Dr. Ahmed Al-Kilani, Research Fellow, Energy Research Centre in the United Kingdom
Initially, it is necessary to clarify the nature of Iraq’s Nationally Determined Contributions (NDC) document and whether it is nationally beneficial for Iraq. In short, it is a national action plan submitted by Iraq as part of its legally binding commitments under the Paris Agreement on Climate Change. It outlines what Iraq will do in the coming years to reduce emissions and adapt to the effects of climate change. It serves as an economic roadmap that directs investments, justifies requests for international funding for Iraq, and assures the market that Iraq has a clear program for energy and infrastructure.
Domestically (Inside Iraq): The NDC document serves as a reference for the government, ministries, and the private sector to determine climate policies and investments; no ministry can exceed what it is allowed to do within the document! Therefore, it defines all investments and plans of ministries and institutions. For example, if achieving the document’s objectives requires a country to reduce the power sector’s emissions to 20 million tons of $\text{CO}_2$ equivalent (e.g.), and the sector’s current emissions are 40 million, this is very important because the document guides the necessary investments to achieve the goal and directs private sector investments, as is the case in most countries, especially Western nations and China. Failure to work towards the goal poses a significant risk to the country’s reputation, in addition to affecting its climate financing, as achieving the NDCs is one of the main goals of the Paris Agreement.
Externally (Internationally): It demonstrates the state’s commitment to the international community and opens the door to climate finance and green investments. International institutions (the Green Climate Fund, development banks, donors) rely on the NDC document to prioritize project funding in the country. Without a clear document, attracting investments or grants becomes difficult.
Unfortunately, in Iraq, some view it as a marginal document belonging to the Ministry of Environment, whereas in reality, most Western countries consider the NDC the reference for all the country’s energy and economic policies, and its contents outweigh any other document. Some countries even make its contents legally binding, such as the United Kingdom. For example, the Net Zero policy is the goal of the UK’s NDC, and the same goal is legislated in Parliament as a law that all ministries must adhere to and achieve, regardless of the cost or the political affiliations of the governing parties!
Why Must Iraq’s NDC Document be the Main Reference for Ministries and Institutions?
It is no secret that most sectoral ministries, such as Electricity, Industry, Oil and Gas, Transport, and Municipalities, use fuel daily as part of their operations. For instance, the Ministry of Electricity burns gas and other fuels in its stations to generate power, leading to greenhouse gas emissions.
Since the NDC document defines the annual amount of emissions for all sectors in the country, it essentially determines the working mechanisms, projects, and investments of the ministries. Ministries and institutions must not exceed the maximum allowable emissions limit for the country set in the document.
One might ask: why must we adhere to the document? Doesn’t this burden the ministries or the state? Here we say that adhering to the document always ensures the implementation of relatively easy emissions reduction projects that serve the Iraqi state’s interest and incur no cost, in exchange for profits and international funding guaranteed by the Paris Agreement. Furthermore, the document does not impose burdens on the state to reduce emissions beyond its capacity, as we will see later.
For example, most projects currently undertaken in Iraq are Energy and Resource Efficiency projects, which are also often emissions reduction projects. It is in Iraq’s highest economic interest to implement them, even if the initial costs are high, because they will yield greater benefits than the costs in the long term or over the projects’ lifespans. Alternatively, these projects are carried out to achieve internal social interests.
Furthermore, removing electricity network bottlenecks will reduce network losses, thus reducing emissions in the long term, and the resulting one-third increase in efficiency from converting simple cycle power plants to combined cycle contributes to increasing electricity supply while secondarily reducing emissions.
Therefore, Iraq undertakes these projects for their economic or social feasibility, regardless of the emissions generated. These projects are not primarily implemented because they reduce emissions, but because they are feasible in raising energy efficiency and increasing energy resources. At the same time, Iraq is one of the countries most affected by climate change impacts and therefore greatly needs funding to adapt to these effects, as well as accessing necessary financing due to losses and damages caused by climate change impacts such as severe storms and heatwaves. Iraq cannot demand financing without a Nationally Determined Contributions document written accurately and scientifically.
Iraq has so far received $50 million USD in funding from the Green Climate Fund to assist Iraq’s agricultural sector in increasing climate resilience, particularly in our southern governorates. If we were to cover all the financing Iraq receives in the field of environment and climate change, the figure would be much larger. The NDC ensures the implementation of emissions reduction projects that do not cost the state and profit from various international funding sources, making the Paris Agreement often economically profitable for Iraq.
What if ministries and institutions do not adhere to the NDC? Iraq will fail to meet its contributions, funding will stop completely, and it will be theoretically outside the Paris Agreement, facing tremendous regulatory and financial isolation in a world that imposes a carbon border price.
Why is the Updated NDC Document for Iraq 2025 Better Than the Old NDC for Iraq 2021?
Firstly, it is the nature of life to learn from our previous mistakes, and there is no harm in that. With the passage of time, keeping pace with scientific and technological advancements, and the continuous momentum of climate action, it is natural for the updated NDC for 2025 to be better than 2021, especially in the Mitigation chapter. The updated NDC was developed according to the latest standards and scientific modeling appropriate for a country of Iraq’s size and history.
For example, for the first time, the Business-as-usual (BAU) scenario was modeled according to sound scientific principles and the available National Greenhouse Gas Inventory for 2020-2021 and Iraq’s Biennial Transparency Report (BTR) to represent a real starting point for estimating Iraq’s total emissions for all sectors.
The figure below (which is not included here) illustrates the BAU scenario for Iraq’s total emissions across various sectors (Energy, Industry, Agriculture, Waste, Land Use) according to the IPCC classification, starting from the 2020 National Inventory. It shows that the energy sector constitutes over 75% of the country’s total emissions and demonstrates that, in the absence of climate policies for emissions reduction and with an increase in Iraq’s population (and thus increased energy consumption and emissions), Iraq’s total emissions could reach 300 million tons of $\text{CO}_2$ equivalent by 2035.
To create the BAU scenario, detailed modeling of emissions determinants in various state sectors must be performed, such as forecasting peak electricity demand now and in the future, forecasting the total number of vehicles in the transport sector, forecasting the oil production rate, incorporating energy efficiency determinants, including projects completed before 2025, and forecasting population and GDP. This is a task that cannot be accomplished overnight but must be done by a modeling specialist.
Without a BAU scenario, emissions reduction cannot be calculated, nor can we determine if a country has achieved its NDC goal under the Paris Agreement, which makes the BAU scenario crucial. Unfortunately, the first NDC document for 2021 lacked a BAU scenario entirely, which genuinely confused the world and UN organizations on how to calculate the 1-2% reduction commitment and what that 1-2% represents as a number.
Based on the BAU scenario and technical and political consensus, Iraq’s commitments under the Paris Agreement regarding emissions reduction were determined as shown below: a 3% reduction from Iraq’s 2030 emissions (a 1% increase over previous commitments) and a 5% reduction from Iraq’s 2035 emissions as unconditional commitments to achieve the goals of the Paris Agreement, and a 17% reduction by 2035 as a conditional commitment dependent on receiving international financing or activating carbon markets.
Furthermore, the Global Change Analysis Model (GCAM), used by the Intergovernmental Panel on Climate Change (IPCC), was utilized to detail the cost of achieving Iraq’s ambitious emissions reduction goals for 2030 and 2035. The cost was estimated at $1.7 billion for the 3% unconditional reduction goal by 2030, about $6 billion for the 5% unconditional reduction goal by 2035, and $21 billion for the 17% conditional reduction goal by 2035. It should also be noted that the benefits resulting from achieving the NDC goals must be calculated within a separate implementation plan and within the Biennial Transparency Reports.
Since the 2025 NDC contains broader and deeper technical and scientific details than the 2021 version based on the above, it represents a significant leap compared to the 2021 contributions, which I detailed in my article highlighting some shortcomings of the previous contributions: The Decisive Answers to Dreamy Fantasies: Iraq and the Paris Climate Agreement, including setting an unrealistic financing goal of $100 billion.
What Does Iraq Need to Implement the NDC and Obtain International Financing?
Frankly, the implementation of Iraq’s NDC, with all its ramifications in mitigation, adaptation, loss and damage issues, obtaining necessary international financing, and entering carbon markets—which are technically and diplomatically complex matters—cannot be achieved as long as there is no supreme authority (higher than the sectoral ministries and institutions) responsible for monitoring and implementing the NDC.
The problem is that some ministries do not adhere to the directives from the Ministry of Environment regarding climate change and the NDC because the Ministry of Environment perhaps lacks the legal authority over those ministries and institutions to achieve and implement the NDC, or because those ministries might believe the document belongs to the Ministry of Environment and therefore does not need to be implemented.
The Council of Ministers’ decision to adopt the NDC document as a “binding national framework” for the country was the beginning of the correct path to implement and act on the NDC in Iraq in a way that serves the national interest and achieves economic benefits for Iraq.
Therefore, Iraq must establish an official, independent supreme body, legislated in Parliament, to advise the government and monitor the implementation of the NDC as required in all the directions and topics it contains.
It is worth noting that the UK Parliament established an independent supreme body in 2008 to be the official and legal advisor to the government on climate change, called the Climate Change Committee (CCC). It monitors the achievement of the UK’s NDC goals across all sectors and advises the government on the policies needed to ensure the lowest cost and highest benefit for the government and citizens. I am also aware that the UAE is in the process of establishing an authority or institution similar to the British CCC.
I mention this because I personally worked with the British CCC to lead the modeling of industrial sector emissions and develop the necessary plans for the UK’s Seventh Carbon Budget by 2038-2042, which will be approved by the British government in mid-2026 to be legally binding for it and the relevant ministries and institutions.