The 2060 Time Trap

The most critical point of this document is the net-sink target set for 2060. In climate science calculations, this decade (2020-2030) is the defining decade. Setting peak emissions in 2030 and net-sink three decades later is a dangerous gamble with time.

By design, delaying drastic emission reductions until after 2035 (post-peak emissions) may ease the short-term economic burden and accommodate the 8% economic growth target for the government. However, this places a much heavier and more expensive mitigation burden on the next generation of leaders. We are writing a blank check that our grandchildren will have to pay with very high interest in the form of hydrometeorological disasters.

The biggest challenge of the SNDC is not only in the numbers, but in the lack of synchronization of the domestic legal architecture. On the one hand, the SNDC document promises an aggressive energy transformation, but on the other hand, the Draft Law on New and Renewable Energy (RUU EBET) is still stuck in endless debate. The absence of a legal umbrella at the level of law creates legal uncertainty for investors who are expected to bear most of the cost of the transition. How can we expect private investment to come in to support the LCCP scenario if the main legal framework is still fluid and has not been ratified?

In addition, the carbon market instrument, which is touted as a funding engine, also faces implementation challenges. Although Presidential Regulation No. 98 of 2021 concerning Carbon Economic Value (NEK) has been issued, the operationalization of the carbon exchange has not yet reached the expected liquidity. Mentioning Presidential Regulation No. 110/2025 in the SNDC as the basis for future carbon market mechanisms does provide hope, but it also raises the risk of regulatory overlap. Don't let regulatory updates become a reason for delaying implementation because business actors have to readjust to the changing rules of the game.

Furthermore, the SNDC document needs to be translated into legally binding obligations down to the sectoral level with clear sanctions. Currently, compliance with NDC targets is often still administrative and voluntary. Without strict sanction clauses in derivative regulations or strict environmental law enforcement, the ambitious targets in the SNDC are only beautiful in international diplomacy documents, but blunt in domestic law enforcement.