers pilot). Budget criteria should prioritize vulnerable districts (DG Khan, Rajanpur, etc.). Equally, Pakistan must strengthen its capacity to access global funds (GCF, GEF) by developing bankable projects. Facilitating PPPs for climate-resilient infrastructure (e.g. flood protection or solar irrigation) and incentivizing green investments via tax breaks would help mobilize private finance.

Capacity Building: Systematic training is needed. The Ministry of Climate Change, in partnership with academic institutes, should offer climate and disaster-risk training for provincial and local officials (e.g. flood modeling, climate-smart agriculture). PDMA staff need workshops on resilience planning, and irrigation/forestry departments need climate adaptation modules. Meanwhile, strengthen technical wings of PDMA and Irrigation (e.g. hire hydrologists, GIS experts). At the community level, roll out NDMA-recommended Community-Based Disaster Risk Management (CBDRM) training for local volunteers, with tailored programs for women and youth. Success has been seen where villagers were trained to operate early-warning equipment and first response.

Inter-Agency Data Sharing and Planning: Establish a centralized climate information clearinghouse (as envisioned in the NCCP). NDMA, MoCC (GCISC/PMD), and PDMA should jointly share hydro-meteorological data (river gauges, rainfall forecasts) with a common portal. Use this data for district contingency planning (e.g. trigger levels for evacuation). Integrate hazard maps into local development plans: for example, exclude floodplains from settlement by law, or require flood-resistant design for infrastructure. The UNDP flood recovery strategy emphasizes mapping hazards and early-warning systems to inform development planning ; Pakistan must adopt this approach.

Link Climate and Disaster Plans: District and provincial disaster management plans should explicitly embed climate change projections. For instance, revise Punjab’s monsoon contingency plans using NCCP guidance: where the policy calls for “local flash flood forecasting and warning systems” , PDMA should install automatic rain gauges in mountain torrents (DG Khan) and train officers to interpret them. NDMA’s experience shows end-to-end warning systems were lacking in 2022 ; correcting this by joint MoCC–NDMA protocols is critical.

Community Engagement: Institutionalize the role of local government and civil society. Establish Climate Change Committees at Union Council level to feed into PDMA, as a bridge between policy and people. Leverage Pakistan’s robust network of elected local councillors (where active) to carry climate messaging. Support local NGOs and researchers (e.g. local universities) to participate in planning. Post-flood recovery programs (e.g. UNDP’s FRP) stress participatory needs assessments and community stockpiles at the council level ; such models should be scaled across Punjab. In summary, closing the implementation gap will require operationalizing the NCCP’s lofty goals through concrete governance reforms, capacity investments, and financing. Recent best practices (such as NDMA’s use of declarations of emergency to unlock funds, enhanced weather forecasting, and pilot community training ) provide a blueprint. By improving inter-agency collaboration, building provincial/local capacity, and embedding climate risk into everyday planning, Pakistan can make the transition from policy to practice – reducing flood losses in places like D.G. Khan and Rajanpur and building a truly climate-resilient Pakistan.

Sources: Government policy documents; peer-reviewed and policy analyses; NDMA/UNDP reports.==

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