NDC 3.0 falls short of ambitions in the power sector

Bangladesh submitted its Nationally Determined Contribution (NDC) 3.0 to the UNFCCC on 29 September 2025, outlining the government's commitment to reducing greenhouse gas (GHG) emissions across key sectors by 2035. 

Prepared under the Paris Agreement, the document was developed by the Department of Environment under the Ministry of Environment and Climate Change, in close consultation with relevant ministries and departments. NDC 3.0 has raised a serious wave of questions regarding the overall and sector-specific GHG emission mitigation targets (unconditional and conditional) for 2035. 

According to the UNFCCC, the parties need to set more ambitious targets for reduction of carbon emission in NDC 3.0 compared to that in NDC 2.0 which was submitted in 2021-22. 

Given the meagre progress in emission reduction reported in the First Global Stocktake (GST1) in 2024, it is decided that countries or parties will set ambitious targets for reduction of carbon emissions for the next ten years. Hence, parties need to submit not only an updated NDC 2.0 but an ambitious NDC 3.0. 

Inforgraphics: TBS

However, the interim government fails to set an ambitious target for reduction of emissions for the next decade. According to NDC 3.0, total emission reduction target is set only 84.9 million tonnes CO2eq (20.3%), of which 26.7 million tonnes CO2eq (6.4%) is 'unconditional' and the remaining 58.2 million tonnes CO2eq (13.9%) is 'conditional' if necessary financial and technical assistance is arranged. 

Ironically, Bangladesh's NDC 2.0 targets were much 'ambitious' compared to that of NDC 3.0. The combined target set in NDC 2.0 was 89.5 million tonnes CO2eq (21.9%) below BAU even by 2030. Out of which 27.6 million tonnes CO2eq (6.7%) was 'unconditional' and 61.9 million tonnes CO2eq (15.1%) was 'conditional'. Both the targets in terms of percentage and absolute number have been reduced from that of NDC 2.0. Such demonstration of less ambitious emission reduction targets has seriously undermined UNFCCs guidelines of setting national measures. 

The power and energy sector, which is the major emitter of carbon and GHG, faced the same fate in NDC 3.0 — it came up with a lower emission mitigation target. The estimated emission from the energy sector in 2035 under NDC 3.0 is comparatively lower than that in 2030 mentioned in NDC 2.0. The estimated emission reduction targets at absolute numbers are also deceiving. The combined target is set at 28.6% (17.6 million tonnes CO2eq) of which 'unconditional' and 'conditional' targets are 9.9% (6.1 million tonnes CO2eq) and 18.6% (11.5 million tonnes CO2eq) respectively. 

To make an ambitious target for the power sector following the UNFCCC guideline, Centre for Policy Dialogue (CPD) carried out a detailed study (Moazzem et al., 2025) and presented the findings to the official team responsible for preparing the NDC 3.0 document. 

According to CPD (August 2025) the projected 'ambitious' targets for the power sector would be as follows — combined emission reduction for 2035 would be 91.2 million tonnes CO2eq — of which, 25% is 'unconditional' and the rest 75% is 'conditional' targets. Unfortunately, nothing is reflected in the official NDC 3.0 prepared by the DoE.

The DoE has tried to explain why the targets in NDC 3.0 are lower than that in NDC 2.0. They said, as the base year for NDC 3.0 has been reset to 2022 (from the previous 2012), the estimated emission scenario in the power sector for 2035 has indicated a lower emission target compared to that in NDC 2.0 for 2030. The government has used this excuse to create a fallacy that the GHG emission mitigation target is as ambitious as the NDC 2.0 if not more. 

But in real terms, the absolute emission reduction target has been reduced in the power sector. In fact, the government should have leveraged this favourable emission scenario and set a much more ambitious target to align with energy transition commitments mentioned in different national and international policy documents. 

According to the draft NDC 3.0, renewable energy will meet 25% of the total electricity demand, which is 11,200 MW by 2035. However, it is not specified whether the share of 25% will be in terms of installed generation capacity or actual electricity demand. Two probable assumptions need to be considered here. Either, if 25% or 11,200 MW is meant in terms of generation capacity, then renewable energy will be able to meet merely around 3,000 MW of electricity demand. Or if it is assumed that 11,200 MW of electricity demand will be met from renewable energy, Bangladesh needs to install RE based power generation. So, either way, the methodology and share of renewable energy mentioned in the NDC 3.0 seem faulty.

NDC 3.0 couldn't let go of the idea of 'greenwashing' not so clean fuel sources in the energy mix. The NDC outlines the priority action of replacing 90% of liquid fuel based peaking capacity power plants with so-called 'cleaner' alternatives meaning hydrogen, ammonia, CCS and nuclear power. Such alternate energy, included under the Integrated Energy and Power Master Plan (IEPMP), has been criticised by the civil society. 

Firstly, these advanced technologies are yet to be proven green or clean. Additionally, even the developed world is not yet ready to deploy such technologies for energy transition given its technological feasibility and economic viability. Being a lower middle-income country, Bangladesh can't consider adopting such expensive technologies disguising fossil fuel. 

Keeping up with the tradition, NDC 3.0 also fails to coherent with other plans and policies of the sector in case of aligning with the 30% renewable energy target by 2040. NDC 3.0 briefly mentions some policies such as Renewable Energy Policy 2025, Updated Integrated Energy and Power Master Plan and Net Energy Metering Guidelines. 

However, the document couldn't successfully build any connection between them. The draft NDC 3.0 included that the share of renewable energy will be 25% of the electricity demand by 2035, but 80% of the target will be conditional. That implies, Bangladesh will not be attaining its energy transition target if there is no international support. 

In addition to that, the calculation of 25% of the total demand resulting in 11,200 MW is doubtful. Because if the IEPMP estimation is considered, 25% of that demand estimation should have been much higher. Woefully, the emphasis on the low carbon options including imported hydrogen and ammonia have been repeated in the NDC 3.0 as well aligning with the IEPMP, completely contradicting with the key essence of NDC. 

However, NDC 3.0 tried to include gender, equality, disability, social inclusion, youth and marginalised groups as cross-cutting measures to make the energy transition just and equitable. Inclusion of such new dimensions is appreciated. 

During the drafting, consultation and validation process of the NDC 3.0, private sector and civil society participation and coordination was almost absent. As per the internal information, a total of seven stakeholders consultation meetings have been arranged to share the progress, review, and receive feedback and consultation. However, those have been carried out with relevant ministries, government authorities and public entities. 

Only one validation workshop has been organised with few CSOs having been hurriedly done just before the submission. Such unwillingness to engage with civil society organisations simply indicates a similar nature of policy making process by the interim government as had been carried out during the fallen regime.

We think that NDC 3.0 needs major revision especially in setting the emission-reduction targets. The interim government should have opted for ambitious, forward looking GHG emission mitigation targets for 2035 in the power sector to uphold its global image.

More importantly, NDC 3.0 has once again shown that making national policy, plan, strategy, or guideline needs independent, impartial and unbiased perspectives and long-term vision and outlook. Setting up an independent commission with experts, academia, CSOs and private sector backed by technical teams and funded by national exchequer could better prepare a 'home-grown', publicly-owned national policy.  

Sketch: TBS

Dr Khondaker Golam Moazzem is a Research Director and Helen Mashiyat Preoty is a Senior research Associate at Centre for Policy Dialogue (CPD). 

Disclaimer: The views and opinions expressed in this article are those of the author and do not necessarily reflect the opinions and views of The Business Standard.