Reconsidering National Adaptation Plans (NAPs) as a Policy Framework under the UNFCCC

ABSTRACT

Under the UNFCCC, the National Adaptation Plan (NAP) plays a central role as a policy framework for adaptation. While significant efforts, including research, have been made on the NAP scheme (which includes NAP formulation as one component), a critical evaluation of the entire NAP scheme is lacking. This includes an analysis of the relationship between the NAP process and the NAPs, their nature and intended functions, the interlinkages and implications of various COP agreements and guidelines on the NAPs, and alignment with the concept of the adaptation planning process. This paper analyzes COP Decisions, relevant documents from constituted bodies, and efforts by relevant international organizations to better understand how the NAP scheme is constructed and operated in order to clarify its strengths and weaknesses. To get an idea of how countries understand the COP Decisions and other relevant guidance for formulating their NAPs, we also reviewed the NAPs of nine countries in the Asia-Pacific region (Bangladesh, Cambodia, Fiji, Kiribati, Nepal, PNG, Sri Lanka, Timor-Leste, and Tonga). As a result, we find critical issues in the international agreements and actions on the NAPs that may become obstacles to global, and eventually national, adaptation efforts and make specific policy recommendations to address these challenges.

Key policy insights

• Neither the NAP process nor the NAPs themselves have been well defined by the COP. As a result, formulated NAPs have no more in common than a ‘plan on adaptation developed by the national government.’

• It is vital for the COP to define the NAP process and the NAPs more clearly, including their roles and relations, and to ensure consistent support for developing countries’ adaptation efforts through the NAP scheme.

• The COP should define the NAP process as the adaptation planning process (AP process) and find the roles of the NAPs as the ‘grand design of the AP process’ to enhance the consistency and effectiveness of global efforts on adaptation.

KEYWORDS:

• Climate change adaptation
• climate policy instruments
• national adaptation plans
• adaptation policy
• adaptation cycle

1. Introduction

Climate change is already causing significant impacts around the world, and such impacts are estimated to worsen in the coming decades (IPCC, 2023). Adapting to these climate changes requires a location-specific approach. This necessity arises from local differences in the types and severity of climate change hazards, as well as varying levels of exposure and vulnerability due to local demographic, socioeconomic, and infrastructure conditions (Huitema et al., 2016; Pisor et al., 2022; Carr & Nalau, 2023). The UNFCCC Paris Agreement emphasizes that adaptation should be a country-driven process under Article 7.5 (UNFCCC, 2016). Under the UNFCCC, National Adaptation Plans (NAPs) are key instruments for developing country Parties to design their adaptation actions (Lesnikowski et al., 2017; Adaptation Committee, 2022; NAP-GSP, 2022). The concept of the NAPs was first introduced as a part of the ‘Cancun Adaptation Framework’ (CAF) in 2010, in a way, as the successor of the National Adaptation Programmes of Action (NAPAs) (UNFCCC, 2010). As a key policy document for adaptation planning efforts, the NAPs are expected to remain relevant under the new UAE Framework for Global Climate Resilience (Framework). This Framework was established at COP28 towards achieving the global goal on adaptation (GGA) after two years of intensive discussions under the Glasgow–Sharm el-Sheikh work programme (UNFCCC, 2021, 2022a, 2023b). In addition, the first global stocktake underlines the importance of the Framework for tracking global progress in adaptation, with the NAPs being key sources of information (UNFCCC, 2018b, 2023a; Qi, 2022).

To date, studies on adaptation policies in developing countries have focused mainly on analyzing the policy landscapes at the local and national levels (Lesnikowski et al., 2016; IPCC, 2023). In contrast, except for a few general assessments of the UNFCCC and the Paris Agreement (Bodansky, 2016; Hall & Persson, 2018), there has been little examination of the international framework for adaptation (Leiter, 2022). A relevant trend is the consideration of institutional aspects of adaptation measures and governance. Here, the effectiveness of individual adaptation measures and the mainstreaming of adaptation plans into environmental plans are also discussed (Yazykova & Bruch, 2018; Donatti et al., 2020). There are also studies of the type that review submitted NAPs to understand their achievements and limitations (Morgan et al., 2019; Woodruff & Regan, 2019). These studies have successfully identified general characteristics of the submitted NAPs and opportunities for improvement. On the other hand, we are unaware of any previous studies that have conducted a critical examination of the NAP framework itself and what it is trying to achieve.

One potential explanation for this research gap is that it might have been taken for granted that the existing framework and guidelines for the NAPs were clear enough. However, bearing in mind the important role that the NAPs can potentially play within the entire framework of global and national adaptation efforts, this gap requires a detailed investigation. Another potential explanation is that adaptation efforts are essentially country-driven processes, and thus, most research has focused on the analysis of national and local level practices and case studies. While it is understandable, given the evolving understanding that adaptation is a global challenge and international cooperation is key in this process (Banda, 2018; Ulibarri et al., 2022), the international framework for adaptation should become a subject of more detailed investigation.

Considering the identified research gap, we examined Decisions of the UNFCCC Conference of the Parties (COP) and other UNFCCC guidelines related to the NAP scheme, as well as the contents of nine submitted NAPs (focusing on Asia-Pacific countries), to get a better understanding of the overall aims of the NAP scheme, its ambiguities and challenges, and points to be made for its improvement. Under the UNFCCC, the Least Developed Countries Expert Group (LEG) has provided guidelines on what could be included in the NAPs. There are also evolving networks and communities of practice to support the development of the NAPs (NAP-GSP, 2022; NAP Global Network, 2023). Developing Country Parties, however, may have differing interpretations of how to develop and use their NAPs based on the existing COP Decisions and guidance, as there is some flexibility and ambiguity regarding the elements to be included in the NAPs. Based on the analysis, we present a strategic interpretation of the COP Decisions and current practices surrounding the NAPs to make the most of the NAPs and discuss policy recommendations for the COP and adaptation policymakers. This research contributes to adaptation literature by improving the understanding of one of the most important policy instruments in this crucial topic.

2. Methods and materials

The primary materials used for our analysis included UNFCCC COP Decisions relevant to the NAPs. These were identified through a full-text search for the term ‘national adaptation plan.’ After retrieving such Decisions, we analyzed them to understand how the NAP scheme, including the national adaptation plan process (NAP process), is structured and evaluated its validity and challenges. We focused on these texts because they represent official agreements, and we did not investigate the negotiation texts leading up to them. Other research suggests the necessity of understanding the political dynamics behind negotiations in order to understand these texts (Hughes et al., 2021). While we do not deny the importance of political contexts, the analysis of formal texts plays an undeniable role in assessing the current agreement among the Parties, and such assessment will inform further negotiations and adaptation practices by various stakeholders more broadly. We also reviewed the concepts close to the NAP process in these texts, namely the adaptation planning process, and analyzed their interrelationships to better understand the entire NAP scheme. In actual negotiations, some ambiguities are intentionally tolerated by the Parties (Hall & Persson, 2018; Vanhala, 2023). However, this paper aims to discover the gaps and challenges caused by inconsistencies and contradictions between provisions and by a lack of common basic understanding of key concepts that cannot be considered introduced intentionally.

To supplement the information from these COP Decisions, we also searched other relevant COP documents and international organizations’ reports and websites to see how these concepts are interpreted and used. In particular, the LEG and the Adaptation Committee (AC) have produced various reports in response to the requests from the COPs. These reports often influence NAP-related efforts, and we pay particular attention to them. The GCF, the world’s largest climate fund, provides a large amount of financial support to countries to formulate their NAPs (162 million USD approved to support 69 countries, in total),¹ so the GCF’s requirements in providing funding may also guide how the NAPs are developed. Hence, we also analyzed the GCF's strategies for its Readiness Programme that had been used to support the NAP formulation.

After clarifying the challenges of the NAP scheme, we examined how countries dealt with them when developing their NAPs. This is because understanding and responding to the challenge may vary from country to country. Specifically, we investigated the NAPs of nine countries from the Asia-Pacific registered in the UNFCCC's NAP Central:² Bangladesh, Cambodia, Fiji, Kiribati, Nepal, PNG, Sri Lanka, Timor-Leste, and Tonga. The selection was grounded in a strategic approach to encompass a representative diversity of geographical, economic, and climatic conditions. We tried to capture varied examples of the unique challenges faced by island nations, low-lying coastal countries, and landlocked countries in the Asia-Pacific region. This region was specifically chosen due to its acute vulnerability to climate change impacts, making it a critical area for adaptation efforts. The countries selected provide a broad spectrum of adaptation challenges, thereby offering a comprehensive view of how different countries interpret and implement the guidance provided by the COP Decisions and other relevant documents.

3. Results

3.1. International agreements on the NAPs

The first agreement on the NAPs was reached at COP16 in 2010. The decision text of the Cancun Adaptation Framework (CAF) states that the COP ‘Decides to hereby establish a process to enable least developed country Parties to formulate and implement national adaptation plans, building upon their experience in preparing and implementing national adaptation programmes of action, as a means of identifying medium- and long-term adaptation needs and developing and implementing strategies and programmes to address those needs’ (UNFCCC, 2010). The CAF also invites other developing countries (non–least-developed developing countries) to employ the same modalities of this process (hereafter, the CAF process).

As a follow-up, Decision 5/CP.17 was agreed in 2011 as below. Notably, this was the first Decision that used the term ‘national adaptation plan process.’ It is worth noting that the starting point was an agreement on the NAP process, not on the NAPs. In this paper, the term, ‘NAP process’ is used as an abbreviation of the national adaptation plan process stipulated in Decision 5/CP.17. ‘NAP’ refers to the national adaptation plan formulated by developing countries through the NAP process.

Decision 5/CP.17 stipulates that the COP:

✓ Agrees that the objectives of the national adaptation plan process are as follows:

a. To reduce vulnerability to the impacts of climate change, by building adaptive capacity and resilience;

b. To facilitate the integration of climate change adaptation, in a coherent manner, into relevant new and existing policies, programmes and activities,[…];

✓ Decides to adopt the initial guidelines for the formulation of national adaptation plans contained in the annex to this decision;

✓ Requests the LEG to provide technical guidance and support to the national adaptation plan process, as appropriate (UNFCCC, 2011).

Responding to this request, the LEG published ‘Technical guidelines for the national adaptation plan process’ (NAP Guidelines) (LDC Expert Group, 2012). Since then, various efforts have been accelerated inside and outside of the UNFCCC regime to support NAP processes in developing countries.

Decision 5/CP.17 introduced the term ‘national adaptation plan process’ (NAP process) without tying it anywhere, and there is no guarantee that it refers to the process that was established by the CAF (CAF process) (Decision 5/CP.17 only recalled the CAF). Decision 5/CP.17 uses the phrase ‘A process to enable least developed country Parties to formulate and implement national adaptation plans’ as the title of Section 2, which is the same as the CAF process. However, there is no explanation of the relationship between the process in that title and the national adaptation plan process specified in Section 1. In addition, Section 2 does not provide any mechanism that deserves to be called a ‘process’. Nevertheless, there is a broad understanding that the NAP process refers to the CAF process. For example, the NAP webpage of the UNFCCC's NAP Central clearly states, ‘The national adaptation plan (NAP) process was established under the Cancun Adaptation Framework (CAF)’.³

While Decision 5/CP.17 stipulates the purpose of the NAP process, it and later Decisions have never explained what the process encompasses. Nevertheless, it is understood that the NAP process is a process to formulate and implement the NAPs. For example, Decision 5/CP.17 officially adopted ‘Initial guidelines for the formulation of national adaptation plans by the least developed country Parties’ and also requested the LEG to develop ‘technical guidelines … for the national adaptation plan process’ based on the initial guidelines. In Decision 5/CP.17, Articles 6, 7, and 8 refer to ‘the initial guidelines for the formulation of national adaptation plans’, ‘the guidelines for the national adaptation plan process for least developed country Parties’, and ‘the guidelines for the national adaptation plan process in least developed country Parties’ respectively, which should be recognized as the same subject.

Thus, there is a clear difference between the NAP process and the CAF process, as the former is perceived as a process to formulate the NAP, while the latter is a process to enable LDCs (least developed countries) to formulate the NAPs. Another observation is that after the introduction of the NAP process, there is no COP Decision regarding what objectives, roles, or scope a NAP will be created with through the NAP process.

As a similar concept to the NAP process, the Paris Agreement introduced the ‘adaptation planning process’ concept in Article 7.9. It states that ‘Each Party shall, as appropriate, engage in adaptation planning processes and the implementation of actions,’ with all the Parties, including developed and developing countries, in mind. It also lists the following as activities that may be included in the process:

✓ The implementation of adaptation actions, undertakings and/or efforts;

✓ The process to formulate and implement national adaptation plans;

✓ The assessment of climate change impacts and vulnerability, with a view to formulating nationally determined prioritized actions, taking into account vulnerable people, places and ecosystems;

✓ Monitoring and evaluating and learning from adaptation plans, policies, programmes and actions; and

✓ Building the resilience of socioeconomic and ecological systems, including through economic diversification and sustainable management of natural resources.

The second bullet, the process to formulate and implement national adaptation plans, is identical to the perceived description of the NAP process. Therefore, the other activities in this list must be outside the scope of it, and the AP process should be interpreted as covering a broader range of activities than the NAP process. For instance, activities such as the implementation of adaptation actions and the assessment of climate change impacts and vulnerability are part of the AP process, but not part of the NAP process. The following table summarizes the concepts related to the NAPs used in the UNFCCC regime, including those described here. (Table 1)

Table 1. Concepts related to the NAPs in the UNFCCC regime (elaborated from the documents listed in Basis)

Names of the Concepts	Contents of the Concepts and their basis
national adaptation plan	National adaptation plans by all countries, independent of whether they are developed or developing countries. In this paper, national adaptation plans are referred Naps. (Basis: Paris Agreement. But no basis exists on what it is for.)
NAP	Abbreviation for national adaptation plans formulated by developing countries through the national adaptation plan process. In this paper, NAPs are also used in the same meaning. This is customary usage in UNFCCC documents and there is no official basis in the COP decisions, except that the initial guideline refers to the term ‘national adaptation plans (NAPs)’. However, the table of abbreviations in these documents states that NAP is an abbreviation for a national adaptation plan and is not explicitly limited to the ones formulated by developing countries. (Basis: UNFCCC secretariat’s reports, LEG reports, NAP Central.)
national adaptation plan process (NAP process)	The process whose purpose is defined in Decision 5/CP.17. Only for developing countries (not limited to LDCs). Generally understood as the same process launched by CAF (CAF process) (Decision1/CP.16). However, this is not correct as explained in the main text. The CAF process has never been referred to in the Decisions after COP 17 and cannot be considered to be the NAP process. It is also commonly understood to mean the process to formulate and implement the NAPs. When this explanation is used in Decisions or other documents after COP 17, it is intended to mean this process. However, as explained in the main text, this is not accurate. (Basis: Decision1/CP.16, 5/CP.17, initial guidelines, NAP Guidelines, LEG Reports.)
adaptation planning process/adaptation planning	A broad concept that includes formulating and implementing Naps and various other activities. It is independent of whether the target countries are developed or developing countries. In this paper, the adaptation planning process in a developing country is called the AP process. (Basis: Decision 5/CP.17, Paris Agreement.)

Table 2. NAPs in Asia and the Pacific (elaborated from the submitted NAPs).

Country	Name of the plan	Target period	Reference
Bangladesh　(LDC)	National Adaptation Plan of Bangladesh	2023–2050	(Ministry of Environment, Forest and Climate Change, Government of the People’s Republic of Bangladesh, 2022)
Cambodia　(LDC)	Cambodia Climate Change Strategic Plan	2014–2023	(National Climate Change Committee, 2013)
Fiji　(SIDS)	Republic of Fiji National Adaptation Plan	Five years*	(Government of the Republic of Fiji, 2018)
Kiribati　(LDC/SIDS)	Kiribati Joint Implementation Plan (KJIP) for Climate Change and Disaster Risk Management	2019–2028	(Government of Kiribati, 2014) The original KJIP process started in 2011
Nepal　(LDC)	National Adaptation Plan	2021–2050	(Government of Nepal, 2021)
Papua New Guinea　(SIDS)	Papua New Guinea National Adaptation Plan	2022–2030	(Climate Change & Development Authority, 2023)
Sri Lanka	National Adaptation Plan for Climate Change Impacts in Sri Lanka	2016–2025	(Climate Change Secretariat, Ministry of Mahaweli Development and Environment, 2016)
Timor-Leste (LDC/SIDS)	Timor-Leste‘s National Adaptation Plan	2020–2030	(Democratic Republic of Timor-Leste, 2021)
Tonga (SIDS)	Joint National Action Plan 2 on Climate Change and Disaster Risk Management (JNAP 2)	2018–2028	(Government of Tonga, 2018) JNAP 1 was endorsed in 2010

* Fiji's NAP only stipulates that it is a five-year plan but does not specify a specific target period. The plan was formulated in 2018.

3.2. NAP process of the NAP Guidelines

The NAP Guidelines published in 2012 explicitly state that the Guidelines are indicative rather than prescriptive, and that countries are not required to follow them (LDC Expert Group, 2012). The Guidelines, nevertheless, have significantly directed the efforts made afterward for the NAP process. After presenting nine guiding principles, the NAP Guidelines identify four steps in the NAP process, i.e. A (Lay the Groundwork and Address Gaps), B (Preparatory Elements), C (Implementation Strategies), and D (Reporting, Monitoring and Review). The NAP Guidelines cover most of the elements in Article 7.9 of the Paris Agreement. The NAP Guidelines understand the four elements as steps of the NAP process, and therefore, a NAP itself is positioned in these steps (B 4. Compiling and communicating national adaptation plans). However, the initial guidelines, on which the NAP Guidelines are based, explain the same four elements as ‘elements of national adaptation plans’ (UNFCCC, 2011). At this point, there is already some confusion in understanding the relationship between the NAP process and the NAPs.

The NAP process is increasingly being viewed as an effort encompassing the AP process. Another example is that, in March 2023, the NAP Global Network, which connects over 2,000 participants from more than 155 countries working on adaptation planning, revised the illustration of the NAP process to reflect the experience of past efforts and released a new diagram (NAP Global Network, 2023). In this diagram, the NAP process is explained as a loop among ‘planning’, ‘implementation’, and ‘monitoring, evaluation, and learning’ with ‘financing’, ‘leadership’, ‘institutional arrangements’, ‘engagement’, ‘data, knowledge and communication’, and ‘skills and capacities’ as its enabling factors. This diagram clearly shows that the NAP process is understood to cover the whole AP process. It also clearly indicates that the role and the scope of a NAP within the NAP process is very vaguely understood, as the NAP formulation is specified nowhere. The NAP process is usually described as a ‘process to formulate and implement national adaptation plans’, a description that focuses on the NAPs. However, the NAP process is now interpreted beyond the literal interpretation of this description.

In addition to the NAP, the NAP Guidelines refer to frameworks, strategies, and roadmaps as possible products generated through the NAP process. In particular, the NAP implementation strategy is given a significant role and is envisioned as a far more specific and detailed blueprint of adaptation actions than the NAP.

3.3. GCF’s strategy on the NAPs

As already mentioned, the GCF provides financial support to developing countries for the preparation of their NAPs under its Readiness Programme, so the strategy and requirements of this Readiness Programme have a strong influence on the NAPs of countries that access GCF funding. The GCF defines Objective 3 of the Readiness Programme's Strategy for 2019–2021 as ‘strengthened adaptation planning’ and lists four outcomes and 16 indicative outputs expected for the projects, which are developed considering the NAP Guidelines (GCF, 2019). This list, which is not comprehensive (certain elements of the NAP process identified in the NAP Guidelines are not explicitly included), is directing efforts on the NAPs to a certain extent. Notably, this list does not refer to the NAP process. Instead, adaptation planning is specified as an outcome, and a national (adaptation) plan is considered as a possible output. The Readiness Programme's Strategy for 2019–2021 has been extended by the Board's decision to remain in effect until 2023 (GCF, 2023).

3.4. NAPs in Asia and the Pacific

Through an analysis of the NAPs of nine countries in the Asia-Pacific, we found several points that illustrate an inconsistent understanding of the NAP scheme among countries (Table 2).

First, although these NAPs are all registered in the NAP Central, their purpose and contents are not necessarily focused only on adaptation. For example, Kiribati and Tonga have developed their NAPs not as adaptation-only plans, but as plans for the joint implementation of adaptation and disaster risk management. Cambodia's NAP is called the Climate Change Strategic Plan, as its scope includes both adaptation and climate change mitigation. This indicates the diversity of the understanding of the countries for the roles and the scope of the NAPs.

Second, most of the NAPs claim that they are comprehensive plans using expressions such as comprehensive, integrated, and holistic. However, the plans only sometimes cover all the elements of the NAP process, with considerable variation in depth of analysis, specification of actions, and levels of transparency. For example, Cambodia's NAP only stipulates strategic objectives and strategies, and leaves identifying and prioritizing specific adaptation actions to a separate action plan that will be developed later. Timor-Leste's NAP leaves most of the identification of specific adaptation efforts to the results of near-term actions, such as vulnerability assessment and stakeholder consultations. PNG’s NAP is designed as a framework for the government Departments and Authorities to lead adaptation efforts and a framework to mainstream adaptation into the ongoing sectoral planning processes. Kiribati, Tonga, and PNG indicate that the NAPs are in a parallel relationship with other plans or policy frameworks for promoting adaptation. Kiribati and PNG list priority adaptation activities in their NAPs but it is not clear how or why these were selected or who was involved in the prioritization process. Bangladesh has developed the NAP as a comprehensive and detailed plan covering most of the elements of the NAP process that includes a fundamental review of the legal system and institutional arrangement and provides logical explanations for selecting and defining various elements and activities.

Third, understanding of the concepts of the NAP process and the NAP also varies from country to country. Kiribati and Cambodia make very limited reference to Decision 1/CP.16, Decision 5/CP.17, nor to the NAP process in their NAPs. Bangladesh stipulates that the NAP process and the NAP are both ‘processes’ at different places in its NAP, which indicates some confusion in its understanding. Fiji also understands the NAP itself as a process. PNG, on the other hand, equates NAP with the AP process. While many NAPs refer to both the NAP process and the NAP, most countries do not clarify how they understand the relationship between the two in their NAPs. As exceptions, Nepal and Timor-Leste state their understanding of the relationship between the two to some degree.

Fourth, regarding the timeframe, while the CAF defines the NAPs as a means of identifying medium- and long-term adaptation needs, no NAPs limit their scope to medium- and long-term adaptation needs. Bangladesh emphasizes effective medium- and long-term adaptation strategies in its NAP, but even that NAP covers short-term adaptation needs. Timor-Leste also indicates its focus on medium- and long-term but incorporates some short-term actions from the NAPA. Fiji's NAP is a five-year plan that summarizes the actions identified as the most urgent according to stakeholders and focuses on short-term rather than medium- to long-term adaptation needs.

4. Discussion

4.1. Bringing consistency to the NAP scheme

As our document review showed, the COP has mainly focused on the NAP process, rather than on the NAPs specifically, in assisting developing countries’ efforts on adaptation. However, there are three issues related to this.

First, there are some inconsistencies in the COP’s efforts to focus on the NAP process rather than the NAPs. As one example, the LEG's annual Progress Reports focus almost entirely on the NAPs and do not evaluate NAP processes. Although Decision 3/CP.20 calls for the Parties to provide information on NAP processes beyond the NAPs, NAP Central compiles and analyzes almost exclusively information about the NAPs. Suppose a country adheres to the NAP Guidelines. In that case, there should be various information beyond the NAP in its NAP process, including the NAP implementation strategy, but they have not been the subjects of most analyses or reports.⁴ The GCF has set Objective 3 of the Readiness Programme's Strategy for 2019–2021 as ‘strengthened adaptation planning’ (GCF, 2019) and plans to put it as ‘National Adaptation Plans and Adaptation Planning Processes’ for 2024–2027 (GCF, 2023). Its current work programme does not even mention the NAP process, but rather the formulation and implementation of the NAPs in its literal sense is the focus of its support (GCF, 2022). While monitoring and evaluation (M&E) of adaptation is frequently discussed in the negotiation process and other occasions, the focus is often on M&E of the NAPs rather than NAP processes. In fact, the Paris Agreement recommends M&E for the adaptation plans but does not mention M&E for NAP processes. Recently, the AC published a report on M&E of adaptation, in which the NAP process was never mentioned (Adaptation Committee, 2023). Hence, the COP should review the efforts on the NAPs to check whether the focus is consistently on the NAP process. The COP and relevant organizations may need to adjust the direction of the efforts in certain areas. This reflection has some implications for developed countries. It would be worthwhile for developed countries to revisit the relationship between their Naps and the adaptation planning processes (equivalent to the AP processes in developing countries) and evaluate, for example, whether it is appropriate to conduct M&E only of their Naps or expand its scope to the adaptation planning processes.

Second, the UNFCCC regime has left the NAP process ambiguous regarding what it is and how the COP and the Parties should engage. Although there are no official agreements, the NAP process is understood as a ‘process to formulate and implement national adaptation plans’. In contrast, the CAF process is a ‘process to enable least developed country Parties to formulate and implement national adaptation plans’. This difference implies that the implementing bodies (subjects) of these two processes must be considered different. The CAF process was originally referred to as ‘The Conference of the Parties … decides to hereby establish’, so its subject is the COP. On the other hand, the subject of the NAP process must be a developing country Party (or an LDC Party) as the objectives of the process are ‘to reduce vulnerability’ and ‘to facilitate the integration’ and it does not make sense the COP itself implement the NAP process with such objectives. In fact, Decision 5/CP.17 states, ‘Also invites least developed country Parties to strive to implement institutional arrangements to facilitate their national adaptation plan process’, and assumes that LDC Parties lead NAP processes. Decision 8/CP.24 also states, ‘Acknowledges that developing country Parties have made progress in the process to formulate and implement national adaptation plans’, and regards developing country Parties as the subjects of NAP processes. The AC stated, ‘It is important to acknowledge that many non-LDCs developing countries have some forms of NAP processes already in place’ (Adaptation Committee, 2013). The LEG submits annual reports to the SBI called ‘Progress in the process to formulate and implement national adaptation plans’ with the same understanding.⁵ Thus, contrary to general understanding, the NAP process differs from the CAF process and is a floating mechanism in the UNFCCC regime. The COP should agree on an anchor to tie the NAP process with the UNFCCC regime to specify how the COP and each developing country should be engaged. In that respect, it is conceivable that the COP agrees on ‘support for NAP processes’ (along with the objectives of the support) while encouraging or inviting each developing country Party to implement the NAP process. It is because the COP's involvement to date has been ‘supportive efforts’ for NAP processes.

More importantly, the COP should define the NAP process, which has not yet been done, to mean the AP process in each developing country. This reflects the fact that the NAP process is now interpreted as such in many cases, and confused understanding exists such that the CAF already defines the NAP process and that a ‘process to formulate and implement national adaptation plans’ is an appropriate description of it.

In agreeing on the engagement of the COP to NAP processes, it is necessary to consider how to treat the CAF's two conditions, as the CAF was intended to be the basis of the NAP process. First, the CAF articulates only LDCs as the direct target countries. However, all developing countries are already targeted for assistance almost equally, and no problems could arise if the COP does not retain this condition. Second, the NAPs under the CAF process are ‘a means of identifying medium- and long-term adaptation needs and developing and implementing strategies and programs to address those needs’, meaning excluding short-term adaptation needs. However, from the perspective of supporting the most needed adaptation actions, excluding short-term needs is inappropriate, even though the NAPA scheme exists for LDCs. None of the nine surveyed NAPs exclude short-term adaptation needs and responses to them in their scope. The fact that these NAPs have been accepted indicates that such a condition in the CAF is already meaningless, and there should be no practical obstacle to eliminating it.

The third issue is that the role and the scope of a NAP in the NAP process is not well specified, and only types of possible components of a NAP (e.g. a summary of the NAP process, key climate vulnerabilities, a list of prioritized adaptation strategies, a plan for establishing indicators, a timeline for reassessing the plan) are briefly indicated in the NAP Guidelines. However, defining the NAP process as the AP process provides one answer to clarify the role of the NAP. Under such a definition, formulating a NAP is not a prerequisite for engaging in the NAP process. Of course, if each country finds it essential to formulate a NAP, nothing can prevent it, and the COP can support their effort even under this definition. However, if a developing country concludes it is more appropriate to develop another policy framework than a NAP, then this judgment should also be respected, and this definition justifies the COP’s support for such an effort.

There are various policy frameworks for promoting adaptation. The most representative framework is a legal system, but strategies, guidelines, and national adaptation support fund mechanisms, among others, are also possible forms. Even as a plan, rather than consolidating everything into a single NAP, there could be approaches, for example, to develop multiple plans, such as a short-term plan and a medium- to long-term plan, or a national plan and local plans, and to define the relationship among them.

The concept of the NAP is a creation of the UNFCCC regime and is not derived from each country's intrinsic needs. Therefore, once NAP formulation becomes a prerequisite for the NAP process, it may result in the loss of opportunities for ‘selecting an appropriate policy framework’ for each country. Countries should select an appropriate policy framework based on their own judgment and an overall assessment of the existing policy frameworks and challenges relevant to adaptation, which could result in formulating a non-NAP policy framework. The COP and the developed countries should recognize the importance of such a step. In this sense, redefining the NAP process has practical implications.

4.2 Redefining the NAP

In the previous section, we pointed out that the role and the scope of a NAP is unclear in the NAP process. However, apart from its relationship to the NAP process, it can be understood that there is virtually no agreement on the intrinsic objectives, roles, or functions of a NAP. Even what a NAP could encompass is left ambiguous after the four elements of a NAP identified in the initial guidelines are reinterpreted as steps of the NAP process in the NAP Guidelines, as explained above. As a result, actual NAPs have been formulated with diverse objectives and scopes, as explained before.

Two points can be made considering this observation. First, there is no reason to expect that the NAPs have anything more in common than their name indicates, i.e. ‘a plan on adaptation developed by the national government.’ NAPs can be developed with different objectives, perspectives, and contents. This fact has a severe implication beyond the issue pointed out by the AC on comparability (Adaptation Committee, 2013). It means not only that comparative and aggregate analysis of the NAPs is of limited value, but also that it is not even clear what precisely the COP is supporting. This difficulty comes partly from the unique character of adaptation, such that it has no natural unified anchor like a GHG reduction target. Without defining what a NAP is for and what it should encompass beforehand as a substitute for an anchor, a NAP can encompass almost anything. Therefore, if support for the formulation of the NAPs remains an essential role of the COP in the future, the COP should ask again what the purpose of such support is and what a NAP should look like to realize such purpose and make efforts to convert the answers into agreements, i.e. defining the roles and scope of the NAPs more clearly to reflect the Parties’ shared intention for introducing this term. Such efforts are also essential to resolve the Parties’ confusion and ambiguity regarding their understanding of the NAP process, NAPs, and their relationship. At the same time, it is necessary to revisit the validity of ongoing efforts to analyze the NAPs or discuss, for example, aggregated financial needs for adaptation or unified M&E of the NAPs (in addition to the issue of the focus being shifted away from the NAP process).

Second, there is a potential value in formulating the NAPs as strategic documents presenting a ‘grand design of the AP process’, as Bangladesh’s efforts on its NAP can be described. Such a NAP contrasts with a NAP that compiles project ideas or focuses on limited aspects of the AP process. In this approach, the NAP functions as a platform for stock-taking and analyzing all the adaptation-related efforts in the country and then for identifying directions for future actions while ensuring transparency by providing thorough explanations of its choices. In such cases, the NAP could become a ‘meta-plan’, as it could articulate the steps for creating new plans or legal systems as needed.

Such an approach gives us an insight into the issues above. Earlier, we pointed out that the formulation of a NAP should become optional when the NAP process is defined as the AP process. If the NAP is a kind of policy framework to address specific adaptation needs, the country should be given a choice to choose another appropriate policy framework. However, if the NAP is developed as the ‘grand design of the AP process’, then a step for ‘selecting an appropriate policy framework’ can be located in the NAP, and we no longer need to worry about constraining the options for the countries.

Moreover, if ‘support for NAP processes’ becomes equivalent to support for AP processes, there is a rationale for seeking the formulation of such NAPs, as they will provide an overall picture of the support target. Also, since M&E of the NAPs and M&E of NAP processes converge, there is less need to discuss the targets of M&E. Above all, encouraging developing countries to prepare such NAPs could promote more systematic and strategic adaptation efforts.

In updating the Strategic Plan for 2024-2027, the GCF has expressed the need to support developing countries to shift from implementing climate strategies such as NAPs through standalone projects to more integrated, systemic, country-owned responses, based on the assessment that the NAPs so far have been formulated by fitting discrete project ideas identified by Accredited Entities or countries into such a narrative (GCF, 2023). The approach presented here is consistent with this GCF's observation.

As mentioned above, making the NAP formulation optional is one approach. However, it would be more desirable if the COP calls for the universal formulation of the NAPs as the ‘grand design of the AP process’ as it helps make the support for NAP processes more consistent and effective. Even if the COP chooses the former approach, it should encourage the Parties to specify the NAP’s role and scope within the overall AP process in their NAPs. That would reveal what AP process elements are envisioned outside the NAPs and help consider appropriate future support. In other words, we must fully understand that NAPs have nothing more in common than ‘a plan on adaptation developed by the national government,’ and constraints and challenges arise from it. If all NAPs (and the Naps by developed countries) become a ‘grand design of the AP process’, aggregated analysis and M&E, mutual learning and cooperation, and support could become more effective and valuable.

4.3. Limitations and Future directions

In this paper, we have revealed the challenges embedded in the NAP scheme, mainly due to the ambiguities in the provisions for the NAP process and the NAPs. We then proposed possible approaches to address these challenges. However, ensuring certain clarity in the provisions may not make the NAP scheme effective enough. We need to continuously examine and identify areas for improvement of the scheme by investigating, for example, the implications of various agreements and guidelines for the NAP process and the NAPs, the characteristics of the adaptation efforts, the actual approaches in formulating the NAPs, and the intended roles and the scopes of the NAPs. The COP has been conducting such examinations periodically, but its scope is usually very limited, and it is impossible for such exercises to be free from political coordination and compromise.

The new Framework was established at COP28 towards achieving GGA articulated in the Paris Agreement (UNFCCC, 2023b). The COP 28 decision on the first global stocktake also emphasized the importance of this Framework for the future (UNFCCC, 2023a). The formulation of this Framework can be seen as calling for even greater international collaborative efforts, underscoring the growing importance of continuing to verify various schemes under the UNFCCC. Although space does not permit a detailed explanation here, the Framework mentions Naps and (adaptation) planning processes alongside policy instruments and strategies, which have not previously been indicated, while introducing a similar concept, the iterative adaptation cycle, without clarifying its relationship to the existing concepts. Such development could potentially lead to further confusion and hinder future collaborative efforts. In addition, while the Framework was developed for all Parties, the NAPs for developing countries have been playing a central role as a policy framework for adaptation under UNFCCC thus far, so clarifying how the NAP scheme is linked to the Framework is also an important issue. The COP is expected to address these challenges and bring consistency and clarity to its schemes to facilitate collaborative efforts towards achieving GGA.

It is, therefore, worthwhile for the academic community to also undertake critical and constructive examinations of such topics to supplement the efforts under the COP. We hope this paper will be considered not only as specific suggestions for improving the NAP scheme, but also as a contribution to a better understanding of the necessity of engaging in research focusing on the designs of various schemes under the UNFCCC.

5. Conclusions

If the COP does not clearly indicate what the NAP process entails, relevant international organizations will have no choice but to provide support for the NAP process based on speculation or their own subjective judgments. If Parties can develop NAPs for whatever purpose, perspective, or content, the COP cannot foresee the global consequences of its efforts to support the formulation and implementation of the NAPs. In that case, the NAPs could have limited value in monitoring regional and global progress of adaptation efforts, including in the context of GGA, and evaluating further support needs.

In this paper, we have identified specific ambiguities, inconsistencies, and contradictions surrounding the NAPs under the UNFCCC regime, which could cause such problems. Although sincere efforts by the individual Parties and the relevant international institutions have addressed these concerns to some extent, the issues require more than just practical responses. There needs to be some formal agreement at the COP to steer future international cooperation in the right direction.

We have suggested one concrete solution: defining the NAP process as the ‘adaptation planning process’ and finding the role of a NAP as the ‘grand design of the adaptation planning process’ while requesting universal NAP formulation in implementing the NAP process. We have proposed that the COP should maintain its focus on the NAP process, rather than the NAPs themselves, to support the adaptation efforts of developing countries. The COP should also strive to provide consistent and practical guidance on the NAP process and the NAPs, including their relationship, nature, and intended functions. Furthermore, clear guidance on the engagement of the COP and the Parties is necessary. Such measures will ensure that the NAP scheme operates more effectively, facilitating on-the-ground adaptation actions. Such suggestions may seem challenging to implement due to high political costs. However, by addressing these topics in discussions about enhanced adaptation actions within the global stocktake and viewing them as opportunities to further refine the NAP scheme – rather than as reactions to previous inconsistencies – it may be possible to achieve significant progress. If the COP aligns these efforts with the ongoing work on GGA, it will further facilitate concerted global efforts toward achieving it. We hope the COP will try to overcome the challenges identified in this paper to promote effective adaptation globally.

Acknowledgments

This research was supported by the Environment Research and Technology Development Fund (JPMEERF20221C06) of the Environmental Restoration and Conservation Agency provided by Ministry of the Environment of Japan. The authors would like to thank Brian Alan Johnson for his comments.

Disclosure statement

No potential conflict of interest was reported by the author(s).

Notes

1 The numbers are taken from the GCF website. See https://www.greenclimate.fund/readiness/naps (last accessed on 27 November 2023)

2 See https://napcentral.org/ (last accessed on 27 November 2023).

3 See https://napcentral.org/about-naps (last accessed on 27 November 2023).

4 The fact that most of the submitted NAPs include implementation strategies, as noted in the LEG's ‘Progress of developing country Parties in the process to formulate and implement national adaptation plans’ (UNFCCC, 2022b), could partially explain the reasons for this.

5 However, such an understanding is not always consistent. For example, Article 4 of Decision 5/CP.17 states, ‘Agrees that the national adaptation plan process should not be prescriptive, nor result in the duplication of efforts undertaken in-country, but should rather facilitate country-owned, country-driven action’. This provision intends that there should be no such coercion from outside. If this is about a country's process, nothing should prevent that process from being prescriptive if it is agreed upon within the country. Hence, this provision understands the subject of the NAP process is the COP.