New National Climate Change Adaptation Plan: What’s Changing?

Introduction

The new version of the National Climate Change Adaptation Plan (PNACC 3) has been officially published and is open for public comment^[1].It represents a significant step forward in defining the actions needed to ensure the resilience of regions, populations, infrastructure (roads, networks, telecommunications, etc.), and economic activities in the face of the future impacts of climate change.
Carbone 4’s Adaptation Division shares its perspective here on this new policy document for adaptation in France.

Why is this PNACC an important tool for adaptation?

The effects of climate change, which we witness on a regular basis, will intensify in both frequency and severity.

Although they receive less media attention than mitigation measures, adaptation policies aim to prepare for these risks and protect against them as much as possible. In France, the PNACC (National Climate Change Adaptation Plan) is the official National Plan developed by the Ministry of Ecology and Sustainable Development. The first PNACC was developed in 2011, and the third version, PNACC3, was released in 2024. The PNACC pursues four main objectives: protecting people and property by ensuring public safety and health; taking social dimensions into account to prevent inequalities in the face of risks; limiting costs while capitalizing on opportunities; and preserving natural heritage.^[2].

We believe that PNACC 3 represents a significant step forward because it aims to mobilize all key stakeholders in the region around adaptation—something we consider essential given the multidimensional nature of climate-related risks.

Adaptation is indeed a complex issue because it is multidimensional: We are talking here about numerous climate-related hazards (floods, heat waves, droughts, disruptions to freeze-thaw cycles, etc.) that will affect every aspect of a region and an organization.

Let’s take the example of an organization “A” (a company or a local government). Risks will have an impact on its assets—whether natural or real estate (fields, buildings)—on physical resources (water, air, soil, ecosystems, etc.), on the infrastructure and equipment on which its operations depend, and, above all, on the population.

However, Organization A is not directly responsible for the condition of the roads that its employees and suppliers use to reach its main production site. Thus, the organization depends on essential services provided by other parties (water supply, road accessibility, employees’ ability to get to work, etc.).

Furthermore, if the organization wishes to embark on an adaptation process, it will need to begin by conducting a risk assessment. To carry out this assessment, it will use data specific to its own organization, as well as external data produced by third parties (such as climate projections) that are specific to each region.

Finally, identifying the actions to be implemented to mitigate these risks and reduce vulnerability, as well as planning for them, also requires distinguishing between the levers of action within the organization’s control and those controlled by other stakeholders (suppliers, service providers, local authorities, industry sectors, etc.).

A systemic and specific approach Risk assessment is therefore essential for identifying these risks and determining the appropriate adaptation solutions for each stakeholder^[3]. That is why we believe PNACC 3 represents a significant step forward, as it proposes adaptation measures for all key stakeholders in the region.

Next, The PNACC highlights key principles which we believe are in line with the best practices observed among leaders in adaptation:

• Prioritize "no-regret" actions—that is, actions that reduce risks regardless of climate trajectories
• to foster an “instinct” for adaptation, that is, “to promote a culture of adaptation throughout society”
• plan actions in a step-by-step and proactive manner,
• prioritize co-benefits (actions that both help adapt to risks and contribute to other areas of focus, such as biodiversity or the mitigation of greenhouse gas emissions)
• and, of course, be tailored to each stakeholder and region.

What does this new PNACC say?

The adaptation plan includes 51 measures divided into 5 areas. We’d like to take a look at some of the key measures that will affect businesses. The following analysis is by no means exhaustive, but it offers some insights on how a company can implement the PNACC^[4].

Through these measures, the PNACC actually provides a fairly well-defined path for businesses.

First, if your organization operates in an essential service or vital sector (for example, rail transportation), it will be required to conduct a risk assessment and develop an adaptation plan (see measures 30, 31, 32, 33). To this end, the PNACC will provide key guidelines: the methods to be used are currently being tested (measure 41), as are the priority impacts by sector (measure 41); the data will be supplemented by an updated natural hazard map (measures 3, 4, 5, 6, and 7); standards aligned with the TRACC (measures 23, 24); lessons learned from initiatives will be shared (measure 40); and there will be a focus on nature-based solutions (measure 20). The life-based productive sector (tourism, agriculture, livestock, fishing, and forestry) is addressed by four measures (35 through 39).

For businesses, the OCARA framework^[5] provides a framework for risk analysis that incorporates this systemic approach. If we apply the OCARA framework to our analysis, the organization may be impacted in Scope A (the scope of its direct responsibility at its site) and Scope B (direct dependence but outside the scope of its direct responsibility).

Scope A includes actions aimed at protecting the health of employees, customers, and on-site service providers (for example, measures 11, 14, 15, 16, 17, 19), as well as the integration of adaptation measures into buildings and equipment (e.g., 12, 24) and risk prevention (19, 40). Scope B includes actions related to water (21), the resilience of transportation, energy, and telecommunications (30, 31, and 32), and other essential services (28, 29, 33) on which all types of organizations depend. The value chain aspect is partially addressed through the focus on supply chains (33). And beyond transportation and energy managers, Measure 34 introduces a requirement that certain public subsidies for businesses be contingent on their proper consideration of adaptation challenges, which appears to be an important lever for broadening the scope of companies incentivized to address this issue.

What is missing from this PNACC?

First of all, a a budget and a realistic schedule.

The ideas are good, and some of the key stakeholders have been identified, but the budget seems pitiful (since most of the actions are marked as “no additional budget”). The timeline is sometimes very ambitious given the scope of the work to be done, as some companies have never addressed this issue in any way, and TRACC data is being made available gradually over the course of several months.

TRACC ((Reference Warming Pathway for Adaptation)^[6], is therefore now the reference trajectory to be used, alongside the other climate change scenarios derived from the IPCC’s international scientific consensus (“RCP” and “SSP”)^[7] and on which reporting frameworks such as the CSRD and the Taxonomy are based^[8]. It will therefore be necessary to make all TRACC datasets available, as well as a guide on how to use this climate data (for example, with recommendations on which indicators to prioritize and in which cases to use other, more pessimistic scenarios). Finally, as we explained in our memo^[9], TRACC analyses should be supplemented by a study of a more pessimistic climate scenario—one that is less likely but would have a significant impact—especially for long-term investments, which require an analysis of risks through the end of the century.

It will also be necessary to provide guidance to businesses on the methods to be used to conduct the analysis, to identify the key characteristics that ensure the quality of risk assessments, and that would help ensure the consistency of the studies and the quality of the action plans.

The project will also involve building and supplying an analytical framework for identifying high-impact climate shock scenarios : These include combinations of climate-related hazards that can disrupt the functioning of certain critical systems, or single points of failure that are particularly sensitive in certain economic sectors. This work could be carried out through a partnership between public and private sector stakeholders.

Finally, while the PNACC helps mobilize a significant number of economic stakeholders around the issue of adaptation, it provides very little clarity on how all these initiatives will be refined and strengthened once the initial studies are released.

OCARA is a PNACC-compatible method

In this context and in light of these objectives, the OCARA method provides a solid analytical framework for addressing the issue, helping to inform frameworks such as Act Adaptation or the CSRD, but above all to develop concrete adaptation pathways tailored to each stakeholder, in accordance with the key principles set forth in the PNACC. This method is publicly available on our website.

With 10 years of experience under our belt Through our work with businesses across all sectors, we have developed solid expertise to best support companies in assessing climate-related risks and developing adaptation plans, both at the site and group levels. Today, we conduct climate risk assessments for our clients, help them develop their adaptation plans, and provide training and tools to support them in adopting and implementing the Adaptation reflex.

Learn About the OCARA Methodology

Learn about Carbone 4's Adaptation Division

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