One day after the public consultation ended, the non-governmental organization criticized the ENAAC 2030, highlighting “structural weaknesses that hinder Portugal’s ability to effectively and socially justly respond” to the escalating impacts of extreme weather events such as heatwaves, severe droughts, torrential rainfalls, rural fires, and coastal erosion.
Despite acknowledging these meteorological phenomena as significant risks, the document fails by “not presenting any financial framework, implementation timeline, or expected outcome projections,” lamented Zero, stating that without a schedule and measurable targets “no strategy can be considered credible.”
Furthermore, according to the association, the document does not mandate climate adaptation as a compulsory requirement in land-use planning instruments, such as the legal framework for territorial management instruments and the legal framework of urbanization and construction.
“Although the climate diagnosis is updated and precise, it lacks what defines a true strategy,” Zero emphasized, citing the absence of concrete goals, priorities, resources, deadlines, and a framework in mandatory legal instruments.
The environmental association also noted that the strategy “marginally addresses” what should be central to any “modern and scientifically robust” response to climate change adaptation, specifically nature-based solutions.
“These solutions are essential for restoring rivers and banks, increasing infiltration, protecting aquifers, creating natural retention areas in urban zones, reinforcing dunes and salt marshes as natural barriers, and reducing the costs of structural interventions,” argued Zero, criticizing ENAAC 2030 for providing only “scattered and insufficient references” on these matters.
The association also warns that in urban areas, the “insufficiency of the proposed strategy becomes more evident,” stressing the “imperative necessity” for mandatory integration of urban adaptation into the legal framework of territorial management instruments and urbanization and construction legislation.
Zero further regretted that the public consultation “excluded civil society, academia, local communities, and vulnerable groups from the coordination group,” proposing the establishment of a National Adaptation Forum to ensure “effective, permanent, and informed participation of social structures.”
In late October, the government introduced the new ENAAC 2030 strategy, aiming to strengthen adaptability to extreme phenomena and particularly invest in flood prevention.
The strategy is intended to adapt all societal sectors to the effects of climate change and needs reviewing “because the impacts in recent years have been much greater than they used to be,” stated the Minister of Environment and Energy, Maria da Graça Carvalho, during the presentation.
