IESR pushes for stronger emission targets in NDC 3.0 and immediate submission to UNFCCC

Jakarta – The Institute for Essential Services Reform (IESR) has called on the government to strengthen its emission reduction targets in the Nationally Determined Contribution (NDC) 3.0 document and submit it to the Secretariat of the United Nations Framework Convention on Climate Change (UNFCCC) before the Conference of the Parties (COP) 30 in November 2025.

Amidst extreme temperature spikes and unpredictable weather affecting many regions in Indonesia, pressure on national climate commitments has intensified. According to IESR, in a written statement on Wednesday, October 22, this swift action will be a tangible manifestation of Indonesia’s leadership on the global stage in efforts to curb global warming, while also reaffirming Indonesia’s position as a country committed to clean energy transition.

“Indonesia has a great opportunity to demonstrate global leadership through ambitious and realistic climate commitments. However, the targets in the current draft of NDC 3.0 are not yet strong enough to meet the goals of the Paris Agreement,” said Fabby Tumiwa, Executive Director of IESR.

Less than ambitious NDC 3.0 draft

IESR acknowledges that there have been a number of improvements in the draft NDC 3.0 compared to the previous version, such as the addition of the marine and upstream oil and gas sectors, as well as the target of zero waste management by 2040. This document also includes the principle of just transition and the use of a new baseline for 2019.

However, Fabby believes that both the conditional and unconditional targets in the draft are still not in line with the Paris Agreement’s goal of limiting global temperature rise to below 2°C. The unconditional target actually allows for an increase in emissions until the middle of the century, while the conditional target only shows a significant reduction after 2035.

As part of the solution, IESR encourages the government to accelerate peak emissions before 2030, among others, by accelerating the cessation of coal-fired power plant operations and accelerating the development of renewable energy.

An analysis by Climate Action Tracker (CAT)—an international research consortium that IESR also participates in—states that to stay on track for 1.5°C, Indonesia needs to reduce greenhouse gas emissions to 850 million tons of CO₂e by 2030 and 720 million tons of CO₂e by 2035, excluding contributions from the land and forestry sectors.

Energy reform and carbon markets

IESR also said the importance of reforming fossil fuel subsidies and improving energy efficiency in the industrial and building sectors. These measures are believed to reduce emissions while lowering energy costs in the long term.

In addition, IESR said that Presidential Regulation (Perpres) No. 110 of 2025 concerning the Implementation of Carbon Value Instruments and National Greenhouse Gas Emission Control, which was recently issued, is an important milestone in aligning carbon policy with national economic activities.

However, Fabby said there is a need for safeguards and transparency to ensure that carbon trading is credible and free from carbon fraud.

“A healthy carbon market can only be built if there is integrity, transparency, and accountability. The government needs to ensure that this instrument actually reduces emissions, rather than merely becoming a financial transaction,” he said.

With less than a month to go before COP 30 in Brazil, IESR hopes that Indonesia will finalise and submit its NDC 3.0 to the UNFCCC. This decision will show that Indonesia is not only a participant, but also a leader in global efforts to tackle the climate crisis.

“The momentum leading up to COP 30 must be used to strengthen Indonesia’s position as a developing country capable of playing a strategic role in the global energy transition,” Fabby concluded. (Hartatik)

Banner photo: Image generated by OpenAI’s DALL·E via ChatGPT (2024)

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