Draft Report on Review Documents on Climate Policy,

Planning and Financing

Prepared by: Syed Amjad Hussain, Climate Policy and Planning Specialist, PPF Sector, ADPC, Pakistan

Reviewed by: Israel P. Jegillos, Senior Project Manager, Disaster Risk Reduction, Risk Governance
Department, ADPC, Bangkok, Thailand
 Table of Content
1. Review of Climate Policy and other related Documents………………………………………………….1
1.1 Purpose of this Review Report…………………………………………………………………………1
1.2 Key Climate Change Policies, Laws and Plans……………………………………………………………1
1.2.1 National Climate Change Policy, 2012……………………………………………………….1
1.2.2 Pakistan Climate Change Act, 2017………………………………………………………….6

1.3 Sector Specific Policies and Plans with focus on Agriculture and Water Sectors………………………12
1.3.1 National Food Security Policy, 2018…………………………………………………………..12
1.3.2 National Water Policy, 2018…………………………………………………………………..14

1.4 Other Climate Change supporting Policies and Frameworks…………………………………………..16

1.4.1 National Disaster Risk Reduction Policy, 2013………………………………………………16
1.4.2 National Disaster Response Plan, 2019………………………………………………………17
1.4.3 National Environmental Policy, 2005………………………………………………………..17
1.4.4 Alternative and Renewable Energy Policy, 2011…………………………………………….17
1.4.5 National Power Policy, 2013…………………………………………………………………18
1.4.6 Updated Nationally Determined Contribution, 2021………………………………………..18
1.4.7 Pakistan’s Second National Communication on Climate Change, 2020……………………..21
1.4.8 Framework for Implementation of Climate Change Policy, 2013……………………………22

2. Review of Planning Documents for Development Projects in Pakistan…………………………………24

2.1 PC-I, II, III, IV & V Proformae…………………………………………………………………24
2.1.1 PC-I Proforma…………………………………………………………………………………..24
2.1.2 PC-II Proforma…………………………………………………………………………………28
2.1.3 PC-III Proformae……………………………………………………………………………......29
2.1.4 PC-IV Proformae……………………………………………………………………………......30
2.1.5 PC-V Proformae………………………………………………………………………………....31
2.1.6 Umbrella PC-I……………………………………………………………………………….......32
2.1.7 PC 1 online System of MoPDSI………………………………………………………………..32
2.1.8 Conclusions………………………………………………………………………………………32
2.1.9 Recommendations………………………………………………………………………………..33

3 Review of Climate Financing Documents………………………………………………………………………34

3.1 Review of Pakistan Climate Change Financing Framework, 2017…………………………34
3.1.1 The Need for Change…………………………………………………………………34
3.1.2 Mainstreaming Climate Change…………………………………………………….. 34
3.1.3 The Solution: A Climate Change Financing Framework…………………………….35

3.2 Review of Climate Public Expenditure and Institutional Review (CPEIR) Document, 2017…36
3.2.1 Process ……………………………………………………………………………………36
3.2.1.1 First Step: Identification of Climate-related Expenditures…………………………….37
3.2.1.2 Second Step: Classification of Expenditures……………………………………………..37
3.1.1.3 Third Step: Weighting of Climate Change Relevance………………………………..37
3.2.2 Institutional and Expenditure Analysis……………………………………………………..37
3.2.2.1 Federal…………………………………………………………………………………….37
3.2.2.2 Khyber Pakhtunkhwa…………………………………………………………………….37
3.2.2.3 Balochistan………………………………………………………………………………..37
3.2.2.4 Punjab…………………………………………………………………………………...38
3.2.2.5 Sindh…………………………………………………………………………………….38
3.3 Trends in Climate Expenditure………………………………………………………………..38
3.4 Institutional Analysis………………………………………………………………………..39
3.5 Recommendations of CPEIR, 2017…………………………………………………………39

4 Country Status on Implementation and Outline of Climate Policy, Planning and Finance National
Guidelines………………………………………………………………………………………………………..40
4.1 Conclusions…………………………………………………………………………………………..40
4.2 Recommendations……………………………………………………………………………………40

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List of Annexes
i. PC-I for New Projects
ii. PC-I for Revised Projects
iii. PC-II Proforma
iv. PC-III Proforma
v. PC-IV Proforma
vi. PC-V Proforma

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Draft Report on Review Documents on Climate Policy, Planning and
Financing
1. Review of Climate Policy and other related Documents
1.1 Purpose of this Review Report
The main purpose of this review was to support the country in development of series of National
Guidelines on Climate Finance and Planning at National and Provincial levels. In order to develop
these guidelines for Pakistan this review of the Climate Change and other related documents of
Pakistan will provide guidance to obtain more country and sector specific information to develop
National Guidelines for Pakistan. As per Paris Agreement, 2015, all Parties to commit to engage
in adaptation planning processes and the implementation of actions, including the development or
enhancement of relevant plans (article 7.9), with a view to contributing to the global goal on
adaptation of enhancing adaptive capacity, strengthening resilience and reducing vulnerability
(article 7.1). The Agreement also stresses that adaptation should follow to integrating adaptation
into relevant socioeconomic and environmental policies and actions (article 7.5). Therefore
mainstreaming Climate Change at planning and finance is mandatory for identification of Climate
Change adaptation and mitigation related public expenditure from country own resources which
may be flaged for tapping International funding from International donors as Pakistan is highly
vulnerable to climate change and Climate change adapatation and mitigation is need and
requirement of the country at the moment which need to be systematically identify and carefully
spend from public expenditure which is only possible, if country should have National Guidelines
on Climate Finance and Planning at National and Provincial levels.

1.2 Key Climate Change Policies, Laws and Plans

1.2.1 National Climate Change Policy, 2012)
The NCCP is the main document informing the policy framework for climate change in Pakistan.
In early 2011, the Ministry of Environment, in collaboration with UNDP Islamabad, initiated the
process to develop the country’s first climate change policy. It took about 1.5 years of extensive
consultation to formulate the policy. It was approved by the Federal Cabinet in September 2012,
and then launched by the newly-formed Ministry of Climate Change in February 2013.

NCCP provides an overarching framework for addressing the challenges that Pakistan faces or
will face in the future due to climate change. The policy outlines some major climateinduced
threats before laying out the policy measures for different sectors. The document takes a sector
approach and recognizes the importance of developing both adaptation and mitigation strategies
to combat climate change threats. NCCP is motivated by its supporting role in achieving
economic growth. NCCP’s policy goal is “to pursue sustained economic growth by appropriately
addressing the challenges of climate change.” This goal acknowledges that challenges and
opportunities posed by climate change cannot be separated from the broader development goals of
the country. However, thus far, the development policies put more emphasis on economic and
human development than direct climate change issues. Short-term development goals, depicted in
annual plans, focus on macroeconomic stability, and achieving high gross domestic product
growth rate, while mediumterm development goals in the Poverty Reduction Strategy Paper II
and the Medium-Term Development Framework focus on increasing human development through
reducing poverty. Under Pillar IV of the Poverty Reduction Strategy Paper II, the Integrated
Energy Development Program acknowledges the nexus of poverty reduction and environmental
sustainability. The subject of climate change only arises under the section on National
Environmental Policy and is limited to “its potential to reverse progress in Millennium
Development Goal achievements.” Similarly, the Vision 2030 document briefly mentions climate
change under “challenges - mitigating climate change” without providing any clear direction on
what the vision is or where it is supposed to take the country, with respect to addressing how

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climate change may affect the gains of other socioeconomic policies, such as macroeconomic and
social stability, poverty reduction, human development, and improved governance1.

NCCP recognizes and prioritizes adaptation measures over mitigation. It gives a set of policy
measures for adaptation in the following sectors: water resources, agriculture and livestock,
human health, forestry, and biodiversity and other vulnerable ecosystems; and for mitigation in
the following sectors: energy, energy efficiency and conservation, transport, industries,
agriculture and livestock, carbon sequestration, and forestry.2

NCCP acknowledges better socioeconomic gains through tackling climate induced-poverty,

mainstreaming gender, and improving town planning. Furthermore, appropriate measures relating
to disaster preparedness, capacity building, and institutional strengthening; technology transfer
and international cooperation for raising Pakistan’s stance regarding climate change at various
international forums have also been incorporated as important components of the policy.

NCCP also has an implementation plan for the policy which emphasizes devising “climate change
action plans” by all relevant ministries, departments, and agencies at the federal, provincial, and
local government levels. Furthermore, “implementation committees” at national and provincial
levels reporting to the “Prime Minister Committee on Climate Change” is considered an
important institutional structure to move forward with climate change implementation and
mainstreaming.

Strengths of the National Climate Change Policy

The strengths of this NCCP document are as below:
i. The extensive consultation process with all the sector federal ministries, provincial
governments, and all relevant stakeholders including federal and provincial line
departments, academia, nongovernment organizations, and civil society organizations who
were involved in the formulation and development of the first NCCP. All the provinces
were fully involved in its developmental phase. It was precisely the time when, under the
18th constitutional amendment, devolution was taking shape and all the stakeholders were
clear that the ultimate responsibility of its implementation would be through the respective
provinces. The federal government is required to provide the national and international
coordination and facilitator role, including the support needed to access international
climate financing.
ii. The policy is comprehensive and inclusive. While on one hand it has adequately covered
adaptation and mitigation challenges in different development sectors of the economy, on
the other hand, it has not ignored the gender aspects of climate change and the impact of
climate change on the poor and marginalized groups of the society.
iii. The policy was developed on the basis of insights gained from the IPCC 4th Assessment
Report, but it is also in line with the findings and scenarios of the IPCC AR5.
iv. This policy was developed intently in reference to these other policies, documents such as
the National Disaster Risk Reduction Policy (2013), Renewable Energy Policy (2011),
draft National Sustainable Development Strategy (2012), and the regulations establishing
the Designated National Authority for the Clean Development Mechanism.

1
Government of Pakistan, Planning Commission. 2007. Pakistan in the 21st Century, Vision 2030. Islamabad. http://www.
pc.gov.pk/vision2030/Pak21stcentury/vision%202030-Full.pdf
2
For detailed policy measures, please refer to the National Climate Change Policy 2012 document

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Challenges of the National Climate Change Policy
i. Institutional overlap and uncertainty post-18th Constitutional Amendment. Under the
1973 Constitution of Pakistan, the subject of “environmental pollution and ecology” was
part of the “Concurrent Legislative List,” which meant both Parliament and
ProvincialAssemblies had the power to make laws on this subject. After the 18th
constitutional amendment, the subject of “environmental pollution and ecology” along
with 46 other subjects including health, education, food, agriculture, irrigation and
population, livestock, forestry, biodiversity and conservation, and socioeconomic and
welfare responsibilities were devolved to the provinces. However, the federal power and
authority remained, ensured through Clause 6 of Article 270 AA (Declaration and
Continuance of Laws, etc.). This means the federal government can still continue its role
and responsibility in the handling of environment and climate change. Federal and
provincial bodies have not challenged nor clarified this situation.

i. Inherent institutional challenges: The effectiveness of the NCCP is generally hampered

by many inherent challenges climate change poses to the society. The time frame for
consequences of climate change impacts extends by decades and even centuries. The
current planning structure of government hinders its ability to deal with such long-term
issues. These challenges include:

a. Long time frame for the impacts of climate change to unfold and be felt is a
constraint to effective policy and planning formulation and implementation,
while the development plans normally cover a short term of half a decade.
b. Cross-sector and multidisciplinary approach is required to understand the
implications of climate change and respond accordingly. It requires a breadth of
skills and expertise within government to address multiple dimensions of
climate change.
c. Strong vested parties with fewer failures and many scattered winners
d. National and International jurisdiction.

The most serious challenge the climate change policy is facing is its implementation: NCCP
makes the gigantic task of policy implementation contingent upon devising an “action plan” at the
federal, provincial, and local government levels. With much confusion and limited understanding
of the administrative and legal powers of the regulations, policies, and programs transferred to the
provinces, there seems to be less interest in adopting a policy with less clear directives.
Furthermore, the government’s priority is focused on other more immediate challenges the
country is facing, such as terrorism and energy shortfalls. Most of the efforts and financial
resources are used up by these problems and limited time or financial resources are left to deal
with climate change aspects. Another challenge is the erosion of climate change policy ownership
by the provinces, due to potentially conflicting or overlapping objectives, responsibilities, and
priorities between provinces and federal agencies. As per NCCP, Pakistan is signatory to major
environmental conventions and protocols. As signatory to the United Nations Framework
Convention on Climate Change (UNFCCC) and a member state of the World Bank, Pakistan
qualifies for financial and technological assistance. NCCP Policy provided following policy
measures in order to benefit from international financial mechanisms and Climate Finance;
- Continue to assess how best to position Pakistan vis-a-vis other groups of developing
countries in order to secure adaptation funding;
- Ensure the access and effective use of opportunities available internationally for
adaptation and mitigation efforts, e.g. through the Green Climate Fund (GCF), Clean
Development Mechanism (CDM), Adaptation Fund (AF), Global Environmental Facility
(GEF), World Bank’s Forest Carbon Partnership Facility (FCPF) and Carbon credit
trading
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 - Establish a “Pakistan Climate Change Fund” for financing climate change related projects
- Continue to push for transparent delivery of new and additional fast start funding by
developed countries;
- Develop public-corporate-civil society partnerships for financing and implementation of
climate change adaptation and mitigation projects;
- Create domestic carbon market opportunities by introducing an appropriate investment
framework linked with regional banking institutions.
ii. The mainstreaming of NCCP into Public sector discourse is not possible without
effective vertical and horizontal coordination efforts with full involvement of all
stakeholders from the government, civil society, technocrats, private businesses, and the
general public. The formal institutionalized coordination efforts in the past have largely
been horizontal, involving mainly the government sector. An effective vertical
coordination among federal, provincial, and local governments has not yet started.
iii. Prime Minister Committee on Climate Change: This committee represents the apex
political body directing climate efforts and is required to meet annually. It is headed by
the Prime Minister of Pakistan, and includes the ministers for water and power, food and
agriculture, science and technology, and environment; the deputy chairman of the
Planning Commission; and the special advisor to the Prime Minister. The committee’s
mandate is to provide the directive to policy formulation on climate change in the
country. The body has suffered from lack of sustainability and, thus, is ineffective in
building interministerial linkages.3
iv. The Ministry of Environment established the Core Group on Climate Change. It
aimed to forge Pakistan’s approach and strategies toward the negotiation underway at the
UNFCCC following the adoption of the Bali Plan of Action (2007). The group was
composed of members of civil society, think tanks and various ministries. The efficacy of
this group was largely hampered by the other important ministries’ apparent lack of
interest in the issue, and it became inactive by the end of 2013.
v. The provision of climate change data and information is considered as a primary
motivational variable for mainstreaming the climate change issue that reduces uncertainty
in decision-making processes.4 In the case of Pakistan, the lack of information and scaled-
down data on climate change impacts, and its associated responses poses a major
challenge in the implementation and mainstreaming of NCCP. Pakistan Meteriological
Department is mainly responsible for the Climate data collection and Global Change
Impact Study Center (GCISC), an attached department of Ministry of Climate Change is
working on climatic data analysis and its impacts on different sector of economy on broad
basis and GCISC in future will able to work on scaled-down data on climate change
impacts on different sectors as well.
vi. Currently, the evidence of the direct impacts of climate change on development is scarce
compared to evidence on natural disasters. At the federal level, each ministry has its own
system for collecting and using data and information, mostly supported by the attached
research institutions. For example, the Ministry of Water and Power generate water and
energy-related data through its organizations such as the Water and Power Development
Authority (WAPDA), Alternative Energy Development Board (AEDB), and the National
Energy Conservation Centre, etc. Similarly, the Ministry of Food Security and Research
generates and collects data from Pakistan Agriculture Research Centre (PARC). Some
agencies such as the PMD and Global Change Impact Studies Centre (GCISC) under
3
I. Khan and S. Munawar. 2011. Institutional Arrangement for Climate Change in Pakistan. SDPI Report Series 19. Islamabad.
4
C. B. Field et al. 2014. Climate Change 2014: Impacts, Adaptation and Vulnerability Part A: Global and Sectoral Aspect.
Contributions of Working Group II to Fifth Assessment Report of the IPCC. Cambridge, UK and NY, USA: Cambridge
University Press

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Ministry of Climate Change generate particular climate-related information. Among ministries
and sectors, coordination, communication, and information sharing remain weak. At the
provincial and local levels, this information generation and dissemination system is quite
fragmented, incoherent, and suffers from lack of legitimacy and authenticity. Decision makers are
unable to make concrete decisions because of the lack of knowledge and capacity to implement
adaptation and mitigation activities. The following are some of the important research institutions
working on different aspects of country-specific climate change issues and impact assessments. It
is notable that there is a considerable overlapping of scientific research related to climate change
across these institutions as the country currently lacks a centralized coordinating system to keep
track of research programs and avoid overlapping efforts. For example, WAPDA, GCISC, and the
water wing of PARC are all working on glaciers, mainly in isolation. These institutions also suffer
from lack of human and financial resources.
Pakistan Meteorological Department (PMD): Established in 1947, PMD recognizes itself both
as a scientific and service department, and functions under the Aviation Division of the Cabinet
Secretariat. It researches, collects, and (re)broadcasts scientific information on a breadth of topics
ranging from early warning of natural hazards including drought, flood, tropical cyclone, tsunami
and seismic activities, weather data for agricultural community, global warming, and research for
renewable energy resources; and advisory services in the fields of planning and development,
town planning, and infrastructure. PMD stands out as one of the primary organizations in the
country in producing data directly supporting climate change efforts at the local scale.

PMD is divided into four divisions, namely:

i. National Centre for Drought Monitoring, Islamabad
ii. Research and Development Division, Islamabad (This division is working on the GLOF
in the Northern Pakistan in coordination with UNDP)
iii. Flood Forecasting Division, Lahore
iv. National Seismic Monitoring and Tsunami Warning Centre, Karachi

The meteorological services are extended on a regular basis to some of the purely scientific and
hybrid organizations involved in both data production and decision making at the higher level
ofgovernance. Among these are the Civil Aviation Authority, PARC, NDMA, Climate Change
Division, Federal Flood Commission, Ministry of Religious Affairs and National Food Security,
and water sector agencies. Likewise, PMD is also a member of the World Meteorological
Organization and the South Asian Association for Regional Cooperation Meteorological Research
Centre in Dhaka, Bangladesh.

Global Change Impact Studies Centre: GCISC is an autonomous and dedicated institution on
climate change impacts in the country that serves as the Secretariat to the Prime Minister
Committee on Climate Change. Established in 2002, it functioned as a Public Sector
Development Project for 11 years. It received the status of a national entity in 2013 through the
“GCISC Act 2013.” Its function encompasses areas of research, capacity building, and
information dissemination and assistance to national planners and policy makers coming from the
various sectors of water, energy, food, agriculture and livestock, forestry and biodiversity, health,
ecology, and new technology. Among other research initiatives, GCISC is engaged in studying
the impact of climate change on glaciers in the Himalayan region. A board of governors chaired
by the federal minister for climate change oversees the GCISC. Other members include different
scientists; technical experts from the provinces, private sector representatives, and various federal
and provincial ministries; NDMA; the Pakistan Space and Upper Atmosphere Research
Commission, and the PMD.

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Pakistan Agricultural Research Council (PARC): PARC is an autonomous body with the
mandate to provide science-based solutions to the agriculture sector. It is administered through a
board of governors which is headed by the Minister for National Food Security and Research.
Other ministries represented in the board are finance, planning and development, food, agriculture
and livestock, and science and technology. PARC is a prime research and policy organization in
the agriculture sector.

Pakistan Council of Research in Water Resources (PCRWR):5 The PCRWR is an apex

autonomous body established with the objective to conduct, organize, coordinate, and promote
research in all aspects of water resources. Since its inception, PCRWR has played its role as a
national research organization by undertaking and promoting applied as well as basic research in
various disciplines of the water sector, more specifically, irrigation, drainage, surface and
groundwater management, groundwater recharge, watershed management, desertification control,
rainwater harvesting, water quality assessment and monitoring, and development of innovative
water resource management, conservation and quality improvement technologies, etc. However, it
is important to note that the organization does not consider climate change as one of the main
challenges to water management in the country.

The overall decision-making body of the PCRWR is its Board of Governors (BOG). The Federal
Minister (Scientific and Technological Division) of the Ministry of Science and Technology is the
President of the BOG, and its Secretary is the Vice President of the BOG.

Water and Power Development Authority (WAPDA):5 Established in 1958, WAPDA is a

semiautonomous body that handles the water and power sector. In 2007, it was bifurcated into
two separate entities: WAPDA and the Pakistan Electric Power Company. The former is
responsible for all aspects of water and hydropower development including irrigation, drainage
and water supply, flood management, prevention of water logging and salinity, and inland
navigation; whereas the latter handles thermal power generation, transmission, distribution, and
billing.

WAPDA has two important wings: water and power. The power wing looks after hydropower
generation. The water wing is more active as it deals with all water-related areas. The
coordination and monitoring subwing is responsible for coordination among various WAPDA
formations with the Ministry of Water and Power and other national and international
organizations and ministries. WAPDA has its own research wing and has been producing science-
based information related to the water, and power issues and challenges.

1.2.2 Pakistan Climate Change Act, 2017

The Prime Minister has notification in the official Gazette, establish the above mentioned
institutions to: co-ordinate and supervise enforcement of the provisions of this Act; monitor
implementation of international agreements relating to climate change specified in the Schedule;
coordinate, supervise and guide mainstreaming of climate change concerns into decision-making
by Federal and Provincial Government's ministries, divisions, departments and agencies so as to
create enabling conditions for integrated climate-compatible and climate-resilient development
processes in various sectors of the economy; approve and monitor implementation of
comprehensive adaptation and mitigation policies, strategies, plans programmes, projects and
other measures formulated by the Authority to meet Pakistan's obligations under international
conventions and agreements relating to climate change including in particular the Sustainable
Development Goal; monitor implementation of the National Adaptation Plan and its constituent
5
The Pakistan Council of Research in Water Resources. http://www.pcrwr.gov.pk/About.aspx

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conventions and agreements relating to climate change including in particular the Sustainable
Development Goal; monitor implementation of the National Adaptation Plan and its constituent
provincial and local adaptation action plans, the National Appropriate Mitigation Action
Framework and National Communication submitted to the concerned Secretariat of the United
Nations Framework Convention on Climate Change (UNFCCC), etc. Climate change is a
burgeoning issue in Pakistan. As it stands now, the country has a population of 208 million
according to the latest census. It ranks third in the list of countries deeply affected by water
shortage. Freshwater reserves are projected to run out by 2025. The immediate ad hoc reforms
need to be capacity building for water infrastructure, meaning that there should be more scientific
water shortage technology and capital in order to bring immediate relief to the crisis affected.
However, climate change legislation is a long-term foundation for any policy pertaining to
mitigating the effects of the inevitable climate change. Whether the policy is to be used to deal
with the long run causes of water shortage, droughts, submerging cities, ecological changes or
agro-based crises; climate change legislation needs to meet international standards to ensure that
these impending crises are being mitigated.

All 197 signatories to the Paris Agreement currently have a climate change law or policy. While
progress is being made internationally, Pakistan’s climate change policy framework lacks behind
the international standards and this has been pointed out by a statistical academic analysis.
Furthermore, there is a lack of discussion about creating a link between international legislative
trends and domestic ones. Consequently, there is a need for such a legislation to be passed by the
Parliament of this age that ensures a scientific way of keeping pollutants and affected parties in
check. While Pakistan is the 153rd most contributing country to climate change worldwide, it is
7th on the number of countries to be most affected by it. There is a dire need to mitigate the
effects of this exogenous pollution primarily through an effective legislation. Conversations such
as these are vastly unheard of and underrepresented in the legal academic circles of Pakistan. This
review is an attempt to catalyze a conversation in Pakistan pertaining to these modernized needs
of legislation.

With this context in mind, the Parliament of Pakistan came forth with the first legislation
regarding climate change in 2017, called the Pakistan Climate Change Act 2017 (‘CCA’). This
highlighted Pakistan’s due diligence in the international climate regime, resulting in conformity
with international legal norms in the contemporary time. The media circles appreciated the step as
a start to the required degree of legislation for the long run. This legislative review will analyse
the problems that can occur due to lack of implementation of a policy pertaining to the practical
control of polluting entities in Pakistan and mitigation of the effects of international climate
change in the country. An Act to meet Pakistan's obligations under international conventions
relating to climate change and address the effects of climatic change. This Act, consisting of 19
sections divided into five Chapters and one Schedule, establishes the requirements to meet
Pakistan's obligations under international conventions relating to climate change and address the
effects of climate change. The Act is divided as follows: Preliminary (Chap. I); Pakistan Climate
Change Council (Chap. II); Pakistan Climate Change Authority (Chap. III); Pakistan Climate
Change Fund (Chap. IV); Miscellaneous (Chap. V).

International and National Context

As the literature review suggested, the void that the legislation hoped to fill was present in a need
for the following factors – international image building, domestic need, and the legislative lag
after the passing of the devolutionary-based 18th amendment.

The legal void in Pakistan’s legislation was highlighted by the Paris Agreement, which Pakistan
ratified in November 2016. It clearly highlights the need to have a domestic legislation in order to
support the international climate related regime. The CCA proved Pakistan as a country which

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placed importance upon climate change issue. Becoming the 104th country to ratify the treaty,
Maleeha Lodhi, Pakistan’s representative to the United Nations, formally presented the
instrument of ratification at the United Nations General Assembly. Pakistan followed India with
regards to the ratification of the agreement, with the former having ratified the treaty in 2002.
Legislation with international connotations has geopolitical image building implications and
Pakistan followed India to keep up the trend of reactionary policy building for Pakistan.

International image building aside, there was an actual need for the CCA, rather than fulfilling
just a hollow obligation mandated by the international treaty and geopolitics. In 2008, a Gallup
poll showed that merely 34% of Pakistanis knew about climate change issues, while it was
considered a serious threat by only 24%. The point of the CCA was to create awareness about the
major root cause behind the crises happening in the country over the previous years. 18 million
people were displaced in Pakistan, owing to floods due to climate change. In tandem with this,
Balochistan and Thar faced droughts and more specifically with regards to Thar, rainfall had
been extremely low in 2014 and 2015. This has resulted in the required water not being available
for the region’s dietary requirements. More so, in 2015, Karachi, which is Pakistan’s most
important economic city, faced a heat wave that claimed the lives of at least a 1000 people. In
comparison to what was seen as a meagre issue, a corresponding Gallup poll in 2015 showed that
Pakistan was on the list of the 19 countries where climate change was seen as a major threat to the
country’s well-being. Additionally, with Pakistan’s water reserves projected to run out by 2025,
the need of the hour was to have a modern and scientific legislative policy which mandated what
type of technologies needed immediate investment.

With international obligations and national requirements in the foreground, another caveat worthy
of importance is the status of the CCA vis-à-vis the 18th amendment. The 18th amendment to the
Constitution provided provincial autonomy in matters, including climate change. Contrary to the
spirit of the amendment to the constitution and rather than empowering provincial governments
and the district commissioners on the ground, the CCA set up a federal level ministry which
centrally provided funds and carried out tasks. Instead, if the district commissioners were ideally
empowered then they would have been able to avoid the bottlenecks and time lags in the supply
chain. This is because an effective legislative policy can be better mandated by the actors most
proximate to the issues. This issue arose due to the time lag in the implementation of the 18 th
amendment in Pakistan, which was because of the overall restructuring which the constitutional
amendment required, not only in terms of the structures of the federation but also in terms of the
attitudes of the lawmakers.

Analysis of CCA, 2017

The Act set up three relevant institutions: Pakistan Climate Change Council, Pakistan Climate
Change Authority, and Pakistan Climate Change Fund. This section shall evaluate the relevant
provisions of the CCA, in light of these institutions. The focal point of the analysis shall be to
determine the reasonability of the procedural norms of these institutions, the powers imbued to
each of these institutions, their strength in achieving potency in terms of policy analysis, the
social impact of the Act, and whether future policy made in light of the Act is actually
representative of the major stakeholders of society. Lastly, the financial and social impact of the
Act will be analyzed.

Pakistan Climate Change Council

The institutional make-up of the council is highlighted under section 3, whereby it is provided
that the council will have representations from the leadership of all avenues of the Federation.
This representation includes relevant chief ministers, leaders, and if required, the leaders of the
disputed territories, Azad Kashmir and Gilgit-Baltistan can also be included in the council
meetings. This is commendable as all avenues of the Federation can discuss the pertinent climate

8
change policy and devise the common standards applicable to all. The council also provides for
inclusion of members of the civil society, which makes the outlook of future policies inclusive.
However, as with the previous Pakistan Environmental Protection Act 1997 (‘PEPA’), the council
is mandated to meet at minimum twice a year with no cap on the upper bound of the meetings.
The issue with the council established under the PEPA was that it eventually became a dead letter
regime, with two meetings held per year, and the sporadic nature of policy-making which was
further exacerbated by the council’s lack of political will in achieving its mandate.

Moving on, section 4 highlights the functions and powers of the council which extends to
supervising the enforcement of the CCA. Moreover, it has the following prerogatives: the
international treaties Pakistan is a part of, giving strategic direction for the implementation of the
United Nations Sustainable Development Goals (‘SDGs’), giving guidelines for the protection of
ecology, and considering the National Climate Change Report. To analyse these functions, while
the CCA gives the council the power to monitor the progress of climate change reports and policy
outside the institution, there is a dearth of punitive measures with regards to the progress of
climate change legislation. This is equally true for the policy measures that come off this Act and
other climate change relevant law. Without an executive oversight, the main function of the
council is rendered to mere strategic decision-making. Additionally, apart from the lack of clarity
on how the council shall hold those not observing the Act liable, there is a lack of policy with
regards to punitive measures that may be taken against the internal constituents of the Council.
Succinctly put, no self-accountability measures have been drawn up.

Furthermore, contradictory to the implementation of the SDGs, there is an overall lack of youth
representation in the council. This is specifically contradictory to SDG 10, which aims to
integrate youth voices in policy framework – recognizing that the legislators consider the
demographic that shall be at the receiving end of their policies in the times to come.

Pakistan Climate Change Authority

Section 5(2) establishes the Pakistan Climate Change Authority (‘PCCA’), with the prerogative
of being a corporate body, which is capable of being sued and can pursue a suo moto case,
acquire assets, loans, and can enter into contracts whenever required. The establishment of a
corporate body is a positive development in Pakistan’s climate regime, as it highlights that such a
body that is responsible for mitigating climate-related disasters and taking preventive measures.
With regards to the pursuance of suo moto, this will result in Pakistan following a global trend of
climate change litigation in courts. Aggrieved parties which in the past may not be able to get due
compensation on account of gross negligence by the state in terms of climate-related policy will
now be able to pursue charges and get due justice.

Moving on, section 8 defines the function of the authority. The main ones include formulation of
mitigation policies and programmes, in order to curb the crisis of climate change in the country.
The technical aspects of compliance to the Paris Agreement also fall within this body’s ambit, as
it is responsible for the submission of the Nationally Determined Contributions to the United
Nations Framework Convention on Climate. This aspect raises a question of accountability, as
upper Pakistan Climate Change Council members do not have a mandate to check the findings
and technical aspects of the Nationally Determined Contributions as compiled by the PCCA.

While sections 8(e) to (u) provide the authority along with the responsibility of not only research
and development but also of ensuring effective marketing and awareness drives for the public.
These activities and plans that are mandated for the PCCA are further emboldened by the status of
section 10, which gives the council its powers. Most notably in section (10)(2)(b), the PCCA is
given the prerogative of establishing partnerships within the private and public sector. The
provision has one added caveat that in order to establish a partnership with organisations and

9
governments of a foreign region, executive permission needs to be taken by the government. This
is a major issue as it highlights potential blocks in the smooth functioning of the organisation,
owing to bureaucratic red tape in administering climate change emergencies. Moreover, this case
of bureaucratic lag is further aggravated by the lack of heed paid to the 18 th amendment and its
case of provincial devolution.

In obtaining partnerships with foreign development organisations that are present in different
provinces and the prospective hurdles, there exists a lack of efficiency. This would have been
counteracted if the Authority could follow a devolved model of forming a corporate body with
different branches all over the federation, rather one centralised branch present in Islamabad.
Several branches are left to be opened when required whose constructions will take more time.

Pakistan Climate Change Fund

Section 12 ordains the formation of a fund pertaining to climate change to be established, in order
to provide a financial base by which the PCCA shall undertake its functioning. Section (12)(2)
highlights that ‘donations, endowments, grants and gifts’ may be used as a pool for the fund to
draw its funding. However, an important question to consider is section (12)(b)’s relationship
with section (10)(2)(b), which requires permission from higher officials of the government before
accepting any sort of foreign-based aid from organizations and governments. A key feature of the
major revenue that comes for developmental projects is that they are foreign in nature,
highlighting an issue with bureaucratic bottlenecks.

International Legislative Trends

A survey into the legislative trends shows a potency of the United Kingdom and the United States
in creating an effective legislative regime within the confines of their domestic spaces. In this
section, two models shall be elucidated and their prospects for implementation in Pakistan shall
be evaluated. The feasibility will be assessed in light of the institutional infrastructure under the
CCA, through the council, authority, and the fund. It is interesting to note that the legislative
regimes in these countries not only show a modern climate change legislation, as in the United
Kingdom but also civic culture as exhibited by the United States. This ultimately raises the
question or whether a bottom-up civic culture helps in enacting law more effectively or a case of
a top-down legislation instils change more effectively. This section explores the hypothesis of the
three models based on international case studies.

The first model pertains to a revised climate change act being enacted in Pakistan, modelled by
UK’s Climate Change Act 2008. The salient features of this Act include a scientifically calculated
five-year carbon budget, continuous adaptation vis-à-vis ad hoc policy measures and mandatory
progress monitoring and accountability. With the PCCA fulfilling its legislative mandate, there is
ample room to create data-driven legislation in Pakistan which works towards reducing carbon
emissions in the coming years. A caveat that needs to be explored is the nuance of enacting
climate change policies in Pakistan, modelled after legislation which is more suited to the
conditions of the developed industrialised countries. Therefore, the derivative legislation in the
country requires a more nuanced approach suited to the requirement of the developing country it
is set in, with its more unique challenges. This requires a more holistic view of ecology in the
developing terrain when setting carbon limits. It is also required that exogenous pollution (outside
of the country’s jurisdiction) be taken into account to mitigate and anticipate any climate change
disaster in advance. There is also a challenge of balancing long-term policy goals in other arenas
to the climate change regime, especially in the energy sector.

Another model is to enact a ‘public vigilance’ system as exhibited by the strategic climate
litigation in the United States. There is a plethora of typography of litigation done by the public
to counteract the major climate change relevant issues in the country. First, there are a dozen

10
lawsuits to counter the Trump regime’s legislative deregulation towards climate change –
showing that the public can be a watchdog, given the proper civic culture. Another type includes a
push for more federal government transparency into the issue of climate change policy coupled
with more environmental cost-benefit analysis into government project funding. This would
ensure that the government’s activities are more cognizant of the climate requirements of the
country, rather than climate concerns being side-lined on the basis of monetary cost-cutting for
other priorities such as defence spending.

Third, the states are also pushing to ‘decarbonise’ their electricity production as shown by the
States of California, New York, Illinois, and Connecticut. The means to achieve this would be
done by public interest litigation and a push by civil society to ensure that the government does
not act in a way counterintuitive to climate change control. Another interesting mean to achieve a
culture of public vigilance is to carry out litigation against the government by seeking
compensation for climate-related damage. This would be done in circumstances where damages
would be sustained due to events that could have been predicted by effective climate change
policy. To understand the feasibility of enacting a ‘public vigilance’ based model in Pakistan,
there is a need to create awareness about the root causes of the major calamities here, which
includes flooding, drought, water shortages, among others. The Pakistan Climate Change
Authority and Fund are responsible for creating advocacy pertaining to the issue. However,
government oversight is perhaps not the most effective way to build a public vigilance culture, if
the neoliberal school of public policy is to be taken into account given the economic inefficiency
and top-down nature. There is a need for external development partners such as the EU, US-AID,
and Oxfam, among others to create a culture and the domestic NGOs within the country to take
initiative.

Apart from setting up institutions and increasing the government machinery, the main focus now
has to be on policy implementation. There is much more that needs to be done in terms of the
implementation of the CCA 2017. Firstly, it has to be ensured that there is regulatory grit in the
institutions that are made. Most importantly, it should be made clear that the CCA is not there
simply for having an ‘external value’ in the form of international semantics. It is also important
that we generate political will for funding of the domestic climate change regime and maintain a
collective pressure to ensure that the stakeholders are forced to give climate policy a central stake.
Furthermore, there is indeed a chance for misappropriation in the CCA fund and financial audits
need to be instilled in future annexes of the Act to ensure that such is not the case. In Pakistan, a
domestic legal regime has been enacted through a three-tiered institutional process consisting of a
council of stakeholder, an executive corporate styled authority, and a fund to ensure that activities
are financially feasible. However, to become complacent to the possibility of an effective climate
policy regime in Pakistan would be highly erroneous at this point. Equally important is the glaring
nuance in Pakistan of balancing the energy crisis to climate change policy. The major concern in
the last issue is to balance the impact of causal avenues. While electricity is imperative for the
daily functioning of human life in the contemporary time, by carbonising its production vis-à-vis
coal-powered plants is a death sentence to climate change mitigation albeit less public candour
exists for the latter. Lots of work needs to be done to mitigate these concerns, but public pressure
with regards to the issue of climate change is the most impactful factor in the regime’s success. It
will sustain the enactment of a more potent domestic legal framework as pointed out in the paper
and enforce it, not just let it wither out as a dead letter regime.

11
1.3 Sector Specific Policies and Plans with focus on Agriculture and Water Sectors
1.3.1 National Food Security Policy, 2018
Pakistan has made significant progress in food production over the last several decades. However,
food security is still a key challenge due to high population growth, rapid urbanization, low
purchasing power, high price fluctuations, erratic food production, and inefficient food
distribution systems. According to the Food Security Assessment Survey (FSA), 2016, 18% of the
population in Pakistan is undernourished. National Institute of Population Studies (NIPS) reported
high level of severe stunting (45%), wasting (15%) and underweight (30%). The malnourishment
problems are high in rural areas (46%) and in certain regions like FATA (58%), GB (51%) and
Baluchistan (52%). Similarly, around half of the population is consuming less than the dietary
requirement of Vitamin-A and Iron. Food insecurity in Pakistan is primarily attributable to the
limited economic access of the poorest and most vulnerable to food. A key factor limiting access
to food, particularly since 2007, is the increase in the prices of essential food items. With the
poorest families spending a substantial part of their income on food, the price rise has exacerbated
under nutrition and vulnerability. To address the challenge of food insecurity, the Government of
Pakistan has taken the initiative to formulate a national food security policy. Pakistan is an
agrarian country and, hence, agricultural development is a prerequisite for achieving food
security. According to Pakistan Economic Survey 2016-17, agriculture contributes 19.5% to
Pakistan’s GDP, employs 42% of the labour force, constitutes 65% of export earnings, and
provides livelihoods to 62% of the population of the country. The agriculture sector in Pakistan
has been facing a number of major challenges over the last decade. As a result, the performance
of this sector has been less than its potential in recent times, with low growth of around 3.3% over
the last decade. Consequently agricultural growth has not benefited the rural poor in Pakistan to
the extent it was expected. Wheat, rice and sugarcane being major food crops were given more
attention in previous policies. The other major factors underlying this underperformance include a
slow rate of technological innovation; problems with the quality, quantity, and timeliness of input
supply; inadequate extension services and technology transfer; limited investment in construction,
road maintenance, and market infrastructure; marketing and trade restrictions; pest and livestock
disease problems; feed & fodder shortages; limited amounts of credit for agricultural production
and processing; and lack of agriculture-specific loan products. For balanced food intake, there is a
need to focus on the production of diverse foods, i.e., vegetables, fruits, nuts, oilseed, pulses, and
livestock products: these not only contribute around 50% of dietary energy, but also significantly
contributes in nutritional food security. Beside that, the harmonization of non-agricultural
activities, such as those related to nutrition, trade, natural resource management, non-farm income
opportunities, targeted income support, and other innovative options within the agriculture sector,
are also recognized as important steps in achieving food security. Pakistan needs to build strong
resilient agriculture sector to cope with the climate change risks. Climate change projections
indicate that there will be greater variability in the weather with more frequent extreme events
such as floods and droughts. Much of the impact of these changes will be on the agriculture
sector, which needs mechanisms to cope and adapt. It is further projected that there will be
immense pressure on limited surface as well as ground water resources. These challenges could
be managed through adopting soil and water conservation technologies, enhanced use of high
efficiency irrigation systems, developing drought resistant varieties, and introducing climate
smart agriculture.

Mission and Goal of Policy

Mission of Policy is to ensure a modern and efficient food production and distribution system that
can best contribute towards food security6 and nutrition, in terms of availability, access,
utilization and stability. The policy goals are to alleviate poverty, eradicate hunger and
malnutrition; promote sustainable food production systems (crop, livestock and fisheries) by

12
achieving an average growth rate of 4% per annum and make agriculture more productive,
profitable, climate resilient and competitive.

Mitigating and adapting to climate change effects on agriculture and livestock is mentioned under
one of major challenges to Food Security and Agriculture policy.

Safe food production for better environment and climate change compatibility is one of the policy
measure under the guiding principles of strategic framework of the food security policy;

One of the policy measure under Land and Water Resources Management is promoting cropping
pattern and climate smart agriculture practices with maximum water productivity.

This policy has given following policy measures for Climate Change;
- Impact assessment and optimization of adaptation strategies under climate change
scenario
- Develop a well-coordinated crop-livestock breeding program involving national and
international research centers
- Conduct basic, strategic and anticipatory research involving federal and provincial
research systems, and CGIAR organizations
- Develop climate-smart crop-livestock sectors while focusing on the use of bio-
technology, resource conservation and harmonious production packages for diverse
ecosystems of the country
- Evaluating the performance of breeding lines in Target Population of Environments
(TPE) and identifying the hot spots for dissemination of suitable varieties and animal
breeds
- Enhance productivity and profitability while preserving environmental quality
- Undertake an adaptation program in order to better deal with climate change impacts
- Promoting crop and livestock insurance schemes as risk coping strategy particularly in
rain fed areas under public private partnership
- Acquisition and judicious exploitation of bio-diversity and genetic resources from
national and international sources.
- Human resource development to address the new breeding and crop-livestock production
challenges under emerging climate change regimes.

This policy has given following policy measures for Emergencies and Disaster Management;
- Coordination with National Disaster Management Authority (NDMA)
- Prepare emergency preparedness plan on food security, agriculture and livestock sector
- Develop agriculture and livestock assessment checklists using remote sensing as a tool for
early warning Develop early warning system for extreme climate events and emergency
response plans for crop and livestock extension departments, and farmers in collaboration
with provincial governments
- Identification of food insecure areas of disaster prone districts in collaboration with WFP
- Create awareness about livestock feed resources among livestock owners and promote its
production in disaster prone districts

6
Food security is a situation that exists "when all people, at all times, have physical, social and economic access to
sufficient, safe and nutritious food that meets their dietary needs and food preferences for an active and healthy life" (as
defined in the World Food Summit Declaration 1996). Food security has four main determinants, i.e., food availability,
food accessibility, food utilization, and food stability, which are simultaneously improved to ensure adequate
nourishment and nutrition for all segments of the population.

13
 - Develop guidelines and minimum standards for cattle camps
- Prepare an inventory of equipment, vehicles, agriculture inputs, and animal vaccine and
medicine suppliers
- Designate a representative to the NDMA for coordination
- Develop plan for agriculture sector for the early recovery phase after disaster
- Conduct initial rapid assessment to assess the crops and livestock losses
- Support to provincial livestock department for the provision of fodder, de-worming
medicines and vaccines for animals during drought and flood periods
- Assessment of post disaster pest attack on the crop and take effective measures for control
- Prepare a detailed report to document the response experiences for future planning
- Preparing alternate crop-livestock production plans for the rehabilitation of effected
communities.
- Collaboration with national and international agencies in food and fodder production in
conflict affected and disaster hit areas

This policy has given following policy measures for policy Implementation Arrangements;
- Cost-benefit analysis of policy measures to prioritise them into those of most value in the short,
medium and long term, and to recognise trade-offs,
- Commitment to the high impact, flagship programs that need public funding and government
leadership, and specific time-frames to produce desired results,
- Structuring and resourcing of government institutions according to activities prioritised under
the policy, with appropriate coordinating mechanisms,
- Government spending to leverage private sector investments for accelerating the attainment of
food security goals,
- Providing sufficient financial incentives through taxation and subsidy regimes with minimal
distortionary effects,
- Using communication, education and awareness methods customised to the language and
literacy status of intended audiences,
- Media and public submissions to achieve cross-section food security.

1.3.2 National Water Policy, 2018

The objective of the National Water Policy is to take cognizance of the emerging water crisis and
provide an overall policy framework and guidelines for a comprehensive plan of action. Pakistan
has a federal system of government and the provinces enjoy a considerable degree of autonomy
under the 18thAmendment to the Constitution. Thus, this policy is a national framework within
which the provinces can develop their master plans for sustainable development and management
of water resources. The water resource is a national responsibility but irrigation and agriculture,
as well as rural and urban water supply, environment and other water related sub-sectors are
provincial subjects. This National Water Policy can provide a major response to the emerging
water crisis if it receives high level political support, as a national imperative. It provides a set of
agreed national targets for water conservation, water storage, water treatment and clean drinking
water. It leads to a sustained national commitment to substantially increase public and private
resources for the water sector. It creates an institutional framework that can address present
deficiencies in project management and cost effective maintenance on a war footing to revive the
technical capacity and efficiency of the system that achieved such remarkable progress between
1950 and 1990. It has become a national imperative to ensure water security for the people of
Pakistan, through a National Water Policy (NWP) laying down the outlines of an integrated water
management strategy that can optimize the economic, social and environmental returns on water
resources, ensure equitable allocation among its competing demands as well as its judicious use
by consumers and safe disposal of post-use effluents. The National Water Policy lays down a
broad policy framework and set of principles for water security on the basis of which the

14
Provincial Governments can formulate their respective Master Plans and projects for water
conservation, water development and water management.

Objectives of Policy
The National Water Policy is based on the concept of Integrated Water Resources Management
and some of main objectives of policy are as below;
- Promoting sustainable consumption and production patterns throughout the water sector
from exploitation to utilization;
- Augmentation of the available water resources of the country through judicious and
equitable utilization via reservoirs, conservation and efficient use;
- Improving availability, reliability and quality of fresh water resources to meet critical
municipal, agricultural, energy, security and environmental needs;
- Improving urban water management by increasing system efficiency and reducing non
revenue water through adequate investments to address drinking water demand, sewage
disposal, handling of wastewater and industrial effluents;
- Hydropower development to increase the share of renewable energy;
- Providing food security and expanding water availability to help adapt to climate change,
population and other large-scale stresses;
- Treatment and possible reuse of waste water - domestic, agricultural and industrial;
- Flood management to mitigate floods and minimize their damages;
- Drought management with emphasis on long term vulnerability reduction;
- Promoting appropriate technologies for rain water harvesting in rural as well as urban
areas;
- Promoting measures for long term sustainability of the Irrigation System;
- Climate change impact assessment and adaptation for sustainable water resources
development and management;

Policy Gaps in Major Areas of Concern

Integrated Planning and Development of Water Resources
- There is no mention of indigenous resources such as rain water harvesting, harnessing the
potential of hill torrents and construction of small dams at feasible sites.
- There is no mention as to how funding for construction of storage dams and other
development plans would be secured

Irrigated Agriculture Sustainable Land Management

- various aspect of land management has not given due consideration e.g. environment
component of biodiversity, ecological integrity and natural capital, these all depend on
efficient management of water resources
- Issue of watershed management although very important has not been given due
importance.

Economic and Financial Management

- Financial stability of water sector is one of the major concern in the point of view of O&
M of infrastructure . but the policy document didn’t emphasize it

Institutions and Legal Aspects

- National Water Council (NWC) has been proposed in the policy documents to implement
activities Existing legislation at federal and provincial levels need review, to meet the
changed conditions Existing water rights are linked to ownership of land affecting major
segment of rural population

15
Stakeholders Participation Donor Driven Institutional Reforms
- Development of independent dichotomous body ( Provincial irrigation authorities ) and
the concept of single size fit to all, is only for the small to medium irrigation project not
for large gravity irrigation system of Indus basin.
- There is frequent breakdown of the network through cutting of banks and wide spread
tampering of the outlets. The new concept of public and private partnership is missing.
- The farming communities are not at all satisfied as frequent tail shortages have been
reported in the areas of poor farming community, because due to influence of big landlord.

Information Management and Research

- Overlapping of responsibilities between ministries at federal and provinces level,
- Lack of qualified personnel and basic research equipments, Scattered information and data
on the water sector with little inter sectoral collaboration.
- No monitoring capacity for temporal changes in the volume of water coming from glaciers
and snow cover etc.

Climate Change
There are direct impcts of climate change on water resources. Policy documents do not mention
any guidelines to offset effects of climate change.

1.4 Other Climate Change supporting Policies and Frameworks

1.4.1 National Disaster Risk Reduction Policy, 2013

This policy (2013) aims to build the nation’s resilience by reducing its exposure to various types
of hazards, adopting principles to strengthen community resilience by improving vulnerability
and risk assessment through a multi-hazard approach, and by assigning a clear division of roles
and responsibilities, inter-organizational partnership, and accountability and transparency.7 The
policy objectives recognize climate change challenges in the context of national capacity building
and development planning, as follows:
(i) Creating an integrated national capacity to identify and monitor vulnerability
and hazard trends including potential climate change impacts.
Promoting development planning that considers and addresses disaster risks alongside
environmental and climate change concernsThe vision statement, however, while emphasizing
building national resilience against natural and manmade hazards, misses out on the strong
linkage of climate change and the increasing frequency and intensity of disasters with the ability
to erode the resilience of communities. It states, “A Pakistan that builds up its resilience to shocks
from natural and man-made hazards with a sense of urgency, creating a solid base to address
disaster risk reduction in vulnerable areas, while involving an increasingly wider range of
stakeholders...” It is important to highlight that the
current policy document is not synchronous with the main thrust of NCCP. The issue of disaster
risk reduction is assigned a separate section in NCCP but in the National Disaster Risk Reduction
Policy, which was formulated after the NCCP, the recognition of climate change mostly does not
go beyond one-liners that acknowledge its role mainly in the context of hydro-metrological
hazards such as floods and droughts, and melting glaciers of the North.

7
National Disaster Risk Reduction Policy. 2013. http://www.ndma.gov.pk/Documents/drrpolicy2013.pdf

16
1.4.2 National Disaster Response Plan, 2019
Revised version of National Disaster Response Plan is the Government of Pakistan's "Multi-
Hazard" Response Plan. The purpose of National Disaster Response Plan is to enhance the
country's ability to manage disasters using a comprehensive national approach. It outlines the
processes and mechanisms to facilitate a coordinated response by the national and/or the
provincial/local level departments/agencies. To achieve this, the National Disaster Response Plan-
2019, incorporates all disaster management activities; from preparedness to response. The revised
plan considered the Global trends in Disaster Response and commitments of Pakistan. This Plan
has four sections. Section I. This section provides brief profile of Pakistan and historical
perspective o Revised version of National Disaster Response Plan is the Government of Pakistan's
"Multi-Hazard" Response Plan. The purpose of National Disaster Response Plan is to enhance the
country's ability to manage disasters using a comprehensive national approach. It outlines the
processes and mechanisms to facilitate a coordinated response by the national and/or the
provincial/local level departments/agencies. To achieve this, the National Disaster Response Plan-
2019, incorporates all disaster management activities; from preparedness to response. The revised
plan considered the Global trends in Disaster Response and commitments of Pakistan. This Plan
has four sections. Section I. This section provides brief profile of Pakistan and historical
perspective of disasters in Pakistan, Section II. This section presents institutional systems for
disaster management in Pakistan, including roles and responsibilities of stakeholders, mainly at
the national level, Section III. This section provides information pertaining to the activation of
NDRP, including roles and responsibilities of the stakeholders at various tiers and Section IV.
This section provides the brief information on the provision of emergency services and public
assistance immediately after a disaster to save lives, reduce health impacts, ensure public safety
and meet the basic needs of the people affected by the disasters. National Disaster Response Plan
also acts as the guiding document for local Government institutions who are responsible for the
development and improvement of local Response Plans related to respective areas of
responsibility.
1.4.3 National Environmental Policy, 2005
The National Environment Policy 2005 was formulated at a time when understanding among
policy makers about the country’s climate change challenges was low.8 The environment policy
recognizes various issues such as dwindling water resources and desertification that could be
linked to the serious outcome of climate change in Pakistan. In this policy document, climate
change is one of the key environmental issues. The issue of climate change is explicitly
mentioned only in Section 4.7 of the environment policy, reproduced below: 4.7. “Climate
Change and Ozone Depletion.” In order to effectively address challenges posed by climate change
and to protect the ozone layer, the government shall: (i) develop and implement the national
climate change action plan. (ii) establish national Clean Development Mechanism (CDM)
Authority. (iii) develop and implement policy and operational framework for effective
management of CDM process. (iv) promote the use of ozone friendly technologies. (v) phase out
the use of ozone depleting substances in line with the provisions of the Montreal Protocol.” This
narrow perspective mainly focuses on CDM, which is a mitigation instrument, and is restricted to
protecting air quality, which is only one of the many manifestations of climate change. This does
recognize the need for a national climate change action plan but fails to acknowledge its serious
cross-sector implications on Pakistan’s fragile demographic profile.
1.4.4 Alternative and Renewable Energy Policy, 2011
The Alternative and Renewable Energy (ARE) Policy 2011, developed by the Ministry of Water
and Power, provides a road map for realizing the full potential of ARE in Pakistan.9 The AEDB,
under the AEDB Act (2011), is empowered to develop the national strategy, policies, and plans

8
National Environmental Policy. 2005. http://environment.gov.pk/NEP/Policy.pdf
9
Government of Pakistan, Ministry of Water and Power. 2011. Alternative and Renewable Energy Policy 2011. Islamabad

17
for the utilization of ARE. The ARE Policy 2011 has an expanded scope encompassing all ARE
sources including solar, wind, small-scale hydropower, biogas, biofuel, and energy from waste.
The ARE Policy 2011 sets out some enhanced financial mechanisms and also addresses areas like
rural energy services and biofuels. It aims to set the requisite infrastructure in place so it can be
fully mainstreamed and integrated within energy planning, and economic and social development.
Likewise, it has tried to resolve policy conflicts, addressed stakeholders concerns, and includes
the proposed establishment of Alternative Energy Development Fund to promote this sector. The
ARE 2011 was developed at a time when stakeholders’ consultations for the development of
NCCP were underway. As such, the ARE Policy 2011 is complementary to the climate change
policy, and most of the policy measures regarding renewable energy are more or less the same in
both polices. Furthermore, as a mitigation effort, the alternative energy indirectly improves the
adaptive capacity of the community. To earn financing for the ARE initiatives, the focus of the
ARE Policy is getting carbon credits by using CDM.10 In this context, the AEDB is authorized to
provide technical expertise to the (former) Ministry of Environment as the DNA in its role under
the CDM. The AEDB assists in the development of local CDM capacities, as well as carries out
CDM promotion and awareness of ARE. Another important focus is environmental and potential
social impacts of alternative fuels, specifically biodiesel supply chains. Under the alternative fuel
chapter, it identifies the EPA as the main agency to develop emissions standards for aldehyde and
methanol production.

1.4.5 National Power Policy, 2013

The National Power Policy was formulated in 2013 under the auspices of the Ministry of Water
and Power.22 The key objective of this National Power Policy is to attract local and foreign
investments for the expansion of the country’s power generation capacity, particularly in the
production of cheap electricity. The National Power Policy strategy focuses on shifting Pakistan’s
energy mix toward low cost sources such as hydropower, gas, coal, nuclear, and biomass. Local
and foreign investments will aggressively seek small- and medium-size runs of river hydel
projects. Selected hydel projects under development will be positioned for privatization, and
multilateral agencies will be invited to partner for large infrastructure hydel projects. The
National Power Policy assessed that 7,000 megawatts (MW) of electricity need to be added to the
system to control load shedding in Pakistan. In the National Power Policy document, clear targets
are laid out in terms of efficiency, affordability, financial viability, the demand–supply gap, and
governance of the system. However, the policy does not have a clear emission reduction strategy.
All over the world, the energy sector is at the forefront in combating climate change due to its
highest share in GHG emissions. In Pakistan, this sector contributes more than 50% of emissions,
but, unfortunately, the policy does not consider how initiation of cheap coal power can change the
country’s present lowemission status. Likewise, it fails to include any initiatives that would drive
energy efficiency and promote clean energy by putting in place the carbon pollution standards for
high emission subsectors.

1.4.6 Updated Nationally Determined Contribution, 2021

Government of Pakistan (GoP) as a Party to the Paris Agreement of the United Nations
Framework Convention on Climate Change (UNFCCC) has performed its role to support the
global efforts in combating climate change. GoP takes ownership and pride in submitting an
updated Nationally Determined Contributions NDC which is inclusive and represents national
consensus to accelerating the transition towards a climate-resilient economy. The current updated

10
CDM is one of the emission reduction instruments of the Kyoto Protocol.

18
NDC submission showcases GoP’s progress in climate action that ranges from policy and
programs on Nature-based Solutions (NbS) to technology-based interventions. Pakistan,
recognizing the role of nature in climate adaptation and mitigation, has developed robust natural
capital restoration efforts including the Ten Billion Tree Tsunami Programme (TBTTP),
Protected Areas Initiative (PAI) etc. These programs have also served as a way to enhance
livelihood opportunities for the most vulnerable, including women and youth. In addition,
Pakistan has introduced a number of policy actions focused on mitigating greenhouse gas
emissions from high emission sectors like energy and industry. The focus of GoP’s climate
actions during the decade ahead is decided by the current climate-induced vulnerabilities, aimed
at achieving reduced poverty and ensuring a stable economy. The current submission is informed
by recent policy development in the country in the NDC sectors, and some ambitious decisions
taken by the pro-climate leadership to enhance Pakistan’s resilience and decarbonize the
economy. In addition—for enhanced contributions—new sectors and new gases have also been
added to the updated NDC. Hence, Pakistan intends to set a cumulative ambitious conditional
target of overall 50% reduction of its projected emissions by 2030, with 15% from the country’s
own resources and 35% subject to provision of international grant finance that would require
USD 101 billion just for energy transition. To reach the target, Pakistan aims to shift to 60%
renewable energy, and 30% electric vehicles by 2030 and completely ban imported coal.
Moreover, Pakistan seeks to expand NbS by implementation of TBTTP, Recharge Pakistan, and
PAI. Pakistan‘s emissions as per 2018 are 489.87 MtCO2e; Billion Trees Afforestation Project
(BTAP) and TBTTP will sequester CO2 around 500 Mt CO2e by 2040, if implemented fully.
Pakistan requires to strengthen its scientific and technical capacities to reach the set transition
targets. Pakistan’s financial needs still remain high, given the country’s vulnerability to climate
change and capital-intensive transition to decarbonize the economy. The country envisages
enhancing the access to international climate finance to deliver the contributions, and also
considers employing the instruments on enhanced ambition provided in Article 6 of the Paris
Agreement. Pakistan has already identified market and non-market-based approaches to help
diversify the funding sources, including Nature Performance Bonds, Green/Blue Bonds, Carbon
Pricing Instruments, etc. Pakistan encourages the private sector to play a crucial role in
implementing its climate ambition across sectors and the development of NbS that address its
mitigation and adaptation potential.

NDC Targets & Means of Implementation

The Government of Pakistan (GoP) will, therefore, follow the greenhouse gases (GHG) emissions
trajectory of 1603 Mt CO2 Eq. for 2030 as announced in Pakistan’s initial Nationally Determined
Contribution (NDC) submission in 2016. However, realizing the importance of reducing the GHG
emissions under Paris Agreement to limit the temperatures to 1.5/2°C, the GoP aims to reduce the
emissions to the maximum possible extent. Pakistan intends to set a cumulative ambitious
conditional target of overall 50% reduction of its projected emissions by 2030, with 15% from the
country’s own resources and 35% subject to provision of international grant finance that would
require USD 101 billion just for energy transition.

Climate Change Mitigation Targets in updated NDC, 2021

i. Renewable Energy: By 2030, 60 % of all energy produced in the country will be
generated from renewable energy resources, including hydro.
ii. Transportation: By 2030, 30 % of all new vehicles sold in Pakistan in various categories
will be Electric Vehicles (EVs).
iii. Coal: From 2020 onwards, a moratorium is in place on new imported coal-based power
plants and no generation of power through imported coal, plans for two new coal-fired

19
 power plants have been shelved in favor of hydro-electric power, and there is increased
focus on coal gasification and liquefaction for indigenous coal.
iv. Land-Use Change & Forestry: From 2016 onwards, continued investments in Nature
based Solutions (NbS) through the largest ever afforestation programs in the history of the
country Ten Billion Tree Tsunami Program (TBTTP) will sequester 148.76 MtCO2e
emissions over the next ten years. The estimated project cost of about US$ 800 million is
being met nationally from indigenous resources, as unconditional contribution.

Climate Change Adaptation Targets in updated NDC, 2021

v. Recharge Pakistan: By 2030, the project envisages the reduction of flood risk and
enhanced water recharge at six sites in the Indus Basin, building resilience of 10 million people
and vulnerable ecosystems. The Project is under review by the Green Climate Fund (GCF) for
funding; in the meantime, Pakistan has allocated PKR 6 billion from national resources to
commence the activities in three sites, namely Manchar & Hamal wetland, Taunsa pond area, and
Dera Ismail Khan.
vi. Protected Areas: By 2023, total protected areas in the country will be enhanced from
12% to 15% that will result in preserving rare fauna and flora, green job opportunities for 5,500
people, and promotion of eco-tourism.

Pakistan will require finance, technology transfer, and capacity building in line with Article 4 of
the United Nations Framework Convention on Climate Change (UNFCCC) and Articles 9, 10 and
11 of the Paris Agreement to fully implement the climate actions contained in these NDCs. These
articles are explicit on supporting developing countries to implement climate change actions and
increasing mitigation ambition, considering ‘the common but differentiated responsibilities and
their specific national priorities’. Paragraph 5 of Article 4 of the Paris Agreement specifically
committed that “support shall be provided to developing country Parties for the implementation of
this Article, in accordance with Articles 9, 10 and 11, recognizing that enhanced support for
developing country Parties will allow for higher ambition in their actions”. The Ministry of
Climate Change (MoCC) will work closely with line ministries and provincial Planning &
Development Departments (P&DD) to mainstream climate considerations into over-arching
development and sectoral planning in a gradual and systematic manner. The wide-ranging
mandate of the MoCC requires capacity-development for strong scientific and technical
knowledge. MoCC and other ministries and departments will also stand to benefit from
institutional and policy reforms, strengthening and capacity-building enactment through upgraded
rules, procedures, guidelines, and standard operating procedures (SOPs) for well-coordinated
climate actions. As per updated NDC, 2021 there is need of embedding climate change and
concurrent actions and investments in following areas;

i. Policies: Cross-referencing to climate change in national and provincial sectoral policies and
action plans on climate adaptation and mitigation will need improvements. Several policies
will need to be refreshed or revised where they exist, or developed where they do not in order
to fully align with Pakistan’s climate change needs and contributions. priority sectors are the
ones dealing with mitigation and adaptation, already mentioned in this Nationally Determined
Contribution (NDC) submission.
ii. Investment Processes: Preparatory and approval systems dealing with the life-cycle of
projects and schemes need to be made climate-smart in order to fully embed climate
adaptation and mitigation indicators. MoCC will lead the process together with its provincial
counterparts, and the Ministry will also provide technical support and backstopping for this
purpose.

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Implementation Mechanisms
As focal agency, MoCC leads the processes for preparation, updating, coordination, and
implementation of NDCs. Mainstreaming of climate change, however, continues to be a collective
challenge. Climate Change has to find place in the country’s several policy planning mechanisms
and forums as well as in economic decision-making such as Natural Income Accounting, GDP
measurement, or annual allocations in the fiscal budgets and engagement. Likewise, it still need to
be integrated with apex policy making bodies of the cabinet, as well as ECNEC, and Public
Sector Development Programme (PSDP), Central Development Working Party Meeting (CDWP),
and Development Working Party (DWP) processes to mainstream climate in sectoral projects and
portfolios. The updated NDC has set the direction of travel for whole-of-government in this
regard. The Prime Minister’s Committee on Climate Change (PMCCC) will oversee the
implementation progress as well as the regional and international partnerships and alliances to
ensure that Pakistan continues to be an active member of global community for the
implementation of Paris Agreement. Relevant national and provincial policies will be reviewed in
order to embed climate change adaptation and mitigation and develop a NDC Coordination and
Implementation Plan (NCIP). For institutional reform and augmenting planning processes, MoCC
will coordinate for climate proofing of planning processes such as PC-1.

1.4.7 Pakistan’s Second National Communication on Climate Change, 2020

Pakistan’s Second National Communication (SNC) contains the updated information until the
year 2015 about the consolidated efforts undertaken by Pakistan in different thematic areas related
to climate change mitigation and adaptation. Chapter 1 builds up the context by briefly describing
the National circumstances since the Initial National Communication (INC). Chapter 2 documents
the GHG inventory with the anthropogenic emissions and removals from key sectors including
waste, land-use- change and forestry, agriculture, industrial processes and energy sector.
Industrial processes includes mining, chemical and metal production whereas the energy sector
entails the manufacturing, transportation and energy industries of the economy. Energy use in
residential, commercial and agriculture is also incorporated in the energy sector inventory of the
GHG. The chapter concluded with listing the energy intensity from 1994 to 2015. It is prudent to
summarize that despite the expanding population, with ever growing energy and water demand,
the total emissions (in kilograms of CO2 - eq) per $GDP (in USD of 2010) of Pakistan was 1.88
kilograms of CO2 - eq in comparison to 1.9 kg eq in 1994. This itself presents the meagre portion
of Pakistan in terms of the anthropogenic cause of climate change as contrast to the collective but
unevenly distributed share of responsibility at Pakistan. Regardless of Pakistan’s very small
contribution to GHG emissions, its role as responsible member of the global community in
combating climate change is highly appreciable, and can be seen from large scale projects such as
the Billion Tree Tsunami, which restores 350,000 hectares of forests and degraded land to surpass
Bonn Challenge commitment. Chapter 3 remains the backbone of this report with modeled results
related to temperature and precipitation changes projected for 2020, 2050 and 2080. It is prudent
to mention here: “The future climate projections developed by using state- of- the- art climate
models indicate higher temperature rise over northern parts of Pakistan when compared with
southern parts. The projected temperature increment along the coastal belt of the country are
comparatively lesser and are in the range of 3 to 4 °C. In case of precipitation, an increase is
projected over northern parts of the country compared to the southern counterpart. These changes,
invariability and expected erratic climate conditions are then trickled down to scope the effects on
crop development, underground and river water inflows, health sector, natural ecosystems, coastal
management, livestock and others. Such key vulnerable sectors are identified and highlighted in
Chapter 3. Chapter 4 postulates the options and challenges associated to the mitigation of current
and projected GHG emissions. From the perspective of projected emissions for a growing
economy, Pakistan’s Intended Nationally Determined Contributions (INDC) were aligned with
the expected GDP growth scenarios as well as with the respective policies, plans and sectoral
growth targets set by various ministries and other government entities. Due importance has been

21
given to mitigation efforts in sectors such as energy, transport, industries, urban planning, forestry
and land- use, agriculture, livestock and waste in Chapter 4. These overlapping thematic areas and
the vulnerable sectors identified in Chapter 3 are then integrated into Climate Change
Considerations into Social, Economic and Environmental Policies in Chapter 5. Such integrations
are big wins for Pakistan in terms of Strategy (National Climate Change Strategy), Plan (Climate
Change and National Development Plan) and Policies (National Climate Change Policy, 2012).
Furthermore, appropriate actions relating to disaster preparedness, capacity building, institutional
strengthening and awareness raising in relevant sectors have also been part of this document.
Inclusive and equitable measures with a focus on the most vulnerable segments of the society is at
the forefront of Pakistan’s response to the threat of climate change. Chapter 6 provides an update
on Research, Technology Transfer and Systematic Observation. It identifies the lack of technical
equipments in particular, and capacity building needs in general, as effective tools to combat the
affects of climate change. Recent trends of extended droughts and intense heatwaves coupled with
the floods including glacial lake outburst floods; the writing is on the wall for the people and
institutions of Pakistan with over USD 18 billion loss to the economy in just five floods (2010-
2014). Discussion of technology requirement and capacity building, stated in Chapter 6, is
complimented with the need assessments of key sectors of energy/ power, transport, agriculture,
water, forestry and waste management in Chapter 7 while also discussing environmentally sound
technologies and their development and transfer as well as related capacity building needs. Such
technological and other capacity building needs that are then articulated in Chapter 8 titled
‘Constraints, gaps, and related financial, technical & capacity needs’. It sought collaborations
from international community and also briefly lists the ongoing such collaborations via bilateral
and multi- lateral institutional framework.

The policy recommend following policy measures for Government;

 Establishment of Prime Minister’s Committee on Climate Change
 The launch of 10 Billion Tree Tsunami
 The launch of Clean & Green Pakistan - the program envisages addressing five
components: plantation, solid waste, liquid waste/ hygiene, total sanitation and safe water
 Efforts to increase the share of renewable energy up to 30% in the energy generation mix
 Promotion of net-metering regime
 Development & Launch of mandatory energy labeling regime for LED Lights, AC and
Refrigerator
 Promotion of solar power irrigation systems
 Efforts for the gradual wiping-out of single use plastics
 Formulation of NDC implementation roadmap
 Formulation of Electric Vehicle Policy
 Launch of Ecosystems Restoration Initiative (ESSRI)

1.4.8 Framework for Implementation of Climate Change Policy, 2013

This framework provides a guideline for the implementation of the NCCP by considering both the
current and future anticipated climate change threats to the country. Keeping in line with the
NCCP’s policy measures, it spells out a comprehensive list of both adaptation and mitigation
strategies, and actions for each key sector primarily identified in the NCCP, while prioritizing the
adaptation efforts at the sector level. These cover actions to address issues in various sectors such
as water, agriculture, forestry, coastal areas, biodiversity, health and other vulnerable ecosystems.
Notwithstanding the fact that Pakistan’s contribution to global greenhouse gas (GHG) emissions
is very small, its role as a responsible member of the global community in combating climate
change has been highlighted by giving due importance to mitigation efforts in sectors such as
energy, forestry, transport, industries, urban planning, agriculture and livestock. Furthermore,
appropriate actions relating to disaster preparedness, capacity building, institutional

22
strengthening; and awareness raising in relevant sectors has also been part of this document. The
framework document aims to provide a basis and form the building block that will lead to the
development of a National Adaptation Plan, National Appropriate Mitigation Action, and the
preparation of the Second National Communication to the UNFCCC. The implementation time
frame ranks action strategies into priority action (within 2 years), short term (5 years), medium
term (10 years), and long term (20 years), with identification of the relevant organizations and
ministries to play a role in each. However, the framework does not assign clear roles and
responsibilities to these organizations and, most importantly, does not itemize how coordination
among these would be effective regarding institutional power and authority after the 18th
constitutional amendment. The framework enlists important enabling factors for its success that
includes building highlevel political support, besides enhancing donor community interest and
attracting international climate financing. It pinpoints the donor community’s lack of interest in
climate change-related initiatives as a major implementation challenge for the mainstreaming of
the NCCP. Similarly, it identifies the importance of the private sector’s role in the successful
implementation of climate change adaptation and mitigation programs in the country.

23
2. Review of Climate Planning Documents
2.1 Review of Planning Documents Proformae for Development Projects (PC Forms) in
Pakistan
In Pakistan, the present method for planning, processing and reporting on development projects is
based on the "Rules of Procedure for Economic Council", Planning Commission and Planning
Sub-Commissions, issued by the former Ministry of Economic Affairs, Government of Pakistan
in September, 1952. In addition to laying down an effective organization for planning, five (5)
proformae (Revised in 2019) were prescribed for preparation and implementation of development
schemes. Two of these deal with submission of project proposals (PC-I and PC-II), one is
concerned with the progress of ongoing projects (PCIII) and two i.e. PC-IV and PC-V are to be
filled in after completion of a project. All of these have been reviewed in detail in the following
paras;

2.1.1 PC-I Proforma

PC-I is the basic form on which all projects/schemes are required to be drawn up. It was
introduced in its simple form in 1952 and substantially revised in July, 1961 and lastly revised in
2005 and 2019. This was a composite form and was used for all sectors. But as the time passed
on, bigger and complex projects had to be prepared which required quite detailed information for
pre-investment appraisal. PC-I form, therefore, was continuously made more elaborate and 12
separate forms suitable for particular sectors were introduced in July, 1974. In 1995, a Task Force
headed by Deputy Chairman, Planning Commission was set-up to review the project planning
process from identification to approval as well as PC-I and II proformae to improve project
quality. Following are the main development projects for public sectors.

a. Production Sectors
i. Agriculture Production
ii. Agriculture Extension
iii. Industries, Commerce and Minerals

b. Infrastructure Sectors
i. Transport & Communication
ii. Telecommunication
iii. Information Technology
iv. Energy (Fuel & Power)
v. Housing, Government Buildings & Town Planning
vi. Irrigation, Drainage & Flood Control

c. Social Sectors
i. Education, Training and Manpower
ii. Health, Nutrition, Family Planning & Social Welfare
iii. Science & Technology
iv. Water Supply & Sewerage
v. Culture, Sports, Tourism & Youth
vi. Mass Media
vii. Governance
viii. Research

Proforma for Development Projects and Instruction to fill in PC-I Proforma is same for all above
mentioned sectors and is given at Annexure-I, however in addition to above, the above sectors
specific information be provided in the production, Infrastructure and social sub-sectors. The PC-I

24
 Proforma for Preparation of New Projects (Revised 2019) comprise following sections and sub-
sections and is placed at Annexure-I.

i. PC-I for New Projects

Part-A (Project Digest)

1) Project Title:
2) Location: (Tehsil/Taluka, City, District and Province)
3) Authorities responsible for:
i. Sponsoring:
ii. Execution:
iii. Operation & Maintenance after completion:
4) Project objectives:
5) Project Brief Description, Justification and Technical Parameters:
6) Implementation Period (in months):
i. Planned commencement date:
ii. Planned Completion date:
7) Status of Feasibility Study (if eligible, attach copy):
i. Feasibility study conducted by
a. In house
b. Outsourced
ii. Conclusion/ Recommendation of Feasibility Study: (in bullets form)
8) Cost Estimates (Million Rs):
i. Total Cost Local component, FEC component 2 (Foreign loan/grant)
ii. Date of Preparation of Cost Estimates (Also indicate if these are still valid
iii. Basis of Cost Estimates: (CSR, SSR etc.)
iv. Unit Cost (Please attach specification):
v. Comparison of unit cost of this project with similar other projects in the
sector/Area: (in case of variation, detailed reasons/ justification be given)
vi. Annual Operating and Maintenance Cost after completion of Project and the Name of
Authority/ Source to bear this Cost:
9) Item-wise cost break-up:
10) Item-wise Physical Phasing & Financial Phasing: 10) Item-wise Physical Phasing & Financial
Phasing:
11) Financing:
i. Mode of Financing:
ii. Sources of Financing (Federal, Provincial / Donors etc)
iii. Status of Foreign Loan / Grant Commitment: (Please attach EAD’s confirmation)
iv. Status of Concept Clearance

12) Plan Provision: Linkage with Perspective/Five Year Economic Development Plan/
Economic Development Policies of the Government:
13) Sector Strategy:
• Priority of Project within overall Sector Strategy:
• Major on-going projects in the sector/sub-sector:

Part – B (Project Requirements)

14) Project Scope:
15) Management structure and manpower requirements including specialized skills
during construction/implementation and operational phases:
i. Management Structure with Responsibility Matrix:
25
 ii. Manpower Requirements:
16): Employment generation
17) Status of Surveying and Mapping Activities: (Please enclose requisite certificate- specimen
attached as Attachment-A)
18) Status of Land Acquisition:
19) Responsibility/Ownership of Assets (Procured/Acquired/Developed) after Completion of the
Project
20) Additional projects/ decisions required to maximize socio-economic benefits from the
proposed project:

Part – C (Appraisal and Analysis)

21) Project Quantifiable Benefits:
i. Financial
ii. Economic
iii. Social
iv. Other

22) Revenue Generation /Annual Income after completion of Project:

23) Financial & Economic Analysis: (with methodology & assumptions)
i. Bench mark/opportunity cost/discount rate computation
ii. Provision of Cash flow statement of Cost & Benefit with payback period of
investment
iii. Weighted Average Cost of Capital (WACC)

24) Sensitivity and Risk Analysis:

Impact of delays on project cost, revenue and viability
25) Financial/Economic Results
i. Net present worth
ii. Benefit cost ratio
iii. Internal Financial Rate of Return (IFRR)
iv. Unit cost analysis
v. Break-Even Point (BEP)
vi. Internal Economic Rate of Return(EIRR)
26) Stakeholder Consultation Analysis:
27) Environmental & Social Impact Assessment:
(TORs of the Consultant should cover Environment & Social Impact Assessment, Social Action Plan, Resettlement
Action Plan, Environment & Social Management Plan and Socio-economic Management Plan)

i. Is the development project contributing to the Climate Change response?

Yes or no
(Ref: Supporting note 1 for categories, Attachment-B)
ii. Which classification of Climate Change relevance does the development project fall into?
(Ref: Supporting note 2 for categories, Attachment-B)
iii. Has the Cost-Benefit Analysis (CBA) taken into consideration the expected
future climate change? Yes or no

28) Clean Development Mechanism Assessment:

• (For Energy, Transport, Industry, Forestry, Waste Management etc. projects)
• Questionnaire for assessment of Clean Development Mechanism (CDM) potential is at
Attachment-C
• CDM eligibility test for assessment and identification of CDM project is at Attachment-D

26
 29) Disaster Risk Reduction Analysis:
(DRR checklist (Attachment-E) be also attached)

30) Project Monitoring Mechanism:

i. Result Based Monitoring (RBM) Indicators (should be specific, measurable,
attainable, realistic and time bound):
ii. What are monitoring arrangements at:
a) Project Management level
b) Administrative Ministry/ Department/ Provincial Government level

31) Mechanism for Sustainability of Project/Activities After Completion

(Please indicate mechanism by which project activities will be continued on sustainable basis)

The PC-I Proforma for Preparation of Revised Projects and comprise of following sections and
sub-sections and is placed at Annexure-II.

ii. PC-I for Revised Projects

Part-A (Project Digest)

1) Project Title:
2) Location: (Tehsil/Taluka, City, District and Province)
(Attach map of the area clearly indicating the project location. Give GPS Coordinates)
3) Authorities responsible for:
i. Sponsoring:
ii. Execution:
iii. Operation & Maintenance after completion:
4) Project objectives:
(Precise in bullet form)
5) Project Brief Description, Justification and Technical Parameters:
6) Implementation Period (in months): (Implementation Plan be provided)
i. Planned & Actual commencement date:
ii. Planned & Expected Completion date: (indicate reasons of delay in
completion)
7) Status of Feasibility Study (please attach copy in case new feasibility has been conducted):
8) Cost Estimates (Million Rs):
i. Total Cost Local component, FEC component 2
(Foreign loan/grant) 1
(Give Original approved Cost, Revised (proposed) Cost
ii. Date of Preparation of Cost Estimates
iii. Basis of Cost Estimates: (CSR, SSR etc.)
iv. Unit Cost (Original & Revised):
v. Comparison of unit cost of this project with similar other projects in
the sector/Area: (in case of variation, detailed reasons/ justification be given)
vi. Annual Operating and Maintenance Cost Revised after completion of
Project and the Name of Authority/ Source to bear this Cost:
9) Financing:
i. Mode of Financing:
(Public Sector, Private Sector, Public-Private Partnership (PPP). Also discuss in detail why the
project cannot be
implemented in Private Sector or on PPP mode, in case project is financed through public sector)
ii. Sources of Financing (Federal, Provincial & Donors etc)

27
iii. Status of Foreign Loan / Grant Commitment:
(Please attach EAD’s confirmation)
(Currency Unit in Million; mention Rupee Exchange Rate, if applicable)
10) Financial Phasing (Expenditure incurred/to be incurred):
11) Item-wise Planned & Actual Expenditure:
12) Physical Targets and Achievements:
13) Indicate change in revenue generation: (if any)
14) Project revised due to:
Original Revised % Change
i. Change in Scope
ii. Increase in cost of Equipment/Material
iii. Exchange Rate Fluctuations
iv. Inflationary Impact
v. Others
15) Is there any change in quantifiable benefits of the Project? If yes, provide details:

2.1.2 PC-II Proforma

PC-II is required for conducting surveys and feasibility studies, in respect of larger projects
intended to get full justification for undertaking the project before large resources are tied up with
them. The PC-II Proforma for Preparation of Proposal for conducting Feasibility Study/Survey
and comprise of following sections and sub-sections and is given at Annexture III.

1) Title:
2) Authorities responsible for:
i. Sponsoring:
ii. Execution:
3) Implementation Period (in months): (implementation plan be provided)
i. Commencement Date:
ii. Completion Date:
4) Objectives of the Study/Survey:
5) Scope and justification of Study/Survey: (in terms of quantifiable items)
6) Cost Estimates along with source:
7) Item-wise summary of cost along with year-wise phasing:
8) Indicate studies/surveys already undertaken on the subject. In case studies have
already been undertaken it may be certified that present study/survey is
necessary to add or validate/update the existing study/survey available with the
sponsoring or other departments:
9) The study (TORs of the consultant) should cover the following:
a) Possibility of prospective project financing and implementation through
different modes i.e., Private Sector/Public-Private Partnership (PPP) etc.
b) Environmental Impact Assessment including CDM and DRRA:
c) Financial Analysis (FIRR, NPV and BCR)
d) Economic Analysis (EIRR, NPV and BCR)
e) Risk and Sensitivity Analyses and proposed mitigation measures
f) Forward and backward linkages of the propose study/survey
g) Expected output of the proposed feasibility study/survey
10) Management structure and manpower requirements including specialized skills
required during implementation:
• Management Structure:
• Manpower Requirements:

28
2.1.3 PC-III Proformae
PC-III (A) form is designed to furnish information on the progress of on-going projects on
quarterly basis and is required to be submitted by the executing agencies/departments within 20
days of the closing of each quarter. This form gives financial as well as physical progress of the
schemes with information on any bottlenecks experienced during the execution of a project. The
PC-III Proforma for Progress Monitoring and it consists of Project Profile Proforma (PW002),
Quarterly Monitoring report (PW003) and Monthly Progress Report (PC-III (B) Form) and have
following sections and sub-sections and given at Annexture IV.

A. Project Profile Proforma (PW002)

Name of the Project
2. Sector
3. Location
4. Sponsoring Ministry/Agency
5. Executing Agency
6. Name of Project Director
7. Postal Address
8. Telephone
9. Fax No.
10. E-mail address
11. Date of approval by DDWP, CDWP, ECNEC
12. Decision of the DDWP
13. Decision of the CDWP
14. Decision of the ECNEC
15. Objectives of the Project
16. As per PC-I
17.Completion Date
18. Approved cost of the project
19. Source of financing
20. Financial Phasing, Releases and Expenditure
21. Itemised cost as per approved PC-I and Expenditure
22. Physical scope of project as per approved PC-I and achievements (in quantifiable terms)

B. Quarterly Monitoring Report (PW003)

1. Name of the Project
2. Name of Ministry/ Division/ Agency
3. Approved/Capital Cost
4. Breakdown of the Capital Cost
i. Land Acquisition
ii. PMU
iii. Civil Works
iv. Procurement of equipment/ Machinery
v. Vehicles
vi. Trainings (HRD)
6. PSDP Allocation for the current year
7. Requirements, Releases Expenditures
8. i) 1st Quarter
ii) 2nd Quarter
iii) 3rd Quarter
iv) 4th Quarter

29
9. Financial allocation as per Cash Plan, Releases and Expenditure
10. Physical Targets and Achievements (in quantifiable terms)
Whether Financial/ Administrative powers have been delegated to the Project Director (Pl. tick
the relevant box)
11. Overall Implementation of the Project
12. Observations in the last Monitoring Report and action taken
13. Problems/ Bottlenecks in the Project Implementation
14.Indicate only one main problem
15.Observations of the Monitoring Officer
16.Recommendations

C. Monthly Progress Report (PC-III (B) Form)

1. Report for the month of
2. Name of the Project
3. Financial Status
i) PSDP allocations for the current year
ii) Current quarter requirements as per cash plan
iii) Releases during the month
iv) Expenditure during the month
4. Itemized expenditure during the month under report
5. Physical Status Physical achievements during the month under report
6. Other Indicators
7. Problems/Bottlenecks in Project Implementation

2.1.4 PC-IV Proformae

PC-IV form is required to be submitted at the time when the project is adjudged to be completed
PC - IV Proforma of Development Projects for Project Completion Report and comprise of
following sections and sub-sections and given at Annexture V.

1. Project Title and Location

2. Sector and Sub-Sector
3. Sponsoring Ministry/Agency
4. Executing Agency
5. Agency for Operation & Maintenance after completion
6. Date of Approval
• Original
• Revised
7. Implementation Period
8. Capital Cost
9. Financing of the Project
10. Financial Phasing as per PC-I and Expenditure
11. Physical Targets and Achievements
12. Item-wise Planned & Actual Expenditure
13. Achievement of Objectives
14. Year-wise Income from Services/Revenue Generation
15. RBM Indicators
16. Assets acquired and handed over to
• Indicate Agency
• List of Assets
17. Mechanism for Sustainability of Project/Activities After Completion
i) Financing requirement
a. Resources generated by project

30
b. Grant from the Government
ii) Manpower requirement with justification
18. Quantifiable Benefits achieved
i) Financial
ii) Economic
iii) Social
iv) Employment generated
v) Other
19. Financial/Economic Results Based on Actual Cost
a) Financial
• Net present worth
• Benefit cost ratio
• Internal Financial Rate of Return (IFRR)
• Unit cost analysis
b) Economic
• Net present worth
• Benefit cost ratio
• Internal Economic Rate of Return (EIRR)
20. Project Implementation
Whether the Project has been implemented as per approved scope of the project,
if not provide detailed justification of variation.
21. Lessons learned during project implementation:
22. Suggestions for planning & Implementation of Similar Projects

2.1.5 PC-V Proformae

PC –V Proforma for Development Projects is used for annual performance report after completion
of project comprise of following sections and sub-sections and given at Annexture VI.;

1. Name of the Project:

2. Name of executing agency/sponsor
3. Objectives & scope of project as per approved PC-I and state as to what extent the objectives
have been met:
4. Planned and actual cost of the project, with details:
5. Planned & actual manpower employed:
6. Planned and actual physical output of the project:
7. Planned and actual income of the project:
8. Planned and actual benefits to the economy:
9. Planned and actual social benefits:
10. Planned and actual cost per unit produced/sold:
11. Marketing mechanism:
12. Arrangement for maintenance of building & equipment.
13. Whether output targets or facilities as envisaged in the PC-I have been achieved. If not,
provide reasons:
14. Environmental impact assessed during the studies and the actual after completion of the
project.
15. Lessons learned during the year in:
i) Operation
ii) Maintenance
iii) Marketing
iv) Management
16. Any change in project management during the year:
17. Suggestions to improve projects performance:

31
18. Contribution of the project in achieving the SDG

2.1.6 Umbrella PC-I

Sometimes a Federal Ministry is required to prepare a PC-I having provincial components to be
financed through a joint loan by a donor agency. Such a PC-I is called an Umbrella PC-I and
could fall in any one sector of the economy. Since some inter-provincial coordination is also
required, the preparation of the Umbrella PC-I is, sometimes, delayed just because of non-
submission of PC-I by a certain province(s). This holds up the entire project. Therefore, proper
coordination between the Federal Ministries and the Provincial Governments is required. In such
cases, the Federal Ministry can prepare the Umbrella PC-I on the basis of the appraisal report of
the project which contains all the necessary information/data in respect of each provincial
component. However, if there is delay in submission of PC-I by any province and the Federal
Ministry finds it difficult to prepare the Umbrella PC-I, then the matter is to be reported to the
CDWP in which the provincial representatives participate and can be advised to expedite.
Moreover, efforts should be made to negotiate aid separately for each province particularly in
social sectors like primary education, population and rural health projects etc., where project
implementation is exclusively the responsibility of the Provincial Governments.

2.1.7 Intelligent Project Automation System (iPAS) for online Submission of PC 1(s)
Ministry of Planning Development and Special Initinatives started Intelligent Project Automation
System (iPAS) for online PC 1 Submission to speed up the process of public sector project
submission, PSDP budget formulation, execution, fund management and for monitoring and
evaluation of projects. iPAS will improve workflow and enhance productivity, reduce operational
risks, and improve Government businesses in the internal processes which ultimately will
establish efficiency and transparency. In short, iPAS will enhance the Core Business Functions of
the Ministry of Planning, Development & Special Initiatives.

2.1.8 Conclusions
1. After a detailed review of Planning Documents Proformae (PC Forms) for
Development Projects in Pakistan, it is found that Project formulation forms (PCs)
have also been revised in 2019 and it included impact of climate change, and disaster
risk management assessment under Environmental & Social Impact Assessment and
Clean Development Mechanism assessment for Public Sector Projects of Pakistan at
planning or approval stage by MoPDSI.

32
 2. However, National Guidelines for Pakistan on Climate Finance and Planning to
integrate Climate Change (CC) into the planning and budgetary processes is not
available.

2.1.9 Recommendation
1. There is urgent need to develop National Guidelines for Pakistan on Climate Finance and
Planning to integrate Climate Change (CC) into the planning and budgetary processes.

33
3. Review of Climate Financing Documents
Pakistan Climate Change Financing Framework, 2017 and Climate Public Expenditure and
Institutional Review (CPEIR) Document, 2017 are the two Climate financing documents which
were used to review.

3.1 Review of Pakistan Climate Change Financing Framework, 2017

As the effects of climate change become increasingly apparent, governments around the world are
trying to understand the threats they face. Pakistan is one of the most vulnerable countries to
climate change: it ranks 8th in the world in terms of long-term risks, and was the –5th worst
affected country in 2014. Pakistan along with Philippines features in the German watch list both
in the long term index and in the last 4 years’ lists of countries most affected. With a poverty rate
of 21 percent11 and a large proportion of the population dependent on agriculture (which
contributes 23 percent to GDP) Pakistan must take the threat of climate change seriously. The
impacts of climate change cut across several aspects of life. Water, health, energy and food
security are increasingly stressed, and in some areas can pose genuine concerns for livelihoods
and even survival. These concerns particularly affect the poorest in society.

3.1.1 The Need for Change

Climate change is now a core part of the global development agenda and governments are
recognizing the need to adopt low carbon economies and build resilience of the poor and
vulnerable to climate change. Pakistan faces particularly stiff challenges in adaptation and
developing community resilience. Important steps have already been taken. Pakistan now has a
Ministry of Climate Change. The country has formulated a National Climate Change Policy and
developed an implementation framework, and the Lahore High Court has established a
commission for its implementation. But given the challenges Pakistan faces, a far more proactive
approach is required. Because of the wide ranging impacts of climate change, there is a need to
mainstream climate change in sectoral policymaking, particularly for core areas such as energy,
water management and agriculture.

3.1.2 Mainstreaming Climate Change

For a systematic response to climate change, which links policy frameworks with budgeting and
efficient and transparent allocations and utilization of financial resources,12 climate change must
be integrated into budgeting and planning. This requires a careful understanding of the impacts
of climate change on the country’s finances. The need to embed climate change into budgeting
and planning is accentuated by the increased international funding available for climate change
related activities. At the Climate Change Conference held in Copenhagen in 2009 developed
countries that were party to the United Nations Framework Convention on Climate Change
committed to mobilizing US$ 100 billion per year by 2020. To access this international finance,
countries such as Pakistan should be able to demonstrate:
- A transparent public financial management system which ensures that resources are
utilized efficiently and transparently.
- Their own financial contributions to addressing climate change.

11
World Bank's Poverty Head Count Analysis 2014. -nance.gov.pk/survey/chapters_14/15_Poverty_Social_Safety_Nets
12
Eective and transparent utilization of the climate change -nance requires: a. Identifying the climate change -nance available,
both from international sources and the funds governments reserve for climate change related activities; b. Classifying climate
change expenditures and determining the expenditures actually being made by the government; c. Tracking climate change
related expenditures to analyse their coverage and eectiveness.

34
However, Pakistan’s readiness to face climate change is affected by a lack of reliable data on the
extent of financial losses due to climate change, and its impact on GDP. To help address this, in
2015, a Climate Public Expenditure and Institutional Review (CPEIR) was carried out to identify
climate change related expenditures by the Federal Government and Khyber Pakhtunkhwa
Province.

Federal Government Climate Change related Expenditures13

Years Expenditure in %
2010-11 7.52
2011-12 6.52
2012-13 5.78
2013-4 6.22

This was the first attempt to provide reliable data on climate change expenditure, and is an
important basis for informed decision making by policymakers. While the CPEIR provided
extremely useful data, it took more than a year to carry out the exercise and required the services
of a team of consultants and data analysts. Thus, while CPEIR is a useful methodology, it is an
expensive exercise and cannot be repeated every year. Moreover, CPEIR alone does not make
climate change a formal part of public financial management, as it is not part of the planning or
the budgetary process. Informed policy response is possible only if climate change is
mainstreamed into the planning and budgetary system across sectors, and is an intrinsic part of
development policies.

3.1.3 The Solution: A Climate Change Financing Framework

In order to provide a structured response to climate change, it is necessary to establish a
framework which focuses on climate change starting from the planning stage, and creates a
robust monitoring system which can gauge the volume and effectiveness of climate change
related expenditures. Developing a Climate Change Financing Framework (CCFF) is an
effective way to mainstream climate change into the planning and budgeting cycle. CCFF can be
thus a useful instrument to help in systematically tracking, managing and publicly reporting
climate-related expenditure in national budgets - so that the risks are transparent. This can
provide a number of important fiscal and economic benefits, many of which have multiplier eff-
ects such as increased employment, poverty reduction and disaster management, include:

 Ensuring existing public investments in climate-change initiatives are being used

efficiently and effectively;
 Helping to protect the country’s sovereign credit rating against downgrades by
providing greater fiscal transparency at a time when credit agencies are factoring
in climate change initiatives;
 Attracting greater foreign direct investment by creating a more transparent (and
consequently lower-risk) investment climate for increasingly climate-sensitive
corporations and fund managers;
 Attracting additional international climate finance by satisfying donor’s public
financial management requirements;
 Identifying green growth opportunities in different sectors;
 Encouraging the private sector, notably the insurance sector, to share the risks by,
again, providing the necessary transparency of the risks and reassurance that
adaptation and mitigation strategies are in place

13
Climate Public Expenditure and Institutional Review (CPEIR) 2015.

35
 In Pakistan, the CCFF will build upon the National Climate Change Policy and the Medium
Term Budgetary Framework (MBTF)6 and their links with sectoral policies. Within the policy
parameters of the National Climate Change Policy, the CCFF will begin by recommending a
framework which will help to create an enabling environment for mainstreaming climate
change, and identify the systems required to integrate climate change into public finance
management. It will also capture different sources of financing for climate change and any
gaps between the financing required and that which is available. An agreement on answers to
these questions will mean that a structure of CCFF has been formulated outlining systems and
processes necessary for integration of CC in budgetary and planning systems. After this the
next stage will be to create an integrated CCFF, which means integrating climate change into
the MBTF. Specific steps include:
• The Ministry of Finance approaches all federal ministries and divisions through a Budget
Call Circular to help identify allocations related to climate change.
• The Ministry of Planning and Development and Special Inatinatives is supported to
incorporate climate change into the planning cycle.
• The Government’s planning formats, such as the PC1, are revised to ensure climate
change sensitive planning.
• Climate change actions are costed as per the National Climate Change Policy and sectoral
policies.
• Key performance indicators are established for climate change. Using the MBTF’s output-
based budgeting system, all federal ministries prepare a medium-term strategic plan
linking planning and budgeting processes.
• The MTBF incorporates inputs and outputs relating to climate change.

3.2 Review of Climate Public Expenditure and Institutional Review (CPEIR) Document,
2017
With the completion of a National Climate Public Expenditure and Institutional Review (CPEIR)
for Pakistan, this document aims to synthesize and simplify the analysis contained within the
CPEIR. A Climate Public Expenditure and Institutional Review (CPEIR) is a systematic analysis
of a country's public expenditures and how they relate to climate change policies. It presents
evidence on expenditures across all ministries and tailors its focus and definitions on a country-
by-country basis. The reviews also examine climate change plans and policies, institutional
frameworks and the public finance architecture in order to make recommendations to strengthen
them. A CPEIR can be a useful tool for national planning and budgeting, especially in terms of
identifying and tracking budget allocations that respond to climate change challenges. In Pakistan,
the existence of a National Climate Change Policy and strong institutional mechanisms provide a
solid basis to address the challenges posed by climate change. The CPEIR further supports this by
analysing policy and budget alignment including through examining the institutional structures
and more importantly public resource allocations so that a reliable assessment of progress on
different policy areas can be made. The CPEIR is being replaced with the Climate Expenditure
Coding and Tracking System that has been developed by the Controller General of Accounts.
This will help in tracking climate change expenditures on an ongoing basis enabling policy
makers and stakeholders to analyse trends and better align their policies if need be. Results for FY
15-16 have been obtained for the federal government using this system which marking a smooth
transition.

3.2.1 Process
The CPEIR was carried out in Pakistan in two phases- the first phase, completed in 2015, analyzed
expenditures at the Federal level as well as Khyber Pakhtunkhwa (KP) and three Federal regions
during Fiscal years 2009 to 2013. The second phase, completed in May 2017, included an

36
institutional and expenditure analysis at the National level - i.e. the Federal Government, all four
Provincial Governments and the 3 Federal Regions.

3.2.1.1 First Step: Identification of Climate-related Expenditures

The identification of budget lines with climate-related expenditures followed the definition of two
key elements of CC i.e. adaptation and mitigation. Expenditures that had both Mitigation and
Adaptation content were identified. All expenditures identified as climate change related were
taken forward for further consideration.

3.2.1.2 Second Step: Classification of Expenditures

Classification of those line items using a set of tasks determined from NCCP policy objectives.
This was done to ensure a tight linkage between NCCP policy objectives and the classification of
budget items.

3.2.1.3 Third Step: Weighting of Climate Change Relevance

The expenditure line analysis determined the climate relevance of expenditures, which was
expressed as a percentage of the total expenditure attributed to Climate Change. The activities
based on the objective and nature were assigned high (75 % plus), medium (50-74 %), low (25-49
%) and marginal (less than 25 %)

3.2.2 Institutional and Expenditure Analysis

3.2.2.1 Federal
The total Federal climate-related expenditure (development + current budget) was estimated to be
between 5.8 and 8.1 % of total Federal expenditures in the four studied years and the system
generated result for FY 15-16. The relative proportion of the climate-relevant budget spent on
adaptation and mitigation varied significantly across studied years; with adaptation 36 and
mitigation 57 % during 2014/15. In terms of absolute expenditure, between 60 and 80 % of the
total climate-related actual investment expenditure during the four years is split between two
ministries, the Ministry of Water and Power (MoWP) (including the Water and Power
Development Authority [WAPDA]) and the Cabinet Division (including the Atomic Energy
Commission [AEC]).

3.2.2.2 Khyber Pakhtunkhwa

Total climate-related spending has increased 105 % from 2011 to 2015, PKR 18.8 billion to PKR
38.6 billion) which is greater than the increase in total revenues. Climate-related expenditures
represent between 10 and 14 % of the KP development budget and 5.3 and 9.7 % of the total
provincial budget. Climate Change expenditure is common, widely spread and stable across
departments in KP. The Departments of Irrigation and Power, Environment and Forestry and
Population Welfare have the highest proportion of Climate Change expenditure (55–60 %).

3.2.2.3 Balochistan
Between 6 and 15 % of Balochistan’s budget is climate-related for the period under review.
During 2012-16, the rate of annual increase in climate-related development investment was much
higher than that of the overall Balochistan. Between 6 and 15 % of Balochistan’s budget is
climate-related for the period under review. During 2012-16, the rate of annual increase in
climate-related development investment was much higher than that of the overall development
budget (29.2 % compared to 7.3 %). The Annual Development Plan (ADP) climate expenditure
across studied years is relatively stable in terms of average climate relevance of each department
and the proportion of climate-related investment per department.

37
3.2.2.4 Punjab
Total climate-relevant spending in Punjab increased from PKR 54.4 billion in 2011/12 to PKR
112.7 billion in 2014/15, an increase of nearly 107 %. Climate-relevant expenditure represents
between 6.2 and 9.3 % of the total provincial budget for the period 2011-2015 and 13.7 % in 15-
16. Between 13 and 15 % of Punjab’s development budget is climate-related. The ADP climate
expenditure across studied years is relatively stable in terms of average climate relevance of each
department. However, the proportion of climate-related investment per department fluctuates in
most of the departments. The departments of Forestry, Health and Irrigation and Power generally
lead on Climate Change spending- with 24–57 % of their budgets on climate-relevant
investments.

3.2.2.5 Sindh
Climate-relevant expenditure represents between 4.1 and 6.9 % of the total provincial budget.
Between 5.6 and 10.0 % of Sindh’s development budget is climate-related. The ADP climate
expenditure across studied years is relatively stable in terms of average climate relevance of each
department. However, the proportion of climate-related investment per department fluctuates in
most of the departments. In most of the four years, Forestry, Irrigation and Social Welfare, spent
16–86 % of their budgets on climate-relevant investments.

Table1: Summary of Pakistan’s Climate Relevant Expenditure Details

2011-12 2012-13 2013-14 2014-15 2015-16
Federal 6.5 % 5.8 % 6.2 % 8.1 % 6.5 %
Khyber 7.2 % 5.3 % 7.1 % 9.7 % 8.9 %
Pakhtunkhawa
Balochistan 7.3 % 10.4 % 11.1 % 11.3 % 11.9 %
Punjab 6.2 % 7.1 % 8.2 % 9.3 % 13.7 %
Sindh 5.7 % 4.2 % 4.3 % 6.9 % 7.2 %
FATA 13.1 % 12.5 % 11.6 % 11.9 % 10.2 %
Gilgit Baltistan 16 % 19 % 20 % 28 % 25.6 %

Azad Jammu & 9.2 % 14 % 12.5 % 16.9 % 14.3 %

Kashmir
National 6.7 % 6.1 % 6.7 % 8.5 % 8.4 %

3.3 Trends in Climate Expenditure

The overall results of the CPEIR compare well with other countries- the national average of
climate related expenditures range from 6.1 to 8.5 %. Climate expenditure trends within the
federal and provincial governments is in line with the core functional areas of the respective
governments and the changes in assignment of functions as a result of 18th Amendment. Federal
climate expenditure leans clearly towards mitigation and the provincial governments generally
spend more on adaptation related activities. At the federal level, owing to government
investment in the energy sector, the Ministry of Water and Power has the highest climate related
expenditures; at the provincial level leading climate expenditure is often related to forest and
irrigation, however in Sindh and Punjab significant climate expenditure goes towards transport
and communication.

38
3.4 Institutional Analysis
At the time of the review, the most effective institutional structures exist at the federal level with
a dedicated ministry for climate change. A National Climate Change Policy and an
Implementation Framework add to the strength of the federal level institutional structure. The
recent enactment of the Climate Change Act has further strengthened the institutional. Climate
change specific institutions are also evolving in four provinces at differing speeds- Sindh, for
instance, has an Environment, Coastal Development and Climate Change department and Punjab
is establishing a climate change unit in the Planning and Development Department. All four
provinces have their own Environmental Protection Agencies (EPAs) which are now also
responsible for delivering adaptation and mitigation planning, following the devolution process.
While all the provinces have Environmental Protection Acts, none has a climate change specific
law. The EPAs generally tend to have weak linkages with sectoral departments and more
powerful provincial institutions involved in policy planning. Broader policy instruments also
bolster climate institutions - for example the Federal Vision 2025, KP Green Growth Initiative
and Punjab Agriculture Policy. The provinces are also in the process of developing their
respective climate change policy.

3.5 Recommendations of CPEIR, 2017

a. Integrating CC into the budgetary and planning processes

i. Support CC integration in the planning process (by the MPDR and P&D
departments). Support CC integration in the planning process (by the MPDR and
P&D departments).
Climate Change is not a formal part of the planning process. In order to integrate CC
into planning, CC appraisal should be included in PC-Is, so that the DDWP, PDWP
and CDWP can consider this facet at the time of project approval. At the federal level,
the MPD, in coordination with the MoF, should ensure that the MTBF of CC-relevant
ministries/departments have CC-related outputs/outcomes. A similar process needs to
ensue at the provincial level through the P&D Departments in coordination with the
Finance Department. Currently, the MTBFs of sector ministries tend to concentrate on
their own sector priorities as the main drivers for the derivation of their planned
expenditures.

ii. Develop a detailed guidebook/guidelines for planning wings. Such a document

could be used to train officials in filling-out and appraising CC components in the PC-
I–PC-V formats

b. Strengthening the Climate Institutional Framework at National and Provincial levels

c. Strengthening Institutional CC-relevant Entities

- Strengthen the technical and professional capacity of Ministry of Climate Change
- Provide technical support to the provinces in the development of detailed action plans
for NCCP implementation
- Provide support to CC-relevant ministries for the incorporation of climate-responsive
budgeting.

39
4. Country Status on Implementation and Outline of Climate Policy, Planning and Finance
National Guidelines
As per published manual for development projects, 2019 provides knowledge and guidelines
about managing development projects implemented under the public sector development
programme. An overview of project cycle, including project identification, appraisal, approval,
monitoring, closing and evaluation of development projects and other standard activities involved
in the project management. Besides providing guidance to the project sponsoring and
implementing agencies, the document gives an authentic compilation of Government instructions
on various aspects of development project directors and other project officials, sanctioning
powers of various project approving forums etc. After a detailed review of Planning Documents
Proformae (PC Forms) for Development Projects in Pakistan, it is found that Project formulation forms
(PCs) have also been revised in 2019 and it included impact of climate change, and disaster risk
management assessment under Environmental & Social Impact Assessment and Clean
Development Mechanism assessment for Public Sector Projects of Pakistan at Planning or approval
stage by MoPDSI which is mentioned below;

27) Environmental & Social Impact Assessment: (TORs of the Consultant should cover
Environment & Social Impact Assessment, Social Action Plan, Resettlement Action Plan,
Environment & Social Management Plan and Socio-economic Management Plan)

5 Is the development project contributing to the Climate Change response? Yes or no (Ref:
Supporting note 1 for categories, Attachment-B)
6 Which classification of Climate Change relevance does the development project fall into?
(Ref: Supporting note 2 for categories, Attachment-B)
7 Has the Cost-Benefit Analysis (CBA) taken into consideration the expected future climate
change? Yes or not

28) Clean Development Mechanism Assessment:

• (For Energy, Transport, Industry, Forestry, Waste Management etc. projects)
• Questionnaire for assessment of Clean Development Mechanism (CDM) potential is at
Attachment-C
• CDM eligibility test for assessment and identification of CDM project is at Attachment-D

4.1 Conclusions
1. After a detailed review of Planning Documents Proformae (PC Forms) for Development
Projects in Pakistan, it is found that Project formulation forms (PCs) have also been
revised in 2019 and it included impact of climate change, and disaster risk management
assessment under Environmental & Social Impact Assessment and Clean Development
Mechanism assessment for Public Sector Projects of Pakistan at planning or approval
stage by MoPDSI.
2. However, National Guidelines for Pakistan on Climate Finance and Planning to integrate
Climate Change (CC) into the planning and budgetary processes is not available.

4.2 Recommendations
1. There is urgent need to develop National Guidelines for Pakistan on Climate Finance and
Planning to integrate Climate Change (CC) into the planning and budgetary processes.

40
 Annex-I
The PC-I Proforma for Preparation of New Projects (Revised 2019)
 Annex-II
The PC-I Proforma for Preparation of Revised Projects
 Annex-III

The PC-II Proforma for Preparation of Proposal for conducting Feasibility Study/Survey
 Annex-III
The PC-III Proforma for Progress Monitoring
 Annex-V
The PC-IV Proforma for Complection of Projects
 Annex-VI

The PC-V Proforma for Preparation of Annual Performance Report after complection of
Projects