From Climate Plan To Climate Action: Assessing Kerala’s State Action Plan On Climate Change (SAPCC 2.0) 2022 – IMPRI Impact And Policy Research Institute

Policy Update
Ayana N K

Background 

Kerala’s first State Action Plan on Climate Change came out in 2014, but by the time a decade had passed, it no longer felt like it matched the reality on the ground. The state had watched Cyclone Ockhi swirl in from the sea, endured the devastating floods of 2018 and 2019, grappled with Nipah outbreaks, and seen landslides become alarmingly routine in the Western Ghats. With monsoon patterns turning erratic and temperatures creeping up, the old plan simply could not keep up.

So in December 2022, the Directorate of Environment and Climate Change released a fully revised version, SAPCC 2.0, meant to guide Kerala through 2030. This time around, the preparation was far more grounded. Over 220 nodal officers from 91 different departments chipped in, bringing practical, on‑the‑ground knowledge to the table. The plan also included a district‑by‑district vulnerability check, using 17 different measures, and it singled out Wayanad, Idukki, and Kozhikode as the most at risk. Looking ahead, the projections, based on climate scenarios RCP 4.5 and 8.5, warn of a temperature rise of 1 to 2 degrees Celsius in the near future, along with a sharp increase in very heavy rainfall across every district.

The financial commitment is significant too, with an indicative budget of about ₹52,238 crore for the mitigation component alone, not the overall climate-action budget. The plan separately estimates about ₹38,407 crore for adaptation, bringing the combined indicative outlay for SAPCC 2.0 to roughly ₹90,645 crore. This money is expected to come from state funds, central programmes, and outside support, including a €100 million loan from the French Development Agency, signed in December 2022 under the Rebuild Kerala Initiative. Beyond that, Kerala has set itself ambitious long-range goals: shifting entirely to renewable electricity by 2040 and reaching net carbon neutrality by 2050. SAPCC 2.0 is designed to turn those bold promises into real, actionable steps.

Functioning 

In simple terms, Kerala’s second climate action plan has a clear institutional setup on paper, but in practice, the roles blur in ways that make it hard to tell who is ultimately responsible for what.

The Department of Environment and Climate Change (DoECC) is the formal coordinator. It hosts a small Climate Change Cell that acts as the secretariat for a State Level Steering Committee, and it pulls together sectoral working groups covering agriculture, water, energy, forestry, coasts, health, and cities. The Institute of Climate Change Studies (ICCS) is the technical brain. It crunches data and supports research. And the Rebuild Kerala Initiative (RKI), which was set up after the devastating 2018 floods, has quietly become the main pipeline for actually building things, especially climate resilient infrastructure paid for with foreign loans like the one from AFD.

So you have three bodies with overlapping turf. DoECC holds the policy pen and reports upward, ICCS supplies the evidence base, and RKI gets things built on the ground. The problem is that the plan never draws a clear line between where DoECC’s oversight stops and RKI’s day to day project independence begins. That ambiguity is a recipe for diffused accountability. When something goes wrong or stalls, it is not obvious who should answer for it.

The monitoring picture is just as fuzzy. SAPCC 2.0 does lay out two separate tracking frameworks, one for mitigation tied to emissions and one for adaptation tied to vulnerability, but the plan itself admits this system was still being set up when the document was published. Three years later, no public report has come out showing indicator by indicator progress on either front. In other words, the monitoring framework exists on paper well ahead of its real world use. That gap makes it very difficult for anyone outside government, including this review, to independently check whether the plan is actually working.

In short, the architecture looks solid on paper, but the lines of responsibility are smudged, and the scorekeeping has not really started. That combination makes it hard to know who is driving, who is building, and whether Kerala is actually moving the needle on climate resilience.

Performance

Three years in, some of the building blocks are clearly visible. The DoECC, working with the Vasudha Foundation, released an updated Greenhouse Gas Inventory Report in mid-2026. It extends Kerala’s emissions time series to 2023 and sharpens the 2024 baseline inventory. The report finds that land use, land use change and forestry continues to act as a significant net carbon sink, offsetting more than half of the state’s gross emissions in 2023. It also lays out a mitigation pathway that targets a reduction of roughly 57,000 kilotonnes of CO2 equivalent by 2030. That gives Kerala something rare, a data anchored basis for tracking its own mitigation trajectory, which few other state plans have managed at this stage.

On financing, the commitment is real but scattered. The state’s most recent full budget set aside Rs 305.61 crore for forestry and wildlife conservation, framed around water security and forests as a shield against climate change. It also put Rs 750 crore toward rehabilitation after the 2024 Wayanad landslide. Separately, the Centre approved an interest free capital investment loan of about Rs 530 crore for Wayanad rehabilitation projects.

The trouble is that these three pots of money sit side by side instead of flowing together. One is a state budget line for conservation, one is a state budget line for disaster rehabilitation, and one is a central loan for the very same disaster. Each comes with its own reporting timeline and its own conditions. Nothing ties them into a single, coordinated climate finance stream.

That fragmentation became very visible when the state government publicly called out the unrealistic disbursement timeline attached to the Centre’s loan. It laid bare a familiar friction point between how fast Kerala can actually implement projects and the conditions imposed from Delhi. A genuinely converged climate finance architecture under SAPCC 2.0 would need to resolve that tension, not just absorb it.

Taken together, actual disbursement remains a fraction of the plan’s indicative INR 52,238 crore outlay specifically to the proposed mitigation outlay under SAPCC 2.0. A comprehensive, sector wise expenditure tracking report against that figure is not yet publicly available three years in. The scale of this gap is easier to see visually than in isolated figures.

Table 1: Selected quantitative indicators for SAPCC 2.0 financing, mitigation targets, and Wayanad vulnerability, compiled from official and secondary sources cited in the References section.

Impact 

The clearest test of SAPCC 2.0’s real world traction came with the July 2024 Wayanad landslide, which struck Chooralmala, an area the plan’s own vulnerability assessment had already flagged as highly exposed. More than 40% of Wayanad district is landslide and flood prone, and most of its gram panchayats are classified as environmentally fragile. Decades of forest loss in the district had already been documented well before the disaster. In that sense, the plan’s risk mapping exercise was empirically vindicated. The district it identified as most vulnerable is exactly where the state’s worst climate disaster to date occurred.

But the implementation record after the disaster raises harder questions about whether risk identification is actually translating into equitable protection. Reporting on the post landslide resettlement process found that a draft beneficiary list for the flagship township initially left out around 200 families, disproportionately tribal households. Those families were only allotted separate land nearly two years later, with five acres set aside for 13 Scheduled Tribe families, and they were kept apart from the main resettlement site.

This points to a broader gap in the plan’s design. SAPCC 2.0 does include a dedicated section on gender responsiveness and inclusivity, and it draws on the language of intersectionality. Yet it frames social vulnerability mainly through categories such as gender and, notably, different tribal groups. That framework comes from global climate justice literature, and it maps imperfectly onto Kerala’s own social reality, where caste and tribal status are the more salient axes of exclusion in exactly the kind of terrain the plan itself identifies as high risk.

Emerging Issues 

First, there is a gap between the plan’s sophisticated vulnerability mapping and the actual protection people received on the ground when disaster struck. That suggests risk data alone is not translating into inclusive implementation. This is less a knowledge gap and more a monitoring and accountability gap.

Second, the plan’s social inclusion framework needs sharper localisation. Adopting globally circulating justice vocabulary without adapting it to Kerala’s specific caste and tribal dynamics risks producing a document that reads as progressive while leaving real exclusion unaddressed.

Third, financing remains fragmented across state budget lines, central schemes, and external loans, each with differing conditionalities and timelines. That complicates both disbursement and the tracking of whether the proposed INR 52,238 crore outlay is actually being realised.

Fourth, the monitoring and evaluation system for distinguishing mitigation outcomes from adaptation outcomes appears to still be maturing. That limits how far independent assessments, including this one, can verify progress against SAPCC 2.0’s own targets.

Way Forward 

First, the state should publish an annual, sector wise financial and physical progress report against the SAPCC 2.0 outlay. That way, implementation can be tracked with the same rigour that went into the plan’s vulnerability assessment.

Second, the DoECC should revisit the plan’s social inclusion framework and explicitly integrate caste and tribal status as vulnerability parameters, particularly for high risk terrain such as the Western Ghats. Relying solely on internationally derived categories leaves too much unaddressed.

Third, resettlement and rehabilitation protocols after climate disasters should build in independent, real time audits of beneficiary lists. That would help prevent the kind of exclusionary delays seen in Wayanad.

Finally, the AFD loan’s performance based structure gives Kerala an opening. The state can use its reporting obligations to that facility as a forcing mechanism for stronger, more transparent domestic monitoring and evaluation. Done well, an external financing requirement could become a genuine accountability tool for the plan as a whole.

References 

Centre for Public Policy Research. (2025, May 13). Landslide risk reduction in Kerala: A climate adaptation policy approach. https://www.cppr.in/articles/landslide-risk-reduction-in-kerala 

Centre for Science and Environment. (n.d.). Kerala’s action plan to combat climate change. https://www.cseindia.org/kerala-s-action-plan-to-combat-climate-change-11590 

Deccan Herald. (n.d.-a). Centre sanctions Rs 530 crore loan for Wayanad rehabilitation to be utilised by March 31. https://www.deccanherald.com/india/kerala/centre-sanctions-rs-530-crore-loan-for-wayanad-rehabilitation-to-be-utilised-by-march-31-3406335 

Deccan Herald. (n.d.-b). No major sops in Pinarayi govt’s last full budget; thrust on tapping Vizhinjam potential, Wayanad rehabilitation. https://www.deccanherald.com/india/kerala/no-major-sops-in-pinarayi-govts-last-full-budget-thrust-on-tapping-vizhinjam-potential-wayanad-rehabilitation-3394818 

Department of Environment and Climate Change, Government of Kerala. (2026). Kerala State Action Plan on Climate Change 2023–2030 (SAPCC 2.0). https://climatechange.envt.kerala.gov.in/kerala-state-action-plan-on-climate-change-2023-2030/ 

Directorate of Environment and Climate Change, Government of Kerala. (2022). Kerala State Action Plan on Climate Change 2.0 (2023–2030). https://www.envt.kerala.gov.in/wp-content/uploads/2022/12/Kerala-State-Action-Plan-on-Climate-Change-2.0.pdf 

Directorate of Environment and Climate Change, Government of Kerala, & Vasudha Foundation. (2026). Kerala GHG inventory report 2005–2023 (SAPCC 2.0 implementation). https://vasudha-foundation.org/kerala-ghg-inventory-report-2005-2023-sapcc-2-0-implementation/ 

The Diplomat. (2026, May 22). Kerala’s climate plan speaks the language of justice — but erases caste. https://thediplomat.com/2026/05/keralas-climate-plan-speaks-the-language-of-justice-but-erases-caste/ 

About the Contributor

Ayana N K is a Political Science graduate from the University of Calicut. With a keen interest in public policy, international relations, and development studies. She enjoys researching contemporary social and political issues and exploring how policies shape society. 

Acknowledgement

The author extends her sincere gratitude to the IMPRI team for their expert guidance and constructive feedback throughout the process.

Reviewed by Manisha Kumari and Ashi Verma.

Disclaimer 

All views expressed in the article belong solely to the author and not necessarily to the organization.

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